Compliance and Anti-Bribery & Corruption Policy Statement

Luopay, as a Group, is committed to applying the highest ethical standards in all its activities. Every member of the Group, director, employee or agent, will conduct the Group’s business openly, fairly and with integrity, wherever he/she operates. We strive to abide by all applicable laws in our countries of operations, and to uphold the highest international standards aimed at countering corruption.

The Group is committed to comply with all applicable anti-bribery, corruption, and financial crime laws, including:
- Canada: Corruption of Foreign Public Officials Act (CFPOA), Criminal Code, Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA); but also 
- International texts : US Foreign Corrupt Practices Act (FCPA), UK Bribery Act 2010 or French Sapin II Law. 

‍"Corruption" is defined by the Council of Europe as “requesting, offering, giving or accepting, directly or indirectly, a bribe or any other undue advantage or prospect thereof, which distorts the proper performance of any duty or behaviour required of the recipient of the bribe, the undue advantage or the prospect thereof”.

All members are forbidden to bribe or participate in corrupt activities. The Group will also require its business partners to comply with anti-corruption laws.

An anti-bribery and corruption program will soon be implemented within the whole Group and will notably consist of:
- forbidding facilitation payments
- a gifts and hospitality policy
- a training plan

Reporting Mechanism

Any employee, director, manager, contractor, agent, supplier, business partner, or third party interacting with Luopay may report suspected misconduct such as : 
- Bribery, corruption, or facilitation payments;
- Money laundering or terrorist financing;
- Fraud, theft, embezzlement;Conflicts of interest or any violation of applicable laws or Luopay policies.

Reports may be submitted to whistleblowing@luopay.co. Reports may be submitted anonymously. All reports will be treated confidentially, and Luopay will protect the identity of whistleblowers to the maximum extent permitted by law. Retaliation against individuals reporting in good faith is strictly prohibited.

Reports will be reviewed promptly by Compliance. Internal measures will be taken where necessary, and matters may be escalated to FINTRAC or relevant authorities. 

Date : 17 June 2025