Preamble

In order to achieve lasting and sustainable success, SUNGALLON and its subsidiaries (“SUNGALLON”) conducts its global business in compliance with all applicable laws and regulations. All employees are held to adhere to the rules of the legal system they work in. They must avoid violations of the law at all times, commit to act upon the highest ethical standards and treat others with respect and integrity.

SUNGALLON does not tolerate violations of law. Employees who violate laws or binding regulations may face disciplinary action and criminal prosecution.

A) Criminal law

In their own best interests and the interests of SUNGALLON, all employees must respect and comply with criminal law.

Disregarding criminal law may in individual cases not only result in criminal prosecution of the employee involved but may also lead – in the case of business-related offenses – to severe fines at SUNGALLON’s expense as well as substantial damage to SUNGALLON’s reputation among customers, suppliers and the public. In particular:

1. Corruption

Under Chinese criminal law (as well as under foreign criminal law), corruption towards public officials is penalized. SUNGALLON will not tolerate any action that could be perceived as corruption.

Employees of SUNGALLON must therefore not demand, allow themselves to be promised or accept any benefits for themselves or for third parties in return for promising to provide specific competitive advantages (receiving a bribe). Conversely, the offer, promise or granting of such a benefit (bribing) is not permitted either. This also applies in particular to public officials or persons entrusted with special public service functions in view of their official function, unless they have legally effective permission from their supervisor.

The granting or receipt of benefits that are reasonable and appropriate with respect to the specific business relationship is not liable to prosecution. The value of benefits of this type for SUNGALLON employees must not exceed ￥350. If benefits in excess of this amount are to be granted or received, approval from the compliance officer or management board must be obtained in advance. Approval can only be granted if the benefit is not related to a specific business. The compliance officer must be involved in advance whenever public officials are to be granted any benefits.

B) Miscellaneous

SUNGALLON and its employees are committed to comply with all other applicable laws and ethical standards. The information below is meant to serve as overview of important obligations.

1. Compliance with health and safety regulations

SUNGALLON’s staff members are obliged to ensure a safe and healthy workplace at all times. They must always comply with applicable safety regulations. Any deficiencies are to be reported to the supervisor in charge and remedied.

2. Environmental protection and animal welfare

SUNGALLON is committed to ecologically sustainable business practices. All employees are therefore obliged to protect the soil, water, air, biological diversity and cultural assets. Environmental damage must be avoided by using appropriate environmental protection measures consistent with the applicable laws. Damage caused to the environment must be reported to the supervisor in charge and remedied. All rules on animal welfare must also be complied with.

3. Product safety, traffic safety and consumer protection

SUNGALLON develops high-quality products that meet applicable legal and safety requirements. Quality management systems evaluate and control our products. The systems ensure that our products represent the “state of the art and science” and meet the relevant safety standards and specifications. This particularly applies to products used in sensitive areas of traffic safety.

SUNGALLON is responsible for detecting, reporting and remedying possible safety problems. We report defects to the responsible authorities, if necessary, and take all necessary measures to ensure product safety and consumer protection.

4. Equal opportunity, anti-discrimination and respectful conduct

All SUNGALLON employees treat all people, especially those with different origin and experience, with respect and integrity. Discrimination on the basis of race, gender, religion or ideology, disability, age or sexual orientation will not be tolerated. SUNGALLON stands for an open-minded, upright and tolerant company culture.

SUNGALLON is wholeheartedly committed to the protection of human rights. We will not enter into business with any company that violates these fundamental rights, e.g., by exploiting employees, adolescents or children.

5. Confidentiality and data privacy

As a company, SUNGALLON owns valuable patents and know-how. All employees are obliged to observe strict confidentiality in relation to this type of information and all other trade and business secrets. Information that contracting partners and customers regard as sensitive is also included in this obligation. Such data and information must not be disclosed to third parties.

The legal principles for protecting personal data must be complied with at all times. This obligation continues after the end of employment.