Goermicro is committed to strictly complying with all applicable national and international trade policies and practices, including PRC laws, relevant international trade compliance policies and practices, and applicable foreign laws and regulations. Goermicro earnestly fulfills trade compliance responsibilities and obligations, and establishes an image of integrity and responsibility in international business, to win the trust of customers, suppliers, and partners.

Goermicro has appointed a dedicated trade compliance personnel in our legal department and intellectual property department, which is fully responsible for formulating and improving the Company’s trade compliance policies, systems, organization, and processes. It clarifies responsibilities across various business areas, strengthens trade compliance knowledge and skills training for employees and managers, and regularly conducts internal assessments of the trade compliance system to ensure the continuous and effective implementation of various internal compliance policies and systems. The Company has long been committed to technology research and development, enhancing its competitiveness in the international market, and thus providing greater possibilities for expanding into global markets

Goermicro strictly implements compliance reviews and has zero tolerance towards any illegal or non-compliant behavior in its business operations. Employees who violate compliance policies and practices will be held legally accountable. The Company will review this statement annually and revise it as necessary.

The Company will review this statement annually and revise it as necessary.

Goermicro regards research and development as the foundation for competition and innovation as the driving force for corporate development, continuously increases investment in research and development, and consistently strengthens the protection of innovative intellectual property. Goermicro creates a legal environment that encourages knowledge innovation and protects intellectual property, and practices an intellectual property culture that respects knowledge, advocates innovation, upholds integrity and lawfulness, and promotes fair competition.

Goermicro strictly abides by the PRC Patent Law, the PRC Trademark Law, the PRC Copyright Law, the PRC Anti-Unfair Competition Law, and intellectual property-related laws and regulations of the countries or regions where it operates. It has set up a Legal and Intellectual Property Department, which is responsible for formulating the Company’s intellectual property strategic planning and regulations, and has established intellectual property management policies and management systems, to assist and guide various business departments in carrying out intellectual property compliance work and risk screening.

Goermicro respects the intellectual property of others and ensures its compliance and legality in procurement, research and development, production, and sales. At the same time, Goermicro also focuses on the protection of its own intellectual property, actively defending against infringements such as counterfeiting, trademark infringement, and unfair competition that harm the Company’s intellectual property and legitimate interests, firmly safeguarding the Company’s legitimate rights and interests, effectively enhancing the Company’s ability to utilize intellectual property, and promoting continuous innovation and sustainable business development.

Goermicro complies with national laws, regulations, and relevant standards, strictly protecting customer business information during the operation of its information security management system, and ensuring that all activities of the Company can meet information security requirements.

To ensure that Goermicro’s information security management requirements and objectives can be cascaded down to each department, Goermicro has established a security management organization to ensure that the information security management requirements and objectives can effectively promote the implementation of information security strategies and ensure the achievement of information security objectives.

Goermicro has implemented the following key measures to ensure information security compliance:

· To establish information security-related management systems such as cybersecurity and trade secret protection, requiring all Goermicro employees to strictly observe trade secrets while also respecting the others’ trade secrets, complying with relevant laws and regulations, and prohibiting improper acquisition, disclosure, use, or disposal of others’ trade secrets.

· To regularly conduct training and promotional activities of information security and trade secret protection for all employees to continuously raise their awareness of information security compliance.

· To supervise the implementation of various requirements for information security and trade secret protection through risk assessment, inspection, and auditing, to ensure the effective implementation of policies, processes, and systems.

Goermicro has always attached great importance to the building of an integrity culture, and believes that commercial bribery damages fair competition and has an adverse impact on both society and the Company’s development. We adhere to operation integrity, abide by business ethics, and maintain a “zero-tolerance” attitude towards corruption.

The Audit Department is an anti-commercial bribery compliance department for the whole Company, responsible for building the Company’s integrity culture and anti-commercial bribery compliance work.

Goermicro has implemented the following key measures to ensure anti-corruption and anti-commercial bribery compliance:

· All management employees of Company have signed an Honesty and Integrity Agreement, pledging to conduct business dealings with partners based on principles of fairness and impartiality, ensuring that they do not accept any benefits from partners, and guaranteeing that they will not engage in any actions that harm the Company’s interests for any reason.

· To issue regulations such as the Administrative Regulations on Reward and Punishment of Employees’ Code of Conduct and the Code of Business Conduct of Goermicro, effectively conveying and ensuring compliance with the provisions of the above systems to employees through training for all employees and signing commitments.

· To emphasize partners integrity management and sign a Commitment Letter of Honesty and Integrity with them, committing to transparency and adherence to business ethics in cooperation, and not to engage in any bribery actions to Goermicro’s employees. Otherwise, their bribery actions will be punished in accordance with relevant commitments, and cooperation qualifications for serious breaches may be revoked.

· To establish a robust whistleblowing and feedback mechanism that allows both internal and external personnel to submit complaints and whistleblowing via email, WeChat, telephone, and other means. The Company has strict confidentiality and protection measures for whistleblowers to ensure they are not subject to retaliation.

· To reinforce the development of an integrity culture, and continuously enhance employees’ awareness of integrity. The Company irregularly organizes integrity training for key positions, and promotes integrity concepts to employees and partners through integrity promotional posters during national statutory holidays.

Whistleblowing hotline:0532-58569387

Whistleblowing email:audit@goermicro.com

Goermicro values its cooperative relationship with suppliers. The Company and its employees have always adhered to the core values of integrity, pragmatism and win-win cooperation, strictly comply with all applicable laws, regulations, policy requirements and basic business principles to promote multi-dimensional and multi-field compliance construction, so as to ensure the sustainable and healthy development of the Company. Goermicro has always attached great importance to the construction of an integrity culture, strictly prohibits any form of commercial bribery, kickbacks, transfer of benefits and other violations, adheres to honest operation, abides by business ethics, and maintains a “zero-tolerance” attitude towards corruption. The Company attaches importance to integrity management of its partners and signs the “Commitment Letter of Honesty and Integrity” with them, committing to transparency and adherence to business ethics in cooperation, and not to engage in any bribery actions to Goermicro’s employees. Otherwise, their bribery actions will be punished in accordance with relevant commitments, and cooperation qualifications for serious breaches may be revoked.

Integrity Procurement Core Values

1．Cost reduction and efficiency improvement: digital system for full life-cycle supplier management

2．Risk prevention and control: supplier blacklist system and integrity database

Integrity Procurement Principles

1．Full-process transparency: the procurement process and decision-making process are open and transparent, and fully traceable.

2．Matrix assessment: independent review in three dimensions: technical, commercial and financial.

3．Integrity agreement: 100% of suppliers sign a letter of commitment on integrity with clauses on accountability for breach of contract.

4．Fair competition: all suppliers shall have opportunities for fair competition under the same conditions, and any form of discrimination and favoritism is prohibited.

5．Integrity cooperation: establish a long-term and stable cooperative relationship with suppliers. Both parties shall uphold good faith and jointly adhere to contractual agreements and business ethics.

6．Legal compliance: strictly comply with national laws, regulations and industry norms to ensure that procurement activities are legal and compliant, and to eliminate illegal acts such as commercial bribery and unfair competition.

7．Responsibility: pay attention to the performance of suppliers’ social responsibility, give priority to suppliers with good social responsibility performance, and jointly promote sustainable development.

8．Regulating related transactions: dynamic management system for the list of related parties + independent procurement/sales channels, 100% in line with the rigid requirements of regulatory compliance, and maintaining market credibility.