Business Ethics Code of Conduct-Notice-Xispek

In order to strengthen employees' awareness of the code of conduct, Cispec has formulated the Cispec Code of Business Conduct (hereinafter referred to as the “Code”), so that employees can raise their awareness in the performance of their duties, and in the face of contradictions with the interests of the company or in the middle of a conflict, they can act ethically and carry out their responsibilities in a fair and upright manner.
This Code applies to all employees of the Company and all affiliated companies, including full-time, part-time and outsourced employees.
1. Ethics and Integrity
Personal ethics and integrity are the cornerstone of the company's success. We shall avoid getting involved in any situation that could lead to the influence of impartiality or be perceived as a conflict of interest. It is prohibited for anyone to use his or her position for improper gain. The Company will not tolerate the misuse or misappropriation of Company assets. All information relating to the Company's business, customers, suppliers and employees shall be kept confidential and privacy shall be safeguarded.
1.1 Bribery, Networking and Benefits
The Company strictly prohibits bribery and will not tolerate any employee giving, soliciting or accepting a bribe, including soliciting or offering any benefit to customers, suppliers, legislative and/or law enforcement authorities or others involved in the Company's business; or acting as a third party intermediary in order to offer, solicit or accept any benefit. It is a violation of this Code for any person, with or without the permission of a supervisor, to use his or her position to solicit or accept benefits of any kind.
1.1.1 Offering Benefits:Under no circumstances shall an employee offer a bribe or improper benefit to any person or organization for personal gain or for the benefit of the Company.
1.1.2 Solicitation of Benefits:Employees shall not solicit, directly, indirectly, or in any form, any benefits from any organization or individual related to the Company's business.
1.1.3 Acceptance of Benefits: Employees shall not accept any benefits directly or indirectly related to the Company's business if such acceptance would impede their objective judgment and handling of the business in question, induce them to be contrary to or detrimental to the Company's interests, lead to violations of laws, regulations and the requirements of the Listing Site, generate complaints of favoritism or misconduct, and/or make them feel the need to reciprocate the giver in the business.
1.1.4 All behavior related to unbundling fees is prohibited.
1.2 Dealing with Conflicts of Interest
1.2.1 Definition of Conflict of Interest
Common conflict of interest situations include, but are not limited to, the following.
1.2.1.1 Undeclared financial interests/transactions with any supplier, service provider or related person doing business with the company.
1.2.1.2 Employing service providers who work or have worked for the Company to work or provide services, goods, etc. for him/her and/or his/her immediate family members. 1.2.1.3 Providing special privileges to individual vendors, service providers, customers, job applicants, subordinates, or superiors, etc. for personal reasons.
1.2.1.4 Employees or their immediate family members (including parents, children and spouses) are engaging in, or considering engaging in, things, investments or activities that have a conflict of interest with the Company, or that may lead to a conflict of interest; and
1.2.1.5 to use work time, company assets (including human resources), for outside work within the company; and
1.2.1.6 Providing assistance to competitors of the Company; and
1.2.1.7 Privately providing or manufacturing services or goods that are in competition with the Company.
1.2.2 Declaration of Conflicts of Interest
Employees are expected to avoid actual or predictable personal conflicts of interest with the Company or to influence their judgment in the performance of their duties. Employees shall be required to declare all actual or predictable conflicts of interest in a timely manner.
1.2.2.1 If an employee realizes that a conflict of interest with the Company exists or may exist, he/she must immediately and truthfully declare it in writing to his/her department head.
1.2.2.2 Failure of an employee to comply with the above requirements may result in severe disciplinary action, including demotion and dismissal.
1.3 Insider Trading
1.3.1 If an employee has any material information and/or price-sensitive non-public data about the Company or any other listed companies with which the Company has business dealings, the employee should not buy or sell any securities of the Company or such listed companies, or disclose the relevant information to others, before such data is made public.
1.3.2 Employees shall comply with all legal regulations regarding insider trading. Any employee who participates in insider trading will be penalized or even dismissed in accordance with the relevant company systems. At the same time, the Company will also report to the relevant law enforcement authorities.
1.4 Anti-Money Laundering
Money laundering is the use of otherwise legal business transactions to conceal the source of illegally obtained funds, usually involving payments in the form of cash or money orders. Suspicious activities include large cash transactions and customers who are unwilling to provide verifiable information. We comply with applicable anti-money laundering laws and regulations. We do not tolerate, support or facilitate money laundering.
All employees are expected to
1.4.1 Pay attention to the compliance of payment methods.
1.4.2 If there are concerns about a payment, they need to be reported to your supervisor.
1.4.3 If a transaction is suspicious, report the matter to Legal Compliance even if the transaction does not continue.
1.5 Anti-Undue Competition
In a free market system, competition drives efficiency and innovation. However, violating laws that protect competition can result in penalties including substantial fines, imprisonment, damage to reputation and exclusion from government contracts. We are committed to complying with anti-undue competition/antitrust related laws and regulations in any place of business to maintain a fair and orderly marketplace.
All employees shall.
1.5.1 Always refer to this Code when interacting with competitors.
1.5.2 Seek guidance from the Legal Compliance Department whenever anti-unfair competition/anti-trust issues arise.
1.5.3 Make full use of public information and the competitive environment for competitive activities.
1.5.4 Keep in mind that illegal and unethical behavior is not permitted under any circumstances.
1.5.5 Prohibit discussing with competitors any of the Company's competition-related terms, work, customers or prices.
1.5.6 It is prohibited to discuss with a competitor plans to submit bids or quotes on any particular project or customer.
1.5.7 It is prohibited to talk with anyone about boycotting or rejecting certain suppliers or customers.
1.5.8 It is prohibited to take any action for the purpose of harming or retaliating against a competitor.
1.6 Use of IT facilities and services
1.6.1 The Company I facilities and services are available for use by employees in the performance of their duties. The Company has established an Information Security Policy and a series of rules and regulations to safeguard the security and integrity of information. Employees are expected to follow these policies and regulations when using I facilities and services.
1.6.2 The IT department will monitor the use of these facilities and services without violating the privacy of employees to ensure compliance with IT rules and regulations, and violators will be subject to disciplinary action.
1.6.3 Company mail is used for company business management purposes. Employees shall use the service appropriately in accordance with national laws and regulations as well as social morals and ethics. Employees shall not send emails that are defamatory, harassing, pornographic, discriminatory, obscene, degrading, teasing, fraudulent, inflammatory or otherwise offensive.
1.6.4 Employees shall use the Internet facilities provided by the Company legally, appropriately and ethically. Employees shall use these facilities appropriately in accordance with national laws and regulations as well as social morals and ethics, and shall not participate in online games, download offensive or obscene materials, illegal software, freeware or shareware from the Internet, or utilize the facilities to operate or support businesses unrelated to the Company or unapproved by the Company for profit.
1.7 Confidential/Sensitive Information
1.7.1 Unless required by law or regulation, employees shall not disclose any confidential and/or sensitive information of the Company to any person outside the normal course of the Company's business at any time without the approval of their supervisor.
1.7.2 Such information and data include all data relating to the Company's operations that are transmitted and/or maintained in electronic and/or other forms such as written, faxed or verbal, including bidding information, contract prices, investment strategies, business strategies and plans, financial projections, employee and customer information, rules and regulations, patent applications, customer databases, and research and technical data.
1.7.3 Data relating to and provided by outside persons with whom the Company has or will have business dealings, such as customers, service providers, suppliers, partners or any other persons.
1.7.4 All employees who are authorized to access or manage any of the Company's data must take adequate measures to protect the data from accidental public disclosure, misuse or abuse. Examples of improper use of data include disclosure of data in exchange for monetary or other rewards, use of data for private interests or purposes, disclosure of data to the detriment of the Company, or any other use that jeopardizes or damages the interests and reputation of the Company or its employees.
2、Protect the rights and interests of employees
Employees are our most valuable assets. We care about their well-being, respect their personal characteristics, and establish a working environment of mutual trust and love. Mutual love and care helps employees' personal and professional development, and is also conducive to the company's development and profit growth.
2.1 Employee Privacy
We respect the privacy of our employees. Employees' personal information is protected and kept strictly confidential. We will avoid collecting unnecessary personal data. At the same time, we will comply with personal data (privacy) requirements when collecting and using personal data.
2.2 Equal Opportunities
The Company actively promotes equal opportunities and prohibits all kinds of discriminatory behaviors, and provides equal opportunities to employees in matters of recruitment, training, promotion, transfer, remuneration, benefits and termination of contracts. Such opportunities are not affected by factors such as age, gender, pregnancy, physical health or mental condition, marital status, family position, race, color, nationality, religion, political affiliation and sexual orientation. In addition, we recognize and reward employees for their contributions, performance and skills. We offer compensation and training opportunities to all employees based on their position, individual abilities and performance as objective criteria. In addition, we will not tolerate any discrimination, harassment, vilification and targeting (discrimination by victimization) in the work environment.
2.3 Health and Safety
We comply with all relevant occupational health and safety regulations and formulate occupational health and safety policies covering all full-time, part-time, outsourced and contractor employees of the company, and are committed to providing a safe and healthy working environment for our employees to fully safeguard their health and safety. The Safety and Environmental Protection Department of the company has formulated rules and regulations related to production safety, and all employees have the corresponding responsibilities and obligations to protect their own occupational health and safety and that of all related personnel.
3、Protect the environment
Efforts to improve environmental standards, actively respond to climate change and continuously improve processes all contribute to the company's green and sustainable development. The Company has developed an Environmental Policy that demonstrates our commitment to implementing best practices on environmental issues and outlines the improvements and efforts we have made. The policy covers environmental compliance, climate change, emission reduction, resource use, recycling, biodiversity, etc.
All employees are expected to
3.1 Comply with environmental laws and regulations that apply to their jobs.
3.2 Participate in training programs related to environmental protection.
3.3 Report any violations of environmental laws and regulations.
3.4 Read and understand our environmental policy.
4. Compliance with the Code of Conduct
All employees are responsible for understanding and complying with this Code of Conduct, and are obligated to follow procedures for reporting violations of the Code. Anyone who violates the Code will be subject to disciplinary action.
4.1 Announcement and Training of the Code of Conduct
Each unit head shall instruct his/her subordinates to understand and apply the principles and requirements of this Code. To ensure that employees comply with and implement the Code, all employees should receive training on the Code when they join the company. Employees who encounter problems with the implementation of the Code, or have any comments or suggestions, should bring them to the attention of the relevant department for follow-up action.
4.2 Reporting and Investigation of Violations of the Code of Conduct
The Company expects and encourages employees and persons with whom the Company has business dealings (e.g., customers, suppliers, rights holders and debtors) to report to the Company any possible misconduct in financial reporting, internal control or other matters, any actual or suspected violation of the Code, and any inappropriate or unlawful behavior in relation to the Company.

4.2.1 Whistleblowing
4.2.1.1 Any actual or suspected violation of the Code of Conduct, including fraudulent and unlawful conduct, should be reported in writing or orally to the Company's HR department, along with the relevant information.
4.2.1.2 Every report will be kept confidential. The identity of the whistleblower will not be disclosed without his/her consent, except as required by applicable laws and regulations or as required by an order or directive of any court having jurisdiction over the Company.
4.2.1.3 Every effort will be made to protect the Whistleblower and the information received about the report. We will not discriminate against or retaliate against or victimize an employee who makes a report, even if the report ultimately proves to be incorrect or unsubstantiated, if the reporting employee provides a true reason and accurate information. Harassment, discrimination, retaliation and victimization of a whistleblower will be considered serious misconduct and, if proven, may result in termination of employment.
4.2.1.4 However, if the whistleblower has an ulterior motive or maliciously makes a false report for personal gain, the Company reserves the right to take appropriate action against the relevant persons, including the whistleblower, and to take disciplinary action against the internal staff in accordance with the relevant provisions of the Company.
4.2.2 Investigation
4.2.2.1 Receiving any report, the investigation team will be fair and effective investigation. The purpose of the investigation is to assess whether the reported matter is indeed a violation of internal rules and regulations and/or the Code of Conduct.
4.2.2.2 After completing the necessary procedures, the investigation team issues an investigation report based on the facts verified by the investigation.
4.2.2.3 During the investigation, the employee under investigation may be suspended.
4.3 Penalties for violating the Code of Conduct
4.3.1 We will not tolerate any violation of the Code of Conduct. Any employee found to have directly or indirectly violated the requirements of the Code will be subject to disciplinary action, including dismissal.
4.3.2 In the event of suspected embezzlement or other forms of illegal behavior detrimental to the Company, the matter will be referred to judicial authorities with the approval of the Company.
4.4 Revision and Updating of the Code of Conduct
The Company shall check whether the contents of the Code are applicable or need to be updated at least once every three years or as necessary, and revise, improve and enhance the Code according to the actual situation, as well as publish it to the employees on the Company's intranet or official website.