1. Purpose

   Sao Bac Dau Technologies Corporation and its subsidiaries (collectively referred to as "SBD") are committed to conducting business fairly with integrity and transparency, always complying with all applicable legal regulations. SBD developed this Third Party Code of Conduct to explain the Code of Conduct, Business Ethics as well as the Anti-Corruption and Bribery Policy published by SBD.

   Third party means any organization (including managers, employees, subcontractors, persons related to the organization), individuals, business partners, joint venture partners, suppliers, prime contractors, subcontractors, agents, other intermediaries etc. that engage in or will enter into transactions with SBD for the supply of goods, services, consulting, non-material services (including legal services, consultants, etc.), sales representatives, customs brokers, etc. related to the project of providing goods/services to SBD customers.

2. Objectives

   The objective of the Third Party Code of Conduct is to promote compliance by SBD and the Third Party with regulations relating to SBD's Code of Conduct, Business Ethics and Anti-Corruption and Bribery Policy and all applicable legal provisions related to anti-corruption.

3. Scope

   The Third Party Code of Conduct is not a substitute for SBD's Code of Business Conduct and Ethics as well as its Anti-Corruption and Bribery Policy. This Code of Conduct provides an overview of SBD's requirements for Third Parties to work with SBD.

   The Third Party Code of Conduct applies to all Third Parties working with or on behalf of SBD, SBD expects the Third Party to comply with the requirements of this Code of Conduct. SBD understands that there is no Code of Conduct that can prescribe every situation a Third Party may encounter. Therefore, this Code of Conduct cannot substitute for the responsibility of third parties to identify and consult on proper business conduct.

4. Third-Party Assessment and Due Diligence

   SBD will carry out assessments and due diligence (as necessary) of risks in SBD's relationship with the Third Party. SBD expects the Third Party to provide complete and accurate information to facilitate SBD's assessment and appraisal upon request.

   If SBD determines that a Third Party is in violation of this Code of Conduct, depending on the case, SBD may require the Third Party to take remedy(s) or SBD may suspend or terminate its relationship with the Third Party.

5. SBD's requirements and expectations with third parties

   SBD expects the Third Party to conduct business or on SBD's behalf in an ethical manner that complies with all applicable laws and SBD's internal policies and procedures. SBD's specific expectations of the Third Party are based on the requirements of the Code of Conduct, business ethics as well as SBD's anti-corruption and bribery policy.

   SBD expects the Third Party to implement such policies, procedures and training as the Third Party deems necessary to comply with this Code of Conduct

   + Fair transactions, healthy competition

     Third parties must not engage in unfair trading activities, unfair competition in accordance with the provisions of competition and antitrust       laws, whether conducted alone or in combination with other organizations and individuals.

   A third party may not enter into any formal or informal agreement aimed at limiting illegal competition, fixing prices, or engaging in inappropriate practices in the distribution of interests or distribution of customers or services to or on behalf of SBD or in connection with any relationship with SBD.

   + No corruption, bribery in any form

SBD prohibits bribery and corruption from SBD employees themselves in any way to anyone anywhere worldwide, and SBD requires Third Parties to abide by such a standard. No third Party shall be fined or liable for any delay in the performance of the contract with SBD due to refusal to commit acts of bribery and/or corruption.

A third party may not promise, offer, provide (directly or indirectly) anything of value to any other party for the purpose of obtaining or maintaining business or preferential treatment to SBD or anyone else. This prohibition also applies to agents, representatives, subcontractors or other business partners who may act on behalf of a Third Party.

It is SBD's policy not to make any payments in violation of applicable laws and SBD expects Third Parties to ensure that the Third Party does not take any action that could be deemed to violate any anti-corruption regulations, bribery in any country worldwide.

   + Concept of corruption, bribery

    • Corruption is the act of abusing assigned positions and powers for personal gain or bringing improper advantages.

    • Bribery means acts that include offering, promising, soliciting, giving, accepting or permitting the giving or receiving or payment of money, gifts or anything of value directly or indirectly to or from officials, civil servants, officials at all levels of Vietnam or foreign government officials or any person in an inappropriate manner that affects the action or decision to gain or maintain an unfair, non-transparent business advantage. It is a violation to simply commit an act of bribery of any kind, even if the transfer of money or valuables did not occur or the purpose of the bribery was not carried out.

    • Anything of value means any benefit given to gain or maintain business operations or to gain any other non-conformable advantage in order to improperly influence an action or decision, including but not limited to:

        - Cash or equivalent item(s) (including gift cards), inappropriate gifts, charitable or political donations, forms of in-kind help;

        - Agreements on non-bidding or fraudulent bidding, acts of collusion in bidding or preventing competition in bidding;

        - Travel, entertainment, tourism or hospitality (payment of hotel, meal, living expenses or expenses of trip(s) or resort...);

        - Job offer or promise of future employment, whether the trainee has salary/allowance or not (including relatives and relatives);

        - Unauthorized facilitating payments...

     • Foreign Government Officer is understood as:

        - Any elected or appointed public servant or public servant, employee (regardless of rank) or any person acting on behalf of a foreign Government entity; or

        - Any official of a foreign party or candidate for foreign political office or any person acting on behalf of an official of a foreign party or candidate for foreign political office.

   + Do not commit money laundering, economic crimes

   The third party may not provide services or enter into agreements that facilitate or may create SBD that are directly or indirectly involved in economic crimes, including money laundering activities. Third parties may not transfer any funds intended to finance or support illegal activities such as terrorism, tax evasion, fraud.

   + Maintain books and records

   Third parties must not knowingly misrepresent facts about SBD and/or SBD's business activities and must not create any false or misleading information in books and records related to SBD. The third party must conduct all business transactions transparently and accurately reflected in the third party's business books and records, and must implement compliance monitoring, recordkeeping and enforcement procedures to ensure legal compliance.

   + Avoid conflicts of interest

   A conflict of interest is understood as a situation that may raise doubts about the objectivity of the provision of goods or services or in connection with the operation of SBD. Conflicts of interest include the use of inappropriate information or position for personal gain or competition with SBD.

   If the Third Party perceives that there are any actual or potential conflicts of interest or circumstances that could lead to serious problems affecting the reputation, image or customer relationship with SBD or similar situations, the Third Party shall promptly notify SBD.

    + Recruitment and employment

   SBD expects the Third Party to maintain working conditions in accordance with labor laws, human rights and other relevant standards and regulations. Third parties shall not discriminate against any person in the employment and/or employment of workers, including against race, ethnicity, color, age, sex, gender identity, sexual orientation, religious ideology, etc. disability, family status, health status, economic status or any other condition or characteristic not related to the qualities of that individual or the requirements associated with the vacancy.

   + Information security

   The third party shall maintain the integrity of all information received from SBD and ensure that such information(s) is used solely for the purpose of conducting transactions with SBD. This also includes information provided by SBD customers and other individuals/entities in connection with SBD's business.

   + Intellectual property rights

   SBD expects Third Parties to respect SBD's intellectual property rights and those of other individuals and organizations, such as Third Parties not to use SBD's intellectual property rights without SBD's consent or use uncopyrighted software or technology to support or perform tasks related to transactions with SBD.

   + Information technology security

   The third party must use security controls that meet SBD's requirements to store and protect information including physical and digital assets received from SBD, SBD's customers, and other parties.

   + Social media

   SBD expects Third Parties not to engage in disrespectful, unprofessional, harassing, defamatory, discriminatory and prohibited activities on social media platforms. A third party may not act or speak on SBD's behalf, represent itself, or express any views that could be attributed to SBD (unless SBD's written consent is obtained on a case-by-issue basis).

    6. Report illegal and unethical behavior

   If the Third Party becomes aware of any illegal or unethical conduct or believes that applicable laws or regulations have been violated, the Third Party shall promptly report the matter to SBD in any manner including face-to-face meeting, telephone, e-mail messaging, etc text... are acceptable. The third party when reporting may use a real name or anonymize. However, SBD encourages the use of real names to ensure the reliability of the source of information and the effectiveness of subsequent investigations. SBD is committed to protecting the reporter's information in accordance with SBD's confidentiality regulations.

   Report contact information:

       Sao Bac Dau Technologies Corporation

       Head office address: Block U.14b-16a, Road 22, Tan Thuan EPZ, Tan Thuan Dong Ward, Dist. 7, Ho Chi Minh City, Vietnam

       Email: Compliance-CMS@saobacdau.vn

       Telephone: (+84-28) 37700968 ext 8744 or 8681

       Mobile: (84-93) 8870 429 or (84-039) 8888178

   SBD expects the Third Party to inform management, employees, any person of the Third Party that it will not be retaliated against for proper reporting.

   SBD will review and investigate the contents of the report and, if necessary, transfer the information to the Third Party for monitoring and monitoring.

   7. Recognizing the Third Party Code of Conduct

   Third parties working for or together with SBD and SBD's customers upon receipt of this Code of Conduct agree:

       + Comply with the requirements and expectations outlined in this Code of Conduct;

       + Provide complete and accurate information to support the assessment and appraisal process for third parties conducted by SBD;

       + Comply with applicable laws and regulations in the country in which the Third Party operates.

Head Office - Ho Chi Minh

 Block U14B - 16A, No.22 Street,      Tan Thuan Export Processing Zone, District 7, Ho Chi Minh City

(84-28) 3770 0968
(84-28) 3770 0969

Ha Noi Office

  3rd Floor, CT1AB,                          VOV Me Tri Urban Area, Me Tri Ward, Nam Tu Liem District, Ha Noi
(84.4) 37722989
(84.4) 37723000

Da Nang Office

  Room 408, 04th floor,                        15 Quang Trung Building, Hai Chau 1 Ward, Hai Chau District, Danang City
(84.511) 3812175
(84.511) 3812175


No. 27/14B Cach Mang Thang Tam, Quang Vinh Ward, Bien Hoa City, Dong Nai Province

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