CODE OF BUSINESS CONDUCT AND ETHICS

Business Conduct & Ethics Directors Senior Management Employees
(a) Conduct of Business and Fair Dealings The Company shall not enter into arrangements with its competitors to arbitrarily set prices of products and other terms of the market/industry. Customers and suppliers should be dealt with fairly.
(b) Receipt of gifts from third parties Acceptance of gifts and other favors from customers, suppliers, or any other third party which might compromise one’s ability to make objective decisions or which might affect the performance of one’s duty is strictly prohibited.
(c) Compliance with Laws & Regulations Ensure the Company’s faithful compliance with all applicable laws, regulations and best business practices.
(d) 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.
(e) Use of Company Funds, Assets and Information Company assets and funds cannot be used for personal benefit or for the benefit of anyone other than the Company. Everyone is discouraged from engaging in personal activities during working hours.
(f) Disciplinary action The Company strictly observes the provisions on disqualification and temporary disqualification of directors as provided in the Company’s Manual of Corporate Governance. Rules and regulations shall be enforced fairly and consistently by the respective subsidiaries and affiliates. Violations shall result in disciplinary actions depending on frequency, seriousness and circumstances of the offense. The employee shall be given the opportunity to present his side. Rules and regulations shall be enforced fairly and consistently by the respective subsidiaries and affiliates. Violations shall result in disciplinary actions depending on frequency, seriousness and circumstances of the offense. The employee shall be given the opportunity to present his side.
(g) Conflict
Resolution		 Conflicts are resolved internally as much as possible. It should be resolved in the lowest possible level using procedure that addresses and respects the needs, interests, and rights of the parties involved.

The Company has a compliance officer who monitors compliance of ethics or conduct.

Directors submit annually a list of business and professional affiliating through which provide conflicts-of-interest may be determined. Relative to senior management and employees, the Human Resources Department of each subsidiary and affiliate implements and monitors compliance with the code of ethics or conduct.