Code of Conduct


I. General Provisions

The Company is committed to conducting global business in a lawful, ethical and sustainable manner. This Code of Conduct sets forth our fundamental principles regarding labor rights, occupational health and safety, environmental protection and business ethics. It applies to all employees of the Company, and all suppliers, subcontractors and business partners are required to comply accordingly. We firmly believe that responsible business practices lay the foundation for long-term trust and win-win cooperation.

II. Labor and Human Rights

We strictly abide by the core conventions of the International Labour Organization (ILO) as well as laws and regulations of all countries where we operate, and respect and safeguard the basic human rights of every employee.

2.1 Equal Employment and Anti-Discrimination

All employment terms (including recruitment, promotion, compensation and dismissal) shall be determined based on individual job competency and position suitability rather than personal attributes. We prohibit all forms of discrimination and harassment (including sexual harassment, verbal abuse and mental coercion) regardless of race, skin color, gender, sexual orientation, religion, political opinions, age, marital status or disability.

2.2 Prohibition of Forced Labor

The Company resolutely rejects all forms of forced labor, bonded labor, indentured labor and prison labor. All employment is entirely voluntary, and employees are entitled to resign freely with reasonable prior notice. The Company will never withhold employees’ identity documents or collect any employment deposits.

2.3 Prohibition of Child Labor

No person below the local statutory minimum working age (or below 15 years of age, whichever is higher) shall be hired. If underage workers are recruited by mistake, immediate remedial actions will be taken with top priority given to the best interests of the minor.

2.4 Working Hours and Remuneration

We comply with local laws governing working hours, guarantee at least one rest day per week and provide legally mandated paid leave. Overtime work is voluntary and compensated at legal premium rates. The Company promises to pay fair wages no less than the local statutory minimum wage or industry benchmark, and complete social insurance contributions in accordance with law.

2.5 Humane Treatment and Freedom of Association

We respect employees’ right to work with dignity and respect. Any cruel or inhumane disciplinary measures are forbidden. Meanwhile, employees’ legal right to form and join trade unions and engage in collective bargaining is recognized.

III. Occupational Health and Safety

We strive to build a safe, clean and healthy working and living environment. All applicable occupational health and safety regulations are strictly followed, and effective measures are implemented to prevent work injuries and occupational illnesses. Specific requirements are as follows:
  • Sufficient medical facilities, clean restrooms and accessible drinking water are provided;
  • Workspaces are well-lit and adequately ventilated;
  • Employees are protected against hazardous chemicals and harsh working conditions such as high temperature and excessive noise;
  • Staff dormitories meet equally stringent health and safety criteria;
  • Regular safety training and emergency drills are organized.

IV. Environmental Protection

The Company actively fulfills corporate environmental responsibilities and minimizes environmental footprints through continuous improvement. Our commitments include:
  • Full compliance with all applicable environmental laws and regulations;
  • Promotion of energy conservation, emission reduction and lower greenhouse gas and waste discharge;
  • Waste reduction and resource recycling;
  • Ban on direct discharge of untreated pollutants into the environment.

V. Ethical Business Practices

We conduct business with the highest integrity standards and refrain from all corruption, fraud and unfair competition.

5.1 Anti-Corruption and Anti-Commercial Bribery

We abide by the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and anti-corruption laws of all operating jurisdictions. Employees are prohibited from offering, promising or authorizing any tangible benefits (including bribes, kickbacks, excessive gifts or hospitality), directly or indirectly, to government officials, clients or third parties to seek improper business advantages. Reasonable and legitimate routine business expenses such as standard business meals require prior approval and full and accurate accounting.

5.2 Anti-Fraud and Fair Competition

All deceptive acts targeting clients, suppliers or the Company are prohibited, including financial falsification, document forgery and fraudulent expense reimbursement. We uphold fair competition and comply with antitrust and anti-unfair competition laws worldwide.

VI. Financial Integrity and Accounting Controls

All business transactions must be recorded truthfully, accurately and completely. The Company maintains rigorous internal accounting controls to ensure:
  • All transactions are supported by authentic and legal vouchers;
  • Off-book funds, undisclosed assets or liabilities are forbidden;
  • All expenditures receive proper authorization and approval from management;
  • Accounting manipulation for illegal purposes such as tax evasion and money laundering is strictly banned.

VII. Confidentiality and Data Protection

We attach high importance to information security and privacy protection and strictly protect confidential information belonging to clients, employees and business partners.

7.1 Trade Secrets and Inside Information

Employees must not disclose trade secrets, proprietary technologies or undisclosed material inside information to unauthorized third parties. Such information shall only be shared internally with colleagues on a need-to-know basis within the narrowest necessary scope.

7.2 Data Privacy

For cross-border data processing activities, we comply with applicable data protection laws including the EU General Data Protection Regulation (GDPR) and relevant privacy rules. Personal data of employees, customers and consumers is collected and processed lawfully, fairly and transparently, with proper technical safeguards deployed to secure data.

VIII. Conflicts of Interest

Employees shall actively identify and avoid potential conflicts between personal interests and corporate interests. The following circumstances must be reported to management immediately:
  • Unauthorized use of corporate assets or resources for personal gain;
  • Holding substantial financial interests or employment positions in entities with business ties to the Company;
  • Abusing professional authority to obtain improper benefits for themselves or relatives;
  • Engaging in external activities competing with the Company’s core business.

IX. Intellectual Property Rights

We respect and legally protect intellectual property rights. In global operations, we commit to the following:
  • No infringement upon third-party patents, trademarks, copyrights and trade secrets;
  • No unauthorized use, reproduction or distribution of copyrighted software, documents or designs;
  • Proactive protection of the Company’s own intellectual property assets against infringement.

X. Legal Compliance (International Trade Compliance)

As an import and export enterprise, we abide by laws and regulations of all countries and regions involved in our business, particularly international trade control rules:
  • Compliance with all applicable export control, economic sanction and trade embargo laws, including regulations issued by the U.S. Bureau of Industry and Security (BIS) and EU sanction rules;
  • Accurate customs declaration and adherence to rules of origin and tariff laws;
  • Full compliance of products with destination-market requirements on safety, labeling and environmental standards such as RoHS and REACH;
  • Zero tolerance for money laundering in any form.

XI. Supplier Compliance Accountability

All suppliers, subcontractors and tier-two suppliers are expected and encouraged to acknowledge and adhere to the identical standards set out in this Code. The Company will:
  • Circulate the requirements of this Code in writing to the whole supply chain;
  • Prioritize partners who share our values on labor rights, environmental protection and business ethics;
  • Require suppliers to establish proper mechanisms to guarantee compliance within their own supply chains.

XII. Oversight and Compliance Enforcement

The Company establishes robust oversight mechanisms to ensure full implementation of this Code.

12.1 Inspections and Audits

The Company reserves the right to conduct on-site audits (including scheduled and unannounced inspections), review employment records and hold private interviews with employees to verify compliance.

12.2 Reporting Channels and Anti-Retaliation

Employees and stakeholders are encouraged to report suspected violations of this Code via the following channels:
  • Direct reports to supervisors or the Human Resources/Compliance Department;
  • Anonymous feedback via the designated compliance hotline or email.
The Company strictly prohibits dismissal, threats, discrimination or retaliation of any kind against individuals who report violations in good faith.

12.3 Penalties for Violations

Any employee or business partner found in violation of this Code will face disciplinary actions proportional to the severity of misconduct, up to contract termination or termination of business cooperation. Violations involving criminal offenses will be referred to judicial authorities for legal handling.