Company's Policies
| Business Conduct & Ethics | Directors | Senior Management | Employees |
| (a) Whistle Blower | Reports of wrongdoing may be made directly to the Chairman for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower. | Reports of wrongdoing may be made directly to the Chairman or President for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower. | Reports of wrongdoing may be made directly to the Chairman or President for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower. |
| (b) Conflict of Interest | A director should not use his position to profit or gain some benefit or advantage for himself and/or his related interest. If an actual or potential conflict of interest may arise on the part of a director, he should fully and immediately disclose it and should not participate in the decision-making process. | An employee should disclose any relationship or association to the proposed supplier or contractor or its authorized representative to avoid possible conflict of interest. | An employee should disclose any relationship or association to the proposed supplier or contractor or its authorized representative to avoid possible conflict of interest. |
| (c) Respect for Trade Secrets/Use of Non-public Information | Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position. Should not reveal confidential information to unauthorized persons without authority of the Board. | Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position. Should not reveal confidential information to unauthorized persons without authority of the Board. | Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position. Should not reveal confidential information to unauthorized persons without authority of the Board. |
| (d) Employment & Labor Laws & Policies | Ensure the Company’s faithful compliance with employment and labor law & policies. | The Company seeks to reasonably assist its and its subsidiaries and affiliates’ employee and his family in providing for their economic security. | The Company seeks to reasonably assist its and its subsidiaries and affiliates’ employee and his family in providing for their economic security. |
Related Party Transactions
(a) Policies and Procedures
| Related Party Transactions | Policies and Procedures |
| (1) Parent Company | Ensure that the transactions are entered on terms comparable to those available from unrelated third parties |
| (2) Joint Ventures | |
| (3) Subsidiaries | |
| (4) Entities Under Common Control | |
| (5) Substantial Stockholders | |
| (6) Officers including spouse/children/siblings/parents | Ensure that the transactions are entered on terms comparable to those available from unrelated third parties. Disclosure of relationship or association is required to be made before entering into transaction. No participation in the approval of the transaction. |
| (7) Directors including spouse/children/siblings/parents | |
| (8) Interlocking director relationship of Board of Directors |
(b) Mechanism
| Directors/Officers/Significant Shareholders | |
| Company | Independent Directors are required to submit a list of positions/other directorships to determine any conflict. Directors, officers and employees must voluntarily disclose any conflict prior to occurrence of the same. |
| Group | Independent Directors are required to submit a list of positions/other directorships to determine any conflict. Directors, officers and employees must voluntarily disclose any conflict prior to occurrence of the same. |