definiens: means, Luoxin and each of its Representatives not, directly or indirectly, ( a ) making, offering, authorizing, providing or paying anything of value in anyform, whether in money, property, services or otherwise to any Government Official, or otherPerson charged with similar public or quasi - public duties, or to any customer, supplier, or anyother Person, or to any employee thereof, or failing to disclose fully any such payments inviolation of the laws of any relevant jurisdiction to ( i ) obtain favorable treatment in obtaining orretaining business for it or any of its Affiliates, ( ii ) pay for favorable treatment for businesssecured, ( iii ) obtain special concessions or for special concessions already obtained, for or inrespect of it or any of its Affiliates, in each case which would have been in violation of anyapplicable Law, ( iv ) influence an act or decision of the recipient ( including a decision not to act)in connection with the Person ’s or its Affiliate ’s business, ( v ) induce the recipient to use his or herinfluence to affect any government act or decision in connection with the Person ’s or its Affiliate’sbusiness or ( vi ) induce the recipient to violate his or her duty of loyalty to his or her organization, or as a reward for having done so ; ( b ) engaging in any transactions, establishing or maintainingany fund or assets in which it or any of its Affiliates shall have proprietary rights that have notbeen recorded in the books and records of it or any of its Affiliates ; ( c ) making any unlawfulpayment to any agent, employee, officer or director of any Person with which it or any-8 - of its Affiliates does business for the purpose of influencing such agent, employee, officer ordirector to do business with it or any of its Affiliates ; ( d ) violating any provision of applicable Anti - Corruption Laws ; ( e ) making any payment in the nature of bribery, fraud, or any other unlawfulpayment under the applicable Laws of any jurisdiction where it or any of its Affiliates conductsbusiness or is registered ; or, ( f ) if such Person or any of its Representatives is a GovernmentOfficial, improperly using his or her position as a Government Official to influence the award ofbusiness or regulatory approvals to or for the benefit of such Person, its Representatives or anyof their business operations, or failing to recuse himself or herself from any participation as aGovernment Official in decisions relating to such Person, its Representatives or any of theirbusiness operations