Code of Business Ethics

Code of Business Ethics

Code of Conduct for Employees

We promise that every member of GigaDevice is responsible for complying with the Code of Conduct for Employees:

• Being in good faith is the fundamental principle and requirement.

• Complying with applicable laws and regulations that guide our global business operations.

• Being honest, fair and reliable when handling all business activities and relationships at GigaDevice.

• Avoiding conflicts between public and private interests.

• Creating and developing an atmosphere within the Company where everyone boasts equal opportunities.

• Providing employees with a safe working environment.

• Being committed to environmental protection.

• Creating and maintaining a corporate culture that everyone recognizes and promotes integrity, and practices it personally through the joint efforts of employees.

• Keeping internal information confidential, including but not limited to salary, technology and trade secrets, and business data, and avoiding intentional or unintentional disclosure of them.

Anti-bribery Compliance

The Company is committed to complying with all applicable anti-corruption and anti-bribery laws and regulations in its business, and resolutely eliminating any form of corruption and bribery so as to regulate its business activities. To be specific, employees, entities or individuals engaged in business activities on behalf of the Company shall:

• not offer, promise, give, solicit or accept bribes (including but not limited to cash, commissions, rebates, securities or valuable items) to or from public officials or other entities and individuals in any direct or indirect manner for the purpose of obtaining business opportunities;

• not participate in reception and entertainment activities organized by institutions with business connections or their affiliated parties that may affect business fairness or obtain improper benefits;

• if any supplier, agent, consultant or other partner engages in the above-mentioned behavior towards employees of GigaDevice for the same purpose, refuse and report it to the Company;

The Company will never tolerate any form of corruption and bribery, nor will it allow any behavior that may damage the Company's reputation or interests.

Customer Privacy Protection

Regulations such as the Graded and Classified Data Management Policy and the Management Measures for System Account Authority and Passwords are developed to protect customer privacy and ensure that all customer information and data are used and kept in accordance with relevant management measures. Employees are obliged to protect customer privacy and data, and to comply with the implementation procedures of their business departments regarding privacy and data protection.

Supplier Relationship

The Company shall develop relationships with suppliers in a legal, fair and effective manner, and respect their intellectual property rights and legitimate requirements for trade secret protection. It is prohibited to trade with suppliers who violate local laws or regulations of GigaDevice regarding equal employment opportunities, environmental protection, health and safety.

Anti-unfair Competition

When conducting business activities, the Company and its employees shall not violate the principles of voluntariness, equality, fairness and integrity, as well as legal and business ethics,  disrupt the order of market competition, illegally subdue rivals through any improper means, deliberately fabricate and disseminate false facts, or harm the legitimate rights and interests of other operators or consumers.

Export Control Compliance

The Company and its employees shall strictly comply with all applicable laws and regulations regarding export control and economic sanctions related to GigaDevice's operations. All employees of GigaDevice shall strive to achieve the Company's goal of trade compliance, and strictly implement the relevant trade compliance policies of the Company. It is not allowed to use the Company's technologies, products and services for prohibited end uses such as nuclear weapons, weapons of mass destruction, specific rocket systems, biological and chemical weapons, terrorism and military; nor is it allowed to export or transport the Company's technologies, products and services to countries or regions subject to sanctions or embargoes imposed by applicable governments or organizations. The Company shall formulate an internal control regulation on trade compliance, promote and conduct training regarding trade compliance laws and regulations, strengthen the internal audit of trade compliance, and assign the responsibilities of various departments involved in trade compliance.

Prevention of Money Laundering

The Company shall strictly resist money laundering, require all employees to comply with laws and regulations such as the Anti-Money Laundering Law of the People's Republic of China, and eliminate all forms of financial support for illegal and criminal activities.

Environment, Health and Safety (EHS)

The Company shall abide by applicable regulations and standards related to occupational health and safety, and attach great importance to the health and safety of employees. Committed to creating and maintaining a safe working environment for employees, the Company shall comply with local safety regulations, reduce waste and emissions, as well as the use of toxic materials, and take appropriate measures to prevent potential safety hazards. The Company shall strictly comply with relevant laws and regulations, implement special labor protection for female employees, and not assign them to labor with the Ⅳ physical work intensity or other prohibited labor specified by China.

Equal Opportunity Employment and Anti-discrimination

Adhering to the requirements of the Labor Contract Law of the People's Republic of China and its supporting laws and regulations, the Company shall provide fair job opportunities to internal and external applicants, abide by the principles of gender equality and ethnic equality, and avoid any form of discrimination based on race, skin color, gender, language, age, religious beliefs, disability, marriage and childbirth, nationality, political status, etc. We should adhere to the above-mentioned principles of equality in every aspect of employment, such as recruitment, hiring, training, promotion, salary and benefits.

Legal Employment

During recruitment, the Company shall not collect any form of deposit from employees, or detain their documents such as ID cards, passports and educational certificates. It is not allowed to recruit child labors under 16 and minors aged 16-18, nor accept any request to introduce child labors or minors to work for the Company. Employees hired must be at least 18 years old.

The Company shall not use or support any form of forced labor, including but not limited to bonded labor, indentured labor, forced labor through punishment or intimidation, etc. All employees shall voluntarily establish labor relations with the Company.

Anti-harassment

The Company prohibits any form of sexual harassment and workplace bullying. We firmly oppose cruel and inhumane treatment of employees, including but not limited to any form of sexual harassment and abuse, corporal punishment, threats, psychological abuse or humiliation, physical oppression or verbal abuse.

Communication Channels

The Company strives to build smooth communication channels, encouraging employees to provide reasonable suggestions. The Company possesses various communication and feedback channels, such as regular communications within departments, cross-departmental communications, high-level face-to-face communications, communication with HR department and administrative management department to establish contacts with employees, so as to accept their supervisory opinions, dynamically understand their various difficulties and feedback, and improve employee satisfaction.

Complaint Reporting and Whistleblower Protection System

The Company has established an employee appeal and reporting mechanism. Employees may submit a report according to the appeal process if they believe that their personal or collective interests have been improperly infringed. They will receive clear feedback after the Company accepts the report and conducts an investigation. The Company has set up a whistleblower protection system that will protect the legitimate rights and interests of the whistleblower and strictly keep the whistleblower's data confidential. If the report involves stakeholders or recipients, a full course of avoidance mechanism will take effect, and the Company will inform the whistleblower of the handling results of the report.

Avoidance of Conflicts of Interest

Employees shall act in line with the best interests of GigaDevice to avoid conflicts of interest. In case of any conflict of interest, employees shall avoid making business decisions where personal needs override the Company's interests. Situations and examples of conflicts of interest are as follows:

Employees should avoid behaviors or relationships that may conflict with their job responsibilities or the Company's interests. Necessary approvals must be obtained before accepting positions in other companies or non-profit organizations (including managers, directors, consultants and any other positions).

Any financial interests or relationships found during activities outside the Company that may conflict with the Company's interests shall be reported in writing.

Prohibition of Insider Trading and Disclosure of Stock Insider Information

Employees shall be obligated to keep confidential undisclosed information (insider information) that involves the Company's operations, finances, or has a significant impact on the Company's stock market price before such information is made public. Prior to a lawful disclosure of insider information, insiders shall not disclose such information to the public in any form without authorization, shall not use insider information to buy or sell the Company's stocks and their derivatives, or suggest others to do so for the benefit of themselves or others. In case of violation, the Company will impose penalties on the responsible person accordingly depending on the severity of the circumstances and reserve the right to claim compensation against such a responsible person; to investigate his or her legal liabilities in accordance with laws, regulations and normative documents; and where a crime is constituted, it will be transferred to the judicial authorities for criminal prosecution in accordance with the law.

Intellectual Property Rights (IPR) Protection

The Company respects the intellectual property rights of others and is committed to protecting self-developed intellectual property rights. We clarify valuable information and protect intellectual property rights in appropriate ways, such as by applying for patents and trademarks, registering copyrights and integrated circuit layout designs, or through technical secrets. Those who use the Company's trademarks and trade names shall comply with our brand management guidelines.

Employees should consult the Company's Intellectual Property Department before engaging in the following activities: using proprietary information such as third-party trademarks; or allowing third parties to use the Company's intellectual property rights.

Penalties for Violating the Code of Business Ethics

All employees of the Company should comply with the provisions of the Code. In case of any violation, the Company will ascertain the responsibility in accordance with laws and regulations and handle it seriously; for those suspected of illegal or criminal activities, they shall be transferred to relevant authorities for legal responsibility in accordance with the law.

GigaDevice Semiconductor Inc.