BITEXCO

GROUP

BITEXCO CODE OF CONDUCT

 IMPORTANT
NOTICE
The CODE OF CONDUCT describes the standards of TRANSPARENCY
and INTEGRITY that BITEXCO Group pursues as well as expects from
its employees. As a diversified multi-industry corporation, rules and
policies of BITEXCO Group related to transparency and integrity in
each business and subsidiary need to be consistent. In any case,
leaders and staff of subsidiaries, affiliated companies, joint venture
companies and partners related to BITEXCO Group will always
comply strictly with the Vietnamese laws and this Code of Conduct.

1
 LETTER FROM
THE CHAIRMAN
Dear Bitexco Colleagues,

It is a privilege and honor to lead the Bitexco Group. This leadership comes with absolute
accountability to our shareholders, customers, partners and employees. I am proud of what we
have so far been able to accomplish together. My pride grows stronger each day as we continue
to learn and to build a common future that emphasizes achieving the highest human potentials.

As leader in critical business sectors - real estate, energy, oil/gas exploration, and infrastructure
development - underlying Vietnam’s economic growth, we are making significant contributions
in ensuring social stability, creating prosperous future and enhancing quality of life of the
Vietnamese people.

To deliver the above contributions, we must join hands and leverage our combined talents in
creating common core values and behavioral standards. Through unified Mission, aligned
Vision, and standardized Code of Conduct, we aim to become a highly respected conglomerate
applying best-in-class international standards. The Code of Conduct will in particular enable us
to live our values and to serve as a daily compass in our efforts to fulfill our Mission.

On behalf of the Bitexco Group, I call for unanimity and absolute compliance from each and
every member of Bitexco Staff to this Code of Conduct. I truly hope that this important
document will provide useful decision making guidance in how we should behave in our daily
life at Bitexco.

Vu Quang Hoi
Chairman

3
 BITEXCO VISION
Bitexco Group's goal is to be a leading international, multi-industry
corporation. We aim to be globally competitive by executing
world-class projects, thus making a significant contribution to the
economic development and future of Vietnam

4
BITEXCO MISSION
The Bitexco Group aspires to lead in the innovation of Vietnam's economy.
Therefore, contributing to Vietnam's economic development and improving the
quality of life for Vietnamese are central to our philosophy. We continually strive
to deliver world class standards on every project we undertake. We adhere to
the highest principles possible in the conduct of our business. We believe that
this path, while challenging, is the only way to generate long-term, sustainable
value and success for all of our shareholders, employees and partners.

6
 SIX BITEXCO VALUES
1. Striving for market leadership in all of the businesses we operate

2. Creativity and efficiency backed by determined actions

3. Achieving industry best practices while honoring traditional values

4. Accountability in all circumstances

5. Teamwork spirit and respect each other's differences

6. Humble about past achievements and resolute to build a brighter

future for our Group and for Vietnam

8

CODE OF CONDUCT
WHAT IS THE CODE?
BITEXCO's code of conduct is a set of
rules, principles and standards
outlining the guidelines for attitude,
thinking and proper practices for any
individual employee or groups of
employees at BITEXCO group
A code of conduct will help BITEXCO
members to align in our choices of
actions and to improve the harmony
as a group. The code helps all of us to
live with our values and follow our
priorities consistently to conquer the
long-term achievements.
WHO IS IT FOR?
BITEXCO's code of conduct is for every employee, director or officer in every
wholly-owned BITEXCO company and in every Joint Venture company,
affiliated company under BITEXCO control.
Contract staff, contractors or consultants who are our agents or working on
our behalf or in our name through outsourcing of services, processes or any
business activity, will be required to act consistently with the code when
acting on BITEXCO group's behalf.
Independent contractors or consultants will be made aware of the code as it
applies to BITEXCO's staff in their dealings with them.
Joint venture companies not under BITEXCO control are encouraged to
adopt similar principles and standards.
WHY DO WE NEED IT?
A code of conduct is intended to be a central guide and reference for BITEXCO's
members in support of day-to-day decision making. It is meant to clarify the
group's mission, values, methods and principles, linking them with standards of
professional conduct. As a reference, it can be used to locate relevant documents,
services and other resources related to ethics within the organization.
The code also serves as an important communication vehicle that reflects the cove-
nant that an organization has made to uphold its important values, such as its com-
mitment to employees, its standards for doing business and its relationship with
the community. A code is also a guide to deal with the ethical dilemmas, prejudices
and gray areas that are encountered in everyday work. Nevertheless, a code is not
meant to substitute for relevant standards, policies and rules, it just complements
them, and support BITEXCO and relevant organizations to create a positive public
identity, standardize processes and policies, and increase level of public confidence
and trust among important constituencies and stakeholders.
HOW DO WE USE IT?
The code provides guidelines for the organization
that are based on BITEXCO's core values as well as
important policies and legal obligations.
Ultimately, BITEXCO relies on every employee to
use good judgment in everything he or she
does.
The code is not a manual that contains all
detailed guidelines for every case in practice.
Each employee needs to evaluate and consider
carefully specific cases in practice to make the
right choices and decisions in everything he or
she does.
Beside the code, every employee also needs to
remember other values, policies and regulations
of BITEXCO to apply according to different cases
Please feel free to ask questions of our managers
or responsible governance office whenever in
doubt as to the appropriate course of conduct.

10 11
BITEXCO CODE OF CONDUCT
Table of content
RELATIONSHIPS WITH RELATIONSHIPS WITH THE CONFIDENTIALITY OUR RELATIONSHIPS RELATIONSHIPS WITH RAISING CONCERNS
COLLEAGUES AND CLIENTS: BITEXCO GROUP: TRUST AND PRIVACY WITH SOCIETY: FAMILY MEMBERS
CREATING A POSITIVE AND TRANSPARENCY BEING GOOD CITIZENS
WORKING ENVIRONMENT
Fair and respectful treatment Upholding Fiduciary Protecting Privacy and Personal Legal Obligations Fair and equal Raising concerns
Page 15 Responsibilities Confidentiality Page 38 treatment Page 45
Page 20 Page 34 Page 42
Appropriate Use of Power Community and Country Protecting confidentiality
Page 16 Personal Conflicts of Interest when conducting
Page 21 Information Security Commitment First employees, then
Page 35 Page 39 family members investigations
Discrimination Partial Conflicts of Interest Page 46
Page 43
Page 17 Page 25 Communication with Environment Commitment
mass media Page 40 Retaliation Protections
Work-Life Balance Superior-subordinate and Whistle-blower
Relationships and Page 36
Page 18 Protections
Supervisory Relationships Page 47
Page 26
Accuracy of Books and Tools and Resources
Records Page 48
Page 27
Contact Information for
Procurement integrity Guidance and Assistance
Page 28 in Handling Issues
Use of BITEXCO Assets Page 49
Page 29
Intellectual Property
Page 30
Preventing and Fighting
Fraud and Corruption
Page 31
Duty to Report
Page 32

12 13
 FAIR AND
RESPECTFUL TREATMENT
OVERVIEW ACTIONS
A fair and respectful working environment Ensuring fair treatment
implies that everyone is given equal chances
to work and develop within BITEXCO group Listen and pay attention to subtle cues

In other words, BITEXCO is built from within,
promoting and rewarding people without
regard to any difference unrelated to
performance. Such foundation is a basis to
attract and retain the finest people. BITEXCO
acts on the conviction that employees are
always the corporate most important asset
Upon this principle, innovation is encouraged
to flourish, creating more values to the group
and its stakeholders
Description - Definition
Fairness
Fairness is being impartial, just, or free
of favoritism. It means BITEXCO treats
everyone the same, regardless of
positions and/or ranking within the
group. The group follow the stated
rules and is honest and reasonable, thus
creating a fair working environment.
Guard against assumptions and biases regarding
differences between us, our colleagues, or
government officials
Be willing to give someone the benefit of the
doubt
Support colleagues facing health, family, or other
life challenges
Role of manager and supervisor
Ensure that staff at all grade levels can
express their views
Transparency in administrative decisions
affecting staff
Performance reviews to provide
constructive feedback
Apply rules and procedures

RELATIONSHIPS WITH COLLEAGUES AND CLIENTS:
CREATING A POSITIVE WORKING ENVIRONMENT
Respectfulness
BITEXCO believes that each employee
possesses unique values and capabilities
and all deserve equal respect from not
only the company itself but also from
each and every subsidiary companies
BITEXCO actively promote and develop
a working environment in which
respectfulness is one of its key elements

Fair and respectful treatment

Appropriate Use of Power
Discrimination
Work-Life Balance
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APPROPRIATE USE
OF POWER
OVERVIEW
In order to build BITEXCO to become a
world-class conglomerate in diversified
businesses, the managers are empowered to
make decisions on their own authorities
It is important that we must use given power
wisely and responsibly when performing our
work
Symptoms for abusing of power
Bullying or harassing behavior
Requesting staff to do personal favors
or errands
Pressuring a staff member to distort
facts or break rules
Interfering with the ability of a
colleague to work effectively (for
example, by impeding access to
information or resources)
Using company letterhead to draw
attention to a personal request
16
ACTIONS
What employees should do
In line with multi-industry and national-scale
characteristics of the group, staff often face
situations in which the appropriateness use of
authorized power might not be explicitly clear
For that reason, contact your manager or
related governance office is necessary for
further clarification on response action
What managers should do
Managers always need to make sure that they
fully understand the situations
Communicate with your subordinates in a clear
and transparent manner
If necessary, ask for help from senior managers
and/or related governance office
DISCRIMINATION
OVERVIEW
The Company will respect the human rights of
all employees and will not discriminate against
on the basis of race, color, creed, national origin,
gender, age, citizenship, religion, regional
background, physical disability, marital status,
or any other characteristics that protected by
law
The Company will determine conditions of
employment and compensation for personnel
in a fair and non-discriminatory manner, taking
into consideration relevant international
standards and national, local or state laws, with
the laws of host jurisdiction prevailing
The Company encourages everyone within its
power to bring questions or concerns in this
area to their management
Strict disciplinary action for violations of this
policy will be taken
Description - Definition
Discrimination is the unjustifiable
differentiation between individuals or
groups within staff
ACTIONS
Each individual at BITEXCO has responsibility in
preventing discrimination in our BITEXCO
working environment
Of managers and supervisors
Ensure the recruitment, selection, recognition,
and career development processes are fair
Encourage and support staff of all backgrounds
to fulfill their potential
Recognize staff for their contributions based on
ability and merit
Provide equal access to opportunities for career
growth and advancement
Promote diversity at all levels of the organization
Ensure that vendors, contractors, and consultants
are selected through a fair and inclusive process
Of staff
BITEXCO staff must understand and follow the
commitment and policy that we pursues and
believes in
Respect everyone you deal with and behave fairly
towards them according to BITEXCO's values of
fairness and respectfulness. Staff should under-
stand the value of the power that comes from
people of diverse backgrounds and experiences
and never discriminate
Management should base hiring, evaluation,
promotion, training, development, discipline,
compensation and termination decisions on
qualifications, merit, performance and business
considerations only
Be aware of other company's rules and cultural
factors that may impact decisions
17
WORK-LIFE BALANCE
OVERVIEW
Work-life balance will help every member of
BITEXCO to have the harmony between
physical health and mental health, a well-being
life, thus we can work and dedicate effectively
to the development of BITEXCO group.
BITEXCO encourages staff to maintain work-life
balance to contribute persistently to the group.
Simultaneously, the group has practical actions
to take care of its members' physical and
mental health.
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ACTIONS
Encourage a culture of “working smart,
not long"
Promote the messages about work-life
balance to individuals in the workplace
Give better training to managers so that they
can spot stress, poor work-life balance and its
effects on the individuals.
Encourage activities that promote good
mental health, for example lunchtime
exercise or relaxation classes
Examples of actions to support
work-life balance
For staff
Planning ahead before leaving on
mission to minimize demands on local
business staff
Understand that local staff members have
other demands and need to maintain the
balance
Maintain a reasonable work schedule
Do not make requests for personal
assistance
For managers and supervisors
Create a number of supporting programs,
resources, and policies
Work stress counseling
Family network
RELATIONSHIPS WITH THE BITEXCO GROUP:
Health care program TRUST AND TRANSPARENCY
Flexible remote work program (time, Upholding Fiduciary Responsibilities
location..) Personal Conflicts of Interest
Partial Conflicts of Interest
Encourage sports and fitness at the Superior-subordinate Relationships and Supervisory Relationships
company Accuracy of Books and Records
Procurement integrity
Use of BITEXCO Assets
Intellectual Property
Preventing and Fighting Fraud and Corruption
Duty to Report
UPHOLDING FIDUCIARY
RESPONSIBILITIES
OVERVIEW
The very core of every BITEXCO member's
heart is the core values and fiduciary
responsibilities, truth, righteousness to every
shareholder, client, partner and stakeholder.
Every member of BITEXCO in every position
has fiduciary responsibilities for whatever
actions they take
20
ACTIONS
BITEXCO members are requested to comply
strictly with internal rules and regulations related
to fiduciary responsibilities.
When we face any confusion or unclear issues, it
is our responsibility to raise question to our line
managers or Governance Office to seek further
support and guidance.
BITEXCO expects its members to behave in
accordance with standard values that go beyond
company rules and regulations. All of our actions
and decisions must be guided by BITEXCO's
values.
BITEXCO will take all actions to nurture and
preserve the fiduciary value for its long-term
sustainable development.
Any violations or non-compliance actions will
not be permitted in BITEXCO work environment.
PERSONAL CONFLICTS
OF INTEREST
OVERVIEW
Personal conflicts of interest can adversely
impact BITEXCO's activities and reflect poorly
on the institution.
Even potential or perceived conflicts of interest
can undermine stakeholder relationships and
damage BITEXCO's reputation.
Definition - Description
Conflicts of interest may arise when a staff
member has competing professional
and/or personal interests. That competion
can make it difficult to fulfill his or her
duties objectively and impartially
ACTIONS
BITEXCO's staff are entrusted with placing the
interests of the entire company ahead of
personal, intra or inter-organizational.
Complying strictly to this principle is the
essential key to develop BITEXCO sustainably.
Having a conflict of interest does not necessarily
mean a staff member has done something
wrong. However, promptly disclosing and
dealing with the conflict is critical to avoiding
potentially serious consequences.
We need to consider carefully feelings and
assessment of partners and public opinion of
BITEXCO's reputation when making decisions
that are sensitive and contain potential conflicts
of interest.
21
PERSONAL CONFLICTS OF INTEREST
Gifts/benefits/favors
OVERVIEW
Gifts, benefits and favors
Gift giving is an accepted way of showing
appreciation.
But giving or accepting a gift may create the
expectation of a favor in return. BITEXCO staff
must, as a general rule, avoid giving/accepting
any gifts, favors, benefits, or gratuities in
connection with their official duties.
Gifts may never be solicited.
22
ACTIONS
Gifts, benefits and favors
In no case may cash or securities be given or
accepted
Giving or accepting gifts of more than nominal
value should be approved in advance by your
supervisor.
It is forbidden to give or accept a gift where it
would be unlawful to do so or if it would
knowingly violate the policy of the other party's
employer.
If there is any doubt about the appropriateness
of accepting a gift, favor, or benefit, staff should
consult their manager.
Refer to the "Evaluating personal conflicts of
interest tools" section.
Gifts/benefits/favors, relatives
and financial interest
OVERVIEW
Relatives
The potential perception of favoritism or
improper influence exists when relatives are
employed whether as staff or through vendors,
restrictions apply.
A conflict of interest exists when an employee
or a family member is in a position to benefit
personally, directly or indirectly, from his or her
relationship with a pers on or entity conducting
business with BITEXCO.
BITEXCO is committed to maintaining
stakeholder relationships based on fairness,
impartiality, and a transparent competitive
process
Personal honesty and integrity are important
BITEXCO core values
Financial interests
It is imperative that our personal financial
circumstances be beyond reproach. All staff
must therefore resolve any conflicts of interest
that arise from their personal financial interests
or business relationships.
ACTIONS
Relatives
BITEXCO staff cannot use their positions to
promote the relatives' interests and harming
the group's general interest.
Directing a grant, business oppotunity or
confidential information, that could be
beneficial to BITEXCO, to a third party with
which the employee (or his/her family
member) has a financial relationship.
Reviewing, approving or controlling a
contractual or business relationship between
BITEXCO and a business with which the
employee or a family member has a financial
relationship.
Hiring, managing, reviewing or appraising a
relative or friend whose competencies do not
meet the job requirements.
Financial interests
Establishing and ensuring the compliance with
rules and policies which are specifically
defined regarding how to deal with the
personal conflicts of interest-financial related
issues, subject to different situations and
environments.
The conflicts must be disclosed to both related
governance offices and the next-inline senior
manager. In consultation, a resolution will be
worked out (eg. as simple as sending an e-mail
to document the nature of the possible
conflict), or could require particular actions
(such as divesting certain stock).
Refer to the "Evaluating personal conflicts of
interest" section for further clarification.
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Tool: PARTIAL CONFLICTS
Evaluating personal conflicts of interest OF INTEREST
ACTIONS OVERVIEW ACTIONS
Evaluating personal conflicts of interest BITEXCO performs multiple roles, with All business decisions must be made and all
numbers of affiliate, associate, subsidiary business activities must be conducted, aligned
companies and business units under the with the best interests of BITEXCO as a group.
Does a gift, proposed activity, or relationship group's management. Therefore, situations in
which conflicts of interest occur between Subsidiaries and affiliated companies should
subsidiaries due to opposite in business avoid any action which may involve, or may
Affect BITEXCO activities or stakeholders? objectives and directions. appear to involve, a conflict of interest with the
Affect BITEXCO relations with the public, or with other stakeholder groups? group.
Consequences of this type if conflict may lead
Create an impression of BITEXCO group or staff bias or partiality? All entities in which BITEXCO has a non-con-
to waste of resources as wel as unhealthy
Overlap with my BITEXCO role or responsibilities? competition within the group. trolling interest, including affiliates (franchisees)
and alliance partners with whom BITEXCO has a
Utilize or result in the disclosure of BITEXCO non-public information?
strategic relationship, are strongly encouraged
Involve others who do-or intend to do-business with BITEXCO? to follow policies in this Code of Conduct.
Involve remuneration?
Any employee or Director who becomes aware
Involve a for-profit concern? of a conflict or potential conflict should bring it
Adversely reflect on BITEXCO's reputation or compromise its operations in anyway? to the attention or a supervisor, manager and
related governance office

If the answer to any of these questions is "yes", refrain from the activity or from accepting the The group's business units are
gift/benefit entrusted with placing the interests of
the entire company ahead of personal,
If the situation is unclear, seek guidance from a senior manager or related governance office
and intra-organizational

24 25
SUPERIOR-SUBORDINATE RELATIONSHIPS
AND SUPERVISORY RELATIONSHIPS
OVERVIEW
Superior-subordinate relationships and
supervisory relationships are important lifelines
that ensure the combined power and engage-
ment of BITEXCO.
Supervisors and managers have responsibilities
to treat their staff in a fair and objective way
without any preconception or partiality.
26
ACTIONS
A healthy supervisory relationship is built on
trust and empathy. It is where managers and
subordinate can openly share views and get
feedbacks to produce the results in the efficient
ways.
Supervisors have responsibility to instruct his or
her subordinates to deliver the expected results
and to develop the career ladder at BITEXCO
group. Subordinates have responsibility to
follow the instruction and take advice from
supervisors.
Responsibility of more senior managers
It is the responsibility of the more senior person
to promptly resolve the conflict of interest by
bringing it to the attention of the next-in-line
senior manager and HR professional by taking
appropriate action.
ACCURACY OF BOOKS
AND RECORDS
OVERVIEW
All accounting books, time recordings, and
other records... of BITEXCO are important asset
that need to meet requirements of laws and
BITEXCO's standards.
Books, diaries, records, and documents must
truthfully and accurately convey BITEXCO's
information.
ACTIONS
BITEXCO commits to maintain transparency
of accounts with accurate recording of
transactions
BITEXCO will accurately record and manage
all transactions in compliance with interna-
tional standards and national accounting
regulations, and will be subjected to
accounting audits by outside parties at
regular intervals.
BITEXCO will make every effort to refrain
from entering into a business relationship
with customers of uncertain identity, and will
not participate nor cooperate with illegal,
false, or irregular transactions
To maintain BITEXCO's valuable reputation,
compliance with our requirements and all
other laws and regulations is essential.
27
PROCUREMENT INTEGRITY
OVERVIEW
BITEXCO upholds its high standard of
ethical and ensure a competitive, fair, and
transparent procurement process both in
its own procurement and in BITEXCO
supported projects
Decisions in purchasing at BITEXCO should be
guided by financial integrity and cost
effectiveness aligned with the group
long-term interests
The procurement policies and controls are
being conducted strictly to protect our
institution against fraudulent and corrupt
practices
BITEXCO will continuously and consistently do
its best efforts to insert control and to insure
the integrity of procurement at BITEXCO
28
ACTIONS
Every individual at BITEXCO make decision and
participate in procurement process with highest
ethical standard and protect the integrity principle
at BITEXCO.
For high-value procurement, the bidding process
with various participants' involvement should be
strictly applied.
When facing any potential conflicts of interest,
BITEXCO member must actively report potential
conflicts to line manager.
Any violations to rules and policies in procurement
should be investigated carefully
Corruption or misbehavior will be punished strictly
USE OF BITEXCO ASSETS
OVERVIEW
In order to develop and compete with
international corporations, BITEXCO will
continuously accumulate, expand, develop and
enrich our properties everywhere we operate.
BITEXCO staff are entrusted with a special
responsibility to protect the group's assets. We
need to use them with appropriate care.
Definition
Asset to be mentioned here is a broad
term, including tangible and intangible
asset, information source and business
advantage that BITEXCO possesses
ACTIONS
BITEXCO's assets are used only for the group's
business purposes.
Avoid loss, waste or damage unnecessarily.
Stealing the group's assets, acting out of self-interest
are not allowed.
Employees should endeavor to protect the Company's
assets and ensure their efficient use. Any suspected
incident of fraud or theft should be immediately
reported to superior for investigation.
Examples of misuse of BITEXCO assets
Using BITEXCO staff, services, supplies,
equipment or facilities for private gain or
for personal purposes, or allowing others
to do so
Using BITEXCO time and resources
(telephone system, email...) for personal
use.
Using the diplomatic pouch to send
prohibited items, such as weapons,
sexually explicit materials, or illegal
goods.
Using BITEXCO information systems to
send, view, or download pornographic,
offensive, or illegal material.
29

INTELLECTUAL PROPERTY
OVERVIEW
To develop BITEXCO become an international
corporation, we need to create valued and
unique intellectual property, initiatives and
improvements with specific characters.
For that reason, being aware of and acting in
compliance with intellectual property is a very
important task with strategic significance.
* Most BITEXCO staffs are both users and
producers of intellectual property.
* When we produce new works as part of our
work in the BITEXCO, the intellectual property
right belongs to the institution.
30
ACTIONS
Ensure that internal intellectual property and
confidential information will not be disclosed
to external parties by its employees without its
prior permission and consent.
Ensure that any proprietary information
acquired through its business activities shall be
recorded and safely kept and managed as
intellectual property.
Respect the intellectual property rights of third
parties, such as patents, copyrights and
trademarks. We shall not intentionally infringe
or improperly use such intellectual property.
Ensure that due attention is paid to the security
of intellectual property during the course of
telephone, data storage or other communica-
tion with external parties.
FIGHTING FRAUD
AND CORRUPTION
OVERVIEW ACTIONS
BITEXCO is committed to demonstrate high Fair dealing with customers and suppliers.
integrity in all stakeholder relationships. It
commits to create a corruption-free environment, Commercial bribery: Any personal payments
which provides utmost transparency in every or bribes to individuals employed by BITEXCO's
relationship. customers or suppliers, or receipt of bribes or
personal payments by employees is not
Management/supervisor may be responsible for permitted.
addressing issues in their respective areas.
Violators will be mandated to terminate contract
or refer to appropriate legal authorities.
31
DUTY TO REPORT CORRUPTION CONFIDENTIALITY AND PRIVACY
AND VIOLATION Protecting Privacy and Confidentiality
Information Security
OVERVIEW ACTIONS Communication with mass media
All staff have a duty to report concerns relating Staff are encouraged to raise concerns about
to significant fraud or misconduct that he or suspected misconduct to a direct manager or
she finds out or suspects. even more senior ones depending on the issue,
and must cooperate with an investigation.

Managers must promptly report allegations or

suspicions of misconduct to the appropriate
BITEXCO office and also must cooperate with an
investigation.

Staff members should not investigate alleged

misconduct such as fraud or corruption
themselves. It may be dangerous and could
compromise an ongoing or future investigation.

Examples

Report on any activities which violate

the BITEXCO code of conduct against
fraud and corruption activities, which
ultimately include the following

Commercial bribery

Accepting or giving anything of material

value without reporting to supervisor
and/or related governance office

Dishonest activities which act in

contrast to BITEXCO's interests

An employee and/or manager and/or

director abuse his/her position of trust in
order to achieve personal gains

The deliberate falsification, concealment,

destruction or improper use of documen-
tation used for a normal business
purpose or the improper use of other
information or position.

32
PROTECTING PRIVACY
AND CONFIDENTIALITY
OVERVIEW
BITEXCO operates in many areas and has access
to many different sources of personal and private
information inside and outside the Group.
In order to achieve sustainable development and
avoid unexpected incidents, we are obliged to
protect personal information, privacy and
confidentialities entrusted to us.
Example of privacy & confidentiality
Documents containing sensitive country
data
Terms of reference and proposals from
contractors and vendors
Records related to BITEXCO – related
investigation
Medical records of staff members
Personnel and benefits files of staff
members
34
ACTIONS
Develop protocols to ensure information is
kept secure and protected from inappropriate
access, unauthorized use, or disclosure.
Develop and strictly implement the policy of
confidentiality for internal information and
stakeholders.
Examine the information security of partners,
contractors and third parties in the access to
and confidentiality of BITEXCO's information.
Respect the privacy and personal information
of BITEXCO's staff members.
Every staff needs to be careful in communicat-
ing and handling personal information in
order to avoid inadvertent disclosure of
information.
Actions to protect privacy and
confidentiality
Protect the confidential and proprietary
information we use in our work
Demonstrate good judgment with
e-mail and other media
Respect the privacy of coworkers by
avoiding gossip
Respect the personal property of
coworkers
Treat documents of BITEXCO Group and
others carefully to protect their
confidentiality, within and outside the
office
INFORMATION SECURITY
OVERVIEW
BITEXCO operates in many important areas of
the economy with high complexity and
knowledge content which requires the ability
to collect, process and retain information in a
professional and effective manner.
Protecting the confidentiality of information
and intellectual assets of BITEXCO is an
important task which dectermines the failure
or success and the sustainable development
of the whole group.
ACTIONS
Need to categorize information and develop
information storage & confidentiality mechanism
with appropriate levels of confidentiality
Only share information in accordance with
information confidentiality rules. When in doubt,
consult competent superiors.
Obey information confidentiality rules even if
you no longer work at BITEXCO
Respect the BITEXCO's password policy and
never share passwords to others.
Follow procedures of disclosing confidential
information to any third party
BITEXCO will not permit any activity that utilizes
proprietary information of BITEXCO for private
gain, for example insider trading, irrespective of
whether or not this activity was conducted
directly by an employee or via third parties
Guidelines on Retaining Records
Employees must comply with the
guidelines in the BITEXCO records
management plan in their retention and
disposal of BITEXCO documents. The plan
applies to information in any media,
including both hard copy and electronic
records such as email...
Information defined as "essential" be
retained in a recoverable format for the
duration of its assigned retention period.
Information that is not essential or whose
retention period has expired should be
disposed of as soon as possible, unless it
is subject to a document retention order
issued by authorized bodies.
Where such an order exists, you must
strictly follow the retention requirements
specified in the order until you receive a
notice from BITEXCO authorized bodies
that the order is no longer in force
35
COMMUNICATION
WITH MASS MEDIA
OVERVIEW
Being a big and prestigious group operating in
many areas and localities, BITEXCO pays special
attention to building and protecting its image
in the eyes of mass media.
Each staff member of BITEXCO must always
respect, maintain and contribute to the good
image of BITEXCO in the eyes of the public. At
the same time, each individual needs to strictly
comply with the rules of communication with
mass media.
36
ACTIONS
Appoint spoke-person to deliver official informa-
tion to media / press and public community ...on
behalf of BITEXCO …
Organize the Corporate Communications depart-
ment to manage the relationship and working with
media / press and public community
Staffs and managers are not allowed to speak and
communicate on behalf of BITEXCO to media /
press and public community without the written
permission from BITEXCO
Refer all media calls to Corporate Communications.
Do not call a reporter directly without first
consulting Corporate Communications.
Corporate Communications will work with you to
gather information and determine if and how the
news media should be contacted. Similar measures
used by editors and reporters will be considered to
determine if your story is newsworthy.
OUR RELATIONSHIPS WITH SOCIETY:
BEING GOOD CITIZENS
Personal Legal Obligations
Community and Country Commitment
Environment Commitment
PERSONAL LEGAL
OBLIGATIONS
OVERVIEW
A staff's failure to act in accordance with the
legal system can indirectly compromise the
interests and image of the Group in the
community and among other stakeholder
groups.
If BITEXCO is notified of a staff member's failure
to meet these obligations, it may intervene
according to applicable rules and policies.
Examples of staff personal legal
obligations
Making payments of child support or
alimony
Paying court-ordered fees
Paying income taxes where required or
repaying personal loans
Complying with local laws, including
immigration laws
38
ACTIONS
BITEXCO staff must be responsible for their own
actions and behaviours not only in working
sites but also in other environments in life.
Staff should be aware that their behaviour at
home or at other environments also affects the
overall image of BITEXCO. Therefore, the Group
also assesses its staff through their behaviour at
other related environments.
All the staff must respect and strictly comply
with personal legal obligations.
Each staff must take every effort within their
capability to ensure and encourage members of
their household to respect their personal legal
obligations.
COMMUNITY
AND COUNTRY COMMITMENT
OVERVIEW
BITEXCO has been and will always be a
responsible citizen in the communities and
countries where we operate and have offices.
BITEXCO considers itself as a part of the
communities where it operates. Contributing
to the development of communities with
innovative and effective methods is the
mission that BITEXCO takes and proudly
pursues in the long term.
ACTIONS
BITEXCO always respects the laws, culture,
values and beliefs of the local communities in
which it operates, and shall contribute to the
improvement of the quality of life of local
residents
The Company, as a corporate citizen, will
contribute to promote and support
public-interest activities such as academic
advancement, art, culture and sports
We will satisfy these commitment through
cooperating with different partners in the
society and community.
We take initiative in creating or participating
in initiatives that bind us to the community,
supporting and sharing with those less
fortunate
BITEXCO encourages involvement of
individual staff in the communities where we
live and work.
39
ENVIRONMENTAL COMMITMENT
OVERVIEW
BITEXCO operates its business activities with
environment friendly manner and towards a
sustainable development.
BITEXCO promotes environmentally sound
and sustainable economic development as a
fundamental element of the company's
management system
40
RELATIONSHIPS WITH FAMILY MEMBERS
Fair and equal treatment
First employees, then family members
ACTIONS
Make every effort to comply with environmental
requirements, national laws and regulations relating
to the environment and internal environmental
regulations within all of its business operations
Actively attempt to minimize the generation of
harmful materials, utilize resources efficiently and
recycle waste products for the benefit of the
environment
Carefully consider and monitor the impact of
projects on local environmental conservation and
protection
Raise questions and concerns regarding conditions
that might be harmful to human health, safety, and
the environment
Are receptive to environmental concerns raised by
partners, governments, and other stakeholders
Model good environmental behavior
FAIR AND EQUAL TREATMENT PRINCIPLE
AMONG FAMILY AND NON-FAMILY MEMBERS
AT BITEXCO
OVERVIEW
BITEXCO commits as its highest efforts to create
a environment of fair treatment and equal
opportunities for everybody—both family and
non-family member—to work and develop
long-term career at the BITEXCO Group and all
its subsidiary and related companies
BITEXCO understands that fair and equal
treatments to every member is the best way to
create sustainable value for its owners and
stakeholders
By treating employees as equal as family
members, BITEXCO can strengthen the
solidarity of the group and the commitment of
its employees
42
ACTIONS
Policy for family members
BITEXCO welcomes all qualified members
(including family members) to contribute to the
enduring growth of the businesses at BITEXCO.
Family members are encouraged to participate
in developing BITEXCO as far as their capabilities
permits
Once a family member becomes an employee,
he/she will be treated as any other non-family
employee
Family employees will be trained, supervised,
evaluated, and promoted the same way as all
other employees
There will be no authority higher than other
employee for family member role
Family member have to follow all of the policies
and direct orders of their line managers just as
every member at BITEXCO
Recruitment and selection
Family members will go through the standard
interviewing, assessment and selection process
The final decision for hiring, or rejecting a family
candidate rests with the HR department and
group leaders
Compensation
Family members will receive compensation
and benefits based on being employees, and
not on the shares they own
Compensation and benefits of family employees
will be based on their position, responsibilities,
qualifications and performance
Will be comparable to that of non-family
employees in the same position and with similar
qualifications
FIRST EMPLOYEE
THEN FAMILY MEMBER
ACTIONS
First employee …
Family members working at BITEXCO have all the obligations and responsibilities the
same as all members in the Group
Behave professionally as an employee in a organization not owned by family
Comply with all requirements of BITEXCO as an employee
Follow the professional communication rules and reporting routes defined by BITEXCO
Align with the interests of BITEXCO and all other members at BITEXCO
… then family member
Family members should have further responsibilities and obligations to the family and to BITEXCO
Behave in the highest ethical manner and set good example as an employee at BITEXCO
Build and protect the reputation of the family in BITEXCO
Remind other members in family to comply with BITEXCO rules and with family constitution and family
internal rule
Support other members at BITEXCO to realize the vision and mission of the BITEXCO Group
How should you treat family members?
Working with and treating family members as every members at BITEXCO with sincerity�and
professionalism
Make friend with family members if you'd like
You should not stay at a distance
Nor try to be more friendly than you want to be
Family members are just as other colleagues at BITEXCO
Give them appropriate and fair orders the same way as others
Challenge them and protect your ideas as you are doing with other colleagues
How family members should treat others?
Respect and treat all members at BITEXCO in a sincere and professional way—no matter they
are family member or not
Making best efforts to perform the roles and responsibilities of the position just as every
other employee at BITEXCO
Listen and follow directions of line managers and other leaders
Perform the best at work to be recognized and promoted
Follow the code of conduct and lines of reports designed by BITEXCO
No short-cuts or "priority lanes" in reporting
43
 RAISING CONCERNS
OVERVIEW
Violation or actions inconsistent with standards
can exist in any organization. A healthy
organization is the one that can detect those
kinds of action early to prevent and correct
them and complete the compliance of the
organization.
BITEXCO encourages everyoone to report
violation or inappropriate actions which can
have a negative impact on the organization.
Raising concerns is respected, recognized and
protected by BITEXCO's policy.
We consider raising concerns as a goodwill
warning which helps us prevent or correct the
violation. Whoever stops and retaliates against
the whistleblower will be strictly punished.
RAISING CONCERNS
Raising concerns
Protecting confidentiality when conducting investigations
Retaliation Protections and Whistle-blower Protections
Tools and Resources
Contact Information for Guidance and Assistance in Handling Issues
ACTIONS
Responsibilities and Obligations of Employees
to raise concerns
Employees are responsible to promptly report
any (potential) misconduct activities to their
supervisor, manager, or related governance
office due to the following vital rationales
Allows the company to resolve problems
Fulfills a shared responsibility to stakeholders
Helps to improve operations
Fosters a more productive work culture
Bolsters open communications within the
company
Contributes to a safer work environment
BITEXCO commit to ensure the best policies to
protect for raising concerns
Confidentiality protections when conducting the
investigation, undisclosed information must
include the identification of a whistleblower, and
perhaps the identification of the potential
misconduct person
Retaliation prevention
Whistleblower protection
Provides explicit guidelines regarding the
reporting and investigating procedures, as well as
tools for evaluating the (potential) misconduct
situation
45
CONFIDENTIALITY PROTECTIONS IN
THE CONDUCT OF AN INVESTIGATION
OVERVIEW
Confidentiality protection in raising concerns
and in the conduct of an investigation is a very
important task to ensure the objectivity,
honesty and accuracy of the investigation.
Confidentiality also helps us prevent undesired
negative effect arising from rumor and gossips,
which affects the morale and atmosphere at
work.
BITEXCO develops standard procedures and
regulations for confidentiality and investigation.
All the staff must strictly comply with these
procedures and regulations.
46
ACTIONS
BITEXCO (business units) involved in an
investigation develops, maintains, and
communicates their confidentiality standards
to staff.
The substance of an inquiry and/or the identity
of staff members are only disclosed on a strict
need-to-know basis. This is determined based
on the facts needed to conduct a thorough
investigation, respond appropriately, and
resolve the situation.
Staff also have the option of raising concerns
or allegations anonymously, although this can
impede the ability of the BITEXCO to follow up
and take action on a concern
Additionally, staff may contact BITEXCO related
governance offices. They cannot disclose any
information without authorization from the
staff member unless there is a risk of imminent
harm
Requirements for disclosure
Employees and Directors must maintain
the confidentiality of the investigation
information entrusted to them by the
authorized offices.
The confidential information related to
the conduct of an investigation is only
disclosed to related and authorized
parties
RETALIATION PROTECTIONS
AND WHISTLEBLOWER PROTECTION
OVERVIEW
We consider raising concerns as a goodwill
warning which helps us prevent or correct the
violation. Whoever stops and retaliates against
the whistleblower will be strictly punished.
Description and example of retaliation
Retaliation is any direct or indirect
detrimental action recommended,
threatened, or taken against (a)
whistleblower(s)
Retaliation in the workplace encompass-
es a range of behavior, from something
as small as a remark to something as
serious as an administrative action
affecting a staff member's work program
Other examples include: Reprimand,
discharge, suspension, demotion, denial
of promotion, and denial of transfer
ACTIONS
Staff members play a critical role in raising
issues and concerns, which helps BITEXCO
better identify, address, and ultimately deter
misconduct
Any staff member who in good faith raises a
concern is protected from retaliation.
BITEXCO has adopted whistleblower
protections to ensure that it provides a safe
environment for reporting and addressing
suspected misconduct
Consult the applicable policies for detailed
information on the retaliation protections
afforded to staff by BITEXCO
Protection policy
BITEXCO has adopted whistleblower
protections to ensure that it provides a
safe environment for reporting and
addressing suspected misconduct
No employee or other person shall be
retaliated against for the good faith
reporting of any violation of this code of
conduct
No employee shall be discharged,
demoted, suspended, threatened,
harassed, or otherwise discriminated
against for providing truthful informa-
tion to his or her manager, BITEXCO's
related governance office, law enforce-
ment agents, or any authorized
legislative or judicial body, or for
assisting in the investigation of conduct
that the employee reasonably believes
constitutes violations of BITEXCO's
policy as well as the laws
47
 OBLIGATIONS TO OBSERVE
TOOLS AND RESOURCES CODE OF CONDUCT
Resources for staff
When staff members face a business conduct issue, the first step is to clearly think through the situation. Obligations of employees
Evaluating a situation does not mean conducting an investigation. Rather, it is a process for identifying
potential issues and knowing when it is appropriate to take action The company shall apply this code of conduct to all of its employees and subsidiaries, and, where
The LEAD steps—learn, evaluate, act, develop a plan—provide a useful framework for determining when relevant and appropriate, shall also recommend specific clause(s) of the code of conduct to affiliates
and how to take action and external business partners

Employees will make every effort to faithfully abide by the code of conduct, and in the case of violation
will be subject to appropriate disciplinary action

A decision making tool Officers and managers will be responsible for cultivating and maintaining a sound organizational
culture by acting as role models in the observance and propagation of the code of conduct
Learn the facts
Who, what , where, when, how?
Do you have all the information you need? (if you suspect misconduct, do not fact-find or Enquiries and improvement of the code of conduct
investigate)
What factors or influences are at play? Any breaches of the global code of conduct should be reported to the head of the employee's
department or respective director, Human Resources Team or Auditing Team

Evaluate the issue Any questions or suggestions for improvement on the global code of conduct should be referred to
What is the business conduct concern? Corporate Governance Office or Human Resources Department.
Who among BITEXCO resources should I consult?
What do the Code, Principles, relevant guidelines, and Staff Rules say?
Which stakeholder(s) could be affected by this?
How might the issue affect the BITEXCO's reputation?
What is my responsibility? Should anyone else be involved?
How would a reasonable person view the situation?

Act appropriately
Should I take action of refer the matter?
What action(s) can help to reach a resolution?
Should any immediate steps be taken?
Does the proposed action(s) uphold BITEXCO values?
Am I unsure of the appropriate course of action(s)?

Develop a plan for follow up

How can I communicate effectively about the issue?
How can I prevent the problem from arising in the future?

48 49
 CONTACT INFORMATION FOR GUIDANCE
AND ASSISTANCE IN HANDLING ISSUES
BITEXCO governance office

Address: __________________________________

Contacts: __________________________________

Email: __________________________________

Hotline: __________________________________

CONFIRMATION OF COMMITMENT
I acknowledge receipt of the BITEXCO Code of Conduct.
I further acknowledge that I have read and wish to show my commitment to the Code of Conduct.

Signature of employee

Name

Date

50