Sennics adheres to the strategic goal of "becoming a leading global company in high grade, precision and specialty chemicals", integrates the idea and standards of Sustainability into corporate governance, and devotes itself to implementing responsible business operations with high ethical standards to ensure that the business conforms to international norms and laws & regulations on fair competition, anti-money laundering, anti-bribery and anti-corruption in all operation sites. The company improves related system and mechanism construction from the aspects of legal and regulatory compliance, anti-corruption, data security and intellectual property protection. The Business Ethics Team (including Legal Compliance & IPR Department, Auditing Department, Operation Center, etc.) under the Sustainability Working Group takes charge of promoting and implementing relevant work, standardizes its own behaviors according to the Integrity and Compliance Manual of Sinochem Holdings, the Compliance Obligation Convention of Sinochem Holdings, the Compliance Responsibility Agreement，and the Anti-Commercial Bribery Compliance Manual of Sinochem Holdings, continuously improves overall risk management, and conducts more active communication, to win the trust and support of stakeholders through standardized operation and transparent management, lay a good governance foundation for the company to achieve Sustainability, and join hands with partners to establish partnerships featuring mutual respect, mutual trust and fair trade.

1.?Conducting honest management and preventing illegitimate interests

【Term Definition】

Corruption refers to the act of using public power or job privileges to seek improper benefits for oneself or others, harming public interests or company interests. According to the United Nations Convention against Corruption, corruption generally includes abuse of power, bribery, offering bribes, and other acts of exploiting one's position to obtain undue benefits.?In a business context, corruption typically manifests as bribery, kickbacks, and the transfer of undue benefits.

Commercial bribery?refers to the act of business operators providing property or other benefits to the counterparties of transactions, intermediary agencies or individuals entrusted by the counterparties, and units or individuals that may influence the transaction, in order to seek trading opportunities or competitive advantages. This definition encompasses various forms of benefit transfer, with the core being the influence of transaction decisions through improper means.

Fraud?refers to the act of one party deliberately providing false information to the other party or intentionally concealing the truth, thereby inducing the other party to make an erroneous declaration of intent. In the chemical industry, fraudulent behavior may manifest as falsely reporting product components, exaggerating product performance, forging quality inspection reports, or concealing safety hazards.

Money laundering?refers to the act of disguising and concealing the source and nature of criminal proceeds and their profits through various means, making them appear legally obtained. Money laundering activities are often closely related to upstream crimes such as drug offenses, organized crime of a mafia nature, terrorist activities, smuggling offenses, and corruption and bribery offenses.

Suspicious transactions?refer to transactions where there are anomalies in terms of amount, frequency, direction, or nature, or where there is reasonable cause to suspect that the transaction is related to money laundering, terrorist financing, or other illegal activities. In the chemical industry, suspicious transactions may manifest as a customer suddenly purchasing large quantities of chemical products that do not match their actual needs, or frequently making small cross-border payments.

A conflict of interest?refers to a situation in which an employee's personal interests conflict with or may potentially conflict with the company's interests. Such conflicts may affect the employee's objective judgment and impartial performance of duties, thereby harming the company's interests. In the chemical industry, conflicts of interest may manifest as: procurement personnel choosing a company run by their relatives as a supplier; sales personnel leaking the company's customer information to competitors, and so on.

Related-party relationships?refer to various connections between employees and the company that may lead to conflicts of interest. These relationships include, but are not limited to: an employee being a shareholder, director, supervisor, or senior manager of the company; an employee being a shareholder, director, supervisor, or senior manager of the company's clients, suppliers, or competitors; and employees having creditor-debtor relationships with the company, such as loans or guarantees.

【Principle Requirements】

In business activities, Sennics adheres to the principles of honesty and integrity, equal consultation, mutual benefit and win-win results, abides by business ethics and complies with relevant laws and regulations. The company participates in market competition according to law, puts the concept of integrity and compliance above the company's economic interests, prohibits unfair competition such as commercial bribery, corruption, fraud, money laundering and monopoly, and fully respects and abides by the laws and regulations related to trade control.

Prohibit commercial bribery and corruption: Sennics adopts a "zero tolerance" policy for commercial bribery and corruption. The company strictly abides by all applicable anti-commercial bribery and anti-corruption laws and regulations, and prohibits any form of bribery and corruption, including but not limited to directly or indirectly giving and receiving cash, cash gifts, securities, material objects, commission, expenses for travel and entertainment, and non-property interests such as employment opportunities.

Prohibit fraud: Sennics strictly prohibits cheating, bribery, forgery, extortion, theft, misappropriation, false statements, collusion, corruption and other intentional fraud for personal or commercial interests.

Standardize gifts and entertainment: At Sennics, all employees are not allowed to solicit gifts and cash gifts by explicit or implicit means, or accept gifts and cash gifts that may affect the fair execution of official duties. Business entertainment and gift expenses should be in strict accordance with the specified standards, and entertainment activities in high-end consumer places should be avoided.

Abide by anti-money laundering laws and regulations: Sennics strictly abides by the anti-money laundering laws and regulations applicable in the countries (regions) where we operate. The company's employees should gain a full understanding of business partners, conduct due diligence, cooperate with reputable counterparties with legitimate sources of funds for business activities, and strictly comply with the company's financial policies and processes. If the employees encounter any suspicious activities or have any doubts before further transactions, they should consult relevant departments of the company in time and preserve relevant evidence.

Prevent conflicts of personal interests: Sennics employees should avoid conflicts between personal interests and the interests of the company, not endanger the interests and reputation of the company, and not use the company's resources or their personal posts to seek interests for any individual or stakeholder outside the company. For any existing and potential conflict of interests, the employees should report to or consult their department heads and relevant departments of the company in time, and take the initiative to avoid the conflict when handling related matters according to the instructions of the company.

2.?Protecting intellectual property and trade secrets

【Term Definition】

Intellectual property?refers to the exclusive rights legally granted to individuals for the fruits of their intellectual labor. Typically, it constitutes the exclusive or monopoly rights conferred by the state upon creators for their intellectual achievements within a specified period. In the chemical industry, intellectual property holds particular significance, encompassing everything from new products, processes, and equipment to product designs, brand logos, and technical documentation.

Trade secrets?refer to commercial information such as technical information and operational information that is not publicly known, possesses commercial value, and has been subject to appropriate confidentiality measures by the rights holder. The scope of trade secrets is extremely broad, including but not limited to: technical formulas, manufacturing processes, design drawings, experimental data, customer lists, supplier information, procurement channels, and pricing strategies. The key characteristic is that the protection of trade secrets relies on their “confidentiality.” Once a trade secret is disclosed, its value ceases to exist.

【Principle Requirements】

Intellectual property protection:?Intellectual property is valuable wealth and one of the most competitive assets for the company. Sennics lays emphasis on the creation, protection and utilization of its intellectual property, respects the intellectual property of others, and actively prevents infringement of intellectual property. The employees should respect the intellectual property of third parties and obtain appropriate authorization and permission for the use of their intellectual property in daily production and business activities.

Trade secret protection:?Sennics has established a sound confidentiality management system and related policies in accordance with all applicable laws and regulations on confidentiality to ensure the security of national secrets and the company's trade secrets. The employees should strictly abide by the laws and regulations on confidentiality and the company's confidentiality policies and provisions, and undertake the same confidentiality obligations for confidential information disclosed by customers or other third parties in their daily business to prevent such confidential information from being leaked.

3.?Fair competition?and regulating information disclosure

【Term Definition】

Unfair competition?refers to acts committed by business operators in production and business activities that violate legal provisions, disrupt market competition order, and harm the lawful rights and interests of other business operators or consumers. Its primary manifestations include acts of confusion, commercial bribery, false advertising, infringement of trade secrets, unfair prize promotions, and commercial disparagement.

【Principle Requirements】

Insist on fair competition:?Sennics insists on competing with rivals through fair trade and legal compliance, strictly abides by applicable laws and regulations on anti-monopoly, and resolutely puts an end to any violation of the Anti-monopoly Law?and other antitrust laws and regulations.

Prohibition of unfair competition:?Unfair competition refers to the act of competing with other operators by violating laws and regulations, going against business ethics and disrupting the market competition order, which damages the legitimate rights and interests of other operators or consumers. Sennics employees should strictly abide by the Anti-unfair Competition Law?and other applicable laws and regulations on fair competition when conducting business, and participate in the competition in a legal and proper way.

Regulating information disclosure：Sennics is committed to maintaining transparent, honest and fair commercial practices in its all business transactions, recording and keeping information, files, account books and financial records about business transactions truthfully and accurately in accordance with the company's relevant rules, and disclosing relevant information according to law. The personnel authorized by the company should disclose information publicly in accordance with the relevant rules of Sennics, and any employee is not allowed to disclose information without prior authorization or approval. The employees responsible for information disclosure should submit and disclose relevant information in a true, accurate, complete and timely manner in strict accordance with the contents and formats of information disclosure stipulated by relevant laws and regulations and regulatory authorities, and ensure that the disclosure does not contain any confidential information. When employees use social media for personal purposes, they should not disclose the work information of the company, colleagues, customers and themselves.

If employees need to conduct related business activities such as investigation, negotiation, contract?signing, tendering, bidding, providing guarantee and issuing certificates in the name of Sennics or Sennics' employees, and to make comments and post messages on behalf of the company on the media, or attend public activities, they should obtain approval or authorization from the company in advance.

4.?Information security?and privacy protection

【Term Definition】

Information security?refers to the establishment and implementation of technical and administrative safeguards for data processing systems, protecting computer hardware, software, and data from accidental or malicious damage, alteration, and disclosure. The core objectives of information security are to ensure the confidentiality, integrity, and availability of information—collectively known as the CIA triad.

Data breaches?refer to incidents where sensitive, protected, or confidential data is accessed, copied, transmitted, or stolen by unauthorized individuals. In the chemical industry, data breaches may result in competitors gaining access to core technical formulas, production control systems being hacked and causing production halts or safety incidents, and customer and supplier information being leaked, leading to the breakdown of business relationships.

【Principle Requirements】

Sennics promises to secure the information of customers, business partners and employees, regularly carry out network security certification, detection and risk assessment, formulate emergency plans for network security incidents, promptly deal with system vulnerabilities, computer viruses and cyberattacks, and effectively prevent the company's information security risks.

Sennics promises to legally collect, use and protect information. The company should follow the principles of legality, legitimacy and necessity when collecting, using and processing information involving individuals, including its employees, and information related to the market, finance, personnel and strategic planning of business partners (including suppliers, contractors, JV partners and customers) and stakeholders, and take prudent measures to ensure information security. Unless obtaining information through public channels, the company should obtain authorization?before?obtaining the above information. The employees are not allowed to illegally process, transmit, sell, disclose or provide the information collected by them to others.

5.?Consultation and reporting

In order to find and eliminate misconduct and complaints, and protect the employees and the company from possible risks or damages, and resist commercial bribery, corruption, fraud and money laundering, unfair competition, information security, discrimination and harassment, and lack of respect for human rights, etc., the employees have the responsibility to report any violation or suspected violation to their department heads or legal departments. If necessary, the employees can provide information about possible violations in confidence or anonymously, and the company will review all reports and take appropriate measures.

The company authorizes Sennics’ Audit Department to receive reports on and investigating violations. If you have any question about the policy, or find anyone suspected of or having committed any illegal act, you can report it through the following channels. Once verified, the company will punish the violators in the form of warning, pay cut, demotion, disciplinary sanction, dissolution of labor contract, termination of labor contract, etc. according to the seriousness of their acts and the degree of losses caused to the company. The company will consider transferring the violators with serious nature and severe consequences to the judicial department and investigate their criminal responsibility.

Email: compliance-sennics@sinochem.com

Tel.: +86-21-68373744

Address: 7F, Sinochem International Plaza, No.233 North Changqing Road, Pudong New Area, Shanghai (Sennics’ Audit Department)

6.?Protecting informers and prohibiting retaliation

Sennics promises to keep the names of informers and reported contents highly confidential, strictly prohibit transferring the reported contents to the involved departments and individuals, and ensure the independence of the personnel receiving and managing the reported information. Sennics will not tolerate any retaliation against the complainants or informers, and will severely punish those who have retaliated against the individuals reporting suspected violations of laws and regulations or the acts that pose risks to the company’s business.