Integrity Policy

Anti-Fraud Awareness and Training

TME provides all employees with regular anti-fraud awareness campaigns, training and assessments throughout their employment. Each employee, on their first day of employment, shall be provided with the Sunshine Code and acknowledge TME’s zero-tolerance stance toward its violation. TME also conducts annual anti-fraud training for board members and all employees, emphasizing the importance of the Sunshine Code and the strict prohibition on misconduct or unethical behavior.

Sunshine Declaration

TME has established the Implementation Guidelines for the Sunshine Code, providing mandatory compliance guidance on personal investments, conflicts of interest, part-time employment, and the acceptance or offering of gifts and hospitality. TME operates the official TME Sunshine Platform for employees to submit declarations.

Policy Maintenance

TME annually reviews and audits its anti-fraud related policies and programs, making revisions as appropriate to ensure alignment with evolving legal and regulatory requirements.

TME’s Red Lines

There are five key provisions (also known as the “Red Lines”) under the Sunshine Code that set out the principal prohibited acts. Violations will result in dismissal and permanent ineligibility for future employment with TME. Any cases involving suspected criminal conduct will be referred to the relevant authorities for further investigation.

The five provisions are set out below. To report any suspected violation of the Sunshine Code involving employees of TME, please contact our Anti-Fraud Investigation Team at TME_jubao@tencentmusic.com.

1. Fraudulent Conduct

   Any fraudulent conduct will be treated as a severe violation of TME’s Red Lines, whether or not the employee has personally benefited from it. Fraudulent conduct includes, but is not limited to, willfully falsifying business, management, expense, or tender records; falsely inspecting or accepting deliverables; fabricating or spreading false information that adversely impacts TME or others; or making any untruthful statement with intent to deceive or cause loss to others or TME.

2. Bribery and Asset Misappropriation

   TME strictly prohibits all forms of bribery, corruption, asset misappropriation, and the misuse or abuse of authority. Solicitation, offering or acceptance of any financial or non-financial advantage, whether directly or indirectly through third parties, from or in connection with any person or entity that has an actual or potential business relationship with TME, is strictly prohibited. Financial or non-financial advantages include, but are not limited to, cash, gifts, kickbacks, loans, job offers, travel, entertainment, or hospitality. The embezzlement, theft, or fraudulent conversion of TME assets for personal benefit; the misappropriation of TME resources; and the use of TME resources for personal purposes or their lending to others are strictly prohibited.

3. Information Security Breaches and Unauthorized Disclosure

   Employees shall comply with applicable TME information security policies, and safeguard confidential or sensitive information relating to TME, 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 may impair an employee’s objective business decisions. TME employees are required to promptly disclose any such situation in accordance with applicable policies. Failure to disclose, or failure to disclose in a timely manner, constitutes a severe violation of TME's Red Lines. Conflicts of interest can arise in various situations, including, but not limited to, engaging in business competition with TME, holding financial interests in a supplier’s or customer’s business, using TME’s resources or working hours for personal business matters, and holding part-time positions in companies that compete with TME.

5. Other Illegal and Non-Compliant Conduct

   TME employees shall not engage in any conduct that violates applicable laws and regulations, as well as TME’s rules and policies. This prohibition extends to illegal activities and other serious misconduct, including intellectual property infringement and sexual harassment, that constitute a serious breach of TME’s cultural values or may adversely affect TME.

Whistleblowing, Whistleblower Protection and Investigations

To facilitate the effective collection of reports, TME has implemented the Tencent Music Entertainment Group Anti-Fraud Investigation Policy and established multi-channel reporting mechanisms publicized both internally and externally. TME encourages employees, suppliers, and business partners to report suspected instances of non-compliance or fraud. Anonymous reports are accepted; however, whistleblowers are encouraged to identify themselves to facilitate follow-up investigations and receive status updates. Reports will be handled rigorously and in strict confidentiality, with zero tolerance for retaliation in any form.

TME assigns the Anti-Fraud Investigation Team to carry out investigations independently. Any supplier or business partner found to have engaged in serious bribery or fraud in connection with TME will be blacklisted and barred from future business dealings. TME will promptly refer cases involving suspected criminal conduct to the relevant authorities for further investigation.

Whistleblowing Channels

1. Hotline: +86 (755) 8654-2596 (voicemail)
2. Email: TME_jubao@tencentmusic.com
3. Dedicated Whistleblowing Mailbox: Dedicated Whistleblowing Mailbox of Tencent Music Entertainment Group, 38/F, Building D3, Kexing Science Park, Keji Zhong 3rd Road, Central Science and Technology Park, Nanshan District, Shenzhen, Guangdong Province, PRC, Postal Code: 518057