As a leading Chinese enterprise specializing in the research, development, production, and application of bio-based intermediates, materials, and polymers with bio-based polyols as its core, Suzhou Cornigs Polyols Co., Ltd. (hereinafter referred to as the "Company") commits to upholding the highest standards of business ethics. The company operates in full compliance with relevant laws and regulations across all sectors of its business, placing significant emphasis on the impact of business ethics on the company itself, customers, employees, and other stakeholders. This code aims to promote the company's sustainable and healthy development.

1. Scope

This policy is a public statement applicable to all employees of the company and its subsidiaries, as well as all external parties having business relations with the company, including customers, suppliers, contractors, and other stakeholders (hereinafter referred to as "partners").

2. Audit

The company's finance department, during the annual audit and/or special audits, focuses on examining behaviors that do not comply with this policy/code. The audit results will be promptly reported to the company's top management.

3. Responsibilities

3.1 Employees

Maintaining the company's corporate culture and enhancing its reputation relies on the support and implementation of this code by every employee. Each employee must comply with national laws and regulations and has a responsibility to not harm or tarnish the company's good image and reputation at any time. If an employee believes there is a violation of this code or suspects that an activity or behavior may lead to a violation, they are responsible for stopping or reporting the matter.

3.2 Managers

As company managers, it is crucial to play a key role in adhering to this code. All managers are required to set an example, uphold behavior that conforms to ethical standards in fulfilling their responsibilities, maintain fairness and honesty at all times, refrain from abusing the power vested by the company, and ensure that all decisions are made in the long-term interests of the company. Managers should assist employees in understanding this code, encourage compliance in daily work, and promote the responsible reporting of improper behavior.

4. Code of Conduct

The company requires all employees to comply with all laws, regulations, and rules applicable to the company.

4.1 Anti-Unfair Competition

The company believes that fair, just, and open competition brings maximum benefits to customers, partners, and society. The company complies with relevant laws and regulations, commits to fair and honest competition, and requires all employees to respect and treat company customers, suppliers, and other employees fairly. The company advocates gaining a competitive advantage through excellent quality and service, rejecting unethical and illegal business practices. Any individual must not gain an unfair competitive advantage through manipulation, concealment, abuse of privileged information, distortion of facts, or any other illegal business activities. Specific requirements for suppliers can be found in the company's "Supplier Code of Conduct."

4.2 Anti-Corruption

The company has always attached great importance to anti-corruption efforts, advocating and strengthening them in daily operations and training activities. All employees must comply with applicable laws and regulations and the company's relevant systems, prohibiting any corrupt behavior. Specific details can be found in the company's "Anti-Corruption Policy."

4.3 Protection and Use of Company Property

All employees of the company should use and protect the company's assets reasonably, including transportation vehicles and electronic equipment provided for personal use due to work requirements. Theft, negligence, and waste can cause unnecessary losses to the company. The use of company funds or assets for any illegal or improper purpose (whether for personal gain or not) is strictly prohibited.

4.4 Human Rights Protection

The company recognizes that employees are the foundation of the group and fully respects and values the protection of the legitimate rights and interests of all employees. The company is committed to providing employees with a healthy, safe, and environmentally friendly workplace, prohibiting any harassing behavior. The company ensures the elimination of inequalities arising from gender, region, age, etc., in employee recruitment, compensation and benefits, training and development, and career advancement, preventing discrimination, and resisting the use of child labor and forced labor. Specific details can be found in the company's "Human Rights Policy."

4.5 Protection of Intellectual Property and Trade Secrets

The protection of intellectual property is the foundation of mutual trust between the company and customers, suppliers, and other third parties. The company places high importance on the protection and management of intellectual property.

4.6 Financial Reporting and Information Disclosure

The company's financial policies should be consistent with all applicable accounting standards and relevant regulations. All information must be recorded truthfully, accurately, and timely, and disclosed according to the relevant laws and regulations.

Employees of the company are not authorized to make any oral, written, or any other form of statements about company policies or decisions without authorization, nor to disseminate any such statements.

4.7 Anti-Money Laundering and Insider Trading

The company strictly complies with the requirements of relevant laws and regulations, strictly prohibiting any form of money laundering and insider trading.

4.8 Conflict of Interest

The company expects employees to act ethically, honestly, and with integrity to the highest degree in implementing and fulfilling their obligations. Employees should avoid any situation that may create a conflict between personal interests and the interests of the company.

5. Complaints and Reporting

If employees or partners of the company discover (or have reasonable suspicion of) any improper or unlawful conduct within their scope of work, they should promptly report to the company or directly complain to the company's general manager (email: sunke@cornigs.com). Whistleblowers will be protected; please refer to the "Whistleblower Protection Policy" for specific information.

6. Policy Review

The company regularly reviews and updates this policy based on legal regulations, its own business development, industry practices, and good standards.

Suzhou Cornigs Polyols Co., Ltd.

December 1, 2022