CSR Commitment

MEKTEC Technology Co., Ltd., based on the business philosophy of the NOK Group spirit, is not only an entity that pursues profit and shoulders social and economic development through fair competition, more importantly, through the implementation of management policies, we are committed to becoming a proud partner of all stakeholders, a company that can continue to pursue dreams and contribute to the society. In order to achieve this goal, we promise:

Based on the following labor and ethics codes, both at home and abroad, we will abide by respect for human rights, abide by relevant laws and regulations, and international norms and their spirit, and fulfill our social responsibilities in the spirit of “a corporate citizen with a conscience”.

1.Labor and Ethics Policy

1-1. Compliance with laws and regulations

As an international enterprise, the company abides by the labor and ethics laws and regulations of the country, region and international regulations.

1-2. Value employees

Regarding employees as corporate assets, implementing the “people-oriented” spirit in the business philosophy, so that they can be respected and dignified in compliance with laws and regulations.

1-3. Honesty and integrity

We adopt ethical behaviors in compliance with laws and regulations when engaging in investment, production, procurement, sales, product services and other activities.。

1-4. Fulfill responsibilities

We not only continue to practice social responsibility itself, but also actively lead our suppliers to comply with the Mektec Supplier Social and Environmental Responsibility Code of conduct set by MEKTEC Technology Co., Ltd., and jointly pursue dreams and improve continuously to contribute to the society with snowballing effect.

2.Labor

2-1. Anti-discrimination

2-1-1.Employees will not be discriminated against wages, benefits, promotion, punishment, dismissal or retirement due to race, color, national origin, religion, party affiliation, gender, sexual orientation, age, marriage, pregnancy, disability, or union status.

2-1-2.The Company will not conduct pregnancy tests on employees or future female employees, and will not affect their work rights due to pregnancy, and will give pregnant employees appropriate adjustments to provide a safe environment.

2-1-3.The Company will not require discriminatory medical examinations for employees or those future employees, unless there are applicable regulations or for the purpose of protecting workplace safety.

2-2. Humane treatment

2-2-1.The Company prohibits any cruel and inhuman treatment of employees during work or training, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse or threats to use any such treatment.

2-3. Prevent involuntary labor

2-3-1. The Company prohibits the employment of any forced, mortgaged (including debt), bonded or involuntary prison labor, and does not slave or trafficked in labor, including for the purpose of exploitation and via coercion, suppression, abduction or fraud to transport, harbor, recruit, transfer or receive involuntary personnel.

2-3-2. Company employees can freely choose to resign and terminate their labor contracts at any time under the notice in compliance with laws and regulations.

2-3-3. Company employees do not need to turn in any ID, passport or work permit as a condition of employment.

2-3-4. When hiring foreign employees, the Company must comply with the laws and regulations of the exporting country and its own country to protect the personnel, and must ensure that personnel will not be charged excessive fees; any charged fees must be clear and reasonable.

2-3-5. The Company uses the language that employees understand during the hiring process, and clearly communicates the employment conditions to the hired employees.

2-4. Avoid child labor

2-4-1. The Company prohibits the employment of children under the age of 16. If employment facts are discovered, corresponding remedial and handling measures must be taken in accordance with laws and regulations.

2-5. Protection of juvenile workers

2-5-1. The Company shall not arrange minor employees under the age of 18 to engage in heavy and dangerous work, and shall comply with the labor laws and regulations stipulating their working hours.

2-6. Work hours

2-6-1. The normal working hours of employees are 8 hours per day, and the total number of extended working hours per month shall not exceed 46 hours. Unless it is an emergency or abnormal situation, the total working hours per week shall not exceed 60 hours (including overtime).

2-6-2. Employees have at least one day off as an official holiday on seven days a week.

2-6-3. Employees apply for overtime voluntarily.

2-7. Wages and benefits

2-7-1. The Company ensures that employees’ wages comply with the legal minimum wage.

2-7-2. The Company pays employees’ wages every month and provides employees’ wages in written or electronic pay slips.

2-7-3. In addition to paying employees for normal working hours, the Company also pays overtime by rates that comply with the laws and regulations for overtime work.

2-7-4. The Company ensures that employees are provided with benefits that are in line with or better than the provisions of the law.

2-7-5. The Company ensures that employees are provided with vacations, official holidays, and holidays that are in line with or better than those stipulated by laws and regulations.

2-7-6. Any fines imposed by the Company shall comply with the standards set by laws and regulations.

2-8. Freedom of assembly

2-8-1. Employees have the right to freely join or organize a labor union, the right to elect labor union representatives or cadres, and the right to conduct collective consultations.

2-8-2. The Company regularly convenes labor-management meetings in accordance with the law to conduct open two-way communication between employees and management to protect the legitimate rights and interests of employees.

2-8-3. The Company encourages and takes seriously the opinions or suggestions mentioned by employees or union representatives, who should not be fear of punishment, retaliation, coercion or harassment.

3.Ethics

3-1. Definition

3-1-1. ” MEKTEC ” refers to the companies, offices, factories, affiliates and (or) other business organizations established by MEKTEC Technology Co., Ltd. now and in the future, directly or indirectly, in various countries and regions.

3-1-2. “Transaction object” refers to any company or any organization or individual in any business type that conducts transactions or cooperation with MEKTEC, including but not limited to suppliers, customers, third parties, contractors or other service providers, intermediaries, and partners, regardless of whether the transaction or cooperation is concluded.

3-1-3. “MEKTEC Affiliated Person” means that MEKTEC is responsible for directly or indirectly negotiating transaction conditions with the signatory (transaction object), reaching or fulfilling the transaction contract of the “Purchase Contract”, which can directly or indirectly affect the transaction completion or execution of the transaction, purchasing, production and related supervisors.

3-1-4.”Improper benefits” include but are not limited to kickbacks, commissions, profit sharing, shares (or anonymously held shares) or improper gifts or entertainment.

3-1-5. “Related persons” refer to the spouse, parents, children, siblings, grandparents, grandparents, grandchildren, and other close relatives and friends of the party concerned.

3-2. Business integrity

3-2-1.Any and all forms of bribery, corruption, extortion and misappropriation of public funds are prohibited for all affiliates of the Company’s trading activities.

3-2-2. The Company, an international enterprise, abides by all applicable anti-corruption laws and regulations, including international and country/regional regulations while conducting trading activities.

3-2-3.The Company must conduct detailed investigations in the event of violations of the above-mentioned business integrity code, strive to take measures to solve the problem, take strict responsibility for the responsible person, and transfer related persons and related persons to the judicial authority according to the seriousness of the circumstances.

3-3. No illegitimate interests

3-3-1. All job performers (parties) of the Company or their related parties shall not provide or accept bribes or other forms of improper benefits.

3-3-2.All job performers (parties) or their related parties in the Company must report truthfully to their direct supervisor immediately and take appropriate evasive measures, if they discover or have any possible illegitimate gains.

3-4. Information disclosure

3-4-1. The Company scrupulously publishes correct and true information at an appropriate time, and manages and utilizes information without compromising the value of the information.

3-4-2. Unless authorized by the Company, employees of the Company are prohibited from providing information about the Company’s business activities, organizational structure, financial status, performance and customers, business partners, suppliers, and employees to media reporters, consultants (companies), securities analysts, etc. When receiving requests from government agencies, officials, investigators, or other law enforcement personnel to provide information related to the Company’s business, it should be transferred to the authority and responsibility management unit or the Company’s legal department for processing.

3-5. Protection of intellectual property rights

3-5-1. The Company respects intellectual property rights; protects customer information and employees’ personal assets; and fulfills its responsibility to protect intellectual property rights when transferring technology and practical knowledge.

3-5-2. When the Company’s products are manufactured, sold, imported, and displayed, timely and appropriately investigate whether there is any infringement of the intellectual property rights of others, and it must be confirmed that there is no infringement of the rights of others.

3-5-3.Employees of the Company are prohibited from any behavior that infringes on the intellectual property rights of others, such as unauthorized copying or use of unauthorized computer software.

3-5-4.During the tenure of the Company’s employees, whether they constitute patents, copyrights, trademark styles or other statutory rights and interests or not, the intelligence information or output of invention ideas, concepts, discoveries, improvements, formulas, procedures, manufacturing techniques, works, or business secrets, etc. obtained due to their duties or the use of Company experience and resources. Rights belong to the Company.

3-6. Fair dealing, advertising and competition

3-6-1.The Company adheres to the practice of fair, transparent and free transactions in the sales of products and procurement of materials.

3-6-2.When trading, the Company must abide by the monopoly law and other legal provisions to prevent unfair transactions.

3-6-3. The Company must abide by the law when contacting or dealing with competitors, and prohibits the use of unfair trading methods such as monopoly. Do not blame or slander competitors or their products, and do not use illegal means to obtain competitor’s confidential information.

3-6-4. When the Company deals with suppliers, it must abide by the contracting law and other relevant laws, and conduct fair dealings with suppliers on an equal footing.

3-7. Protect whistleblowers and anonymous complaints

3-7-1. The Company has established relevant regulations and procedures for reporting or complaining to ensure that employees or suppliers whistleblowers are protected and their identities are confidential.

3-7-2. The Company prohibits any acts of retaliation against employees, suppliers, and employees who have been audited by customers or interviewed by government agencies in good faith.

3-7-3. The Company has established channels and mailboxes for reporting or appeals. Even if the complaint is anonymous, it will be properly investigated and handled.

3-8. Conflict-free minerals

3-8-1. The Company promises not to support and use tin (Sn), tantalum (Ta), tungsten (W), gold (Au) and other metals mined from the Democratic Republic of the Congo and its neighboring countries under armed conflict, illegal mining and poor working environment. Minerals are the so-called “conflict minerals.”

3-9. Privacy

3-9-1. The Company treats all customer information as confidential information of related parties, and cannot disclose it to a third party (either inside or outside the Company) without the permission of the person responsible for the information management of the customer information in advance. It shall not be used for purposes other than those specified by the management responsible person.

3-9-2. If employees of the Company do not need to use customer information due to changes or resignations, they shall return or destroy all information in accordance with the method specified by the person in charge of management.

3-9-3. The personal information between the Company’s employees and people whom they have business dealings with (including suppliers, customers, consumers and employees) includes: business strategies, contracts under negotiation, products under development, undisclosed research results, customer information, business, marketing plans, financial information, personnel information, etc., which are not allowed for collection, storage, processing, transmission and sharing to non- MEKTEC employees or employees who do not need to use such information, and must comply with the Company’s rules and regulations for protecting these information.