Bank Culture and Behavioral Standards

Adhering to the prudent risk value of "Soundness, Balance, Compliance, and Innovation" upheld by the head office of Bank of Communications, we implement the core principle of "fair treatment of customers" across all levels. This fosters a matching banking culture, leading the bank towards sustained growth through excellent prudent risk management. It serves as the value standard that all employees adhere to, the common value goal pursued, and the value norm consciously followed.

Bank of Communications Group Corporate Cultural Philosophy
Mission:		To create shared value	Management Philosophy:	One bank, one customer
Corporate Spirit:		Strive for excellence, responsibility in entrepreneurship, innovation and transcendence	Employee Development Strategy:	Co-creation, Co-prosperity, Share, and Co-development
Strategic Goal:		To build a world-class banking group with distinctive advantages
Values Statement
Soundness:	Implement sound strategies and firmly establish the risk philosophy of "standardized operations and steady development."
Balance:	Achieve a balance between risk and return, with rewards and penalties being implemented simultaneously, strictly adhering to the culture of accountability for negligence and thorough investigation of violations.
Compliance:	Adhere to the principles of legal and compliant operations, resolutely upholding the bottom-line requirements of "compliance with laws and regulations, and strict adherence to systems."
Innovation:	Carry forward innovative thinking, seize development opportunities, and continuously expand management methods that are "progressive and innovative in efficiency."
Fair Treatment of Customers
Uphold the spirit of "putting customers first and basing everything on customers," treat all customers justly, honestly, and fairly to establish and maintain their confidence and trust.
Employee Conduct and Code of Behavior
In practicing the core cultural values and philosophies of the Bank, employees shall adhere to the following conduct and behavior when performing their duties:

Ethical Values	The main ethical values include honesty, integrity, diligence, fairness, fulfilling civic responsibilities, and accountability.
Enthusiastic Service	Be serious and responsible towards work without neglect or prevarication. Serve customers sincerely and enthusiastically, being humble and polite, and not fearing tedious tasks.
Improving Quality	Work hard and actively pursue further education in accordance with the bank's business development requirements. Continuously improve personal quality, introduce innovative work concepts, be keen on change to meet job requirements, and effectively achieve the work targets set by the bank.
Team Harmony and Respect	Subordinates should respect superiors and faithfully execute instructions from supervisors. Superiors should care for and guide subordinates in their work, studies, and character development with enthusiasm. Employees should respect and help each other, working together in unity.
Upholding Law and Order	Do not engage in corruption, bribery, private collection of commissions, fraud, dishonesty, misappropriation of public funds, or any other acts of embezzlement. Comply with relevant laws and regulations (including but not limited to Sections 4, 8, and 9 of the Prevention of Bribery Ordinance and Section 124 of the Banking Ordinance), regulatory requirements (including but not limited to the Monetary Authority’s supervisory policy manual), and internal rules and systems to ensure compliant operations. Employees must not misuse bank resources or handle personal matters during work hours that affect job performance. Without bank approval, employees may not use or appropriate bank resources/assets for personal use.
Strict Confidentiality	All internal affairs of the Bank of Communications, business figures, account books, financial statements, documents, files, and customer correspondence materials must be kept confidential. Unauthorized disclosure is prohibited. Employees must not possess or use others' passwords or authorization cards for various systems within the bank, nor perform related operations on behalf of others (including but not limited to logging into systems, accessing data, entering data, or using another person's authorization card for authorized transactions).
Avoiding Conflicts of Interest or Role Conflicts	When performing duties, employees should always remain vigilant to avoid any situations that could lead to actual or potential conflicts of interest or role conflicts. There should be no monetary transactions or interests between employees and customers/other employees.
Healthy Personal Financial Condition	Employees must maintain a sound and healthy personal financial condition with good financial management habits. They should prudently manage matters that could affect their financial status (including but not limited to borrowing, acting as a guarantor, investing, credit card usage and limits, gambling, etc.).
Considering Customer Interests	Before providing services, advice, or products to customers, assess their inancial capability and needs. Take into full consideration the customer's financial background and the complexity of the service or product offered when giving advice or selling financial products, always keeping the customer's interests in mind.
Providing Appropriate and Comprehensive Information	Clearly explain the main features of the product, the associated risks, and terms to customers, including fees, commissions, or charges. Provide customers with appropriate information before, during, and after sales.
Truthful Disclosure of Information	Provide customers with accurate and easy-to-understand promotional materials and messages while avoiding misleading statements or promotional tactics.
Provide comprehensive communication channels	Provide customers the reasonable channels to make a claim, lodge a complaint and seek compensation without unreasonable impediments to switching banks.
Consider the needs of different customers	Provide the public with reasonable means to access basic banking services, with special attention to the needs of disadvantaged groups.

Internal Reporting

Our bank accords great importance on integrity management and encourages all employees to report any internal fraudulent activities through well-established channels. To safeguard the rights of those who come forward, employees have the option to make reports anonymously. All complaint information will be kept strictly confidential and investigated impartially following a comprehensive internal complaint procedure. The bank commits to taking appropriate actions based on the investigation results and has implemented measures to deter any retaliation thereby ensuring that whistle-blowers do not have to worry about any damage to their interests after making reports. The aforementioned Banking Culture, Behavioral Standards and the Internal Reporting are equally applicable to BCOM Finance (Hong Kong) Limited. The above summarizes the existing Code of Conduct for Employees (the "Code"), which provides employees, both as individuals and as a group, with clear and simple guidelines on how to behave correctly and act properly as a member of Bank of Communications (Hong Kong) Limited. The English translation is for reference only. In case of any discrepancy between the English version and the Chinese translation, the Chinese version shall prevail.