Suzhou Cornigs Polyols Co., Ltd. (hereinafter referred to as the "Company") commits to conducting anti-corruption work in accordance with relevant national laws, regulations, and regulatory systems. To ensure the integrity and clean atmosphere of the company and prevent and control corruption risks, the company, considering its practical situation and based on relevant laws, regulations, and the "Company Charter," has formulated this policy.

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. Definitions

Corruption refers to actions that violate national laws and regulations or group systems, or deviate from the group's values, and involve using various means to seek personal gain, thereby harming the interests of the group. This includes but is not limited to bribery, abuse of power, embezzlement, misappropriation of company property, etc.

3. Anti-Corruption Provisions for Company Employees

Employees of the company must conduct themselves with integrity and self-discipline. During their duties, they must not use their positions to solicit, imply, or accept bribes or obtain other property or non-property benefits for personal gain. This includes but is not limited to personally accepting payments that should be deposited into the company's corporate account. Employees are prohibited from using their authority or influence to give specific partners special treatment (including loans, arrangements for relatives, acceptance of services, technical services, preferential conditions, gaining transaction opportunities, etc.). Employees should strictly adhere to fair competition rules and must not engage in bribery to seek undue benefits. Specific requirements can be found in the company's internal management system, the "Employee Code of Conduct."

4. Anti-Corruption Provisions for Partners

Partners are prohibited from offering any form of commercial bribery to company employees, including providing money, gifts, lavish entertainment, and other acts that provide personal benefits or advantages. Specific requirements can be found in the "Anti-Bribery Agreement" and the company's internal management system, the "Employee Code of Conduct."

5. Training on Anti-Corruption

The company conducts training on this policy and related systems through various forms, including new employee training and supplier training, to ensure that employees and partners are aware of this policy and related systems.

6. Inspection of the Implementation of this Policy

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

7. Reward and Punishment Regulations

Employees confirmed to have engaged in corrupt practices will be held accountable, and the company will impose corresponding penalties in accordance with relevant regulations. In cases of severe violations of the law, the company will transfer the case to judicial authorities for legal liability. Specific requirements can be found in the company's internal management system, the "Employee Code of Conduct."

If partners violate the provisions of the "Anti-Bribery Agreement" or this policy, the company will initiate corresponding punitive measures according to the "Anti-Bribery Agreement." If there is suspicion of a crime, the company will request judicial authorities to pursue criminal responsibility.

8. 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.

9. 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