Anti-Bribery and Anti-Corruption Policy

Applicable to Patsnap West

Updated: January 2025

Overview

Patsnap Limited, including its subsidiaries and their respective employees, officers, directors, and contractors (“Patsnap”) are committed to maintaining the highest ethical standards. Patsnap’s success is built on integrity and adherence to legal and ethical principles, ensuring all practices reflect transparency and accountability.

1. Scope

This Anti-Bribery and Anti-Corruption Policy (“Policy”) applies to all interactions involving:

• Patsnap employees, officers, directors, and contractors (“Patsnap Representatives”).
• Patsnap and its current or prospective customers, vendors, and partners.
• Patsnap and government officials or government agencies and political/lobbying organizations, including their respective employees.

2. Purpose

The purpose of this Policy is to:

• Establish clear guidelines for the exchange of gifts and hospitality.
• Ensure compliance with applicable anti-bribery, anti-corruption laws, and industry best practices in dealings with public and private sector entities.

3. Gifts and Hospitality Policy

3.1 General Guidelines: Acceptable gifts and hospitality must meet the following criteria:

• The fair market value (FMV) does not exceed $75 USD per gift or $ 300 USD annually.
• It does not create or imply a conflict of interest or quid-pro-quo (e.g., agreement for a deal or contract in exchange for something of value).
• The recipient is not involved in an active Request For Proposal (“RFP”) or active contract negotiation with Patsnap.

Definition of “Gift”

 A gift includes any items of value provided without Fair Market Value (“FMV”) payment, such as:

• Money, gift cards, meals, travel, entertainment, or charitable donations.

Hospitality Exception

Routine hospitality must be proportionate, reasonable and only offered as part of building or maintaining good relationships.

Routine hospitality does not require prior approval if it adheres to these thresholds:

• Food/Drink: up to $ 75 USD per individual.
• Post-event meals: up to $ 100 USD per individual.
• Other hospitality: up to $75 USD per individual.

3.2 Gifts Among Employees – Gifts exchanged among colleagues are permitted provided:

• They are paid personally by the giver.
• They are provided fairly and in a non-discriminatory and non-retaliatory manner.
• They are not used as performance incentives.

4. Anti-Bribery and Anti-Corruption

4.1 Prohibition of Bribes and Kickbacks

Patsnap strictly prohibits the offering, promising, or providing of bribes, kickbacks, or other advantage to any individual, especially government officials, under any circumstances.

4.2 Political Contributions and Activities

• Personal Contributions: Patsnap Representatives must not make contributions that suggest Patsnap’s involvement in “Pay-to-Play” activities.
• Volunteering: Personal political activities must be conducted outside of work hours and without using company resources; provided, however, that employees may use their allocation of holiday/vacation/PTO days.

4.3 Corporate Political Contributions

Corporate contributions are permitted only if they:

• Comply with all applicable laws and regulations.
• Align with Patsnap’s mission and values.
• Withstand public and regulatory scrutiny.
• Are pre-approved by Patsnap’s CEO or CFO.

5. Charitable Donations

5.1 Company-Sponsored Charitable Donations

Charitable donations must not be used as a means to influence government officials or gain undue advantage.

5.2 Personal Charitable Donations

Employees may make personal charitable donations independently, provided they are not reimbursable by Patsnap.

6. Special Guidelines for Public Sector Interactions

6.1 Approval of Government Interactions

All interactions with government officials must adhere to applicable local, state, and federal laws. Written pre-approval from the Legal department is required.

6.2 Lobbying and Advocacy

Lobbying activities, including efforts to influence legislation or executive policy, require prior authorization from the Legal department.

7. Recruitment

It is prohibited to recruit someone into a paid or unpaid role within Patsnap where that would influence, or could be perceived as intending to influence, a business decision by a client or other relevant decision- maker (i.e. suppliers, public officials).

Where a candidate for a Patsnap role has a known personal connection to a client, or to the person proposing their onboarding, then additional scrutiny must be applied to ensure that any recruitment is appropriate and in compliance with this Policy and the law.

8. Red Flags

Patsnap Representatives must remain vigilant for unethical practices, including:

• Third parties claiming undue influence or connections.
• Requests for extravagant gifts, entertainment, or prepayments.
• Entities use opaque or questionable financial arrangements.

Any red flags must be reported immediately to the Legal department.

9. Record Keeping and Internal Controls

All gifts and expenses under this Policy must be accurately documented in accordance with Patsnap’s Travel & Expense Policy.

10. Training and Acknowledgment

Employees are required to review and acknowledge this Policy annually. Additional training may be mandated based on role or jurisdiction.

11. Advice, Reporting, and Enforcement

11.1 Seeking Advice

For any doubts regarding this Policy, consult:

• Your manager.
• The Legal department.