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Business Ethics

Business Conduct & Code of Business Ethics

Purpose.

Kinheng is high quality optical material supplier, Our product is widely used in security inspection, detector, aviation, medical imaging and high energy physics.

Values.

·         Customer and products – Our Priority.

·         Ethics – We always do things the right way. No compromises.

·         People – We value and respect every employee and strive to help them achieve their professional goals.

·         Meet Our Commitments – We deliver on our promises to employees, customers, and our investors. We set challenging goals and overcome obstacles to achieve results.

·         Customer Focus – We value long-term relationships and put the customer’s perspective at the center of our discussions and decisions.

·         Innovation – We develop new and improved products that create value for our customers.

·         Continuous Improvement – We continually focus on reducing cost and complexity.

·         Teamwork – We collaborate globally to maximize results.

·         Speed and Agility – We quickly respond to opportunities and challenges.

Business conduct and ethics.

Kinheng is committed to upholding the highest standards of ethical behavior in all aspects of our business. We have made operating with integrity a cornerstone of our vision and values. For our employees, ethical behavior cannot be an “optional extra,” it must always be an integral part of the way we do business. In essence it is a matter of spirit and intent. It is characterized by the qualities of truthfulness and freedom from deception and fraud. Employees and representatives of Kinheng must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Whistleblower Policy/Integrity Hotline.

Kinheng has an Integrity Hotline where employees are encouraged to report anonymously any unethical or illegal conduct observed on the job. All employees are made aware of our anonymous Integrity Hotline, our ethics policies, and code of business conduct. These policies are reviewed annually at all kinheng facilities.

Examples of issues which may be reported through the Whistleblower Process include:

·         Illegal activities on company premises

·         Violation of environmental laws and regulations

·         Use of illegal drugs in the workplace

·         Alteration of company records and intentional misstatement of financial reports

·         Acts of fraud

·         Theft of company property

·         Safety violations or unsafe working conditions

·         Sexual harassment or other acts of violence in the workplace

·         Bribes, kickbacks or unauthorized payments

·         Other questionable accounting or financial matters

Non-retaliation Policy.

Kinheng prohibits retaliation against anyone who raises a business conduct concern or cooperates in a company investigation. No director, officer or employee who in good faith reports a concern shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Company without fear of reprisal.

Anti-bribery Principle.

Kinheng prohibits bribery. All our employees and any third party, to whom this Principle applies, must not provide, offer or accept bribes, kickbacks, corrupt payments, facilitation payments, or inappropriate gifts, to or from Government Officials or any commercial person or entity, regardless of local practices or customs. All Kinheng employees, agents and any third party acting on kinheng behalf must comply with all applicable anti-bribery laws and regulations.

Anti-trust and Competition Principle.

Kinheng is committed to engaging in fair and vigorous competition, in compliance with all antitrust and competition laws and regulations globally.

Conflict of Interest Policy.

Employees and third parties to whom this Principle applies must be free from conflicts of interest that could adversely influence their judgment, objectivity, in conducting Kinheng business activities. Employees must avoid situations where their personal interests could inappropriately influence, or appear to influence, their business judgment. This is called “conflict of interest.” Even the perception that personal interests influence business judgment can hurt Kinheng’s reputation. Employees may take part in legitimate financial, business, charitable and other activities outside their Kinheng’s jobs with the written Company approval. Any real, potential, or perceived conflict of interest raised by those activities must be promptly disclosed to management and updated on a periodic basis.

Export and Import Trade Compliance Principle.

Kinheng and related entities are committed to conducting business in compliance with laws and regulations that apply to our locations throughout the world. This includes laws and regulations pertaining to trade embargoes and economic sanctions, export control, anti-boycott, cargo security, import classification and valuation, product/country of origin marking, and trade agreements. As a responsible corporate citizen, it is incumbent upon Kinheng and related entities to consistently follow established guidelines to maintain integrity and lawfulness in our international transactions. When participating in international transactions, Kinheng and related entity employees must be aware of and follow local country laws and regulations.

Human Rights Policy.

Kinheng is committed to developing an organizational culture which implements a policy of support for the internationally recognized human rights contained within the Universal Declaration of Human Rights, and seeks to avoid complicity in human rights abuses. Reference: http://www.un.org/en/documents/udhr/.

Equal Employment Opportunity Policy.

Kinheng practices Equal Employment Opportunity for all persons regardless of race, color, religion or belief, sex (including pregnancy, gender identity and sexual orientation), sexuality, gender reassignment, national or ethnic origin, age, genetic information, marital status, veteran status or disability.

Pay and Benefits Policy.

We provide our employees with fair and competitive pay and benefits. Our wages meet or exceed local market conditions and ensure an adequate standard of living for our employees and their families. Our pay systems are linked to company and individual performance.

We comply with all applicable laws and agreements on work time and paid leave. We respect the right to rest and leisure, including vacation, and the right to family life, including parental leave and comparable provisions. All forms of forced and compulsory labor and child labor are strictly prohibited. Our Human Resource policies prevent illegal discrimination, and promote fundamental rights to privacy, and prevention of inhuman or degrading treatment. Our safety and health policies require safe working conditions and fair work schedules. We encourage our partners, suppliers, distributors, contractors, and vendors to support these policies and we place value on working with others who share our commitment to human rights.

Kinheng encourages its employees to fully utilize their potential by offering ample training and education opportunities. We support internal training programs, and internal promotions to provide career opportunities. Access to qualification and training measures is based on the principle of equal opportunities for all employees.

Data Protection Policy.

Kinheng will hold and process, electronically and manually, the data it collects in relation to its subjects in compliance with applicable processes, laws and regulations.

Sustainable Environment – Corporate Social Responsibility Policy.

We acknowledge our responsibility to the community and to protect the environment. We develop and implement practices that reduce energy consumption and waste generation. We work to minimize waste disposal through recovery, recycle and reuse practices.


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