Human Rights Policy

Chapter I General Provisions

1.Principles: GigaDevice is committed to supporting and respecting internationally recognized human rights, including those set forth in the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, the core conventions of the International Labour Organization (ILO), and the human rights principles contained in the ILO Declaration on Fundamental Principles and Rights at Work. The Company highly values and protects the rights and interests of every employee. In developing its human rights policies, the Company strictly complies with human rights requirements under relevant social responsibility frameworks as well as applicable national laws and regulations, including the Labor Law of the People’s Republic of China, the Labor Contract Law of the People’s Republic of China, the Law of the People’s Republic of China on the Protection of Rights and Interests of Women, and the Law of the People’s Republic of China on the Protection of Minors. At the same time, the Company proactively aligns with relevant ILO conventions and internationally recognized human rights guiding principles. The Company strives to establish a dual compliance and human rights policy framework that integrates international standards with local regulatory requirements. We closely monitor updates to laws and regulations in jurisdictions where we operate and continuously improve our policies and provisions to ensure all labor practices remain lawful and compliant, while preventing any conduct that violates human rights or labor standards.

2.Purpose: This Policy is formulated in light of the Company’s actual operational needs for the purpose of establishing standardized labor and employment procedures and safeguarding the lawful rights and interests of both the Company and its employees.

3.Scope of Application: This Policy applies to GigaDevice and all of its controlled subsidiaries, branches, and other operating entities to which this Policy applies, covering all employees, including full-time and part-time employees, dispatched workers, and temporary employees. In addition, we require our business partners and suppliers to comply with this Policy and encourage them to adopt similar policies.

4.Where the provisions of this Policy conflict with the laws or regulations of the country or region in which an employee is located, the applicable local laws and regulations shall prevail.

5.Human rights-related matters of the Company shall be supervised and governed by the Human Resources Department.

6.The Company implements a written employment contract system. Employment contracts shall be executed within one month of employment and may be signed in paper or electronic form. Each contract shall be made in duplicate, with one copy retained by the Company and one by the employee. Where the laws or regulations of the country or region in which the employee is located provide otherwise, such laws or regulations shall prevail. 

Foreign employees shall be provided, prior to onboarding, with employment agreements that comply with applicable legal requirements in either the official language of their home country or an internationally accepted language. The Company shall verify their identities and ensure the legality of their employment in China. All employment terms and conditions shall meet the requirements of the Rules for the Administration of Employment of Foreigners in China.

7.Employees are entitled to labor rights including remuneration, rest and leave, occupational health and safety protection, statutory social insurance, and employee benefits. Employees shall also fulfill their obligations, including completing assigned work tasks and complying with the Company’s rules, regulations, and professional ethics.

8.The Company shall fulfill its obligations to employees, including payment of remuneration, provision of appropriate working and living conditions, and protection of employees’ lawful rights and interests.

9.The Company encourages suppliers and business partners to establish a zero-tolerance approach toward child labor, forced labor, and discrimination within their organizations and supply chains. Suppliers and business partners are expected to establish labor compliance programs covering child labor, forced labor, anti-human trafficking, health and safety, freedom of association, discrimination, disciplinary practices, working hours, compensation and benefits, and management systems, including but not limited to the following:

1）Provide employee training to strengthen awareness of forced labor risks based on the ILO indicators of forced labor in supply chains, and clearly define remediation measures for any violations identified;

2）Provide all employees and supply chain participants with anonymous, impartial, and confidential grievance mechanisms. Employees and/or their representatives shall be able to communicate openly with management regarding working conditions and management practices without fear of discrimination, retaliation, intimidation, or harassment;

3）Prohibit discrimination in any form during recruitment and employment on the basis of race, color, ethnicity, gender, sexual orientation, language, age, religion, disability, marital or parental status, nationality, political affiliation, veteran status, or any other legally protected characteristic or circumstance under applicable laws and regulations.

4）Provide a workplace free from harassment and prohibit all forms of workplace bullying, violence, or inhumane treatment;

5）Comply with applicable labor and employment laws and regulations in all countries and regions where employees are hired, execute employment contracts with employees, ensure each party retains one copy of the contract, and prohibit the collection of deposits or collateral from employees or the retention of employees’ identification documents, residence permits, academic certificates, professional qualification certificates, or other personal documents;

6）Ensure wages are paid in accordance with applicable wage laws and statutory benefits are provided in compliance with the laws of the jurisdictions in which operations are conducted or employees are employed, while complying with all applicable living wage requirements and regulations.

Chapter II Employee Recruitment and Training

1.The Company upholds equal opportunity and diversity in employment and welcomes talent from diverse educational and professional backgrounds. The Company prohibits any form of discrimination based on race, color, ethnicity, gender, sexual orientation, language, age, religion, disability, marital or parental status, nationality, political affiliation, veteran status, or any other legally protected characteristics, and ensures a fair and equitable recruitment process. Where laws or regulations provide otherwise with respect to gender requirements for certain types of work or positions, or the employment of persons with disabilities, ethnic minorities, or retired military personnel, such provisions shall prevail.

2.Employees recruited by the Company shall possess valid identification documents recognized by the People’s Republic of China. The Company strictly prohibits the recruitment or employment of child labor in any position, and all hiring practices shall comply with applicable local laws and regulations regarding minimum working age.

3.The Company shall not collect deposits or collateral from employees, nor retain employees’ identification cards, residence permits, academic certificates, professional qualification certificates, or other personal documents.

4.The Company prohibits child labor, human trafficking, corporal punishment, and all forms of forced labor, including but not limited to coercion, detention, and bonded labor. The Company maintains a zero-tolerance approach toward such practices and ensures 100% employee participation in human rights training.

5.Responsibilities of the Human Resources Department

5.1.As the department responsible for centralized recruitment management, the Human Resources Department shall oversee recruitment practices, prohibit the hiring of child labor and underage workers, and implement corrective actions where necessary;

5.2.Personnel responsible for recruitment shall receive training on applicable laws and regulations and document verification procedures. Recruiters shall carefully review applicants’ documentation and verify their identity and age based on educational background, employment history, and other relevant information, with all verified records properly documented;

5.3.Where child labor or underage workers are identified after employment or through subsequent investigation, the matter shall be handled in accordance with the Law on the Protection of Minors and the Provisions on the Special Protection of Minor Workers. The Human Resources Department shall also conduct the following assessments:

5.3.1.The level of education and educational conditions available in the locality of the child or underage worker;

5.3.2.Recommendations and supporting documentation issued by the local labor authorities in the locality of the child or underage worker.

5.4.Based on the investigation results, the Human Resources Department shall conduct a comprehensive assessment and submit the case to the General Manager. Upon approval, the Company shall arrange payment of wages, return travel expenses, and necessary living allowances;

5.5.Where underage workers are identified after employment or through subsequent investigation, the Company shall arrange regular health examinations for such workers;

5.6.Where individuals from the same home region as the child laborer or underage worker are returning home, the Human Resources Department shall coordinate for the individual to travel with them. If no such arrangement is available, the Human Resources Department shall designate personnel to escort the individual to transportation for return travel and retain all relevant records for verification purposes, including payroll records, travel expense records, and separation documents. Overseas employees shall be handled in accordance with applicable local laws and regulations;

5.7.The Company prohibits recommending child laborers or underage workers to other companies for employment.

6.All employees shall receive communication and awareness training prohibiting the referral or introduction of child laborers or underage workers.

7.Employee Training

7.1.The Company is committed to fostering a diverse corporate culture and values system and places importance on employee training and development. Based on employees’ development needs and job requirements, the Company provides diversified training programs, including onboarding training, professional skills training, and on-the-job continuing education, to enhance employees’ professional competence and ethical standards, while helping employees understand the value of a diverse workforce and their roles and responsibilities in cross-team, cross-functional, and cross-regional collaboration;

7.2.Qualification requirements and professional training for specific professional positions shall be implemented in accordance with applicable laws and regulations.

8.The Company has established and maintains formal employee EHS participation mechanisms, safeguards employees’ core EHS rights, and provides comprehensive preventive occupational health services in accordance with the Company’s Environment, Health and Safety (EHS) Policy.

9.The Company provides special labor protection for female employees and underage workers and shall not assign them to work prohibited by laws and regulations. Where laws, regulations, or rules provide otherwise regarding special protections or benefits for female employees and underage workers, such provisions shall prevail.

10.Employees have the right to voluntarily terminate their employment relationship. Employees may terminate their employment contract by providing written notice to the employer at least three days in advance during the probation period or at least 30 days in advance during formal employment.

Chapter III Human-Centered Management

1.Employees have the right to freedom of expression; however, any disclosure of confidential company information shall be governed by Company policies and the Confidentiality Agreement signed by employees.

2.The Company maintains various communication channels to engage with employees, receive employee feedback and concerns, and to better understand and address workplace issues. The Company also respects employees’ rights to collective bargaining and peaceful assembly in accordance with applicable local laws and regulations.

2.1.Communication Channels and Methods

2.1.1.Within departments: direct communication between supervisors and subordinates;

2.1.2.Face-to-face communication: encouraged as a primary means of resolving issues within departments and with Human Resources;

2.1.3.Cross-department / cross-level communication: conducted via email, meetings, or in-person discussions;

2.1.4.HR platform communication: the HR Service Center periodically collects employee concerns and provides timely responses;

2.1.5.Communication with senior management: via email or meetings, as well as company-wide briefings conducted by senior management at quarterly, annual, or ad hoc intervals across subsidiaries and branches.

3.Freedom of Association

3.1.Freedom of association is a fundamental civil right, referring to the freedom of citizens to lawfully form and participate in social organizations and engage in their activities;

3.2.The Constitution of the People’s Republic of China recognizes and protects citizens’ freedom of association. In China, a registration and approval system is applied for the establishment of social organizations. Citizens are required to register with the competent authorities and truthfully submit information including the organization’s name, purpose, address, bylaws, scope and region of activities, leadership background, organizational structure, membership size, and any affiliated or branch entities. Where applicable local laws, regulations, or rules provide otherwise, such provisions shall prevail.

3.3.Employees may, in accordance with applicable laws, freely associate, join or not join trade unions, seek union representation or elect employee representatives, and participate in workers’ committees.

4.The Company places great importance on safeguarding employees’ lawful rights and interests and is committed to improving its governance system and fostering a positive and harmonious working environment. The Company actively listens to employees’ legitimate concerns and provides channels for feedback, suggestions, issue reporting, and grievances, in accordance with the Company’s Reporting and Informant Protection System.

Chapter IV Prohibition of Sexual Harassment and Workplace Bullying

1.The Company strictly prohibits sexual harassment in the workplace or any work-related setting, including but not limited to sexually explicit messages or videos, sexual coercion, threats, humiliation, sexually suggestive jokes or teasing, and unnecessary physical contact. The Company also prohibits all forms of workplace bullying and forbids the use of violence or inhumane treatment toward employees. Employees shall not engage in unreasonable conduct toward colleagues or subordinates, including but not limited to corporal punishment, threats, physical intimidation, verbal abuse, psychological abuse, or humiliation. Where an employee’s conduct causes serious adverse social impact, the Company reserves the right to terminate the employment contract in accordance with applicable laws.

2.Any employee found to have engaged in sexual harassment, other forms of harassment, or workplace bullying shall be handled in accordance with the Company’s Reporting and Informant Protection System. Verified violations shall be deemed serious breaches of Company rules and regulations and will be subject to disciplinary action in accordance with applicable policies.

Chapter V Anti-Discrimination Management

1.The Company advocates equal opportunity and diversity in employment and is committed to providing a workplace free from unlawful discrimination. Company policies, standards, and procedures are established in accordance with applicable laws and regulations and shall not contain discriminatory content or practices. The Company does not tolerate any form of harassment.

2.To ensure fair and equitable employment opportunities and working conditions, the Company prohibits discrimination, harassment, or bias in recruitment, hiring, compensation, training, promotion, termination, benefits, and career development on the basis of nationality, race, ethnicity, gender, sexual orientation, marital status, color, social origin, religion, disability, or any other characteristic protected under applicable laws and regulations.

3.The Human Resources Department is responsible for formulating, implementing, and interpreting anti-discrimination policies, investigating discrimination-related complaints, and taking timely corrective actions.

Chapter VI Working Hours and Leave

1.In accordance with applicable laws and regulations and based on job position, nature of work, and operational needs, the Company implements working hour systems including the standard working hour system, the comprehensive working hour system, and the flexible working hour system. The Company ensures employees receive statutory rest periods and that total weekly working hours do not exceed applicable legal limits. For employees who work overtime with prior approval in accordance with Company policies, overtime compensation shall be paid in compliance with applicable local laws and regulations.

2.Employees are entitled to statutory public holidays, statutory leave, paid welfare leave (including parental leave, marriage leave, paternity leave, maternity leave, and nursing leave), and other leave provided under Company policies. Where employees are required to work outside normal working hours or on rest days or public holidays due to operational needs, such arrangements shall be handled in accordance with applicable laws, regulations, and Company policies. For details, reference may be made to the Company’s Vacation Management Regulation. Where the laws or regulations of the country or region in which the employee is located provide otherwise, such laws or regulations shall prevail.

Chapter VII Compensation and Benefits

1.Employee compensation shall be paid in accordance with applicable laws and regulations. Compensation arrangements shall be reflected and confirmed through offer letters, compensation notices, and payroll statements.

2.The Company shall pay employee wages within the agreed payroll period each month. Specific payroll dates shall be subject to the Company’s relevant policies.

3.Employees are entitled to all statutory benefits prescribed by law, including but not limited to wages, allowances, benefits, annual leave, and public holidays.

4.In accordance with national and local requirements, the Company provides employees with statutory benefits as well as additional Company-sponsored benefits.

5.In accordance with applicable laws and regulations, employee wages paid by the Company shall not be lower than the local minimum wage standard applicable at the place where the employment contract is performed under normal attendance conditions. The Company is also committed to providing comprehensive compensation and benefits that support employees’ livelihood, health, and well-being, ensuring that employee compensation is no lower than applicable local living wage standards. The Company continuously seeks to enhance employees’ sense of fulfillment, belonging, well-being, and overall quality of life.

6.Company policies prohibit unreasonable fines, wage arrears, and unjustified wage deductions.

7.The Company upholds gender equality and equal pay for equal work and maintains a fair and equitable compensation and incentive system. Compensation is determined based on multiple factors, including job contribution, work performance, and development potential. Employees shall not be subject to discrimination or unequal treatment in recruitment, training, compensation and benefits, or career development based on nationality, race, ethnicity, gender, sexual orientation, marital status, color, social status, religion, disability, or any other legally protected characteristic. All employees, regardless of gender, position level, or nationality, shall have equal access to promotion opportunities based on performance and competency, subject to qualification through assessment procedures.

Chapter VIII Human Rights Due Diligence and Risk Management

1.During the recruitment process, background checks shall be conducted in accordance with the Company’s Employee Background Check Management Measures. Candidates presenting potential employment-related risks shall be carefully evaluated before hiring decisions are made.

2.Throughout the entire employee recruitment, hiring, and employment management process, the Company shall implement risk prevention and control measures in accordance with this Policy to mitigate labor disputes and related human rights risks at all stages of employment.

3.This Policy shall be revised, updated, and improved from time to time in accordance with changes in applicable laws and regulations, policy requirements, and the Company’s operational needs.

4.Where the laws or regulations upon which this Policy is based are amended, or where the provisions of this Policy conflict with the laws or regulations of the country or region in which an employee is located, the latest applicable laws and regulations and those of the employee’s location shall prevail, and this Policy shall be adjusted accordingly.

This Policy shall take effect as of the date of issuance and shall be interpreted by the Human Resources Department.