Table of Contents

Company Background, Compliance & Governance Statement** **Asiacom Global Trading Limited

Document Position

This document is published as an external reference statement for institutional review, banking due diligence, public authority enquiries, government office enquiries, financial institution review, business partner review, supplier review, customer review, periodic status confirmation, and other qualified counterparty enquiries.

Publication Status

1. Introduction

Purpose and Basic Policy of this Statement

In recent years, the importance of compliance, corporate governance, anti-bribery and anti-corruption controls, information management, documentation control, and responsible decision-making has continued to increase for companies of all sizes. In particular, companies engaged in trade-related business are often required by banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other relevant parties to provide explanations regarding their business substance, management structure, responsible persons, information management practices, transaction records, and compliance framework.

Asiacom Global Trading Limited is the Hong Kong local entity of the Japan-based Asiacom Group. The company supports practical trade-related operations, sourcing coordination, documentation review, logistics coordination, supplier and customer communication, and related business support functions involving Hong Kong, Japan, and other Asian markets.

As a small and medium-sized enterprise, the company places importance on establishing a reasonable, practical, and sustainable management framework that reflects the actual nature of its business operations, rather than adopting unnecessarily complex internal systems or excessive formal procedures.

Within the Asiacom Group, the company recognises legal compliance, honest business conduct, appropriate record keeping, anti-bribery and anti-corruption controls, proper handling of confidential and personal information, and responsible human confirmation as basic principles for daily business operations. These principles are confirmed by directors and responsible management members and are communicated, guided, and applied to employees and relevant parties as necessary in the ordinary course of business.

This statement consolidates the company’s corporate background, group relationship, governance structure, compliance policy, anti-bribery and anti-corruption policy, information management policy, documentation control policy, and external communication policy. It is intended to serve as a published external reference statement for banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties when reviewing the company’s business substance and management framework.

Through this statement, the company seeks to provide a consistent and transparent explanation of its basic corporate information and management policies in response to external enquiries, institutional review, periodic status confirmation, administrative requests, due diligence review, and other business-related confirmation processes.

Where additional director information, shareholder information, significant controller information, statutory records, transaction records, supporting documents, or other specific materials are required, the company may provide such information separately upon legitimate request and subject to internal confirmation.

2. Company Background and Basic Corporate Profile

Asiacom Global Trading Limited is a Hong Kong-based trading company and the Hong Kong local entity of the Japan-based Asiacom Group. The company supports practical trade-related operations, sourcing and procurement, import/export support, logistics documentation, quality control, supplier and customer communication, and regional market coordination.

The company operates as an external-facing trade and business coordination entity for Hong Kong-side commercial activities. Its business role includes supporting sourcing, import/export procedures, logistics documentation, quality control coordination, and practical communication with suppliers, customers, service providers, and other business counterparties.

As a small and medium-sized enterprise, the company maintains a practical management structure based on responsible human confirmation, appropriate documentation, and clear external communication. The company’s basic corporate information is set out below for institutional review, banking due diligence, public authority enquiries, business partner review, and other qualified counterparty confirmation purposes.

2.1 Basic Company Profile

2.2 Business Role

The company’s primary role is to provide practical trade support and coordination services. This includes sourcing and procurement support, supplier communication, customer communication, quotation coordination, import/export support, shipment follow-up, logistics documentation, quality control coordination, and related business support functions.

The company does not present itself as a financial institution, regulated investment business, public authority, or automated decision-making platform. Its business activities are conducted as a commercial trading and trade-support company.

2.3 External Reference Position

This company profile is provided as part of the company’s published external reference materials. It is intended to assist banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties in understanding the company’s basic corporate background, business role, and operating scope.

Where additional statutory records, director information, shareholder information, significant controller information, business registration documents, transaction records, or supporting materials are required, the company may provide such information separately upon legitimate request and subject to internal confirmation.

3. Directors, Shareholders and Governance Structure

Asiacom Global Trading Limited maintains a practical corporate governance structure appropriate for a small and medium-sized trading company. The company’s governance framework is based on responsible directors, clearly identified shareholders, proper corporate records, documented business communication, and human confirmation of important external matters.

The company recognises that banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties may require a clear explanation of the company’s directors, shareholder structure, responsible persons, statutory records, and control framework. This section provides a general explanation of the company’s directors, shareholding structure, governance framework, and external confirmation policy.

3.1 Directors and Responsible Management

The company has two directors:

The directors are responsible for overall management supervision, business direction, compliance oversight, approval of important matters, and confirmation of external submissions where required.

The company’s day-to-day business operations are conducted under the supervision of responsible management members. Such management may include trade-related communication, sourcing coordination, documentation review, logistics coordination, supplier and customer communication, and other practical business support functions.

Important business decisions, external submissions, banking responses, government-facing explanations, compliance-related responses, and other official communications are subject to confirmation by responsible human members.

3.2 Shareholding Structure

The company maintains shareholder records in accordance with its corporate records and applicable statutory requirements. The shareholding structure is recorded based on the number of issued shares, the class of shares, and the voting rights attached to such shares.

As of the current company records confirmed for this statement, the company’s issued share structure is as follows:

The above shareholding structure is presented based on the number of issued shares. It does not present share capital value, paid-up capital value, or any financial valuation of the company.

3.3 Ownership and Control Explanation

ASIACOMMUNICATION CO., LTD is the principal shareholder of Asiacom Global Trading Limited. The company is therefore positioned as the Hong Kong local entity of the Japan-based Asiacom Group.

The directors and shareholders are recorded in the company’s corporate records. Detailed statutory records, supporting shareholder documents, beneficial ownership information, significant controller information, and other related materials may be provided separately to banks, government offices, public authorities, financial institutions, or other qualified counterparties upon legitimate request and subject to internal confirmation.

3.4 Significant Controller and Statutory Records

The company maintains corporate records, shareholder records, director records, company secretary information, and other statutory records required for a Hong Kong company.

Where applicable, the company also maintains significant controller information and related records in accordance with its statutory record-keeping obligations. Such records are not generally published in full on the public website. However, relevant information or supporting documents may be provided separately to banks, government offices, public authorities, financial institutions, or other qualified counterparties upon legitimate request and subject to internal confirmation.

3.5 Governance and Approval Framework

The company’s governance framework is based on clear responsibility, practical internal confirmation, and appropriate documentation. The company does not rely solely on informal communication for important external matters. Where necessary, important matters are reviewed and confirmed by responsible human members before being communicated externally.

The company’s practical governance structure may be summarised as follows:

This structure is intended to ensure that business activities, external communications, compliance responses, and document submissions are handled with appropriate management oversight and responsibility.

3.6 External Disclosure and Additional Information

The company publishes general corporate background, governance, compliance, information management, and external communication policies as external reference materials on its official website.

Detailed director information, shareholder information, beneficial ownership information, significant controller information, statutory registers, business registration documents, transaction records, and other supporting materials may be provided separately upon legitimate request and subject to internal confirmation.

The company seeks to respond to institutional review, banking due diligence, government office enquiries, public authority requests, periodic status confirmation, and qualified counterparty enquiries in a consistent, accurate, and responsible manner.

4. Relationship with Japan-Based Parent Company and Group Support Framework

Asiacom Global Trading Limited is positioned as the Hong Kong local entity of the Japan-based Asiacom Group. The principal shareholder of the company is ASIACOMMUNICATION CO., LTD, a Japan-based group company.

The company’s relationship with the Japan-based parent company is maintained for group-level business coordination, information management support, documentation standards, administrative support, and back-office coordination. This relationship supports the company’s practical trade-related activities while preserving the Hong Kong entity’s responsibility for Hong Kong-side external communication and company records.

4.1 Position within the Asiacom Group

Asiacom Global Trading Limited operates as the Hong Kong-based trading and business coordination entity of the Asiacom Group. The company supports sourcing, procurement, import/export support, logistics documentation, quality control coordination, supplier and customer communication, and other practical trade-related business functions.

The Japan-based parent company and Tokyo HQ may provide group-level management support, documentation standards, administrative coordination, information management support, and internal back-office assistance where necessary.

Such group support is provided for legitimate business purposes and does not replace the responsibility of the Hong Kong entity for Hong Kong-side external communication, statutory records, business registration matters, bank-facing explanations, government-facing explanations, supplier and customer communication, and external reference materials.

4.2 Parent Company Support Role

The Japan-based parent company may support the Hong Kong entity in the following areas:

The purpose of this support framework is to maintain consistency, accountability, and practical operational control within the group, while allowing the Hong Kong entity to carry out its external business role as a Hong Kong company.

4.3 Responsibility of the Hong Kong Entity

Asiacom Global Trading Limited remains responsible for Hong Kong-side external matters. These include company documents, Hong Kong business communication, responses to banks and government offices, supplier and customer communication, trade-related external reference materials, and other external communications relating to the Hong Kong entity.

External submissions, official responses, bank-facing explanations, government-facing explanations, compliance-related responses, and other important external communications are subject to confirmation by responsible human members.

The Hong Kong entity does not treat group support as a substitute for local management responsibility. Rather, group support is used as a practical management resource to assist the Hong Kong entity in maintaining consistent documentation, responsible communication, and appropriate internal confirmation.

4.4 Information Management Framework

The company recognises the importance of appropriate information management for trade-related business, corporate records, communication records, transaction documents, supplier information, customer information, and external reference materials.

Group-level information management support may be provided under the framework of the Japan-based parent company and Tokyo HQ. Such support may include documentation control, record organisation, administrative review, and internal management support.

Information handled for Hong Kong-side external matters is managed according to legitimate business purpose, appropriate internal confirmation, and the relevant responsibilities of the Hong Kong entity and the Japan-based group.

Where information is required for banking due diligence, public authority enquiries, government office enquiries, periodic status confirmation, business partner review, supplier review, customer review, or other qualified counterparty enquiries, the company may provide relevant information separately upon legitimate request and subject to internal confirmation.

4.5 Regional Coordination

The group maintains corporate and operational functions in Tokyo and Hong Kong, with regional support offices in Taipei and Manila. These offices may provide regional business support, practical communication support, sourcing-related support, administrative coordination, and market-related coordination where required.

Such regional support is used for commercial and operational purposes. The company conducts its activities on a business-oriented, compliance-conscious, and non-political basis.

4.6 External Reference Position

The company publishes basic corporate information, governance information, compliance policy, information management policy, and external communication policy as external reference materials on its official website.

The Hong Kong entity may refer banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties to the company’s published external reference materials for general confirmation of its company background, group relationship, governance structure, and management framework.

Detailed statutory records, shareholder records, director records, significant controller information, transaction records, supporting documents, and official confirmations may be provided separately upon legitimate request and subject to internal confirmation.

5. Operational Separation of External Communication Channels

Asiacom Global Trading Limited maintains its Hong Kong public website and Hong Kong external email environment as separate external communication channels. These channels are used for company information, corporate documents, compliance and governance statements, information management policy, contact information, and downloadable reference materials.

The company recognises the importance of stable, clear, and appropriately managed external communication for banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties. For this reason, the Hong Kong public website and external email environment are maintained for external reference and communication purposes, and are not designed as internal workflow systems.

5.1 Hong Kong Public Website

The Hong Kong public website is operated as a static corporate document website. Its purpose is to publish basic company information, company profile materials, governance explanations, compliance policy, information management policy, contact information, and other external reference documents.

The website is not operated as an online inquiry processing system, internal business portal, accounting system, automated approval system, automated decision-making interface, or internal workflow platform.

The website may be used by banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties to review the company’s published external reference information.

5.2 Hong Kong External Email Environment

The Hong Kong external email environment is maintained as a formal communication channel for the Hong Kong entity. It may be used for business communication, document exchange, external enquiries, supplier communication, customer communication, bank-facing communication, government-facing communication, and other ordinary business correspondence.

External email communication relating to important business matters, bank responses, government office enquiries, public authority requests, compliance-related matters, transaction confirmations, or official company responses may be reviewed or confirmed by responsible human members where necessary.

The company seeks to maintain appropriate records of important external communication in accordance with its documentation and information management principles.

5.3 Separation from Internal AI/API Operations and Workflow Systems

The Hong Kong public website and Hong Kong external email environment are maintained separately from internal AI/API operations, internal workflow systems, accounting workflows, inquiry routing systems, automated approval processes, and automated decision-making systems.

The Hong Kong public website is not designed to function as an entry point into Tokyo HQ internal systems, internal AI operations, internal accounting processes, internal workflow tools, or group-level automated processing environments.

Where internal support, administrative review, documentation control, or group-level information management support is required, such support may be handled separately under the Japan-based parent company and Tokyo HQ framework, subject to legitimate business purpose, internal confirmation, and applicable information management controls.

5.4 Purpose of Separation

The purpose of this operational separation is to maintain external communication stability, operational continuity, jurisdictional clarity, appropriate information management, and clear responsibility between external communication channels and internal business systems.

The Hong Kong entity maintains its public website and external email environment for external reference, communication, and document publication purposes. Internal business systems, internal support tools, group-level administrative systems, and AI/API-related operations, where applicable, are managed separately from the Hong Kong public website and Hong Kong external email environment.

This structure allows the company to provide stable and consistent external reference information while preserving appropriate separation between public-facing communication and internal operational support.

5.5 External Reference and Additional Information

Banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties may refer to the company’s Hong Kong public website for published company information, compliance and governance statements, information management policy, and external reference documents.

Where additional statutory records, supporting documents, transaction records, director information, shareholder information, significant controller information, or official confirmations are required, the company may provide such information separately upon legitimate request and subject to internal confirmation.

6. Information Management Responsibility

Asiacom Global Trading Limited recognises that appropriate information management is an important part of responsible corporate operation, trade-related business, banking communication, government-facing communication, supplier communication, customer communication, documentation control, and external reference disclosure.

The company handles business information, corporate records, transaction documents, communication records, supplier information, customer information, logistics documents, quality control records, accounting-related reference materials, website publication materials, and other business-related information according to legitimate business purpose, responsible management confirmation, and practical information control principles.

6.1 Scope of Information Managed by the Company

The company may handle the following categories of information in the ordinary course of business:

The company manages such information for legitimate business, documentation, compliance, accounting, communication, institutional review, and external confirmation purposes.

6.2 Hong Kong Entity Responsibility

Asiacom Global Trading Limited remains responsible for Hong Kong-side external information, external communication, company documents, bank-facing explanations, government-facing explanations, public authority responses, supplier communication, customer communication, and published external reference materials.

Information used for external submissions, official responses, institutional review, banking due diligence, government office enquiries, public authority requests, periodic status confirmation, or qualified counterparty enquiries is subject to appropriate internal review and responsible human confirmation where required.

The Hong Kong entity does not publish detailed statutory records, personal information, beneficial ownership information, significant controller information, transaction records, or confidential business information in full on the public website. Such information may be provided separately upon legitimate request and subject to internal confirmation.

6.3 Japan-Based Parent Company and Tokyo HQ Support

Group-level information management support may be provided under the framework of the Japan-based parent company and Tokyo HQ. Such support may include documentation standards, record organisation, administrative review, internal management reference, back-office coordination, and group-level information control support.

This support framework is intended to maintain consistency, accountability, and practical management control within the Asiacom Group. It does not replace the responsibility of the Hong Kong entity for Hong Kong-side external communication, external submissions, company records, or official responses relating to the Hong Kong entity.

Where information is reviewed or managed with group-level support, such handling is conducted for legitimate business purposes and subject to appropriate internal confirmation.

6.4 Access, Use and Disclosure Principles

The company applies the following practical principles to information management:

6.5 Public Website Information

The Hong Kong public website is used to publish general company information, company profile materials, compliance and governance statements, information management policy, contact information, and downloadable reference documents.

The website does not publish detailed statutory registers, confidential transaction records, personal information of relevant persons, bank account information, internal approval records, or non-public business records.

The company may update public website materials from time to time to reflect changes in company information, governance arrangements, business operations, regulatory expectations, or internal management policies.

6.6 Additional Information Requests

Banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties may request additional information where necessary for institutional review, banking due diligence, public authority enquiries, periodic status confirmation, transaction review, or other legitimate confirmation purposes.

Where additional statutory records, director information, shareholder information, beneficial ownership information, significant controller information, transaction records, supporting documents, or official confirmations are required, the company may provide such information separately upon legitimate request and subject to internal confirmation.

The company seeks to respond to such requests in a consistent, accurate, and responsible manner while maintaining appropriate information control.

7. Compliance Policy

Asiacom Global Trading Limited recognises compliance as an essential part of responsible business operation, trade-related activity, external communication, corporate governance, and long-term business continuity.

As a small and medium-sized trading company, the company maintains a practical and proportionate compliance framework. The company does not seek to adopt unnecessarily complex procedures that are not suitable for its actual business scale. Instead, it places importance on clear responsibility, lawful conduct, honest communication, appropriate documentation, responsible human confirmation, and practical internal control in daily business operations.

7.1 Basic Compliance Position

The company conducts its business activities on a lawful, honest, commercial, compliance-conscious, and non-political basis.

The company expects its directors, responsible management members, employees, service providers, and relevant business participants to act in accordance with applicable laws, ordinary commercial ethics, internal guidance, and responsible business practices.

The company’s basic compliance position includes the following principles:

7.2 Compliance Responsibility

The directors of the company are responsible for overall compliance supervision, business direction, approval of important matters, and confirmation of external submissions where required.

Responsible management members support daily compliance by reviewing business communication, trade-related documents, supplier and customer communication, logistics documentation, quality control coordination, and other practical business matters.

Employees and relevant business participants are expected to follow company guidance, maintain proper business records, avoid inappropriate conduct, and report matters requiring management attention where necessary.

7.3 Trade-Related Compliance

As a trading company, the company recognises the importance of proper documentation, clear communication, and responsible confirmation in trade-related business.

The company’s trade-related compliance approach includes:

7.4 External Communication and Submissions

The company seeks to provide accurate, consistent, and responsible external communication.

External submissions, bank-facing responses, government office enquiries, public authority requests, compliance-related explanations, and other important external communications are subject to internal review or responsible human confirmation where required.

The company does not intentionally provide false, misleading, incomplete, or inappropriate information to banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, or other qualified counterparties.

Where a matter requires additional verification, the company may confirm the relevant facts internally before providing an external response.

7.5 Compliance Guidance and Internal Awareness

The company’s directors and responsible management members may provide compliance-related guidance to employees and relevant persons as necessary.

Such guidance may include legal compliance, proper documentation, business communication, information handling, anti-bribery awareness, conflict-of-interest awareness, external response procedures, and appropriate handling of company records.

The company seeks to ensure that compliance is not treated only as a formal document, but as a practical principle applied in ordinary business operations.

7.6 Relationship with Other Policies

This compliance policy should be read together with the company’s governance framework, information management responsibility, anti-bribery and anti-corruption policy, documentation and record keeping policy, external communication policy, and human confirmation principle.

The company may update its compliance-related materials from time to time to reflect changes in company information, business operations, regulatory expectations, internal management policies, or external review requirements.

7.7 Additional Information Requests

Banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties may request additional information in connection with institutional review, banking due diligence, government office enquiries, public authority requests, periodic status confirmation, transaction review, or other legitimate confirmation purposes.

Where additional compliance explanations, corporate records, transaction documents, supporting materials, statutory records, or official confirmations are required, the company may provide such information separately upon legitimate request and subject to internal confirmation.

The company seeks to respond to such requests in a consistent, accurate, and responsible manner while maintaining appropriate information control.

8. Anti-Bribery and Anti-Corruption Policy

Asiacom Global Trading Limited recognises that anti-bribery and anti-corruption controls are important elements of responsible business conduct, trade-related operations, corporate governance, banking relationships, public authority communication, supplier relationships, customer relationships, and long-term business continuity.

As a small and medium-sized trading company, the company maintains a practical and proportionate anti-bribery and anti-corruption policy. The company’s approach is based on lawful conduct, honest business communication, avoidance of improper advantages, appropriate documentation, management confirmation, and responsible human judgment in ordinary business operations.

8.1 Basic Policy

The company does not permit bribery, corruption, improper payments, kickbacks, secret commissions, inappropriate benefits, or improper advantages in connection with its business activities.

The company expects its directors, responsible management members, employees, service providers, suppliers, customers, and relevant business participants to conduct business in an honest, lawful, commercially reasonable, and compliance-conscious manner.

The company conducts its business activities on a commercial and non-political basis. Business decisions should be made based on legitimate business considerations, including price, quality, delivery, documentation, reliability, service level, transaction requirements, and responsible management confirmation.

8.2 Prohibited Conduct

The company does not permit the following conduct in connection with its business activities:

8.3 Gifts, Meals, Hospitality and Business Courtesies

The company recognises that ordinary business courtesies may occur in normal commercial relationships. However, gifts, meals, hospitality, entertainment, travel, discounts, benefits, or other courtesies must not be used to obtain improper advantage, influence business decisions, influence official decisions, or avoid proper review.

Any gift, meal, hospitality, or business courtesy should be reasonable, occasional, transparent, commercially appropriate, and consistent with ordinary business practice. It should not be excessive, hidden, misleading, or intended to influence a decision improperly.

Where a business courtesy may create a conflict of interest, appearance of improper influence, or compliance concern, the matter should be reviewed or confirmed by responsible management members before acceptance or provision.

8.4 Supplier, Customer and Service Provider Relationships

The company seeks to maintain supplier, customer, and service provider relationships based on honest communication, commercial reasonableness, proper documentation, and responsible confirmation.

Supplier selection, customer communication, quotation handling, procurement coordination, logistics support, quality control coordination, and related business activities should be conducted based on legitimate business considerations.

The company does not permit suppliers, customers, agents, intermediaries, service providers, or other business participants to offer or receive improper benefits on behalf of the company or in connection with the company’s business activities.

Where a transaction involves unusual payment requests, unexplained commissions, unclear intermediaries, abnormal discounts, requests for confidential treatment without legitimate reason, or other red flags, the matter may be reviewed by responsible management members before proceeding.

8.5 Public Authorities, Government Offices and Banks

The company recognises the importance of proper conduct when communicating with government offices, public authorities, banks, financial institutions, and other institutional counterparties.

The company does not permit improper payments, gifts, benefits, or influence in connection with public authority enquiries, government office communication, banking due diligence, periodic status confirmation, licensing matters, administrative requests, statutory filings, or other official processes.

External responses to banks, government offices, public authorities, financial institutions, and other institutional counterparties should be accurate, consistent, and subject to responsible human confirmation where required.

8.6 Documentation and Record Keeping

The company seeks to maintain appropriate records of business communication, transaction documents, supplier communication, customer communication, invoices, quotations, logistics documents, payment-related correspondence, and other relevant materials.

Payments, commissions, discounts, service fees, reimbursements, and other business-related financial arrangements should be supported by legitimate business reasons and appropriate documentation.

The company does not permit false, misleading, incomplete, or artificial records intended to conceal improper payments, benefits, commissions, gifts, entertainment, or other business arrangements.

8.7 Reporting and Internal Confirmation

Employees, responsible management members, service providers, or relevant business participants should raise concerns with responsible management where they become aware of suspected bribery, corruption, improper payments, inappropriate benefits, conflicts of interest, or unusual transaction requests.

Matters involving anti-bribery or anti-corruption concerns may be reviewed by directors or responsible management members. Where necessary, the company may suspend, decline, review, or terminate a transaction, communication, supplier relationship, service provider relationship, or other business arrangement.

The company seeks to handle such matters in a responsible, practical, and documented manner.

8.8 Relationship with Compliance and Governance Framework

This anti-bribery and anti-corruption policy should be read together with the company’s compliance policy, governance framework, information management responsibility, documentation and record keeping policy, external communication policy, and human confirmation principle.

The company may update this policy from time to time to reflect changes in business operations, regulatory expectations, internal management policies, external review requirements, or practical compliance needs.

8.9 Additional Information Requests

Banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties may request additional information in connection with anti-bribery review, compliance review, banking due diligence, public authority enquiries, periodic status confirmation, transaction review, or other legitimate confirmation purposes.

Where additional anti-bribery explanations, compliance confirmations, transaction records, supporting documents, corporate records, or official confirmations are required, the company may provide such information separately upon legitimate request and subject to internal confirmation.

The company seeks to respond to such requests in a consistent, accurate, and responsible manner while maintaining appropriate information control.

9. Documentation and Record Keeping

Asiacom Global Trading Limited recognises that proper documentation and record keeping are essential for responsible trade-related business, banking communication, government-facing communication, supplier and customer communication, corporate governance, compliance management, and external confirmation.

As a small and medium-sized trading company, the company maintains a practical and proportionate documentation and record keeping framework. The company seeks to keep records that are appropriate for its business scale, transaction nature, administrative needs, statutory obligations, banking requirements, and external review purposes.

9.1 Basic Record Keeping Policy

The company seeks to maintain accurate, clear, and reasonably organised records in relation to its corporate status, trade-related activities, external communication, supplier and customer relationships, compliance matters, and official submissions.

The company does not seek to create unnecessarily complex documentation procedures that are not suitable for its actual business scale. Instead, it places importance on maintaining practical records that support accountability, traceability, transaction confirmation, external review, and responsible management confirmation.

The company’s basic record keeping position includes the following principles:

9.2 Categories of Records

The company may maintain the following categories of records in the ordinary course of business:

9.3 Trade Documentation

As a trading company, the company recognises the importance of maintaining appropriate records for trade-related communication and transaction coordination.

Relevant trade documentation may include quotations, purchase orders, invoices, packing lists, shipping documents, delivery records, supplier correspondence, customer correspondence, inspection or quality-related communication, logistics coordination records, and other transaction-related materials.

The company seeks to ensure that important trade-related documents are handled in a manner that supports transaction confirmation, supplier and customer communication, logistics coordination, accounting reference, compliance review, and external confirmation where necessary.

9.4 External Submissions and Official Responses

External submissions, banking responses, government-facing explanations, public authority replies, institutional review responses, periodic status confirmation materials, and other official company responses may be reviewed or confirmed by responsible human members where required.

The company seeks to avoid providing false, misleading, incomplete, inconsistent, or inappropriate information in external submissions.

Where an external request requires verification of facts, corporate records, transaction records, shareholder information, director information, significant controller information, or other supporting materials, the company may conduct internal confirmation before providing a response.

9.5 Record Retention and Organisation

The company retains records for periods appropriate to business needs, statutory obligations, accounting requirements, banking review, administrative review, transaction confirmation, dispute prevention, and external confirmation purposes.

Records may be maintained in physical form, electronic form, or a combination of both, depending on the nature of the document, business requirement, administrative practice, and practical availability.

The company seeks to organise important records in a manner that allows responsible management members to retrieve, review, and confirm relevant information when necessary for banking due diligence, public authority enquiries, government office enquiries, business partner review, supplier review, customer review, or other qualified counterparty enquiries.

9.6 Version Control of External Reference Materials

The company may publish company profile materials, compliance and governance statements, information management policy, contact information, and other external reference documents on its official website.

Such external reference materials may be updated from time to time to reflect changes in company information, business operations, governance arrangements, internal management policies, regulatory expectations, or external review requirements.

Where appropriate, published external reference materials may include version information, publication status, update date, or other identifying information to support clarity and consistency.

9.7 Confidential and Non-Public Records

The company does not generally publish detailed statutory registers, bank account information, confidential transaction records, internal approval records, detailed beneficial ownership information, significant controller information, personal information, or non-public business records on the public website.

Such records may be provided separately to banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, or other qualified counterparties upon legitimate request and subject to internal confirmation.

The company seeks to maintain an appropriate balance between external transparency and protection of confidential, personal, statutory, transaction-related, and non-public business information.

9.8 Additional Information Requests

Banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties may request additional records or supporting documents in connection with institutional review, banking due diligence, public authority enquiries, government office enquiries, periodic status confirmation, transaction review, or other legitimate confirmation purposes.

Where additional corporate records, statutory documents, transaction records, director information, shareholder information, significant controller information, compliance confirmations, or supporting materials are required, the company may provide such information separately upon legitimate request and subject to internal confirmation.

The company seeks to respond to such requests in a consistent, accurate, practical, and responsible manner while maintaining appropriate documentation control and information management.

10. Human Confirmation and Approval Principle

Asiacom Global Trading Limited recognises that responsible human confirmation is an important part of corporate governance, compliance management, trade-related operations, documentation control, external communication, and institutional accountability.

As a small and medium-sized trading company, the company may use practical business tools, administrative support methods, document preparation tools, communication tools, and group-level support resources where appropriate. However, the company does not treat such tools or support resources as substitutes for responsible human judgment, management confirmation, or director-level responsibility.

10.1 Basic Principle

The company’s basic principle is that important external matters should be reviewed or confirmed by responsible human members where necessary.

This principle applies particularly to external submissions, banking responses, government-facing explanations, public authority replies, compliance-related responses, transaction confirmations, shareholder or director information, statutory information, and other important company communications.

The company seeks to ensure that important external communication is not handled solely by automated processing, informal communication, or unconfirmed draft materials.

10.2 Matters Requiring Human Confirmation

The following matters may require confirmation by directors, responsible management members, or other authorised persons before external use:

10.3 Role of Directors and Responsible Management

The directors of the company are responsible for overall management supervision, business direction, compliance oversight, and confirmation of important matters where required.

Responsible management members support daily operations by reviewing trade-related communication, documentation, supplier and customer communication, logistics coordination, information handling, and external communication where appropriate.

The company’s human confirmation process is intended to support accuracy, accountability, consistency, and practical compliance. It is not intended to create unnecessary delay or excessive procedures, but to ensure that important matters are handled responsibly.

10.4 Use of Business Tools and Support Resources

The company may use practical business tools, administrative tools, document management tools, communication tools, translation support, internal reference materials, and group-level support resources to assist ordinary business operations.

Such tools and resources may support drafting, organising, reviewing, storing, formatting, translating, summarising, or coordinating business information. However, important external submissions and official company responses should be reviewed or confirmed by responsible human members where necessary.

The company does not treat automatically generated, informally prepared, or unconfirmed materials as final official company responses unless they have been reviewed or approved by responsible human members where required.

10.5 External Communication Control

External communication with banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties should be handled in a consistent, accurate, and responsible manner.

Where an external request involves corporate status, director information, shareholder information, significant controller information, statutory records, transaction records, compliance matters, anti-bribery matters, information management matters, or other sensitive information, the company may conduct internal confirmation before providing a response.

If information is incomplete, uncertain, outdated, or requires verification, the company may withhold final response until the relevant facts have been reviewed internally.

10.6 Approval and Version Control

The company may maintain version control for published external reference materials, company profile documents, compliance and governance statements, information management policy, website content, and downloadable documents.

Where materials are updated, the company may record the version date, publication status, update reason, or other identifying information as appropriate.

The purpose of version control is to support clarity, consistency, and traceability when external parties refer to the company’s published materials.

10.7 Relationship with Governance and Compliance Framework

This human confirmation and approval principle should be read together with the company’s governance framework, compliance policy, anti-bribery and anti-corruption policy, information management responsibility, documentation and record keeping policy, and external communication policy.

The company may update this principle from time to time to reflect changes in business operations, internal management practices, external review requirements, regulatory expectations, or practical administrative needs.

10.8 Additional Information Requests

Banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties may request confirmation of company information, corporate records, transaction records, compliance matters, governance arrangements, or external reference materials.

Where additional confirmation is required, the company may provide relevant information separately upon legitimate request and subject to internal confirmation.

The company seeks to respond to such requests in a consistent, accurate, practical, and responsible manner while maintaining appropriate human confirmation, documentation control, and information management.

11. External Communication, Contact and Update Policy

Asiacom Global Trading Limited recognises that clear, stable, and responsible external communication is important for trade-related business, banking relationships, government-facing communication, public authority enquiries, supplier and customer communication, business partner review, and other qualified counterparty confirmation processes.

The company maintains its Hong Kong public website, external email environment, corporate documents, compliance and governance statements, company profile materials, and other external reference materials as part of its practical external communication framework.

11.1 External Communication Policy

The company seeks to provide external communication in a consistent, accurate, and responsible manner.

External communication may include business correspondence, supplier communication, customer communication, bank-facing responses, government office enquiries, public authority replies, due diligence responses, periodic status confirmation, transaction-related communication, and responses to qualified counterparty enquiries.

Where an external request involves important corporate information, statutory records, director information, shareholder information, significant controller information, transaction records, compliance matters, anti-bribery matters, information management matters, or other sensitive information, the company may conduct internal confirmation before providing a response.

The company does not generally treat informal, incomplete, outdated, or unconfirmed materials as final official company responses.

11.2 Official Website and Published Reference Materials

The company may publish basic corporate information, company profile materials, compliance and governance statements, information management policy, contact information, and downloadable external reference documents on its official website.

The official website is intended to serve as a public reference source for banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties.

The company’s published external reference materials may be used to explain the company’s corporate background, group relationship, governance structure, compliance policy, information management responsibility, documentation policy, external communication policy, and human confirmation principle.

11.3 Contact and Enquiry Handling

External enquiries should be directed to the company through its official communication channels.

The company may review and respond to enquiries from banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties according to the nature of the request, the legitimacy of the enquiry, the availability of relevant records, and internal confirmation requirements.

Where an enquiry requires additional verification, supporting documents, statutory records, transaction records, or management confirmation, the company may take reasonable time to review the matter before providing a response.

The company may decline, defer, or limit responses where a request is unclear, unsupported, excessive, unrelated to legitimate business purposes, or inconsistent with appropriate information management controls.

11.4 Update Policy

The company may update its published external reference materials from time to time.

Updates may be made to reflect changes in company information, office information, contact information, directors, shareholders, governance arrangements, business operations, compliance policies, information management practices, documentation procedures, external communication channels, regulatory expectations, or institutional review requirements.

Where appropriate, published external reference materials may include version information, publication status, update date, or other identifying information to support clarity, consistency, and traceability.

Previous versions of external reference materials may be replaced, revised, archived, or withdrawn where necessary.

11.5 Additional Information and Supporting Documents

The company’s public website does not generally publish detailed statutory registers, bank account information, confidential transaction records, internal approval records, detailed beneficial ownership information, significant controller information, personal information, or non-public business records.

Where additional records or supporting documents are required, the company may provide such information separately upon legitimate request and subject to internal confirmation.

Such additional information may include director information, shareholder information, significant controller information, business registration documents, company registration documents, transaction records, trade-related documents, compliance confirmations, banking-related supporting documents, or other materials reasonably required for institutional review, banking due diligence, government office enquiries, public authority requests, periodic status confirmation, transaction review, or other legitimate confirmation purposes.

11.6 No Automatic Approval or Representation

The publication of this statement or any related external reference material does not constitute automatic approval of any transaction, credit arrangement, agency relationship, representation authority, legal opinion, tax opinion, financial advice, investment advice, or regulatory confirmation.

Any specific transaction, contractual arrangement, banking matter, official submission, or legal requirement should be reviewed separately according to the relevant facts, documents, responsible persons, and applicable requirements.

The company may provide additional clarification where necessary upon legitimate request and subject to internal confirmation.

11.7 Final External Reference Position

This statement is published as an external reference document for institutional review, banking due diligence, public authority enquiries, government office enquiries, business partner review, supplier review, customer review, periodic status confirmation, and other qualified counterparty enquiries.

The company seeks to maintain clear, practical, and responsible external communication while protecting confidential information, personal information, statutory records, transaction records, and non-public business information.

The company intends to respond to legitimate external enquiries in a consistent, accurate, practical, and responsible manner, subject to internal confirmation and appropriate information management controls.

12. Statement Status, Limitation and Closing Note

This statement is published by Asiacom Global Trading Limited as an external reference document for institutional review, banking due diligence, public authority enquiries, government office enquiries, financial institution review, business partner review, supplier review, customer review, periodic status confirmation, and other qualified counterparty enquiries.

The purpose of this statement is to provide a consolidated explanation of the company’s corporate background, group relationship, governance structure, shareholding structure, compliance policy, anti-bribery and anti-corruption policy, information management responsibility, documentation and record keeping policy, external communication policy, and human confirmation principle.

12.1 Status of this Statement

This statement is intended to serve as a published external reference document. It may be made available on the company’s official website and may also be provided in PDF or other document format where appropriate.

This statement is not intended to replace statutory records, official filings, business registration documents, company registration documents, shareholder registers, significant controller records, transaction documents, banking documents, legal documents, tax documents, or other formal supporting materials.

Where formal records or supporting documents are required, the company may provide such materials separately upon legitimate request and subject to internal confirmation.

12.2 Scope and Limitation

This statement provides general information regarding the company’s background, management framework, governance position, compliance approach, and external communication policy.

The information contained in this statement is provided for external reference purposes only. It does not constitute legal advice, tax advice, financial advice, investment advice, regulatory advice, credit approval, transaction approval, agency authorisation, representation authority, or any form of automatic confirmation for a specific transaction or arrangement.

Any specific transaction, contract, bank matter, statutory requirement, regulatory matter, tax matter, legal matter, or official submission should be reviewed separately based on the relevant facts, documents, responsible persons, and applicable requirements.

12.3 Accuracy and Update

The company seeks to ensure that the information contained in this statement is accurate, consistent, and appropriate as of the relevant publication or update date.

However, company information, office information, contact information, directors, shareholders, governance arrangements, business operations, compliance policies, information management practices, documentation procedures, external communication channels, and institutional review requirements may change from time to time.

The company may revise, update, replace, archive, or withdraw this statement or related external reference materials where necessary.

Where appropriate, the company may indicate version information, publication status, update date, or other identifying information to support clarity, consistency, and traceability.

12.4 Additional Records and Supporting Documents

The company does not generally publish detailed statutory registers, confidential transaction records, bank account information, internal approval records, detailed beneficial ownership information, significant controller information, personal information, or non-public business records on the public website.

Such records may be provided separately to banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, or other qualified counterparties upon legitimate request and subject to internal confirmation.

Additional information may include director information, shareholder information, significant controller information, business registration documents, company registration documents, transaction records, trade-related documents, compliance confirmations, banking-related supporting documents, or other materials reasonably required for institutional review, banking due diligence, public authority enquiries, government office enquiries, periodic status confirmation, transaction review, or other legitimate confirmation purposes.

12.5 Responsible Communication

The company seeks to maintain clear, practical, accurate, and responsible communication with banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties.

Where an external request involves important corporate information, statutory records, transaction records, compliance matters, governance matters, information management matters, or other sensitive information, the company may conduct internal confirmation before providing a response.

The company seeks to respond to legitimate external enquiries in a consistent, accurate, practical, and responsible manner while maintaining appropriate information control, documentation control, and human confirmation.

12.6 Closing Note

Asiacom Global Trading Limited recognises that compliance, governance, information management, proper documentation, anti-bribery awareness, and responsible human confirmation are important elements of sustainable business operation.

As a small and medium-sized trading company, the company seeks to maintain a practical and proportionate management framework suitable for its business scale, trade-related activities, group structure, external communication needs, and institutional review requirements.

The company will continue to manage its business activities on a lawful, honest, commercial, compliance-conscious, and non-political basis, and will seek to maintain responsible communication with banks, government offices, public authorities, financial institutions, business partners, suppliers, customers, and other qualified counterparties.

This statement is published for external reference and may be updated from time to time as necessary.