I. OUR CODE OF CONDUCT APPLY TO ALL

Our Code of Conduct apply to everyone working at BeyonCa or any of our subsidiaries. It is applicable to all contractors, freelancers or any person working on our premises.

Further, these principles inspire our policies with regard to external stakeholders, suppliers and subcontractors. We see ourselves as a facilitator of change, and encourage improvement or adoption of these standards throughout our day-to-day work.

We understand that our principles cannot cover every case or practical situation. We trust our employees to use their judgement to determine the best course of action, always with respect to our ethics and at all times the local laws and regulations.

WE ARE IN IT TOGETHER/ A SHARED RESPONSIBILITY

Ethics and compliance are team efforts. While we are all independent custodians of the Code of Conduct, there will be times when we encounter grey areas, need a more nuanced understanding or seek ethical guidance. In such cases, our Legal & Compliance Team are available for discussions and advice, and are making sure no one feels unsupported in their decision-making or implementation.

2.INTERNAL EMPLOYEES/ EXTERNAL STAKEHOLDERS TIP-OFF EMAIL ADDRESS

Compliance@beyonca.com When an alert is raised to this email box, it will be subject to a thorough investigation with confidentiality and protection of the whistle-blower. Findings of such investigations are then submitted to the relevant governing committee for appropriate actions.

II. ETHICAL BUSINESS CONDUCT

1.FAIR COMPETITION, OPEN ECONOMY

Fair competitions matter. It is vital for markets to grow and develop freely. We share a common interest with our competitors, customers and suppliers to build a reputable sector through business practices that strengthen collective trust and cultivate long-term viability. We refuse to engage in any anti-competitive activities, and we comply with the relevant laws in the markets where we operate.
WE DO：
• Set our commercial policy and prices independently from competitors
• Act promptly when we receive commercially sensitive information from competitors; In such cases, we report incidents to our management team or our legal & compliance department as soon as possible

WE DO：
• Agree to be confined to one territory or a group of customers
• Accept or apply a price or discount to our customers in agreement with competitors
• Conduct intentional communications using vague language that could be misleading from a competition-law standpoint

2.ANTI-CORRUPTION, ANTI-BRIBERY, ANTI-MONEY LAUNDERING, GIFTS AND HOSPITALITY

Corruption and bribery are prohibited by the law, and unacceptable at BeyonCa. Let us ensure that our activities are always above the board. We uphold a zero-tolerance policy for corruption. This means strictly no unauthorized or hidden payments, kickbacks or facilitation payments (such as those payments made under the pretext of securing or expediting legal or government action). Adherence to our Anti-Corruption Code of Conduct is non-negotiable. In addition, we do not tolerate any actions that can be viewed as money laundering or avoidance of transparent payment flows.

We practice disciplined conduct with gifts and hospitality. We acknowledge that gifts and invitations can help build understanding and business relationships, however it must never be aimed at granting or obtaining an undue advantage, or influencing a decision. Hospitality and gifting must always comply with the necessary criteria of clear business objective, transparency, and reporting, and with a reasonable value. These criteria are detailed in our Gifts and Hospitality Policy.

WE DON’T：
• Highlight our zero-tolerance for corruption and money laundering, both internally and when dealing with third parties
• Comply with our Anti-Corruption Code of Conduct and our Gifts and Hospitality Policy, and report any behavior that may infringe them
• Make sure that all gifts, invitations, sponsorship activities and hospitality packages offered or received are appropriate, lawful and in line with our policies
• Follow all accounting, documentation archiving and financial reporting requirements applicable to payments

WE DO：
• Grant illegitimate benefits to any third party to expedite processes or gain favor
• Request or receive illegitimate benefits from any third party
• Pay for our customer or partners’ trips without a complete review by our legal & compliance department
• Accept or give any gifts in cash

3.INTEGRITY OF BUSINESS AGENTS AND THIRD PARTIES WE CONTRACT WITH

While we are all aware that the use of third parties in our business projects may be necessary, let us also remember that using third parties can prove to be very risky, especially with regards to corruption and unethical practices. Remember, we can be held accountable for the actions of our third parties.

WE DON’T：
• Avoid the use of business agents whenever possible
• If business agents are used, we adhere to our Business Agent Policy and report all third parties in the scope of our contracts clearly, and define their involvement
• Conduct due diligence on third parties in compliance with our internal processes and have them approved by the relevant managers
• Ensure that third parties adhere to the contract without conflict of interest
• Collect and maintain activity reports to rationalize the price paid versus services provided
• Record payments made to business agents and other parties, with accurate and auditable amounts

WE DO：
• Engage in a business relationship with a business agent who has not been subject to the prior approval
• Engage in a relationship with a third party who doesn’t produce evidence to support the scope of work
• Pay a third party without following the payment terms defined in a contract, without the existence of an invoice or without the prior approval from relevant managers
• Conceal payments made to agents or third parties, or record ambiguous and unclear descriptions of such payments

4.TRADE REGULATIONS AND SANCTIONS

Our business is global and involves many markets. BeyonCa, and all our employees, aim to comply with applicable trade sanctions and export control laws and regulations, in each market where we conduct business.

WE DON’T：
• Commit to develop business in respect of trade regulations
• Comply with our Global Export Control Policy and Directive, and any potential non-conformity observation
• Implement and enforce due diligence controls in line with our policies systematically
• Follow reporting and recordkeeping requirements in compliance with the applicable laws and guidelines

WE DO：
• Circumvent any applicable laws and regulations related to our export licensing requirements
• Conduct business activities without prior due diligence and clearance

5.CONFLICT OF INTEREST

Conflicts of interest may arise when our personal interest interferes with our duties at BeyonCa. These situations may unconsciously influence even the most ethical person’s judgment, and often just an appearance of a conflict may cause their integrity to be questioned. We must be cognizant of any potential conflicts of interest, and avoid them at all times. Without a doubt, it is our duty to always preserve the interests and reputation of BeyonCa.

WE DON’T：
• Disclose to our management, in accordance with our internal processes, any potential conflict of interest that might influence our judgment. Should such a conflict of interest arise, we remove ourselves from the decision-making process
• Disclose when we are involved in, or have a financial stake in, any organization that may be our competitor, customer or supplier, as well as how our position allows us to influence that business relationship

WE DO：
• Conceal any information on any conflict of interests
• Allow our decisions or actions to be influenced by favoritism, nepotism or preferential treatment
• Render assistance to a competitor or be employed by one
• Accept remuneration from any organization or business that has a present business relationship or conflict with BeyonCa

6.USE AND PROTECTION OF COMPANY RESOURCES AND ASSETS

Misused assets hurt us all. Our resources and assets are meant solely to help us achieve our business goals and, therefore, we must consciously use them for their intended professional functions. We all take measures to protect our assets against degradation, alteration, fraud or theft of any kind.

WE DON’T：
• Respect and protect company assets to ensure that they are not lost, damaged, misused or wasted, loaned to others, transferred, sold or donated without proper authorization
• Recognize that all company assets and documents belong to BeyonCa

WE DO：
• Use company assets for personal benefit. Limited use is accepted, if this does not incur any unreasonable costs or interfere with our professional responsibilities
• Use assets belonging to a third party (including but not limited to pictures, videos, etc)
• Sell, transfer or dispose of any company assets without proper authorization and documentation

7.SINCERE FINANCIAL STATEMENTS, ACCURATE RECORDS

It is our duty to make sure that all our financial records are accurate, properly maintained and transparent. We make it a point to precisely reflect our performance in our financial and accounting information, keeping with international financial reporting standards. We know this is essential to the honest, efficient and lawful conduct of our business, and must all do our part in ensuring it.

WE DON’T：
• Make sure that financial and business records, including both financial and non-financial reporting, are always accurate
• Maintain records securely and follow any guidelines on archiving

WE DO：
• Accept cash transactions, unless the transaction has been expressly authorized, properly recorded and documented
• Conceal payments via the use of third parties

8.INSIDER TRADING

We do not wish to restrict the freedom of our employees to make personal investments that seem relevant to them. But as employees, we must be mindful of our responsibility of protecting inside information about the company. Should we make privileged information public, it could influence our stock value. Therefore, we must always be cognizant of insider trading and following the accepted policies and procedures.

WE DON’T：
• Remember that using inside information to invest could fall within the scope of insider trading laws
• Maintain the confidentiality of information to which we may have access to avoid any accidental disclosure

WE DO：
• Buy or sell shares of BeyonCa or of any other company if we have inside information at that time
• Disclose inside information to anyone outside of the company
• Disclose inside information within the company to anyone who should not be aware of such information

9.REPRESENTING BEYONCA

We are all guardians of our brand. It is through our actions that the image of the company is built. We are aware that in our communications, either formal or informal, we continue to represent the company. Therefore, we must act responsibly and speak wisely.

WE DON’T：
• Demonstrate our ethics in our professional behavior outside of the company
• Use official communication materials and follow the branding rules and guidelines
• Protect the company’s reputation by constantly having its best interest in mind
• Act cautiously while exchanging information on social networks and web forums, keep in mind that what is on the web is never entirely private and remember that “the internet never forgets” 要记住网络上的东西从来都不是完全私密的、 要记住“互联网永远不会忘记”

WE DO：
• Interact with press or engage in public speaking without prior approval
• Engage in activities that could reflect negatively on the company
• Involve BeyonCa in our personal convictions and beliefs
• Express our personal opinions about BeyonCa through official communications
• Libel the company and colleagues on external forums

III. DIGITALLY TRUSTED AND SECURE

1.CYBERSECURITY

We are aware of the criticality of our digital ecosystem for our users, customers and partners. This is why we subject ourselves to the highest technical standards for risk-detection and response. Our processes, people and technology all contribute to building and reinforcing our digital trust. Apart from paying special attention to all high-risk assets, we put in place reality-check metrics with regular audits. We consciously partner with the best-in-class technology providers, and regular trainings in cybersecurity inform us of potential risks and empower us to naturally integrate best practices into our day-to-day work. We act with cybersecurity in mind at all times.

WE DON’T：
• Treat cybersecurity as being integral to our strategy and incorporate “Cybersecurity by Design” as a principle
• Build cyber-resilience across our whole digital ecosystem
• Design and develop our offers with comprehensive cybersecurity approach
• Support our customers to improve their cybersecurity posture
• We are cautious of compromising our internal networks or devices with data, files or applications from external sources. When in doubt, we contact our digital experts.
• Encourage a “See something, say something” mindset toward risky behavior and cybersecurity related issues

WE DO：
• View cyber risk as separate to company-wide risk
• Use our skills, technologies or systems in a manner that could be harmful to the interests of our employees, customers or stakeholders

2.DATA PROTECTION AND PRIVACY

We believe in the importance of strong governance to ensure resilient data-handling and storage processes, and in strict compliance with laws, regulations and standards. We make it a point to source, process and share data in a responsible manner, in line with our social responsibility and ethics. Thereby, ensuring that anyone with access to data can use it with a fair balance of privacy and autonomy.

WE DON’T：
• Hold privacy and the protection of personal information as a key priority
• Treat data from connected customers, products and solutions in a secure manner
• Take extreme care while analyzing data belonging to other people or companies
• Honestly disclose the type of analysis we are applying to data
• Run dedicated compliance controls and implementation programs in accordance with regulations
• When participating in online meetings, advocate sharing and improve efficiency, while highly respecting the data classification level, strictly follow the relevant processes to protect data, and actively report data breaches

WE DO：
• Misuse our knowledge to violate human rights and civil liberties
• Share data internally or externally without considering criticality and sensitivity
• When participating in online meetings, use a screen capture or filming tool to capture or record a video without the permission of the meeting organizer

3.ARTIFICIAL INTELLIGENCE

We are committed to using the new advancements in Data Sciences as a force for the good of humanity. We see value in exploring these fields to sustain our environmental commitment and cut the carbon emissions globally. However, we are aware of the implied responsibilities therein. We remain vigilant in monitoring the latest developments in areas such as AI bias, interpretability and authenticity.

WE DON’T：
• Educate our specialist teams to consider implication of Artificial Intelligence usage
• Adopt best-in-class frameworks to enhance understanding and transparency of the AI-led actions
• Promote AI usage for the purposes of well-being, dignity and sustainability

WE DO：
• Deploy algorithms that impair unbiased decision-making

IV. ACT FOR THE ENVIRONMENT

1.RESOURCES SAVING AND CIRCULAR ECONOMY

Making a positive impact on the environment starts with us. We take care to limit our consumption, use fewer resources, and develop circular use systems that incorporate reuse, repair and recycle. We are open to innovative service models. By optimizing what we already consume, we support the development of a circular economy.

WE DON’T：
• Innovate with circular offers for our customers, allowing for increased life-cycle services, efficient maintenance and greater recyclability of components
• Include recyclable materials in our products without compromising the safety and quality
• Expand the circular use of materials through reuse, recycle and take-back offers
• Reduce our waste intensity and bring our ratio of waste-to-landfill closer to zero
• Reduce consumption

WE DO：
• Generate waste where it can be avoided
• Ignore irresponsible end-of-life policies
• Leave wasteful practices unaddressed or unresolved

2.ENVIRONMENTAL PROTECTION

We have the greatest admiration for our planet, and value its biodiversity tremendously. We aspire to reconcile economic growth with a deep respect for the nature. It is therefore our pledge to constantly implement rules and processes that minimize our impact on the environment.

WE DON’T：
• Voluntarily comply with high standards and environmental regulations
• Publish detailed information about our products for the benefit of our customers and stakeholders
• Prevent and limit pollution and emissions from our operations
• Report environmental abuses for investigation and remediation
• We seek out suppliers with a high regard for environmental preservation
• Ensure that applicable employees are qualified to perform activities involving environmental risk
• Handle remediation activities to mitigate pollution risks on the environment
• Enforce stringent water protection policies
• Endorse specific initiatives to protect the nature and the wildlife; for example, the reduction of single-use plastics

WE DO：
• Ignore unnecessary waste and irresponsible effluent management in our supply chain
• Seek exemption from substance regulations
• Intentionally disregard the indirect impacts on biodiversity

V. HUMAN RIGHTS AND PEOPLE DEVELOPMENT

1.RESPECT, FAIRNESS AND DIGNITY

How we treat one another defines us. At BeyonCa, we believe that a healthy work relationship starts with respect. We expect and value differences, and welcome contributions from different opinions. We choose our words thoughtfully, and never resort to disparaging, discriminatory or sexual remarks. Together, we are building a workplace where everyone feels safe and welcome. Every time we walk into BeyonCampus, we bring with us a desire to do our best.

WE DON’T：
• Treat all people fairly with respect and dignity
• Value the thoughts and opinions of our peers without judgement
• Respect our competitors and show empathy to our customers
• Hold ourselves to the highest moral, ethical and social standards

WE DO：
• Act out of ill-intent or malice
• Condone, acquiesce, allow or disregard any abuse

2.DIVERSITY, INCLUSION AND INDIVIDUAL DEVELOPMENT

Our world is diverse, and it is only natural that we embrace this diversity at our workplace. At BeyonCa, our ambition is to offer equal opportunities to everyone. We want our employees—no matter who they are, or where in the world they live—to feel uniquely valued, and safe to contribute their best. We work to ensure that all our people have equal access to the tools they need in order to grow, develop and realize their full potential. For us, diversity of people and an environment of inclusion generate greater engagement, performance, and innovation.

WE SUPPORT：
• Equal opportunities for all employees with fair policies, placements and continuous learning
• A mix of global and local talents around the world
• Demonstrating inclusive behaviors by identifying and addressing our biases
• The personal development of everyone’s unique skills and talents
• Building a more inclusive environment by being advocates of change internally and externally

3.ZERO TOLERANCE FOR HARASSMENT

A working environment free of harassment, victimization and discrimination is not only essential, but also a shared responsibility. We are at our best when we feel safe and protected. We foster a workplace that is inclusive and welcoming—one free from intimidation, bullying, sexual misconduct, or any other kind of inappropriate behavior. We keep our policies inclusive and our reporting systems free from prejudice and intimidation. When necessary, we respond promptly to any infringement on this right without hesitation or delay.

WE DON’T：
• Protect difference and expect respectful behavior
• Foster a safe working environment free from extreme opinions
• Provide a safe channel to speak up and report inappropriate behavior

WE DO：
• Intimidate, discriminate, and disrespect
• Tolerate degrading comments on race, sex, nationality, religion, political opinion, age, medical status, marital status, disability, pregnancy, sexual orientation, gender or gender identity

VI. CONCLUSION

Our Code of Conduct serve as a guide for everyone and every team at BeyonCa in terms of ethics and compliance. Together they aid us in pursuing our objectives in a way that is meaningful, inclusive and positive. The Company expects all employees to adhere to these standards. Each employee is separately responsible for his/her actions. Any conduct that violates the law or this Code cannot be justified by claiming that it is ordered by a supervisor or someone in higher management positions. If an employee engages in a conduct prohibited by the law or this Code, the prohibited conduct will subject the employee to disciplinary action, including termination of employment. Should employees have any questions about these guidelines, please feel free to contact the Legal & Compliance Department for more information.