To ensure the continuous improvement of suppliers, suppliers’management requirements have been defined into the Supplier Management Manual to enhance supplier management capabilities through annual audit, project audit, performance evaluation, technical exchange seminars and trainings such as quality and CSR policy advocacy. In April 2023, we hosted the Zhen Ding Holding Worldwide Partners Conference, and in August 2023 we had the Green Supply Chain Conference. These events reflect our commitment to optimizing the supply chain management of Zhen Ding Tech Group and working together with our suppliers to achieve "mutual benefit and win-win" cooperative relations.

Code of Conduct of Supplier’s Social Responsibility

I. Zhen Ding Tech. Group strictly prohibits supplier’s zero tolerance:
1) Child labor.
2) Forced or prison labor, Using prisons as suppliers or subcontractors, limiting personal freedom, and
detaining identity documents.
3) Health and safety issues that can cause immediate danger to life or serious injury. For example, using violence, insult, physical punishment, or sexual harassment, illegal searches, or searches of a different gender.
4) Retaliate the employees who provide information to auditor.
5) The supplier provides Zhen Ding Tech. Group with fraudulent documents.
6) Environmental issues that can result in serious and immediate harm to the community.
7) Prohibition of any media crisis and serious mass disturbances, including the wrongful death (suicide, homicide, Jump off building, sudden death etc.), collective labor dispute or strikes, mass fights, mass poisoning or other group death or injury event.
8) Provide a safe and healthy working environment, take effective measures to prevent potential health safety incidents, diseases that may occur during work or caused by work, such as herd infections caused by infectious diseases.
II. Code of Conduct Instruction
The Code is made up of five sections: Sections 1.1, 1.2, and 1.3 outline standards for Labor, Health and Safety, and the Environmental standard. Section 1.4 outlines the basic requirements of management system to manage conformity to this Code. Section 1.5 outlines standards relating to business ethics.

1.1 Labor
Suppliers should respect and safeguard workers' human rights in accordance with internationally recognized standards of social responsibility. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. The Universal Declaration of Human Rights (UDHR), Social Accountability International (SAI) and the Ethical Trading Initiative (ETI) were used as references in preparing the Code.

1.1.1 Freely Chosen Employment
Forced, bonded (indentured) labor, and involuntary prison labor is prohibited, and labor is not enslaved or trafficked, including the transport, transfer and acceptance of involuntary labor by means of threat, coercion, repression, abduction or fraud for the purpose of exploitation . All workers should be voluntary and workers must be free to leave work at any time or terminate their employment. Workers must not be required to surrender any government-issued identification, passports or work permits as a condition of employment. Excessive fees are unacceptable and all fees charged to workers must be disclosed.

1.1.2 Child Labor Avoidance
Child labor must not be used at any stage of the supplier’s operations. “Child labor" refers to individuals who are under 16 years old (or the child labor age defined by the local government). Apprentices who meet the requirements of laws and regulations are not included in this list. Do not arrange for juvenile workers to engage in work that may endanger their health and safety. Their working hours should meet the requirements of local laws and regulations. Suppliers should arrange regular physical examinations for juvenile workers in accordance with legal requirements. The use of interns must comply with the requirements of local regulations

1.1.3 Working Hours
Decreased productivity, increased turnover rate, increased work-related injuries and illnesses are directly related to worker fatigue. Workers’ overtime hours shall meet the requirements of local laws and regulations. The weekly working hours (including overtime) shall not exceed 60 hours, and workers shall be guaranteed at least one day off per week. Workers’ overtime must follow the principle of voluntariness. Suppliers shall provide workers with holidays and benefits in accordance with the requirements of laws and regulations

1.1.4 Wages and Benefits
Compensation paid to employees must comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws , workers must be compensated for an overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which employees are being paid is to be provided in a timely manner via pay stub or similar documentation.

1.1.5 Humane Treatment
Supplier’s disciplinary policies and procedures should be clearly defined and communicated to employees. No cruel and inhumane treatment of employees, including any form of sexual harassment, sexual abuse, corporal punishment, mental and physical oppression, and verbal abuse, shall not be used to threaten employees. Suppliers should not set unreasonable restrictions on employees' use of basic facilities

1.1.6 Non-Discrimination
Suppliers shall promise that employees will not be harassed or discriminated against. Do not discriminate against employees on the basis of human, color, age, sex, sexual orientation, race, disability, pregnancy, belief, political affiliation, club membership, or marital status. Do not require employees or employees to be hired to undergo discriminatory medical examinations and pregnancy tests (such as pregnancy tests, hepatitis B tests)

1.1.7 Freedom of Association
Open communication and direct engagement between employees and management are the most effective ways to resolve workplace and compensation issues. Suppliers must respect the rights of employees to associate freely, join labor unions, seek representation and join employees’ councils in accordance with local laws. Employees must be able to communicate openly with management regarding working conditions and management practices without fear of reprisal, intimidation or harassment.

1.2 Health and Safety
Suppliers shall recognize that a safe and healthy work environment enhances the worker satisfaction，quality of services, consistency of production and employees’ morale. Suppliers should also recognize that ongoing education training is essential to identifying and solving health and safety issues in the workplace.
Recognized management systems such as ISO45001 and ILO Guidelines on Occupational Safety and Health as references in preparing the Code and may be a useful source of additional information.
The health and safety standards are:

1.2.1 Occupational Safety
Suppliers shall adopt appropriate design, engineering and management control, preventive maintenance procedures, safe operation procedures and continuous safety training to prevent and avoid hazards encountered by employees in the workplace (such as electrical appliances and other energy sources, fire, vehicles, slips and falls, trip and fall etc.). If the source of hazard cannot be effectively controlled by the above methods, employees should be provided with appropriate personal protective equipment. Suppliers should improve the safety awareness of employees through continuous training and education rather than discipline. Suppliers should not impose penalties on employees who report safety issues.

1.2.2 Emergency Preparedness and Response
Emergency situations and events are to be identified and assessed by suppliers, and their impact should be minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, employee training and education, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.

1.2.3 Occupational Injury and Illness
Procedures and systems are to be in place to manage, track and report occupational injury and illness, including provisions to: a) encourage employee reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; e) facilitate return of employees to work.

1.2.4 Industrial Hygiene
Supplier must identify, evaluate and control the influence to workers through the chemical, biological and physical hazardous agents. When hazards cannot be adequately controlled by engineering and administrative means, worker health is to be protected by appropriate personal protective equipment.

1.2.5 Physically Demanding Work
Supplier must identify, evaluate and control the High intensity of physically works, including manual material handling, repetitive heavy lifting, and prolonged standing and highly repetitive or heavy physically works.

1.2.6 Machine Safeguarding
Suppliers shall carry out hazard assessment for production machinery and equipment, provide physical protection, interlocking devices and shields for machinery which cause injury to workers, and carry out proper maintenance.

1.2.7 Dormitory and Canteen
Suppliers should provide employees with clean restrooms and hygienic food and storage facilities, as well as potable water. The dormitory provided by the supplier to the employees should be clean, safe, with adequate emergency exits, hot water, sufficient lighting heating, and ventilation equipment, and reasonable private space and the right to free entry and exit.

1.3 Environmental
Suppliers recognize that environmental responsibility is integral to producing world-class products. In manufacturing operations, supplier should protect biological diversity and land. Adverse effects on the environment and natural resources are to be prohibited while safeguarding the health and safety of the public. Recognized management systems such as ISO 14001, the Eco Management and Audit System (EMAS) were used as references in preparing the Code and may be a useful source of additional information.
The environmental standards:

1.3.1 Environmental Permits and Reporting
The supplier shall obtain all necessary environmental permits (such as emission monitoring), approval number and registration certificate to ensure the validity of the environmental permit, and the supplier’s operation shall meet the requirements of the permit.

1.3.2 Pollution Prevention and Resource Saving
Suppliers should take measures to prevent pollution, and reduce water and electricity consumption by adjusting product process, raw materials, cycle and recovery using raw materials.

1.3.3 Hazardous Substance
Suppliers shall identify and control the hazardous chemicals and other substances released into the environment to ensure that the use, transportation, storage, recycling and processing of these substances will not have an impact on the environment.

1.3.4 Wastewater and Solid Waste
The supplier shall monitor, control and treat the waste water and solid waste generated by the production process and sanitation facilities in accordance with the requirements before discharge.

1.3.5 Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge. Set targets of greenhouse gas emission reduction and conduct regular reviews.

1.3.6 Product Content Restriction
Suppliers shall comply with all laws and regulations prohibiting and restricting hazardous substances, including recycling and disposal laws and regulations, as well as the requirements of customers for prohibiting and restricting the content of limited substances.

1.4 Management System
Supplier shall establish a management system related to the content of this code. The system shall: a) comply with all laws, regulations and customer requirements related to its operations and products; b) comply with this code of conduct; c) Identify and reduce the operational risks associated with this code, and continuously improve. The management system includes the following contents:

1.4.1 Company Commitment
The supplier’s environmental and social responsibility declaration shall state the commitment to comply with laws and regulations and continuous improvement, and be signed by the top management.

1.4.2 Management Accountability and Responsibility
The supplier shall appoint management representatives and authorize them to be responsible for the promotion of the management system. The senior management shall regularly evaluate the operation status of the system

1.4.3 Legal and Customer Requirements
Suppliers shall identify, monitor and understand applicable laws and regulations and customer requirements.

1.4.4 Risk Assessment and Risk Management
Suppliers should develop procedures to identify relevant environmental, health and safety, and labor risks, assess the level of risk, and implement appropriate procedures and measures to control risks to ensure compliance with regulatory requirements

1.4.5 Performance Objectives with Implementation Plan and Measures
The supplier should formulate written standards, performance targets, indicators and implementation plans, and conduct regular evaluations of performance targets

1.4.6 Training
The supplier shall make a plan to train the management and employees so as to implement the supplier's policies, procedures and improvement objectives to meet the requirements of laws and regulations.

1.4.7 Communication
Suppliers should develop procedures to clearly communicate their performance, implementation and expectations to employees, suppliers and customers.

1.4.8 Employee Feedback and Participation
Ongoing processes to assess employees’ understanding and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.

1.4.9 Audits and Assessments
Suppliers should conduct regular self-assessments to ensure compliance with relevant laws and regulations, the requirements of the code, and customer requirements regarding environmental and social responsibility.

1.4.10 Corrective Action Process
The supplier shall formulate procedures to promptly correct the deficiencies found in internal and external evaluations, inspections, investigations and audits.

1.4.11 Documentation and Records
Suppliers shall establish and keep documents and records to ensure compliance with regulations and company requirements, and at the same time shall properly protect confidentiality.

1.4.12 Supplier Responsibility
The supplier shall develop a process to communicate the requirements of this code to the sub suppliers and monitor the compliance of the sub suppliers with the code

1.5 Ethics
Suppliers and their agencies must strictly abide by the following ethics in order to meet their social responsibility requirements and successfully win the market

1.5.1 Business Integrity
The highest standards of integrity should be followed in all business dealings, suppliers should expressly prohibit all forms of corruption, extortion, and embezzlement of public funds. All business transactions should be transparent and accurately recorded in business accounts or records. Suppliers should establish programs to monitor and execute to ensure non-compliance.

1.5.2 No illegitimate gains
Suppliers shall not provide or accept bribes or other forms of improper gains.

1.5.3 Disclosure of Information
Suppliers shall disclose relevant business activities, organizational structure, financial status and performance in accordance with corresponding regulations and industry practices. It is prohibited to forge records or make false statements about situations or operations in the supply chain.

1.5.4 Intellectual Property
Suppliers should respect intellectual property rights and pay attention to the protection of intellectual property rights during technology transfer.

1.5.5 Fair Business, Advertising and Competition
Suppliers should establish fair trading, advertising and competition standards to protect the security of customer information

1.5.6 Protection of Identity
Suppliers should develop procedures to protect the identities of suppliers and employees of
Whistleblowers. Whistleblower definition: Anyone who exposes the improper conduct of company employees, supervisors or civil servants and government agencies

1.5.7 Responsible Sourcing of Minerals
Suppliers shall formulate policies to ensure that the gold, tantalum, tin, tungsten, cobalt and their derivatives used in products will not directly or indirectly fund armed organizations that have caused serious human rights disasters in the Democratic Republic of the Congo and neighboring countries Suppliers should conduct due diligence investigations on the sources of minerals in the supply chain to meet customer requirements.

1.5.8 Privacy
Suppliers shall undertake to protect the reasonable personal privacy of related parties, including suppliers, consumers, customers and employees. Collection of personal information storage, processing, transmission, and sharing shall comply with the requirements of information security laws and regulation Collection of personal information

1.5.9 Non-Retaliation
Suppliers should develop a communication process to allow employees to give feedback on issues of concern without fear of retaliation.