Supplier Code of Conduct

Article I This Code aims to promote transparent and honest business behaviors, enhance corporate social responsibility awareness, regulate the behaviors of external partners and ensure compliance with global standards of business ethics, and establish efficient partnerships with them.

Article II This Code applies to all partners who supply raw materials, semi-finished products, finished products, and services to our company.

Article III Partners shall comply with the relevant provisions of this Code and require all their affiliates, subsidiaries, suppliers, and other partners to jointly comply with such Code, while actively promoting the business ethics and corporate social responsibility awareness reflected herein.

Article IV The following behaviors are the basic rules that we expect our partners to follow:

1. Comply with applicable laws and regulations

When conducting business dealings with or on behalf of GigaDevice, suppliers must fully comply with all applicable laws and regulations in their business activities, as well as the following requirements (without limitation):

• Anti-corruption and anti-bribery

Suppliers shall comply with all applicable laws and regulations, international conventions of anti-corruption and anti-bribery, as well as anti-bribery compliance requirements issued by GigaDevice from time to time. They shall resist corruption and bribery, and shall not offer, promise, facilitate, or authorize the payment of any remunerations, gifts, or other valuables, entertainments or benefits to any government agency, company, enterprise, or other organization or group, government official, state personnel, or non-state personnel, directly or indirectly, for the purpose of obtaining or retaining businesses, seeking trading opportunities and competitive advantages, or obtaining any improper benefits. And they shall develop and establish relevant anti-corruption and anti-bribery policies and systems, and implement corresponding audit projects to monitor the implementation of such policies and systems. Upon discovering that any partner or GigaDevice's employee is suspected of violating or has violated applicable anti-corruption and anti-bribery laws and regulations, as well as GigaDevice's related anti-corruption compliance requirements, please report it via email: woodpecker@gigadevice.com. GigaDevice will investigate relevant reports and protect informants from threats or retaliation.

• Anti-money laundering

Suppliers shall comply with the anti-money laundering laws and regulations as well as international conventions of China and all applicable countries/regions, including but not limited to the Anti-Money Laundering Law of the People's Republic of China and the Law of the People's Bank of China of the People's Republic of China. They shall do a good job in customer identification, keep customer information and transaction records, and timely report large and suspicious transactions. And they shall strictly comply with relevant regulations on anti-money laundering and anti-terrorist financing supervision, and do a good job in internal control of anti-money laundering.

• Anti-monopoly and fair competition

Suppliers shall comply with all applicable laws and regulations of anti-monopoly and fair competition, and shall not monopolize the market or engage in unfair competition behaviors alone or in collaboration with other market entities. Prohibited behaviors include but are not limited to: carving up the market through agreement or collusion, fixing resale prices or limiting minimum resale prices, limiting production or sales quantities, restricting access to or development of new technologies, concerted refusal to deal, collusive tendering, bundle sales, abuse of market dominant position and other behaviors that harm the order of competition.

• Trade compliance

Suppliers shall comply with all applicable laws and regulations of export control and sanctions, including those of the United Nations, China, the United States, and the European Union. They shall promptly provide export control information about their products, software, technology, and services, with necessary information and supporting documents, including but not limited to ECCN, license exceptions, licenses, and CCATS, to cooperate with GigaDevice's compliance work in this field. In addition, they shall promise not to directly or indirectly: (1) export or sell products, software, technology, or services obtained from GigaDevice to locations subject to embargo restrictions imposed by the United Nations, China, the European Union, the United States, and the Organization for Security and Cooperation in Europe; or (2) use them for prohibited end uses such as nuclear weapons, weapons of mass destruction, specific rocket systems, biological and chemical weapons, terrorism, and military.

2. Business ethics

Suppliers must conduct business interactions and activities in good faith and must comply with the following requirements (without limitation):

• Conflicts of interest

Suppliers shall avoid all conflicts of interest and situations that may lead to potential conflicts of interest, including conflicts of interest between any individual (including his/her spouse, family members, and friends) and GigaDevice, as well as situations that may lead to potential conflicts of interest, for example, employees, managers, or directors (or their spouses, family members, or friends) of GigaDevice obtain personal benefits from suppliers or have business dealings with them. When any above situation occurs, suppliers shall immediately notify GigaDevice.

• Business records

Suppliers shall honestly and accurately record and report all business information, and comply with all applicable laws and regulations regarding the completeness and accuracy of such information. And they shall create, retain, and process business records in full accordance with all applicable laws and regulations.

• Gifts and entertainments

Suppliers shall not give or accept gifts for the purpose of obtaining improper collective or individual benefits or attempting to influence business decisions. No jewelry, gem, cash or cash equivalents (such as checks, equity, prepaid cards, gift cards, gas gift cards, recharge or value cards, gambling chips, and other securities) shall be accepted or given as gifts. And they shall comply with applicable laws and regulations as well as the compliance requirements of GigaDevice regarding gifts or entertainments.

• Insider trading

Suppliers shall comply with applicable laws and regulations of securities. If suppliers and their personnel obtain unpublished information (insider information) that involves GigaDevice's operations, finances, or has a significant impact on its share price in their business dealings with GigaDevice, they shall keep such information confidential before it is disclosed by GigaDevice. Insiders of such information shall not disclose it in any form without authorization, or use it to buy or sell GigaDevice's stocks and their derivatives, or suggest others to do so for their own or others' benefits. Otherwise, GigaDevice will impose corresponding penalties on the responsible person based on the severity of the situation, and reserve the right to claim compensation from such person. GigaDevice can also ascertain the legal responsibility in accordance with laws, regulations, and normative documents. If a crime is constituted, it shall be transferred to the judicial authorities for criminal responsibility investigation in accordance with the law.

3. Intellectual property protection, information security, and privacy protection

Suppliers shall respect and protect intellectual property in accordance with applicable laws and regulations, and shall not intentionally infringe or abuse the intellectual property of others. They shall strictly keep the confidential information obtained during the cooperation with GigaDevice, and shall not use such information for any purpose other than the cooperation with GigaDevice. And they shall comply with applicable laws and regulations regarding personal privacy protection, and take appropriate measures to prevent unauthorized disclosure or use of personal information.

4. Human rights and labor

Suppliers shall abide by the applicable labor and employment laws and regulations, and must comply with the following requirements (without limitation):

• Legal employment

Suppliers shall abide by the labor and employment laws and regulations of various countries/regions during employment, and shall sign a labor contract (one copy for each party) with the employee. And they shall not collect deposits or collaterals from employees when hiring them, or withhold their ID cards, temporary residential permits, educational certificates, professional certificates, and other documents.

• Forced labor

Suppliers are prohibited from engaging in forced labor and human trafficking, nor supporting or participating in any form of human trafficking or forced labor through threats, detention, guarantees, force, fraud, or other coercions.

• Child labor

Under no circumstances shall suppliers hire child labors, i.e. individuals under the age of 16 or under the legal minimum working age (whichever is more stringent).

• Working hours and wages

Suppliers shall comply with the laws and regulations of various countries/regions regarding minimum wages, working hours (including overtime), etc. And they shall respect employees' right to rest and pay wages no less than the local legal minimum wage standard for all working hours. If overtime is required, overtime wages shall be paid in accordance with applicable laws and regulations.

• Occupational health and safety

Suppliers shall provide a safe working environment with a health and safety management system to protect the health, safety, and well-being of employees, contractors, visitors, and other personnel affected by their activities. They shall comply with all applicable laws and regulations related to environmental protection, health, and workplace safety. And they shall implement special labor protection for underage workers and female employees, i.e. not arranging underage workers to engage in labor or dangerous operations that are too heavy, toxic, or harmful to their physical and mental health, or arranging female employees to engage in labor with the fourth level physical labor intensity specified by China or other prohibited labor. GigaDevice encourages suppliers to obtain occupational health and safety management system certification, such as ISO45001.

• Anti-discrimination and prohibition of sexual harassment

Suppliers shall advocate for the principles of equality and diversity in employment, and shall not engage in any form of discrimination based on race, cultural background, religious belief, age, gender, nationality, marital and family status, disability, or other circumstances protected by applicable laws and regulations during the employment process. And they shall provide employees with a working environment that is free from harassment, prohibiting any form of workplace bullying, treating employees in violent or inhumane ways, or sexual harassment in the workplace or any work place.

• Freedom of association

Suppliers shall, in accordance with local laws, respect the right of all employees to voluntarily form or join labor unions, engage in collective bargaining and peaceful assembly, and refuse to participate in such activities.

5. Environment

• Greenhouse gas emissions and energy consumption

Suppliers shall track and record energy consumption and all related greenhouse gas emissions at the company level. They shall explore and develop cost-effective methods to improve energy efficiency and minimize energy consumption and greenhouse gas emissions. And they are encouraged to use renewable clean energy for products or services designated by GigaDevice.

• Pollution prevention and waste management

Suppliers shall take measures to reduce or eliminate the emissions and releases of pollutants, and waste generation from the source, such as adding pollution control equipment, improving production, maintenance, and facility processes, or other measures. And they shall adopt a systematic approach to identify, manage, reduce, and responsibly dispose or recycle waste (including wastewater, exhaust gas, and solid waste).

• Resource efficiency

Suppliers shall encourage and practice the principle of circular economy, such as recycling, waste reduction, and product remanufacturing. And they shall prioritize the use of renewable materials and promote the recycling of products and materials.

• Biodiversity, prohibition of deforestation, or land protection

Suppliers shall avoid, minimize, and, if necessary, offset any substantial impact of their production and operation activities on biodiversity. They shall take measures to use natural resources, including water, fossil fuels, minerals, and virgin forest wood in a controlled manner, such as improving production, maintenance, and equipment processes, using alternative materials, reusing, protecting resources, recycling, and other methods.

Article V This Code applies to all or part of the businesses owned by partners and all or part of those interacting with our company.

Article VI This Code shall be widely promoted among partners for their subsidiaries and partners on the upstream and downstream of the industrial chain to comply with and practice, so as to achieve our company's business objectives and corporate social responsibility.

Article VII If any partner violates this Code, our company has the right to suspend or terminate the partnership, and reserves the right to resort to other legal means.

Article VIII Our company will regularly review, revise, modify or abolish this Code based on the latest national laws and regulations, policy documents, and actual operation conditions. For any modifications, this Code shall be revised separately and widely promoted among various partners.

Article IX Our list of suppliers is constantly being updated.

Article X This Code shall be interpreted by the Operation Department of GigaDevice.

Article XI This Code shall come into effect from the date of its formulation.