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Compliance Monitoring Policy

  1. Compliance Monitoring Commitment
    Winking Studios Limited and its affiliated entities (hereinafter collectively referred to as the "Company") are committed to conducting all business activities in strict compliance with applicable laws, regulations, and internal policies. This Compliance Monitoring Policy (hereinafter referred to as the "Policy") is established to promote and maintain a culture of legality, integrity, and ethical conduct within the Company.

  2. Purpose of the Policy
    The purpose of this Policy is to ensure that all directors, officers, employees, contractors, and agents of the Company (hereinafter collectively referred to as "Company Personnel") adhere to all relevant laws, regulations, and internal policies. The Policy aims to proactively identify, assess, and mitigate potential regulatory risks, ensuring that the Company's operations remain compliant with all applicable legal and regulatory requirements.

  3. Scope of the Policy
    This Policy applies to all Company Personnel, including but not limited to employees, officers, directors, contractors, and agents, across all business units and subsidiaries of the Company.

  4. Policy Components
    • Internal Auditing: The Company shall conduct regular and systematic internal audits to evaluate compliance with applicable laws, regulations, and internal policies. Audit findings shall be documented, and any non-compliance shall be promptly addressed through corrective action plans.
    • Risk Assessment: The Company will perform ongoing risk assessments to identify, evaluate, and mitigate potential legal and regulatory risks. These assessments will be conducted in accordance with industry standards and best practices to ensure a proactive approach to compliance.
    • Reporting Mechanism: The Company shall establish and maintain a secure and confidential reporting mechanism that allows Company Personnel to report any suspected or actual violations of laws, regulations, or Company policies. Reports shall be reviewed and investigated by the Legal Department, and appropriate actions shall be taken. Company Personnel shall be protected from retaliation for making good-faith reports.
    • Training and Awareness: The Company shall implement a comprehensive and continuous training program to ensure that all Company Personnel are fully aware of their compliance obligations and responsibilities. The training shall be tailored to the specific roles and risks associated with different positions within the Company.
    • Transparency and Accountability: The Company is committed to upholding transparency and accountability in all business activities. All Company Personnel, including contractors and business partners, are expected to adhere to the highest standards of legal compliance and ethical conduct. Any breaches of this Policy or applicable laws will result in disciplinary action, up to and including termination of employment or contract.
    • Continuous Improvement: The Company will regularly review and update this Policy to reflect changes in laws, regulations, and business needs. The Company will allocate sufficient resources to ensure the ongoing effectiveness of the Compliance Monitoring Policy and will continuously strive to enhance its compliance framework.

  5. Responsibilities
    It is the duty of all Company Personnel to strictly adhere to this Policy and all applicable legal standards. Failure to comply with this Policy may result in disciplinary actions, including termination and potential legal consequences.

  6. Reporting and Contact Information
    If any Company Personnel have questions regarding this Policy or compliance matters, they are encouraged to contact the Legal Department at the following: