This Policy is established for the purpose of ensuring that the Frontier Management Group (the “Group”) complies with all applicable anti-bribery and corruption laws and conducts its activities in a manner consistent with societal and ethical standards.

• (1)

  The Group shall not, whether directly or indirectly, engage in bribery or any conduct that may give rise to suspicion of bribery toward public officials or persons in similar positions (including current public officials, deemed public officials, officers or employees of government owned or government controlled enterprises, and former public officials who continue to exert influence by virtue of their former positions).
  Such prohibited conduct includes, but is not limited to, providing entertainment or gifts that exceed socially accepted norms, offering travel or accommodation expenses, or providing or promising any other benefits.
  The Group also recognize that acts of bribery committed by agents or other intermediaries may be regarded as acts of bribery by the Group. Accordingly, the Group shall not cause or instruct any agent or intermediary to engage in bribery on its behalf.

• (2)

  The Group shall not, for the purpose of influencing decisions on business terms or selection of counterparties, receive or provide any benefits from or to private-sector companies or individuals (including sole proprietors), whether directly or indirectly, including entertainment or gifts that exceed socially accepted norms, travel or accommodation expenses, or any other benefits, promises, or offers thereof.

• (3)

  The Group shall not ignore or overlook any actual or suspected instance of bribery or improper benefit provision.

In the event that any officer or employee violates applicable anti-bribery laws or this Basic Policy, the Group shall take strict disciplinary action or governance measures in accordance with internal rules and regulations.