Tencent is committed to strengthening its corporate culture, which is built upon our values, vision, and purpose. Our values are Integrity, Proactivity, Collaboration, and Creativity.

Integrity means to uphold principles, ethics, openness and fairness in everything we do. We have developed robust systems and measures to prevent, detect, and deter corruption or any misconduct that is not consistent with our values. All employees of the entire Group are required to follow and strictly comply with the Tencent Sunshine Code of Conduct (later referred to as “the Sunshine Code”), which prohibits corruption, fraudulent activities, and any other actions that are not in compliance with applicable laws and regulations.

Increasing Awareness of Fraud and Corruption

Tencent provides regular anti-fraud education and training to all employees throughout their employment with the company. Each employee, on their first day of employment, is provided with the Sunshine Code and informed of the company’s zero-tolerance approach toward its violation. Tencent also conducts annual anti-fraud training for board members and all employees, emphasizing and reiterating the importance of the Sunshine Code and strict prohibition of any misconduct or unethical behavior.

Updated Management Principles

Tencent reviews the anti-fraud related policies and programs regularly and makes revisions as appropriate to ensure that it complies with all applicable laws and regulations.

Tencent’s Red Lines

There are six key provisions (also known as the “Red Lines”) under the Sunshine Code which stipulate the major prohibited acts, violation of which could result in the consequences of dismissal and denial of any future employment with Tencent. Any cases involving criminal elements will be referred by Tencent to relevant government authorities for further investigation.

The six provisions are set out below. To report any violation of the Sunshine Code, please contact our Anti-Fraud Investigation Department at [email protected].

1) Fraudulent Conduct

Any form of fraudulent conduct will be treated seriously, regardless of whether the employee has personally benefited from it or not. Fraudulent conduct includes, but is not limited to, the willful falsifying of business, management or personnel records or information; forgery; tender fraud; making any untruthful statement with intent to deceive or cause loss to others.

2) Commercial Bribery and Asset Misappropriation

Tencent says “no” to all forms of bribery, corruption, asset misappropriation, and misuse or abuse of authority or power. Solicitation, offering or acceptance of any financial or non-financial advantage, whether directly or indirectly through any others, with anyone who has direct or potential business relationships with Tencent is strictly prohibited. Financial or non-financial advantages include, but are not limited to, cash, gifts, kickbacks, loans, job offers, travel, entertainment, or hospitality. Engaging in activities such as embezzlement, theft, or fraud to convert company assets into personal property, misappropriating company resources, or using company resources for personal purposes or lending them to others are strictly prohibited.

3) Information Security Violation and Divulgence of Confidential Information

Employees are obliged to comply with relevant Tencent information security policies, and protect confidential or sensitive information about the company, customers, employees, and business partners from unauthorized disclosure. Confidential or sensitive information includes, but is not limited to, trade secrets, internal communication records, non-public source code, and bid or tender information.

4) Conflicts of Interest

A conflict of interest occurs when competing interests impair an employee’s ability to make impartial and objective business decisions. Tencent employees are required to promptly disclose any such situation to the Anti-Fraud Investigation Department and take necessary actions as instructed. Conflicts of interest can arise in various situations, including, but not limited to, engaging in business competition with Tencent, having financial interests in a supplier’s or custormer’s business, using Tencent's resources or working hours for personal business matters, and holding part-time positions in companies that compete with Tencent.

5) Damage to the Rights and Interests of the Company or Employees

Engaging in activities which may infringe upon the rights and interests of Tencent, a third party, or employees is prohibited. This includes, but is not limited to, infringing on intellectual property rights of Tencent or a third party, sexual harassment, and any other inappropriate behaviors that may have adverse impacts on Tencent.

6) Other Violations of Laws and Regulations

Tencent employees shall not engage in any conduct that constitutes a violation of the laws and regulations, as well as Tencent's rules and policies. This includes, but is not limited to, participating in illegal activities or engaging in any other misconduct that may have an adverse impact on Tencent.

Whistleblowing and Investigations

Tencent has implemented the Anti-Fraud Whistleblowing Policy. The Group encourages employees, suppliers, and business partners to report any concerns they may have regarding any non-compliant or potentially fraudulent activities. We provide various whistleblowing channels as noted below. Anonymous reports are also accepted. We encourage informants to leave their contact information so that effective follow-up investigations could be conducted and to provide them with updates if necessary. Reports will be handled in a serious manner and with the highest level of confidentiality.

Tencent delegates the Anti-Fraud Investigation Department to carry out investigations independently. Employees who are proven to have violated the “Red Lines” under the Sunshine Code could face dismissal and denial of any future employment with Tencent. Any supplier or business partner found to have engaged in serious bribery or fraudulent activities while working with Tencent will be blacklisted and Tencent will not engage with them in the future. For cases involving potential criminal elements, Tencent will immediately refer them to relevant government authorities for further investigation.