ANTI-BRIBERY POLICY OF HOUSE OF HĀNM LTD.

1. Policy Statement

House of Hānm Ltd. is committed to conducting its business with integrity, transparency, and fairness. This Anti-Bribery Policy reflects our zero-tolerance approach to bribery and corruption in all forms, whether direct or indirect. We uphold all laws relevant to countering bribery and corruption in every market where we operate, including but not limited to the UK Bribery Act 2010.

2. Scope of the Policy

This policy applies universally to all employees of House of Hānm Ltd., regardless of their position, level, or location. It also extends to individual contractors, consultants, agents, sponsors, or any other person or entity associated with House of Hānm Ltd. (collectively referred to as "associated persons"). Each associated person under the scope of this policy is required to adhere to the same standards and principles outlined herein.

3. Definition of Bribery

Bribery involves the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust. Bribes can take on many forms, including but not limited to cash payments, gifts and hospitality, or the uncompensated use of company services or assets.

4. Prohibited Conduct

House of Hānm Ltd. prohibits:

• The offering, giving, receipt, or solicitation of any bribe, whether cash or other forms of inducement, to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company.
• Any indirect involvement in bribery, including through an intermediary, such as a broker, agent, or other intermediary.

5. Gifts and Hospitality

This policy does not intend to prohibit the normal and appropriate hospitality (given and received) to or from third parties, provided the following requirements are met:

• It is not intended to influence the party to whom it is being given, to gain any commercial, contractual, or regulatory advantage for House of Hānm Ltd. in a way that is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
• It is given in the name of the company, not in an individual’s name.
• It does not exceed £100 in value for any one individual within a 12-month period.
• It is appropriate in the circumstances, taking into account the reason for the gift, its timing, and the setting.

6. Facilitation Payments and Kickbacks

Facilitation payments, which are typically small, unofficial payments made to secure or expedite a routine or necessary action, and kickbacks, are strictly prohibited. This applies even if such payments are customary or considered negligible in certain locations.

7. Political and Charitable Donations

House of Hānm Ltd. does not make donations, whether in cash, kind, or by any other means, to political parties. Charitable donations and sponsorships are allowed; however, they should not be used as a disguise for bribery. We will ensure that all charitable donations made are legal and ethical under UK law and the laws of the country in which the donations are made.

8. Record Keeping

House of Hānm Ltd. will maintain accurate and complete records of all financial transactions related to the prohibition of bribery and corruption, including gifts, hospitality, donations, and expenses submitted by employees or associated persons, ensuring all payments are legitimate and justifiable.

9. Raising Concerns

Employees and associated persons are encouraged to raise concerns about any instance of malpractice or wrongdoing at the earliest possible stage. This policy guarantees that no individual will suffer any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future.

10. Training and Awareness

To ensure that all employees and associated persons are aware of their responsibilities under this policy, House of Hānm Ltd. will provide regular training on how to recognize and avoid bribery and corruption. This training will be part of the induction for new employees and ongoing training for all staff.

11. Third-Party Due Diligence

Before engaging with any third parties, including suppliers, contractors, and agents, House of Hānm Ltd. will conduct due diligence to assess their integrity and compliance with anti-bribery laws. This process will help mitigate the risk of bribery and corruption in our business dealings.

12. Whistleblower Protection

House of Hānm Ltd. ensures that any employee or associated person who reports concerns in good faith will be protected from retaliation. We will maintain a secure and confidential channel for reporting suspected bribery or corruption, and all reports will be investigated thoroughly.

13. Policy Enforcement and Disciplinary Measures

Violations of the Anti-Bribery Policy will result in disciplinary action, up to and including termination of employment or contracts. House of Hānm Ltd. will also report any criminal activity to the relevant authorities.

Conclusion and Commitment

House of Hānm Ltd. is dedicated to upholding the highest standards of environmental responsibility, ethical conduct, CSR, and anti-bribery measures. By embedding these principles into every aspect of our business, we commit to operating sustainably, responsibly, and with integrity, contributing positively to society and the environment. Our policies will be reviewed and updated regularly to reflect new developments, ensuring that House of Hānm Ltd. remains at the forefront of corporate responsibility.