Business Conduct and Ethics Policy

1 General Provisions

1 Purpose

The Code of Business Conduct and Ethics is the business conduct principle of Sieyuan Electric Co., Ltd. and all its subsidiaries worldwide.

2 Scope

This standard applies to all directors and employees (temporary or long-term) worldwide, regardless of the specific entity or subsidiary of Sieyuan Electric Co., Ltd. (wholly or partially controlled) (hereinafter collectively referred to as "Sieyuan Electric employees" or "employees").  We also encourage business partners, contractors, suppliers, and other stakeholders to apply this code where feasible.

3 Responsibilities

The Sustainable Development Committee of Sieyuan Electric is responsible for developing, reviewing, and updating this code of conduct annually to ensure compliance with the latest local laws, regulations, and industry standards.  By establishing internal control mechanisms, monitoring business ethics and sustainable performance, and regularly reporting.

The senior management bears ultimate responsibility for complying with this code of conduct in their operations.

Employees have the obligation to understand and strictly abide by the principles stipulated in this code, actively participate in relevant training activities, and enhance their own awareness.  Timely report any behavior that may violate this policy.

4 Communication and Reporting

Sieyuan Electric regularly communicates with all employees, business partners, contractors, suppliers, and other stakeholders regarding this code of conduct.  We encourage employees, suppliers, contractors, and other stakeholders to monitor the implementation of this code and promptly report any violations of this code.

We promise to protect the reporter's information from disclosure and prevent any possible retaliation.  The contact email for the report is hgfwb@sieyuan.com  .

For specific reporting methods, please refer to the company's "Reporting Management Measures V1.1_Internal"

This policy should be updated every three years and communicated with stakeholders in a timely manner.

2 Principle

Employees of the company should always uphold high standards of business ethics.  All employees of the company must sign the "Commitment Letter to Business Conduct and Ethics Code" when they join. Violation of business conduct and ethics code will result in disciplinary action by the company, up to dismissal or even legal responsibility.

Here is our code of conduct and explanation:

1 Laws, Regulations and Provisions

Sieyuan Electric is committed to ensuring that all of its business operations comply with all applicable laws, regulations, and rules.  Such regulations include anti-monopoly and promotion of fair competition, anti bribery, anti-corruption, anti fraud, anti money laundering, anti insider trading, privacy and information security, labor standards and human rights protection for companies and supply chains (related to the prohibition of forced labor, child labor, human trafficking, and slavery), environmental protection, safety, and other related provisions.

Every employee is responsible for complying with all applicable laws and regulations in the country or region where Sieyuan Electric operates.  Those who do not comply may face disciplinary action and even legal responsibility.

2 Anti Corruption and Anti Bribery

Sieyuan Electric adopts a zero tolerance policy towards any form of corruption, including bribery, fraud, embezzlement, and other corrupt practices.  All employees shall abide by the highest ethical standards, and no employee of Sieyuan Electric shall provide, give or accept any payment or valuable item to any government official or any other third party (such as customers, suppliers or other private parties) for the purpose of obtaining or retaining any form of commercial benefit.  Bribery, kickbacks, or similar payments are strictly prohibited, whether to government officials, customers, suppliers, or other private parties.  Similarly, employees are not allowed to request or accept such payments.

Sieyuan Electric promises to comply with all applicable anti bribery and corruption laws.  We strive to avoid the occurrence of undue influence.

Employees should be alert to the following examples of possible corruption risks. If you suspect any relevant situation, please contact the internal control or risk control department of Sieyuan Electric.

l The act of abusing delegated power for personal gain;

l Directly or indirectly giving, promising to give, demanding, or accepting money, assets, or any valuable items to any individual or entity, inducing the recipient to improperly perform their duties in order to gain an unfair business advantage;

l Giving or requesting cash, cash equivalents (such as coupons/cards), stocks, real estate, and assuming or waiving debts;

l Gifts, meals, entertainment, and travel that exceed reasonable standards (any business travel, gifts, entertainment, and meals must be commensurate with the occasion and comply with local laws and company regulations);

l Political donations (specific compliance with relevant national laws);

l Charitable donations - if donated to charitable organizations at the direct request of government officials or business partners, it can be considered as indirect bribery for obtaining or retaining business or obtaining other improper commercial benefits;

l Job opportunities or internship rewards - Job opportunities provided to government officials (or their relatives) may carry the risk of violating anti bribery or anti-corruption laws and regulations.  Before making such an offer, it is necessary to consult with the compliance department of Sieyuan Electric.

For specific details, please refer to the company's "Integrity and Compliance Guidelines for Sieyuan Electric Co., Ltd."

3 Gifts, Entertainment, and Hospitality

Employees are prohibited from providing, giving, or accepting gifts, hospitality, or entertainment that may affect or be perceived to affect business decisions.  All gifts and hospitality received or provided must comply with reasonable and customary business practices and must be properly recorded.  Gifts, hospitality, and entertainment are allowed to be given and received if the following requirements are met:

l Its purpose is not to influence third parties in seeking to obtain or retain business or business advantages, or to explicitly or implicitly exchange benefits or advantages;

l Excluding cash or cash equivalents (such as gift certificates or vouchers);

l Publicly, in compliance with any applicable local laws, and in accordance with business practices.

4 Anti Money Laundering

Money laundering refers to any act or attempt to conceal or disguise the identity of illegal gains, with the aim of making it appear that the illegal income comes from legitimate sources.  Sieyuan Electric strictly prohibits money laundering, and employees should be alert to the following examples of potential money laundering risks. If you suspect any related situations, please contact Sieyuan Electric's audit and internal control department.

l Payments made by non contracting parties;

l Payments from suspicious non-commercial accounts;

l Using shell companies for business activities;

l Fictional transactions;

l Abnormal transaction modes, such as bulk purchase of gift cards or repeated cash payments.

5 Anti Fraud

Sieyuan Electric strives to ensure that all its business activities are conducted and reported honestly, accurately, and transparently.  Sieyuan Electric strictly prohibits fraud and any other form of dishonest behavior.  Employees should be alert to the following examples, and if they suspect any relevant situations, please contact the audit and internal control department of Sieyuan Electric.

l Forging contracts;

l Falsifying transaction information;

l Falsifying or falsifying financial information or documents;

l False data disclosure.

6 Fair Competition

Sieyuan Electric conducts its business in an honest, fair, and upright manner, complies with laws, regulations, and principles of fair competition, and does not engage in monopolies, unfair competition, or other behaviors that violate fair competition.  All employees should treat customers, suppliers, competitors, and any other person they come into contact with during the performance of their work fairly.

Employees are not allowed to engage in the following behaviors. If you suspect any relevant situations, please contact the audit and internal control department of Sieyuan Electric.

l Discuss pricing or pricing strategies with competitors.

l Agree to determine prices, coordinate bidding, allocate markets or customers.

l Agree with anyone and do not deal with other companies.

7 Conflict of Interest

Employees must avoid situations where their personal interests conflict with the interests of the organization, ensuring that all actions are transparent and traceable. If it is determined that there is an actual conflict, Sieyuan Electric may take any appropriate corrective measures based on the situation.  Failure to disclose facts will constitute grounds for disciplinary action.

Examples of conflicts of interest include but are not limited to the following behaviors. If discovered, employees must immediately report to their supervisor, human resources manager, or audit internal control department.

l Nepotism, such as employees in management positions hiring or promoting close relatives or friends based on relationships rather than actual qualifications.  The romantic or personal relationship between superiors and subordinates can also lead to regulatory issues, potential sexual harassment claims, and morale problems;

l External employment, such as employees employed by or related to competitors of Sieyuan Electric, including but not limited to becoming customers, distributors, suppliers, serving as directors, or engaging in activities as consultants, volunteers, or other similar roles, is or can be reasonably expected to promote the interests of competitors.

l Insider trading refers to the use of confidential or non-public information by employees to make investment decisions, thereby giving them an unfair advantage.

8 Trade Agreement

Sieyuan Electric supports international efforts to prevent the trade of technologies, substances, and materials that may be misused for war or similar warfare activities, the manufacture of illegal drugs, or other internationally prohibited activities. Sieyuan Electric respects and complies with the export control laws of every country where Sieyuan Electric conducts business.

9 Data Privacy Protection

Sieyuan Electric respects the privacy of its employees, customers, and business partners.  The company is committed to collecting, storing, processing, and transmitting personal data solely in accordance with its privacy policy and all applicable data privacy laws and regulations.  Employees must ensure that any personal information collected by the company is treated with caution, protected, and used legally and correctly.  Employees should comply with the following requirements. If any violations are found, please contact the audit and internal control department of Sieyuan Electric.

l Use information solely for legitimate commercial purposes;

l Information usage authorization must be obtained;

l Information must be stored and processed securely.

10 Company Assets and Confidential Information

The products, services, concepts, and other information generated by Sieyuan Electric on a daily basis are important proprietary business assets of the company.  Every employee has an obligation to protect the company's assets from waste, destruction, theft, or unauthorized disposal.  Maintain confidentiality of sensitive information and trade secrets.  Employees are not allowed to disclose confidential or sensitive information unless the following conditions are met.

l Officially authorized by the company;

l Comply with reasonable commercial purposes;

l Take appropriate protective measures.

11 To Protect Intellectual Property (right)

Protecting the intellectual property rights of Sieyuan Electric is crucial for maintaining the company's competitive advantage.  Employees should support the establishment, protection, maintenance, and defense of the company's rights in all commercially significant intellectual property, and use these rights responsibly.

l Comply with intellectual property laws;

l To regulate the use of software or technical services, formal commercial authorization must be obtained.  For example, software must use commercial genuine versions.

12 Business Partnership

Sieyuan Electric acts with integrity and expects business partners to make the same commitment. Sieyuan Electric carefully selects our business partners, requiring them to fully comply with all legal requirements applicable to their business operations and committing to higher ethical, social, and environmental standards.

l Before establishing any business relationship with third parties, Sieyuan Electric will conduct appropriate due diligence to assess and mitigate the risk of corruption.  Detailed information about the due diligence process.

l Suppliers, customers, and all other third parties of Sieyuan Electric shall not bribe any Sieyuan Electric employees or their close relatives related to Sieyuan Electric's business in any form.

l Sieyuan Electric encourages suppliers, customers, and all other Sieyuan Electric third parties to report any suspicious or known violations of this policy to us.

l Suppliers, customers, and all other third parties of Sieyuan Electric are obligated to cooperate with Sieyuan Electric's anti-corruption audits when necessary.

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