Sinotruk (Hong Kong) Limited

Code of Business Ethics

The Group is one of the leading truck manufacturers in the PRC which specializes in the research, development and manufacture of HDTs, LDTs, etc., and related key assemblies, parts and components. Through our diversified product portfolio, we serve a wide range of customers from different major industries including infrastructure, construction, container transportation, logistics, mining, steel, chemical, etc.

The Group mainly manufactures trucks and also produces assemblies, key parts and components such as engines, cabins, axles, steel frames, gearboxes, etc. The Group is a truck manufacturer which has research and development and production capability in trucks as well as the complete production chain. The Group sells truck engines and engines for use in industrial and construction machinery to third parties in addition to our own use. Our products are not only sold domestically but also exported to other countries and regions in the world. In addition, the Group provides financial services for those parties related to the production and sales of Group’s products and to the CNHTC Group.

As we conduct our business, we have sought to gain the full trust of our customers and to grow alongside them in support of their mission; to adhere to the highest standards of business ethics in all locations in which we operate; and to build a strong security infrastructure and robust corporate culture that protects and preserves the intellectual property and data of our customers. We are implementing green manufacturing and sustainable operations across our business units, helping to improve the environment and the communities in which we operate. We are committed to and maintain an inclusive and vibrant workplace that fosters collaboration among and professional development for all Sinotruk employees.

Compliance with Local Regulatory Requirements

We strictly adhere to local laws and regulations in the regions in which we operate, and regularly take into account economic, social and environmental factors in our decision-making and operations.

Data Security and Privacy

A core tenet of our business is to preserve the trust, confidence and privacy of our customers. Data privacy and security is our highest priority. Since our founding, Sinotruk has maintained a strong track record based on a rigorous and multi-layered internal process – everything we discover, develop and deliver to our customers is secure, separated and protected. Sinotruk ensures that all personal identifiable information (PII) is anonymized and protected. Further, we maintain a robust system of corporate governance to ensure customers information is protected and used in accordance with the guidelines laid out by our customers and global privacy and healthcare policies.

Intellectual Property Protection

Integral to the continued success and competitiveness of our customers–and therefore a lifeline of our business–is their unique intellectual property (IP). Our approach to IP protection is embedded in our founding principles of integrity, unwavering commitment to global quality standards and world-class security. Our standards include a comprehensive IP management and infringement accountability system. We are dedicated to adhering to industry best practices in all of our facilities worldwide.

Anti-Discrimination

Discrimination refers to penalizing qualified individuals in the workplace due to irrelevant personal factors such as gender, age, race, ethnicity, nationality, skin color, cultural background, disability, or other protected characteristics. SINOTRUK respects employee diversity and complies with all applicable anti-discrimination laws. We are committed to evaluating individuals and making employment decisions based solely on merit, skills, and experience. Employees are encouraged to actively report any observed discriminatory behavior or if they believe they have been subjected to unfair discrimination.

Conflict of Interest

SINOTRUK monitors situations where personal interests conflict with the Group’s legitimate interests, ensuring disclosure, management, and proactive avoidance of such conflicts. We are committed to resolving conflicts fairly and equitably for all parties involved.

Antitrust/anti-competitive

Our competitors include any independent companies that compete or may compete with SINOTRUK in a specific market. We compete through products and services, refraining from measures that violate competition laws (e.g., collusion with competitors), and select suppliers based on objective criteria.

Business Ethics and Anti-corruption

Sinotruk has zero-tolerance for any form of corruption. Since our founding, we have maintained a steadfast commitment to the integrity of our work, and we strictly adhere to local laws and regulations and the highest standards of business ethics across the regions in which we operate. Sinotruk demands adherence to these standards by each of our employees.

Response of Whistleblows and Protection of Whistleblowers

If any bribery, embezzlement, corruption, etc. is discovered, anyone can report and provide relevant clues and materials to the department responsible for compliance. Upon receipt of the report, the department in charge will, after communicating with the whistleblower, carry out the relevant investigation in accordance with the relevant anti- commercial bribery and anti-corruption investigation process.

The Group will maintain the confidentiality of the informant's information and protect the informant's personal rights, property rights, work rights, honor rights, and other legitimate rights and interests. For those reported cases which are verified, we encourage whistleblowers  to be rewarded according to the nature of the case, and timely rectification of internal control gaps identified during investigations.

For more information on the process of receiving reports and whistleblower protection, please refer to the Policy for Whistleblowing and Whistleblower Protection. The Group develops appropriate supervision procedures, conduct regular safety inspections and audit assessments, report results and take improvement measures promptly not to engage in any corruption or commercial bribery or money laundering.

Anti-Money Laundering

Money laundering refers to acts aimed at concealing or disguising the origins and nature of proceeds derived from criminal activities—including but not limited to drug-related crimes, organized crime, terrorism, smuggling, corruption, financial fraud, and other offenses—through means such as providing financial accounts, converting property, cross-border transfers, or other methods.

Potential money laundering activities include but are not limited to: Providing financial accounts; Converting property into cash, financial instruments, or securities; Transferring funds via transactions or other payment settlements; Cross-border asset transfers; Any other means to conceal or disguise the illicit origins or nature of criminal proceeds. Any identified red flags must be immediately reported to the Risk Management Department for further investigation.

Donations

The Group shall cooperate with governments in good faith and maintain political neutrality. It is prohibited to donate to any political party or candidate. All donations made by or in the name of the Group must comply with limits set by the Board of Directors and obtain prior approval under the Sponsorship and Donation Policy.

Environment, Health and Safety (EHS)

Sinotruk seeks to reduce the environmental impact of our operations by improving how we conduct our operations. Our goals are to reduce the environmental impact of our supply chains, prevent pollution and use our resources efficiently. We seek to promote the well-being of the environment and our global society across all business operations.

Sinotruk is committed to production safety. All Sinotruk facilities meet stringent safety standards and strictly abide by the relevant laws and regulations of their local jurisdiction. To supplement these standards, we have established corresponding risk prevention and management systems.

Employee Welfare

The intellect, experience and dedication of our employees is Sinotruks most valuable asset. They are the driving force that enables Sinotruk to build an open-access platform, providing comprehensive capabilities and technologies to the healthcare industry.

Sinotruk is an equal opportunity employer. We are proud of our diverse workforce, recruited from across the global health sciences community. Sinotruk strives to foster an inclusive and collaborative workplace, with robust on-the-job training and a commitment to professional development. Sinotruk is committed to protecting the occupational health and safety of all employees and promoting a healthy work-life balance.