AGAPE ATP CORPORATION Statement of Policy Concerning Trading in Company Securities Adopted

of Policy Concerning Trading in Company Securities

SUMMARY OF POLICY CONCERNING TRADING IN COMPANY SECURITIES

is the policy of AGAPE ATP CORPORATION and its subsidiaries (collectively, the "Company") that it will, without exception,

comply with all applicable laws and regulations in conducting its business. Each employee, each executive officer and each director is

expected to abide by this policy. When carrying out Company business, employees, executive officers and directors must avoid any activity

that violates applicable laws or regulations. In order to avoid even an appearance of impropriety, the Company's directors, officers

and certain other employees are subject to pre-approval requirements and other limitations on their ability to enter into transactions

involving the Company's securities. Although these limitations do not apply to transactions pursuant to written plans for trading

securities that comply with Rule 10b5-1 under the Securities Exchange Act of 1934 (the "Exchange Act"), the entry

into, amendment or termination of any such written trading plan is subject to pre-approval requirements and other limitations.

THE USE OF INSIDE INFORMATION IN CONNECTION WITH TRADING IN SECURITIES

U.S. securities laws regulate the sale and purchase of securities in the interest of protecting the investing public. U.S. securities

laws give the Company, its officers and directors, and other employees the responsibility to ensure that information about the Company

is not used unlawfully in the purchase and sale of securities.

employees, executive officers and directors should pay particularly close attention to the laws against trading on "inside"

information. These laws are based upon the belief that all persons trading in a company's securities should have equal access to

all "material" information about that company. Information is considered to be "material" if its disclosure would

be reasonably likely to affect (1) an investor's decision to buy or sell the securities of the company to which the information

relates, or (2) the market price of that company's securities. While it is not possible to identify in advance all information

that will be deemed to be material, some examples of such information would include the following: earnings; financial results or projections;

dividend actions; mergers and acquisitions; capital raising and borrowing activities; major dispositions; major new customers, projects

or products; significant advances in product development; new technologies; major personnel changes in management or change in control;

expansion into new markets; unusual gains or losses in major operations; major litigation or legal proceedings; granting of stock options;

and major sales and marketing changes. When doubt exists, the information should be presumed to be material. If you are unsure whether

information of which you are aware is inside information, you should consult with the Company's Chief Financial Officer. No individuals

other than specifically authorized personnel may release material information to the public or respond to inquiries from the media, analysts

or others. If you are contacted by the media or by a research analyst seeking information about the Company and if you have not been

expressly authorized by the Company's Chief Financial Officer to provide information to the media or to analysts, you should refer

the call to the Chief Financial Officer. On occasion, it may be necessary for legitimate business reasons to disclose inside information

to outside persons. Such persons might include investment bankers, lawyers, auditors or other companies seeking to engage in a potential

transaction with the Company. In such circumstances, the information should not be conveyed until an express understanding has been reached

that such information is not to be used for trading purposes and may not be further disclosed other than for legitimate business reasons.

For example, if an employee, an executive officer or a director of a company knows material non-public financial information, that employee,

executive officer or director is prohibited from buying or selling shares in the company until the information has been disclosed to

the public. This is because the employee, executive officer or director knows information that will probably cause the share price to

change, and it would be unfair for the employee or director to have an advantage (knowledge that the share price will change) that the

rest of the investing public does not have. In fact, it is more than unfair; it is considered to be fraudulent and illegal. Civil and

criminal penalties for this kind of activity are severe.

general rule can be stated as follows: It is a violation of federal securities laws for any person to buy or sell securities if he or

she is in possession of material inside information. Information is material if there is a substantial likelihood that a reasonable investor

would consider it important in making an investment decision. It is inside information if it has not been publicly disclosed in a manner

making it available to investors generally on a broad-based non-exclusionary basis. Furthermore, it is illegal for any person in possession

of material inside information to provide other people with such information or to recommend that they buy or sell the securities. (This

is called "tipping"). In that case, they may both be held liable.

Securities and Exchange Commission (the "SEC"), the stock exchanges and plaintiffs' lawyers focus on uncovering

insider trading. A breach of the insider trading laws could expose the insider to criminal fines up to three times the profits earned

and imprisonment up to ten years, in addition to civil penalties (up to three times of the profits earned), and injunctive actions. In

addition, punitive damages may be imposed under applicable state laws. Securities laws also subject controlling persons to civil penalties

for illegal insider trading by employees, including employees located outside the United States. Controlling persons include directors,

officers, and supervisors. These persons may be subject to fines up to the greater of $1,000,000 or three times profit (or loss avoided)

by the insider trader.

information does not belong to the individual directors, officers or other employees who may handle it or otherwise become knowledgeable

about it. It is an asset of the Company. For any person to use such information for personal benefit or to disclose it to others outside

the Company violates the Company's interests. More particularly, in connection with trading in the Company's securities,

it is a fraud against members of the investing public and against the Company.

directors, executive officers and employees of the Company must observe these policies at all times. Your failure to do so will be grounds

for internal disciplinary action, up to and including termination of your employment or directorship.

Who Does the Policy Apply To?

prohibition against trading on inside information applies to directors, officers and all other employees, and to other people who gain

access to that information. The prohibition applies to both domestic and international employees of the Company and its subsidiaries.

Because of their access to confidential information on a regular basis, Company policy subjects its directors and certain employees (the

"Window Group") to additional restrictions on trading in Company securities. The restrictions for the Window Group

are discussed in Section F below. In addition, directors and certain employees with inside knowledge of material information may be subject

to ad hoc restrictions on trading from time to time.

Other Companies' Stock.

executive officers and directors who learn material information about suppliers, customers, or competitors through their work at the

Company, should keep it confidential and not buy or sell stock in such companies until the information becomes public. Employees, executive

officers and directors should not give tips about such stock.

Hedging and Derivatives.

executive officers and directors are prohibited from engaging in any hedging transactions (including transactions involving options,

puts, calls, prepaid variable forward contracts, equity swaps, collars and exchange funds or other derivatives) that are designed to

hedge or speculate on any change in the market value of the Company's equity securities.

in options or other derivatives is generally highly speculative and very risky. People who buy options are betting that the stock price

will move rapidly. For that reason, when a person trades in options in his or her employer's stock, it will arouse suspicion in

the eyes of the SEC that the person was trading on the basis of inside information, particularly where the trading occurs before a company

announcement or major event. It is difficult for an employee, executive officer or director to prove that he or she did not know about

the announcement or event.

the SEC or the NYSE were to notice active options trading by one or more employees, executive officers or directors of the Company prior

to an announcement, they would investigate. Such an investigation could be embarrassing to the Company (as well as expensive), and could

result in severe penalties and expense for the persons involved. For all of these reasons, the Company prohibits its employees, executive

officers and directors from trading in options or other derivatives involving the Company's stock. This policy does not pertain

to employee stock options granted by the Company. Employee stock options cannot be traded.

Pledging of Securities, Margin Accounts.

securities may be sold by the pledgee without the pledgor's consent under certain conditions. For example, securities held in a

margin account may be sold by a broker without the customer's consent if the customer fails to meet a margin call. Because such

a sale may occur at a time when an employee, executive officer or a director has material inside information or is otherwise not permitted

to trade in Company securities, the Company prohibits employees, executive officers and directors from pledging Company securities in

any circumstance, including by purchasing Company securities on margin or holding Company securities in a margin account.

following guidelines should be followed in order to ensure compliance with applicable antifraud laws and with the Company's policies:

Nondisclosure. Material inside information must not be disclosed to anyone, except to persons within the Company whose positions

require them to know it. Tipping refers to the transmission of inside information from an insider to another person. Sometimes this involves

a deliberate conspiracy in which the tipper passes on information in exchange for a portion of the "tippee's" illegal

trading profits. Even if there is no expectation of profit, however, a tipper can have liability if he or she has reason to know that

the information may be misused. Tipping inside information to another person is like putting your life in that person's hands.

So the safest choice is: Don't tip.

Trading in Company Securities. No employee, executive officer or director should place a purchase or sale order, or recommend

that another person place a purchase or sale order in the Company's securities when he or she has knowledge of material information

concerning the Company that has not been disclosed to the public. This includes orders for purchases and sales of stock and convertible

securities, including engaging in any "short sales" of the Company's securities. The exercise of employee stock options