1、WHAT TO KNOW

The Company's relationships with suppliers must be based on lawful, efficient and fair practices. We expect our suppliers to obey the laws that require them to treat workers fairly, provide a safe and healthy work environment and protect environmental quality. Following the Company guidelines helps ensure that our supplier relationships will not damage the Company's reputation.

2、WHAT TO DO

• COMPLY WITH APPLICABLE LAWS and government regulations covering supplier relationships.
• DO BUSINESS only with suppliers that comply with local and other applicable legal requirements and the Company guidelines relating to labor, the environment, health and safety.
• FOLLOW GOVERNMENT ACQUISITION REGULATIONS when purchasing materials and services for fulfilling government contracts.
• PROVIDE A COMPETITIVE OPPORTUNITY for suppliers to earn a share of the Company’s purchasing volume, including small businesses and businesses owned by the disadvantaged, minorities, women and disabled veterans.
• SAFEGUARD THE COMPANY’S CONFIDENTIALAND PROPRIETARY INFORMATION with a confidentiality agreement, and safeguard any supplier-provided information protected by any confidentiality agreement.
• SAFEGUARD “PERSONAL DATA” obtained from suppliers.

3、MORE INFORMATION

Please contact CAMS Compliance office for more policies and information.

1、WHAT TO KNOW

International trade control (ITC) laws affect the transmission of goods, services and technology across national borders. These laws apply to many aspects of the Company’s operations — not just the shipment of products. Exchanges of information across national boundaries are also subject to trade controls. The Company must comply with all applicable trade control laws, including those of China and the United States.

2、WHAT TO DO

• FOLLOW RELEVANT ITC REGULATIONS and the Company procedures as they relate to importing and exporting goods, technology, software, services and financial transactions.
• REPORT ALL RELEVANT INFORMATION to ensure accurate and complete import declarations. Ensure the Company or its agent provides accurate and complete information to government authorities.
• CHECK THE EXPORT CLASSIFICATION of the product, software or technology prior to export to determine whether special authorization is required.
• SCREEN YOUR TRANSACTIONS AND BUSINESS PARTNERS against all applicable rules that restrict transactions with certain sanctioned countries, persons and prohibited end uses (watchlists).
• DO NOT COOPERATE WITH ANY RESTRICTIVE TRADE PRACTICE or boycott that is prohibited or penalized under applicable laws.

3、MORE INFORMATION

Please contact CAMS Compliance office for more policies and information.

1、WHAT TO KNOW

People involved in criminal activity — e.g., terrorism, narcotics, bribery, and fraud — may try to “launder” the proceeds of their crimes to hide them or make them appear legitimate. More than 100 countries now have laws against money laundering, which prohibit businesses from conducting transactions that involve proceeds of criminal activities.

The Company is committed to complying fully with all anti-money laundering laws throughout the world. The Company will conduct business only with reputable customers involved in legitimate business activities, with funds derived from legitimate sources. The Company will implement a risk-based due diligence procedure calibrated to the risk in question, so that employees can take reasonable steps to prevent and detect unacceptable and suspicious forms of payment. Failing to detect customer relationships and transactions that place the Company at risk can severely damage the Company's integrity and reputation.

2、WHAT TO DO

• COMPLY WITH ALL APPLICABLE LAWS and regulations that prohibit money laundering and that require the reporting of cash or suspicious transactions. Understand how these laws apply to your business.
• FOLLOW DD PROCEDURES.Collect and understand documentation about prospective customers, agents and business partners to ensure that they are involved in legitimate business activities and their funds come from legitimate sources.
• FOLLOW YOUR BUSINESS’S RULES concerning acceptable forms of payment. Learn the types of payments that have become associated with money laundering (for example, multiple money orders or travelers checks, or checks on behalf of a customer from an unknown third party).
• IF YOU ENCOUNTER A WARNING SIGN of suspicious activity, raise your concern ASAP.

3、MORE INFORMATION

Please contact CAMS Compliance office for more policies and information.

• COMPLY with all applicable competition laws and regulations as well as competition law decrees, orders and agreements with any competition regulator about how business will be conducted.
• REVIEW AND UNDERSTAND COMPANY policies and procedures, and if you have questions or issues, bring them up with Company compliance or legal resources.
• DO NOT propose or enter into agreements or understandings — expressed or implied, formal or informal, written or oral — with any competitor regarding any aspect of the competition between the Company and the competitor. Do not discuss with a competitor or competitor representative:
  • prices
  • bids
  • sales territories, allocation of customers or product lines
  • terms or conditions of sale
  • production, sales capacity or volume
  • costs, profits or profit margins
  • market share
  • product or service offerings
  • customer or supplier classification
  • distribution methods
• DO NOT propose or enter into agreements with anyone (including competitors, agents, brokers or customers) regarding whether to submit a bid or the terms of a bid where there is an understanding that the bid is submitted for any purpose other than winning the business.
• AVOID CONTACTS of any kind with competitors that could create the appearance of improper agreements or understandings.
• DO NOT propose or enter into agreements or understandings with suppliers that restrict the price or other terms at which Company may resell or lease any product or service.
• CONSULT with Company legal counsel to help reduce the risks of noncompliance in the evaluation of any proposed merger, acquisition, joint venture or any other business arrangement that could raise competition law issues (examples of arrangements that need to be discussed with counsel are listed in “What to Watch Out For” below).

MORE INFORMATION

Please contact CAMS Compliance office for more policies and information.

1、WHAT TO KNOW

In any case, any commercial bribery or bribery to obtain commercial benefits is unacceptable, which will make the company and himself face criminal proceedings.

Therefore, the company explicitly forbids giving or offering bribes and accepting or soliciting bribes. Corruption is a serious problem in business transactions, which leads to unreasonable business decisions, or to achieve the purpose of damaging the interests of the company.

At the same time, it will make itself face criminal proceedings and bear criminal responsibility. Therefore, the company will take all means to eliminate the possible corrupt behaviors or phenomena. Commercial bribery or bribery should not be confused with the following items: small business gifts in accordance with the law, reasonable small gifts with company logo in a certain amount, and business entertainment expenses directly related to product promotion or contract execution. These fees are permissible on the premise that they are in line with the company's code of business conduct. The CCO reviews and monitors the expenses of these expenses. If the amount exceeds a certain limit, the approval of the BOM is required.

2、WHAT TO DO

• BEFORE GIVING A GIFT, engaging in customer entertainment or reimbursing customer travel expenses, make sure you understand applicable legal requirements, the customer’s own rules and the Company guidelines.
• MAKE SURE RECORDS OF SUCH EXPENDITURES accurately reflect the true nature of the transaction.
• NEVER OFFER A BUSINESS COURTESY, such as a gift, contribution or entertainment, under circumstances that might create the appearance of an impropriety.
• NEVER OFFER, PROMISE, PAY OR AUTHORIZE anything of value (such as money, goods or services) to a government official or employee of a customer to obtain or retain an improper advantage.
• NEVER GIVE A GRATUITY or other payment to government officials or employees to expedite a routine administrative action without fully disclosing it to the CCO.
• REQUIRE ANY PERSON OR FIRM WHO REPRESENTS THE COMPANY (such as a consultant, agent, sales representative, distributor or contractor) to comply with this policy and related laws.
• FOLLOW YOUR BUSINESS' DUE DILIGENCE PROCEDURES when selecting persons or firms to represent the Company.

3、MORE INFORMATIO

Please contact CAMS Compliance office for more policies and information.

1、WHAT TO KNOW

On the job or in your free time, nothing you do should conflict with your responsibilities for the Company. In addition, no activity at work or at home should hurt the Company’s reputation or good name. Misusing Company resources or influence is also prohibited. Even when nothing wrong is intended, the appearance of a conflict can have negative effects. It is crucial to consider how your actions might appear, and to avoid the perception of a conflict of interest.

2、WHAT TO DO

• DISCLOSE (in writing to your manager and to Company legal counsel) all of your outside activities, financial interests or relationships that may either present a conflict or the appearance of one.
• USE GOOD JUDGMENT in all personal and business dealings outside your job with the Company.
• AVOID ACTIONS OR RELATIONSHIPS that may cause potential conflicts or create the appearance of a conflict with your job or the Company's interests.
• DO NOT MISUSE or use for personal gain Company resources, intellectual property, time or facilities — this includes office equipment, e-mail and computer applications.
• DO NOT TAKE for yourself personally any opportunities that the Company could have an interest in that are discovered through the use of the Company position, information or property.

3、MORE INFORMATION

Please contact CAMS Compliance office for more policies and information.

1、RAISE YOUR VOICE:

• RAISE CONCERNS EARLY.
• The longer we wait to address a concern, the worse it may become.
• YOU MAY REMAIN ANONYMOUS.
• However, if you identify yourself, we are able to follow up with you and provide feedback.
• CONFIDENTIALITY IS RESPECTED: Your identity and the information you provide will be shared only on a “need-to-know” basis with those responsible for resolving the concern.
• RETALIATION VIOLATES COMPANY POLICY: the Company absolutely prohibits retaliation against anyone for raising or helping to address an integrity concern. Retaliation is grounds for discipline up to and including dismissal.