Sinoma International strictly complies with policies and regulations such as the Several Regulations on the Executives of State-owned Enterprises for Performing Management Duties with Integrity, the Code of Integrity and Self-discipline of the CPC, the Working Rules of the CPC Discipline Inspection Organ on Supervision and Discipline Enforcement, the Regulations of the CPC on Disciplinary Punishments, and the Regulations on the Punishment of Managers of State-owned Enterprises. The Company implements the Provisions on the Prohibition of Business Relationships with Enterprises of the Group by Relatives of Leaders of Enterprises and Persons with Other Specific Relationships Running Businesses of the Group, and is committed to eradicating corruption in all aspects of the Company's value chain, continuously enhancing anti-corruption awareness among employees at all levels and suppliers, ensure that they conduct themselves in accordance with professional ethics, and fulfill their responsibilities with a fair and upright attitude.

This standard applies to all employees of the Company and all affiliated companies, including full-time, part-time, outsourced employees, as well as stakeholders who have business dealings with the Company and all affiliated companies.

（The English translation of the Policy is for reference only and the Chinese version shall prevail in case of any inconsistency between the Chinese version and English translation thereof）

1 Bribery, communication and benefits

Bribery is strictly prohibited by the Company, and no employee is allowed to offer, solicit or accept bribes, including soliciting or providing any benefits from or to customers, suppliers, legislative and/or law enforcement agencies or other personnel related to the Company’s business; or act as a third-party intermediary to provide, solicit or accept any benefits. Anyone who solicits or accepts benefits in any form by taking advantage of his authority, regardless of getting permission from superior leaders, shall be deemed as violation of the Code.

1.1 Providing benefits: under no circumstances should employees offer bribes or illegitimate benefits to any individual or institution to seek personal gains or Company benefits.

1.2 Soliciting benefits: employees shall not directly, indirectly or in any form, solicit any benefits from any institution or individual related to the Company’s business.

1.3 Accepting benefits: if an employee accepts any benefits directly or indirectly related to the Company’s business, which hinders his objective judgment and processing of related business, induces him to violate or harm the interests of the Company, leads to violation of laws and regulations and requirements of the place of listing, triggers complaints about favoritism or misconduct, and/or makes the employee feel that is is necessary to repay the giver in business, the employee shall not accept the benefits.

1.4 All acts related to facilitation payment are prohibited.

2 Handling conflicts of interest

2.1 Definition of conflict of interest

The common conflicts of interest include but are not limited to the following situations:

2.1.1 Have undeclared financial interests/transactions with any suppliers, service providers or related personnel that have business dealings with the Company;

2.1.2 Hire service providers who are working or have worked for the Company to work or provide services, goods, etc. for themselves and/or their immediate family members;

2.1.3 Provide special preferential treatment to individual suppliers, service providers, customers, job seekers, subordinates or superior leaders, etc. for personal reasons;

2.1.4 Employees or their immediate family members (including parents, children and spouses) are getting engaged in or consider engaging in the things, investment or activities that have a conflict of interest with the Company or may cause a conflict of interest;

2.1.5 Carry out external work within the Company by taking advantage of the working hours and the Company’s assets (including human resources).

2.1.6 Provide assistance to the Company’s competitors; and

2.1.7 Privately provide or manufacture services or goods that compete with the Company.

2.2 Declaration of conflict of interest

The employees shall avoid actual or foreseeable conflicts of interest between individuals and the Company or that affect their judgment in performing their duties. The employees shall report all actual or foreseeable conflicts of interest in a timely manner.

2.2.1 If the employees realize that there is or may have a conflict of interest with the Company, they must immediately report to their department heads in writing.

2.2.2 If the employees fail to comply with the above requirements, severe disciplinary punishment may be caused, including demotion, dismissal, etc.

3 Insider trading

3.1 If employees have any important information about the Company or any other listed companies with which the Company does business and/or non-public data sensitive to stock prices, the employees shall not buy or sell the securities of the Company or these listed companies, or disclose relevant information to others before such data is made public.

3.2 The employees shall abide by all laws and regulations regarding insider trading. Any employee involved in insider trading will be punished according to relevant rules of the Company, or even dismissed. Meanwhile, the Company will also report to relevant law enforcement agencies.

4 Preventing Money Laundering

Money laundering is using otherwise lawful business transactions as a way to hide the source of money that has been obtained illegally. Money laundering typically involves payments in the form of cash or money order. Suspicious activity includes: large cash transactions as well as customers who are reluctant to provide verifiable information.

We are committed to complying with applicable anti-money laundering and counter terrorist financing laws and regulations. We do not condone, facilitate, or support money laundering or terrorist financing.

All the employees should:

4.1 Watch out for irregularities in the way payments are made.

4.2 If you have concerns about a payment, request an alternative form be used and report the concern to your manager.

4.3 If the transaction seems suspicious, report it to Legal and Compliance, even if you do not move forward with the transaction.

4.4 Determine if your business has specific preventative measures in place.

5 Competing Fairly

In a free market system, competition drives efficiency and innovation, and companies compete on a level playing field. Violations of laws that protect competition can lead to penalties that include large fines, jail time, damaged reputation and exclusion from government contracts. Fair competition is in everyone’s best interest. We are committed to complying with competition/antitrust laws wherever we operate.

All the employees should:

5.1 When interacting with competitors always refer to the Code.

5.2 Seek guidance from Legal and Compliance, whenever a competition/antitrust law question arises.

5.3 Compete vigorously, using public information and competitive circumstances to your best advantage.

5.4 Remember that compliance is always in the Company’s best interest. No one is ever authorized to violate the law.

5.5 Do not discuss with a competitor any terms on which you compete, prices, or allocations of jobs, customers, or markets.

5.6 Do not discuss with a competitor whether or not you intend to submit a bid or quote for any particular project or customer.

5.7 Do not talk to anyone about boycotting or refusing to deal with a supplier or customer.

5.8 Do not take any action just to hurt or retaliate against a competitor.

6 Illegal and Improper Payments

The Company and all employees are not allowed to use property or other means to bribe and sell goods. Those who secretly give kickbacks to the other party's company or individual outside of the account shall be punished as bribery. When selling services and goods, if discounts are required to be given to the other party, including but not limited to commissions, physical items, etc. to intermediaries, they must be explicitly given to the other party, and possible supporting documents must be provided, and the finance department must be notified to truthfully enter the account.

7 Business partners, suppliers, and customers

7.1 Access to goods and services

The Company guarantees fair trade with our suppliers, fair competition in the competitive evaluation process to determine suppliers, without any discrimination or deception. The selection of suppliers should be based on the prices, services, quality, and reputation provided by the suppliers, and in accordance with the principle of being beneficial to the long-term business development of the company. When dealing with suppliers, employees should always maintain fairness and should not attempt to exert influence to obtain "special treatment" for a specific supplier, as this can jeopardize our competitive selection process. Employees cannot accept or demand personal benefits from suppliers and target suppliers to prevent damaging the fairness of supplier product and price evaluation. Employees should also keep confidential the pricing or product information submitted by suppliers or potential suppliers to the Company. The procurement agreement should be appropriately approved and clearly define the services and products provided, the calculation basis for payment, and the applicable prices and fees. The payment amount must match the service or product provided.

7.2 Items, discount, and gifts

For items, discount and gifts provided by suppliers during the procurement negotiation process, they should be reflected in the procurement contract in principle. For situations where there is no contract or cannot be reflected in the contract, the gift should also be considered as an asset of the Company, rather than a personal gift for employees participating in negotiations.

7.3 Interactions with potential customers and clients

The Company is committed to meeting all customer needs, ensuring customer satisfaction, and maintaining long-term partnerships with customers. Employees shall not intentionally make false statements to customers regarding the products or services of the Company or competitors. All comparisons with competitors must be accurate, based on publicly available information and not misleading. Employees are not allowed to sign sub agreements or private agreements with clients outside of written contracts. Employees shall not directly or indirectly provide money or any other form of bribery to government officials in order to obtain or retain customers.

8 Donations

Donations, patronage, and sponsorship may be used to conceal an undue advantage. They may constitute, or be seen to constitute, acts of direct or indirect corruption regardless of their monetary value. This risk is greater when public officials have a direct or indirect connection to the event or activity benefitting from the donation, patronage, or sponsorship. All contributions, whether they are made in the context of patronage, donations, or sponsorship, must go through an approval process which becomes more rigorous as the value of the contribution increases. Close attention must be paid to what the financing or donations are used for, especially when the potential beneficiary of patronage, donation, or sponsorship is or has ties to a public official, public authority, a Politically Exposed Person (PEP), or has ties to one of our customers.

9 Requirements for suppliers

The Company implements a "fair, open, and just" sunshine procurement model, by strictly implementing the bidding process, expanding the scope of price seeking, and continuously improving procurement transparency. All departments and affiliated companies of the Company should send integrity notification letters or sign integrity commitment letters and integrity contracts to relevant parties when signing contracts with suppliers, including clauses prohibiting cooperation from providing various benefits and conveniences to the Company staff, their relatives, and specific related parties. At the same time, as a one vote veto system, clean and honest employment will prevent suppliers from participating in bidding and will be blacklisted in case of any violations. For the requirements of suppliers in anti-corruption, please refer to the Company's Supplier Code of Conduct.

10 Reporting and investigation of violations of the Policy

The Company expects and encourages employees and those who do business with the Company (stakeholders that conduct business relationship with the Company, such as customers, suppliers, etc.) to report to the Company any actual or suspected breach of the Policy.

10.1 Reporting

10.1.1 If any actual or suspected violation of the code of conduct is found, including violations of rules and discipline, it is important to submit a written or oral report to the Discipline Inspection Commission of the Company, and provide relevant information. Reporting hotline: 010-64399331; E-mail: jubao@sinoma.com.cn; Address: Sinoma International Engineering Co., Ltd, Discipline Inspection and Supervision Office; Postcode: 100102.

10.1.2 We strengthen the protection of whistleblowers. Strictly implement confidentiality requirements for reports and accusations, and keep the names (unit names), work units, addresses, and other relevant circumstances of the reports and accusations, as well as the content of the reports and accusations, strictly confidential. For details, please refer to the "Rules for the Handling of Reports and Accusations by Discipline Inspection and Supervision Organs".

10.1.3 We crack down on false accusations and frame-ups. The Company's Commission for Discipline Inspection will strengthen the analysis and screening of reports and accusations, and focus on verifying abnormal reports and accusations. and where it is falsely accused and framed, it is to be strictly handled in accordance with regulations, discipline, and law, or transferred to the relevant organs for handling in accordance with law. Specifically, see the Regulations on Disciplinary Sanctions of the Communist Party of China, the Rules for the Handling of Reports and Accusations by Discipline Inspection and Supervision Organs, the Law on Governmental Sanctions for Public Employees, and the Regulations on Sanctions for Managers of State-owned Enterprises.

10.1.4 However, if the whistleblower makes false reports maliciously because of ulterior motives or for personal gain, the Company shall reserve the right to take appropriate actions against relevant persons including the whistleblower; internal employees will be subject to disciplinary punishment according to relevant regulations of the Company. Please refer to the Working Rules for Disciplinary Inspection and Supervisory Organs in Handling Complaints and Accusations.

10.2 Investigation

10.2.1 The investigation team will conduct fair and effective investigation to any report received. The investigation is designed to assess whether the reported matter actually violates the internal rules and regulations and/or codes of conduct.

10.2.2 The investigation team shall issue an investigation report based on the facts verified after completing necessary procedures.

10.2.3 During investigation, the employee under investigation may be suspended from his/her job.

10.3 Penalties for violation of the Policy

10.3.1 We will not tolerate any violation of the Policy. Any employee who is found to directly or indirectly violate the Policy will be subject to disciplinary punishment, including dismissal.

10.3.2 In the case of suspected corruption or other forms

of illegal behaviors that are detrimental to the Company, it will be submitted to the judicial organs for processing after approval by the Company.

11 Supervision and inspection

11.1 According to the Implementation Measures for the Inspection Work of the Party Committee of Sinoma International and the Inspection Work Plan of the Party Committee of Sinoma International, the Company's Party committee conducts an annual inspection, and achieves 100% coverage of affiliated enterprises every five years.

11.2 The Company's Discipline Inspection Commission organizes and carries out the construction of a comprehensive supervision system. The Company organizes meetings of the leading group and coordination groups meetings for the building of Party conduct and integrity and anti-corruption efforts, deploys supervision tasks, carries out joint supervision and inspection, and leverages the collective power of supervision.

11.3 The Commission for Discipline Inspection of the Company organizes special control inspections each year and has achieved 100% coverage of its enterprises. Enterprises at all levels are required to self-check and self-correct; the Party organizations of the affiliated enterprises of the Company report the progress of the anti-corruption work every year, and the Commission for Discipline Inspection of the Company visits grassroots units periodically to listen to their progress of anti-corruption efforts.

11.4 The Commission for Discipline Inspection at all levels of the Company establishes an Annual Political Supervision List to promote integrity, discipline and anti-corruption in an integrated manner, leverage the collective power of supervision, and enhance the quality and effectiveness of its oversight efforts.