A message from General Director

Our shared core values and beliefs of innovation, engagement and responsibility reflect the culture of GS battery Vietnam Co., Ltd (called as “the Company” or “GSV”). Ethical behavior and unquestionable integrity form the core of our company culture. Our reputation for ethical behavior and integrity is one of our most valuable company assets. It is the result of our daily actions and as such it is an integral part of our endeavor to create sustainable success and value.

Each one of us is personally responsible and accountable for helping the Company maintain its reputation for the highest ethical behavior and unquestionable integrity. The Company management has revised the Company’s Code of Conduct in order to support us all in maintaining the highest standards of ethical conduct and in complying with laws, binding standards and our policies. Please, take this time to read our Code of Conduct carefully and continue to apply the principles to your daily work. I am counting on you to commit and adhere to the principles laid out in our GSV Code of Conduct.

  1. Objective

    With this Code of Conduct we aim to secure the sustained long-term success of the Company through appropriate conduct of every employee. The guiding principle is that we act as loyal, motivated, honest individuals who accept responsibility for our own actions.

  2. Validity

This Code of Conduct is binding for and applies to all employees within GSV, any contractors or vendors performing work for GSV or any of its subsidiaries. Certain subjects covered by this Code of Conduct may be further detailed in specific guidelines. Failure by employees to follow the Code of Conduct may result in disciplinary action up to and including dismissal.

We are committed to doing business in a sustainable and socially and environmentally responsible manner. While conducting our activities, we take into consideration the efficient use of energy and materials and the safe and responsible disposal of residual wastes, save air quality, save water quality and comsumption (air emissions and odours).

3. Conduct in our work

a) We adhere strictly to applicable laws and binding standards

Employees are expected to know and follow the law of each relevant market in which GSV does business. Adherence to all laws and regulations in the countries in which GSV operates, and to this Code of Conduct as well as to all relevant policies and guidelines is a condition of employment for every employee.

b) We respect and follow antitrust and competition laws

Competition laws and antitrust laws exist to ensure free and open competition in the market place, a principle that GSV fully supports.

Examples of prohibited conduct include but are not limited to:

- Agreements with competitors to fix prices, restrict sales or allocate territories;

- Exchange of confidential information with competitors;

- Agreements with distributors/resellers to fix resale prices as well as certain other resale restrictions in relation to territories and/or customers;

- Abuse of market dominant position.

c) We protect our intellectual property

Our intellectual property helps us deliver the unique solutions that differentiate us from our competition and make us one of the leading companies in our industry. Intellectual property is a company asset found in the creative ideas that lead to innovations and advancements in our products, technology and services. We think of it most commonly as our inventions, patents, trademarks and copyrights.

The intellectual property we develop for the Company belongs to the company. We must be alert in identifying it, taking appropriate steps to protect it, and making sure it is used only for the benefit of the Company.

d) We protect and value company property

As an employee of GSV, you are provided with access to certain company property such as computers, mobile phones etc. Unless otherwise specified, company property may be used for legitimate company business only and not for personal benefit or gain.

e) We keep relevant information confidential

The Company has a wide variety of confidential information that is not known or available outside the company and would be valuable to our competitors. Some examples include technical know-how, research and development data, manufacturing methods, cost figures, business plans and strategies, employee information, customer lists, financial information and software source codes. These are significant assets of the company.

We must take proper steps to protect this kind of information and may not disclose it to people outside the company, except in approved business transactions. The company will vigorously pursue any unauthorized disclosures of confidential information. Our obligation to protect the confidentiality of information continues even after the employment with GSV ends.

f) We respect the proprietary rights of others

We respect the intellectual property rights of others and do not obtain confidential information of other parties by improper means or disclose such information without authorization.

g) We keep data secure and comply with data privacy

We protect confidentiality and integrity of data, including the data of employees and customers, by technical and organizational means. We adhere to the applicable data protection regulations.

h) We prohibit insider trading

Prohibiting insider trading, bans disclosure of material information that has not been publicly disclosed. We share a common interest in prohibiting insider trading, thereby protecting the reputation of the company.

i) We use e-mail, internet and social media appropriately

The use of the business tools of e-mail, internet and social media may have legal implications for the company and the employees personally. The content of the e-mails and documents we create and the data we access over the internet must always be appropriate. E-mail, internet and social media must not be used to access or disseminate illegal, offensive, disruptive or potentially discriminating content such as pornographic or obscene material. Unless otherwise specified, e-mail, internet and social media shall be used for legitimate business purposes only.

j) Separation from organized crime

- We will not provide any form of benefit in excess of the normal shareholder’s right to any person or company associated with organized crime.

- We will cut off business or any other relationships with individuals and organizations having an indication of support for organized crime.

k) Legal compliance for political funds control

 We will not contribute for political funds, requesting some business advantage in return, such as acquisition or maintenance of trading, or access to nondisclosure information. Also, we will comply with the conditions stipulated by the laws and regulations of each country and region in which we operate before making political contributions.

4. Conduct towards our employees and colleagues

a) We consider our employees as key to our success

Our employees are the lifeblood of GSV. We share relevant information and work as a team. We believe in treating each other with respect, fairness at all times, and we value the differences of diverse individuals.

b) We avoid conflicts of interest

You are expected to do your job for the benefit of GSV, its customers, and its shareholders. A conflict of interest occurs when your private interests interfere in any way, or even appear to interfere, with the interests of GSV as a whole. A conflict of interest can arise if you take actions or have interests that may make it difficult for you to perform your company work objectively and effectively. Examples of conflicts of interest include working directly or indirectly for a competitor of GSV, contracting of relatives, acting as a member of a Board of Directors for a competitor or – either by the employee or by immediate family members – partially owning or having a stake in a company that competes directly or indirectly with GSV.

c) We foster diversity in our company

The diversity of languages, ethnic origin, religions, health status and cultures is reflected in our company. We foster this diversity as an important key to our success.

d) We respect the personal integrity of our employees and & Respect for individual personality

- We prevent bullying and sexual harassment by observing relevant rules and consistently punishing violations. Our policy is to provide a work environment free from harassment. Although “harassment” most frequently refers to sexual harassment, workplace harassment may also include harassment based upon a person’s ethnic origin, religion, national origin, gender, sexual orientation, gender identity, age, physical disability, or any other inappropriate or illegal action. GSV prohibits harassment and discrimination in any form, whether physical, verbal, or non-verbal.

- We will not condone the removal of human rights of any individual person, including sexual harassment and power harassment, nor the reduction of personal dignity of others.

- Be sensitive in the way you approach your colleagues and respect individual privacy at all times. You are encouraged to report instances of harassment to your manager or, as appropriate, to your local Human Resources Managers. Your report will be kept confidential to the greatest extent possible, and no complainant or witness will suffer retaliation because of a report made in good faith.

e) Respect for labor rights

We will respect labor rights including freedom of association and collective bargaining rights, in accordance with the laws of each country and region in which we operate.

f) Prohibition of forced labor and child labor

We will neither force labor, nor employ children under the legal working age. Furthermore, we will not tolerate forced labor or child labor in any way. We will neither force labor, nor employ children under the legal working age. Furthermore, we will not tolerate forced labor or child labor in any way.

g) Avoidance of complicity in human rights abuses

Directly or indirectly, we will not be complicit in human rights abuse.

5. Conduct towards working environment

a) Conservation and improvement of safety and health in working environments. We will maintain and improve environments from the perspective of health and safe-ty in accordance with laws and regulations of the country or region in which operate.

b) Ensuring approptiate working hours, securing minimum wages and prohibiting unreasonable wage reduction.

- We will provide management in order to maintain appropriate working hours and will make every effort to take measures to prevent mental and physical health dis-orders caused by overwork.

- We ensure that the salaries we pay are over the minimum wage of the country or region in which we operate, and that there will be no unreasonable reduction.

c) Mid to long-term human resources development and appropriate ability assessment. We will make every effort to proactively support career development in accordance with each employee’s abilities and aptitudes. Performance of each employee will be assessed adequately.

d) Respect for individual work-life balance. We will make every effort to respect diverse working styles, so as to ensure work- life balance and to maintain physical and metal health of employees.

e) Offer of equal employment and working opportunities. We will offer equal opportunities in recruitment and promotion, as well as forbid any arbitrary or discriminatory treatments.

6. Conduct towards our customers

a) We put customers first

Customers are at the center of our business. We want our customers to tell their friends about the positive experience they have had with GSV. We keep our promises to customers and want our customers to feel that we take them seriously. We continue to help each customer until his/her issue is solved.

b) We conduct our business fairly and do not tolerate bribery

We conduct our business fairly, relying on the merits of our products, services and employees. It is not appropriate, and may be illegal, to try and influence a customer or supplier to make a business decision in GSV’s favor by offering a payment or unusual gift. Even if not illegal in every country, such payments may create the appearance of impropriety and damage the company’s reputation. No improper payments (bribes, kickbacks, or other payments for illegal purposes) shall be made to government employees or officials, customers, or others. This prohibition applies not only to direct payments, but extends also to indirect payments made in any form through consultants or other third parties.

c) We comply with international trade regulations and export controls

Depending on the destination and on the nature of our products the export of our products is subject to export control regulations and trade sanctions. These restrictions either prohibit trade, prohibit an export, require a license or the notification of authorities. Non-compliance with international trade regulations expose individuals as well as the company to substantial fines, denial of export privileges and imprisonment (in the case of individuals).

d) Control counterfeit parts: All partners & employee of company must not purchase/ or supply fake materials/ products to the customers. If any discovering of the counterfeit parts on the market, please inform to the company immediately. Training & controlling the signs of the geneuine parts to discover the fake parts.

  • Maximize availability of authentic parts.
  • Procure parts from reliable sources.
  • Assure authenticity and conformance of procured parts.
  • Control parts identified as counterfeit.
  • Report counterfeit parts to other potential users and Government investigative authorities.

e) Focus on safety and quality

We will address to prioritize safety and quality throughout our business. For this purpose, we will strive to provide safe products and services to maintain and improve satisfied quality for customers, through all our business activities which are research & development, design, procurement, production, sales and after sales service.

f) Making product safety information information accessible

We clarify safety information on our products and services. Safety information includes instruction manual supplied with products, labelling of products, web portal communication, etc. We will make safety information accessible for customers as well as for any other stakeholders involved in commercialization of our products and services.

g) Solutions in case of product accidents

We address to prevent spin- off effects on the extent of damages of accidents as well as swiftly react in case a serious accident occurs on our product or service. And also, we investigate and collate the relative facts, research of causalities, make a necessary report on these inside and outside our company group, and then we disclose information so as to take preventive steps.

7. Conduct towards global environment

  1. Promoting environmental protection

    - We will evaluate environmental impact resulting from our business activities, products and services; strive for environmental protection (including prevention of pollution) through energy saving, greenhouse gas reduction, efficient use of raw materials and water as well as waste reduction and recycling, and aim to increase our environmental performance through continuous improvement of these aspects.

    - We will address to reduce the environmental burden resulting from the activities conducted at each stage of the life cycle of products and services, from acquisition of raw mateials, development and design/ conception, production, transportation use, until end-of-life treatment and final disposal.

     We will satisfy environmental needs corresponding to comply with environmental laws and regulations. In addition, if necessary, we address to develop our environmental risk management with operational control by voluntary management standards and for preventing accidents likely to lead to environmental pollution.

  2. Providing environmenttaly conscious products

We will contribute to the environmentally conscious society through the provision of products and services corresponding to the environmental requirements.

8. Conduct towards the public and local communities

a) We inform the public and local communities in a timely and accurate way. It is our policy to make full, fair, accurate, timely and understandable disclosure in reports and other documents available to the public. Only our General Director and persons specifically designated by General Director may speak to the public on behalf of the company.

b) Building better relationships with local communities. Contribution to the sustainable development of communities. We recognize that we are member of the community and we aim to work together in cooperation with the local community which is our foundation. We will respect local culture and customs.

c) Adoption of local human resources. We will actively adopt local human resources in the business activities of our over-seas affiliates and contribute to the development of local communities through our business activities.

9. Conduct towards our suppliers and business partners

a) We respect the interests of our business partners

Generally speaking, our business partners have a commercial, long-term interest in the business relationship with GSV. We respect this and work to create a win-win situation.

We expect our business partners and suppliers to comply with not only laws and internationally established business rules, but also to take their social and environmental responsibility seriously.

b) We use caution when accepting or giving gifts to and from our business partners

Occasionally when dealing with business partners and suppliers we are offered gifts and/ or entertainment-related items.

It is the policy of the Company that we do not accept or give items above a nominal value as further detailed in specific guidelines (if any). Gifts should in no way construe the acceptance of a vendor or business relationship.

c) Ensuring social responsibility within our supply chain

Responsible procurement promotion. We will share responsible procurement guideline among our suppliers, then address to promote responsible procurement upon interactive cooperation, aiming to ensure our social responsibilities across overall supply chain.

10. Conduct towards our competitors

We are committed to fair competition: Our competitors have legitimate business interests. So do we. May the best company win. Customers should benefit from this rivalry, which is why the competition should be fair.

11. How to get help

Although this Code of Conduct provides a framework, it cannot cover all possible situations. If the question involves a matter of law, our course is clear and unambiguous – we follow the law. Employees are encouraged to report suspected violations immediately.

12. GSV Code of Conduct compliance hotline

Our Compliance Hotline enables employees around Vietnam or the world to call to voice concerns related to potential violations of the Code of Conduct. Independent specialists answer the calls and forward reports to the appropriate person in GSV for further investigation. Employees can later ask for follow-up information.

Your report will be kept confidential to the greatest extent possible, and no complainant or witness will suffer retaliation because of a report made in good faith.

Phone Number: (+84) (0274) 3756 360

Email: legal@gsbattery.vn

13. Approval

This GSV’s Code of Conduct was approved by Director Board of GS Battery Vietnam Co., Ltd on 10 July 2018.

The first amended and supplemented version is made on the date 17th January 2020.

The second amended and supplemented version is made on the date 07th July 2020.