Complicance Policy

Policy Statement & Highest Commitment

Suzhou Worldful New Material Technology Co., Ltd. (hereinafter referred to as the “Company”) affirms, through its Board of Directors and top management, that integrity and compliance are the foundation of the Company’s sustainable development and the core assets that earn the trust of customers, partners, employees, and the public. To establish, implement, maintain, and continuously improve an effective compliance management system, we solemnly commit to the following:

1

Strictly comply with all applicable laws, regulations, supervisory requirements, and industry standards in every country and region where the Company operates.

2

Firmly prevent and prohibit any form of bribery, corruption, fraud, collusion, extortion, money laundering, and related misconduct.

3

Integrate compliance management into all aspects of corporate governance and business operations, ensuring that compliance progresses in parallel with business growth.

4

Foster a corporate culture that upholds “integrity as the foundation and compliance as a source of value,” embedding compliance awareness into the mindset of every employee.

This policy serves as a fundamental document of the Company’s compliance management system. It applies to all Company entities and to all employees—including directors, executives, and both full-time and temporary staff. It also requires our suppliers, contractors, consultants, and other third-party partners to follow the spirit and core principles of this policy when representing the Company or conducting business with the Company.

Policy Objectives

Set the Tone

Establish the firm stance of the Company’s top management on compliance and its “zero-tolerance” attitude toward violations.

Provide a Framework

Offer an overarching structure and direction for establishing, implementing, and maintaining a compliance management system aligned with ISO 37301 and ISO 37001 standards.

Guide Conduct

Provide clear guidance for all employees and third parties to make decisions and act in accordance with ethical and legal requirements during business activities.

Mitigate Risks

 Effectively prevent, identify, and manage compliance risks—particularly bribery and corruption risks—in order to safeguard the Company’s assets and reputation.

Core Principles

Integrity

All employees must conduct their work with honesty and integrity, and the Company maintains zero tolerance for any form of corruption, fraud, or misconduct.

Fairness and Impartiality

In interactions with customers, suppliers, competitors, and government authorities, all personnel must adhere to the principles of fair competition and strictly avoid any form of unfair or improper competitive conduct.

Respect for the Law

All business activities must strictly comply with applicable laws and regulations, including but not limited to those governing financial and tax compliance, anti-unfair competition, labor and employment, intellectual property, information security and data compliance, and external market transactions.

Responsibility and Accountability

Every employee is responsible for understanding and complying with this policy. Senior management is accountable for overseeing its implementation and leading by example.

Compliance Management and Multi-Domain
Compliance Development

Compliance Management and Multi-Domain Compliance Development

  • Prohibited Conduct: The Company will conduct rigorous due diligence on all third-party partners to ensure their compliance and to prevent any bribery conducted through third parties on behalf of the Company.
  • Gifts and Hospitality: Any gifts, hospitality, travel, or related benefits given or received by employees must follow the Company’s approval procedures and value limits to ensure they do not constitute bribery.
  • Third-Party Management: The Company will conduct rigorous due diligence on all third-party partners to ensure their compliance and to prevent any bribery conducted through third parties on behalf of the Company.

Conflict of Interest

  • Identification and Disclosure: Employees are responsible for identifying and promptly disclosing any potential conflicts of interest, such as when a family member holds a key position in a customer or supplier organization.
  • Management Measures: The Company will assess disclosed conflicts of interest and implement appropriate management measures to ensure the fairness and impartiality of business decisions.

Financial and Tax Compliance

  • Financial Records: Ensure that all financial records are true, accurate, and complete, in accordance with accounting standards and applicable laws and regulations. The falsification or alteration of financial data is strictly prohibited.
  • Tax Compliance: Strictly comply with applicable tax laws in reporting and paying taxes, ensuring the Company’s full tax compliance.

Anti-Unfair Competition

  • Financial Records: Ensure that all financial records are true, accurate, and complete, in accordance with accounting standards and applicable laws and regulations. The falsification or alteration of financial data is strictly prohibited.  
  • Tax Compliance: Ensure that all financial records are true, accurate, and complete, in accordance with accounting standards and applicable laws and regulations. The falsification or alteration of financial data is strictly prohibited.

Labor and Employment Compliance

  • Employment Legality: Strictly comply with relevant laws and regulations, such as the Labor Contract Law and Social Insurance Law, ensuring that employment contracts, working hours, compensation, and benefits are in full accordance with legal requirements.
  • Fair Employment: Commit to providing equal employment opportunities and strictly prohibit any form of discrimination.

Intellectual Property Compliance

  • Protection and Respect: Respect the intellectual property rights of others and refrain from infringing upon patents, trademarks, copyrights, or other proprietary rights.
  • Internal Protection:  Safeguard the Company’s trade secrets and intellectual property, and do not disclose them without proper authorization.

Information Security and Data Compliance

  • Protection and Respect: Respect the intellectual property rights of others and refrain from infringing upon patents, trademarks, copyrights, or other proprietary rights.
  • Internal Protection:  Safeguard the Company’s trade secrets and intellectual property, and do not disclose them without proper authorization.

External Market Transactions

  • Contract Management:  Ensure that all external transaction contracts are legal, valid, and strictly enforceable in accordance with their terms.
  • Export Control: Comply with applicable export control laws to ensure that all international trade activities are conducted in full compliance.

Compliance Management
& Oversight

Phone

0512-83518986

Mailing Address

Room 5, No. 918 Pengqing Road, Huaqiao Town, Kunshan, Suzhou, Jiangsu Province — Risk Control Management Committee

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