• February 10, 2020

深圳市碧澄电子科技有限公司 管理体系及政策细则 Shenzhen Bicheng Electronics Technology Co., Ltd. Compliance Management System and Policy Details 一、商业行为准则 Code of Conduct 1. 秉持诚信、公正、透明的核心价值观，贯穿于所有国内外业务活动及客户往来。 Uphold the core values of integrity, fairness, and transparency in all domestic and international business activities and customer interactions. 2. 严格遵守中国及所有出口目的地的适用法律法规、国际贸易规则及行业标准。 Strictly comply with applicable laws, regulations, international trade rules, and industry standards in China and all export destinations. 3. 坚守公平竞争原则，在全球市场中反对任何形式的不正当竞争、垄断及排他性行为。 Adhere to fair competition principles, opposing any form of unfair competition, monopolistic practices, or exclusionary conduct in the global market. 4. 员工须恪守职业道德，不得利用职务之便谋取私利或从事任何损害公司声誉及客户利益的行为。 Employees must uphold professional ethics and shall not use their positions for personal gain or engage in any conduct that damages the company's reputation or customer interests. 5. 禁止任何形式的欺诈、虚假陈述或隐瞒重要信息，确保所有业务文件、报告及与客户的沟通真实准确。 Prohibit any form of fraud, misrepresentation, or concealment of material information, ensuring all business documents, reports, and communications with customers are truthful and accurate. 6. 严禁向客户、供应商、代理商或其他商业伙伴输送、索取或收受任何形式的不正当利益。 Strictly prohibit offering, soliciting, or accepting any form of improper benefits to or from customers, suppliers, agents, or other business partners. 7. 尊重每一位员工，营造无歧视、无骚扰的国际化工作环境，禁止基于任何个人特征的歧视行为。 Respect every employee and foster an international work environment free from discrimination and harassment, prohibiting discrimination based on any personal characteristic. 8. 保护公司及客户的知识产权、商业秘密及专有技术，严禁未经授权使用或披露。 Protect the intellectual property rights, trade secrets, and proprietary technologies of the company and its customers; strictly prohibit unauthorized use or disclosure. 9. 规范与客户、供应商及公众的信息披露，确保对外发布的信息真实、准确、完整。 Standardize information disclosure to customers, suppliers, and the public, ensuring all external communications are truthful, accurate, and complete. 10. 员工须主动识别并及时向合规部门申报任何潜在的利益冲突，特别是在涉及海外业务或合作方时。 Employees must proactively identify and promptly report any potential conflicts of interest to the compliance department, especially when involving overseas business or partners. 11. 严禁挪用公司资金、侵占公司或客户财产，或未经授权处置公司资产。 Strictly prohibit embezzlement of company funds, misappropriation of company or customer property, or unauthorized disposal of company assets. 12. 严格遵守保密规定，不得泄露公司商业秘密、客户信息、供应链细节及内部敏感数据。 Strictly adhere to confidentiality regulations; do not disclose company trade secrets, customer information, supply chain details, or internal sensitive data. 13. 规范面向海外客户的宣传材料与沟通内容，禁止虚假或夸大宣传，确保信息准确无误。 Standardize marketing materials and communications directed at overseas customers, prohibiting false or exaggerated claims to ensure accuracy. 14. 员工须保持廉洁自律，在与客户及合作伙伴的商务往来中，不得收受或提供可能影响公正决策的馈赠。 Employees must maintain integrity and self-discipline in business dealings with customers and partners, and...

• February 01, 2020

Compliance Manual for the Employment of Minors Chapter 1 General Provisions February 1, 2020 1.1 Purpose To strictly comply with the Labor Law of the People's Republic of China, Regulations on the Prohibition of Child Labor, Minor Protection Law and other relevant laws and regulations, fulfill corporate social responsibilities, protect the physical and mental health of minors, and eliminate any possibility of employing minors under the age of 18 (including child labor under the age of 16 and juvenile workers aged 16 to under 18), this manual is formulated in light of the production characteristics of the PCB (Printed Circuit Board) industry. It aims to establish a "zero-tolerance" control system to ensure the company's complete compliance in employment. 1.2 Scope of Application This manual applies to all operating entities, all departments (including but not limited to the Human Resources Department, all production departments, EHS Department, Supply Chain Management Department, Administration Department, etc.) and all management personnel and employees of the company. This manual applies to all employment links and forms, including: ·Direct employment: all regular employees, temporary workers, interns, seasonal workers. ·Indirect employment: all dispatched workers, outsourced service personnel, on-site personnel assigned by project partners, on-site personnel from suppliers. ·Other forms: any person providing labor or services on the company's premises. 1.3 Core Prohibitions and Principles ·Absolute Prohibition: The company strictly prohibits recruiting or employing minors under the age of 18 for any reason and in any form. ·No Exception Principle: This prohibition applies to all positions, all employment emergencies and all forms of cooperation without any exemption. ·Extended Liability Principle: The company bears the primary responsibility for its own employment acts, and also has the responsibility of prudent review and continuous supervision over the employment compliance of cooperative entities such as labor dispatch and business outsourcing parties. ·Full Staff Responsibility Principle: All employees are obligated to abide by and supervise the implementation of this prohibition. Management personnel at all levels bear direct management responsibility for the implementation in their respective departments/teams. Chapter 2 A Comprehensive Prohibition Control System 2.1 Absolute Prohibition in the Recruitment and Onboarding Process ·Recruitment Promotion: All recruitment advertisements, brochures and notices must clearly state that "the company strictly prohibits the employment of persons under the age of 18, and applications from such persons are declined". ·Age Threshold Setting: The minimum age requirement is compulsorily set as "18 years old and above" in the recruitment system and job application forms. ·Interview Screening: Interviewers shall make a preliminary judgment on the candidate's age, and for those who are obviously young or w...

• March 15, 2021

Supply Chain Human Rights and Environmental Due Diligence Management Rules 15-MAR-2021 Chapter 1 General Provisions Article 1 Purpose of Formulation To comply with the sustainable development compliance requirements of clients and strictly abide by the current laws and regulations of the People's Republic of China, standardize the management of human rights, labor affairs, anti-corruption, environmental protection and other work across the company’s entire supply chain, establish a systematic supply chain due diligence system, identify, prevent and rectify supply chain compliance risks, and ensure the sustained compliance of business operations, these Rules are hereby formulated. Article 2 Scope of Application These Rules shall apply to all departments and on-the-job employees of the Company, as well as all direct suppliers, indirect suppliers, subcontractors, service providers, external cooperation partners and other business partners throughout the supply chain. The Company and all supply chain partners shall comply with these Rules, relevant laws and regulations, and external compliance agreements. Article 3 Basic Principles 1.Full-chain Coverage: Due diligence shall extend to primary, secondary and downstream multi-level supply chains. All partners are required to pass down compliance requirements layer by layer. 2.Priority of Local Laws: Prioritize compliance with the laws and regulations of the People's Republic of China while meeting external cooperation compliance standards. 3.Proactive Risk Prevention: Adhere to pre-inspection, in-process supervision and post-rectification to continuously mitigate risks relating to human rights, labor affairs, the environment and integrity. 4.Transparency and Traceability: Cooperate with audits and inspections conducted by partners and third parties in accordance with laws, and truthfully submit relevant due diligence documents. 5.Accountability and Rectification: Initiate rectification immediately upon discovery of violations. Terminate cooperation in accordance with laws and regulations for parties who refuse to rectify or commit serious violations. Chapter 2 Compliance Implementation and Contract Constraints Article 4 Standard Dissemination Requirements 1.Prior to contract signing, the Procurement/Supply Chain Department shall fully inform all partners of these Rules and external compliance obligations. 2.A special compliance clause shall be added to all external cooperation contracts, stipulating that partners must abide by these Rules and all external compliance requirements, and shall impose corresponding constraints on their downstream suppliers to ensure compliance requirements are implemented throughout the entire supply chain. 3.All new suppliers shall pass compliance access review. No cooperation shall be launched for suppliers failing the review. Article 5 Compliance with Laws and Regulations 1.The Company and its supply chain partners shall strictly abide by the current laws and regulations ...