Code of Conduct

ADMINISTRATIVE SANCTIONS
Neither the Company nor members of the BOD and members of the BOC of the Company were not subjected to any administrative sanctions by the Capital Market authorities and other authorities in the 2019 fiscal year.

CODE OF ETHICS EXISTENCE OF CORPORATE ETHICS
To protect the Company’s interests, and to support the implementation of functions and duties of all the Company’s elements in developing the Company’s business, the Company has “Code of Ethical Business Conduct” (“Code of Ethics”) with the latest edition (2nd Edition) published in January 2019.

CONTENTS OF CODE OF ETHICS
The Code of Ethics contains general provisions that require all employees to comply with all laws and regulations in connection with his/her work in the Company, and the provision of specific measures that can affect employees in performing work for the Company. This includes:
a. Compliance with applicable law;
b. Unauthorized Payments;
c. Commissions, gifts, meals, or other considerations;
d. Conflict of interest;
e. Relationships between employees;
f. Employing family members;
g. Contributions to social groups, sports coaching, and
communities;
h. Provision of benefits;
i. Hiring government officials or employees;
j. Political contributions and activities;
k. Financial recording.

CODE OF ETHICS APPLIES IN ALL ORGANIZATIONAL LEVELS
Code of Ethics clause 2 states that the Code of Ethics is applicable throughout the Company, from the BOC, the BOD, to the employees. One item in the General Provisions of the Code confirms that the provisions of the Code of Ethics requires all employees to comply with the Code of Ethics, laws, and regulations and other applicable provisions. The Code of Ethics is applicable to all the Company’s business units.

SOCIALIZATION AND ENFORCEMENT OF CODE OF ETHICS
In 2019, the socialization of Code of Ethics was carried out by distributing the Code of Ethics Book 2nd Edition to all staff of the Company and its subsidiaries, and sending a new “Anti-Fraud” poster to all subsidiaries. There were no violation cases of Code of Ethics and Business Conduct in 2019.