STATEMENT ANTI-BRIBERY AND CORRUPTION POLICY IN PURCHASING, COOPERATION AND PARTNERSHIP AT SEABANK

1.    INTRODUCTION
Southeast Asia Commercial Joint Stock Bank (SeABank) has established our Anti-bribery and corruption policy, setting out implementation principles, framework and regulations  on preventing and combating corruption, bribery, negativity and crime in business activities, transactions with customers, interactions with external parties (partners, suppliers, contractors or any related individuals and organizations) and other activities on behalf of the bank. SeABank ensures our compliance with laws and regulations promulgated by State Agencies and other competent authorities governing the process on anti-corruption, bribery and negativity.
This statement provides SeABank's partners, contractors, suppliers... with implementation principles, requirements and instructions on how to handle problems arising in the course of business and cooperation to ensure the prevention of corruptive, bribery and negative acts from occurring and in accordance with the provisions of law on this aspect.
2.    SCOPE OF APPLICATION
Applicable to activities pertaining to procurement of goods and services, lease/purchase of premises, capital construction, cooperation and other activities of SeABank with partners, suppliers, contractors or any relevant individual or organization.
3.    TERMS EXPLANATION
a)    SeABank: Southeast Asia Commercial Joint Stock Bank, its affiliates/branches and all officers and employees of Southeast Asia Commercial Joint Stock Bank (employees).
b)    Partners: are individuals, organizations, enterprises, units that have business activities, associate, cooperate, provide goods and services ... with SeABank, including their subsidiaries, joint ventures, associates, employees, agents and representatives, contractors and sub-contractors.
c)    Corruption: is the act of a person having a position, authority or being assigned a task or power, which takes the advantage of his or her assigned position, power, or task for self-interest.
Person with position and authority is a person who is assigned to perform certain tasks or jobs and is given certain powers during the performance of those tasks or jobs.
Self-interest is a material or spiritual benefit that a person with a position or authority obtains or can obtain through corruptive acts.
d)    Negativity: refers to improper phenomena and behaviors that have negative, obstructing and bad effects on the development process of the organization and society.
The concept of "negative" in the operation of an organization is the manifestations and behaviors that individuals and units perform that are contrary to the views, guidelines, policies and legal regulations issued by the Party and State; charters and regulations of companies, organizations; professional ethical standards, code of conduct; They adversely affect the reputation, image or assets of the organization, deprave the staff and hinder the common development.
e)    Bribery: An  act of using money, property, other material benefits or immaterial benefits directly or through an intermediary to suggest, promise, give or will give to a person with a position, authority or another individual or organization to allow a person with a position or authority to do or not to do something for the self-interest or at the request of the person giving the bribe. Bribery includes three acts: giving bribes, accepting bribes and brokering bribes.
f)    Related person of an organization or individual means an organization or individual that has a direct or indirect relationship with an organization or individual 
g)    Conflict of interest: is a situation in which the interests of SeABank employees or their related persons affect or will improperly affect the performance of duties and responsibilities of such employees at SeABank.
4.    GENERAL POLICY DISCLOSURE
-    SeABank fully complies with policies, legal regulations and regulations promulgated by State bodies and competent agencies related to the prevention and fighting of corruption, negativity, and bribery.
-    SeABank says “NO” to corruption, negativity and bribery; 
All acts related to corruption, negativity and bribery are strictly prohibited. The acts include but are not limited to offering, giving or receiving bribes, facilitation payments, kickbacks, gifts, any other material or moral benefit, either directly or indirectly through any third party in order for the recipient to perform the job functions in a manner contrary to the law and/or the internal regulations of SeABank at the request of the briber.
-    SeABank strictly handles any violations of anti-corruption, negativity, bribery and will take necessary actions including but not limited to actions such as:
(i)   For employees who violate: labor discipline measures, penalty in accordance with the law and internal regulations of SeABank; hiring or appointment will be taken into consideration…
(ii) For SeABank Partners violating: appropriate measures and sanctions to prevent other partners/contractors/suppliers/third parties from continuing to do business with SeABank.

SeABank reports to relevant authorities any wrongdoing, in accordance with the regulatory requirements, laws and SeABank's internal regulations.

5.    SEABANK'S REQUIREMENTS
The following principles and requirements apply to all SeABank's employees, its subsidiaries and other partners, suppliers, contractors and third parties that cooperate with SeABank.
We believe that SeABank's common commitments on conduct, compliance with standards of integrity, honesty and ethics in business relations, and cooperation with SeABank's partners are a solid foundation for trusted working relationships help create sustainable shared value.
5.1.    Prevention of corruption, negativity, bribery
SeABank's partners need to comply with:
-    Comply with regulations on prevention and combat of corruption, negativity and bribery under Vietnamese law.
-    Do not directly or indirectly promise, demand, suggest, give/receive money or other benefits (including but not limited to any kickbacks, bonuses, commissions, incentives, gifts...) to any SeABank employee, or an individual, organization, company, or business of a related person of SeABank's employees in order to govern SeABank's decisions to acquire or maintain business; or to obtain any unfair business or competitive advantage; gain other unwarranted advantages over SeABank;
-    Do not directly or indirectly give or accept bribes of officials/officers at competent state agencies…when performing their obligations under contracts/agreements related to SeABank, to influence actions or obtain improper benefits for or from SeABank;
-    Coordinating with SeABank in the cooperation process, signing contracts, agreements, commitments, memorandums of understanding, and other documents on policies to prevent and combat corruption, negativity, bribery and crime in accordance with laws and regulations of SeABank from time to time.
5.2.     Gifts and Entertainment
SeABank's partners need to comply with the following:
-    Do not directly or indirectly give gifts, entertainment, or give material/non-material benefits in any form to SeABank employees, unless otherwise agreed in writing with SeABank.
-    Do not directly or indirectly ask/receive money or other material/immaterial benefits in connection with the performance of any service with SeABank or any other activity on behalf of SeABank in addition to the fees agreed upon under the contract and other documents signed between the partners and SeABank.
5.3.    Anti-conflict of interest
Individuals/units of partners, suppliers, contractors… do not enter into any financial or other relationships with SeABank employees that could lead to actual or potential conflicts of interest with SeABank.
5.4.     Protection of SeABank's information, assets and interests
Partners, suppliers, contractors... are required to protect SeABank's information, assets, and reputation that is provided, disclosed, or assigned to them in order to perform related work, contracts, or agreements with SeABank; Do not disclose, damage, or use this information or property for any other purpose.