Opera Hong Kong Limited(OHK)(hereafter referred to as the Company) regards

enforcement authority concerned.

27. A Director andstaff member should also report other irregularities observed in the course of their official dutiesto the General Manager or Chairman of the Board as appropriate. All such reports should be treated in the strictest confidence.

Compliance with the Code

28. It is the responsibility of every director, non-director board committee member and staff member of the Company to understand and comply with this Code, irrespective whether performing his/herduties to the Company in or outside Hong Kong. Managers and supervisors should also ensure that the staff under their supervision understand well and comply with this Code.Under no circumstances will ignorance, either real or alleged, of the contents of this Code be accepted as an excuse for non-compliance with the Code’s provisions.

29. Any directorand non-director board committee memberin breach of this Code will have their appointments terminated. Any staff member in breach of this Code will be subject to disciplinary action, including termination of employment . Any enquiries about this Code or reports of possible breaches of this Code should be made to the General Manageror the Chairman of the Board as appropriate. In cases of suspected corruption or other criminal offences, a report should be made to the appropriate authority.

Review

30. This Code is subject to review and revision from time to time by the Company.

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