CITIC Securities Company Limited (hereinafter referred to as “CITIC Securities”, or the “Company”) attaches great importance to anti-bribery and integrity management. In accordance with the Securities Law of the People's Republic of China, the Regulations on the Supervision and Administration of Securities Firms, the Regulations on Integrity in the Practice of Securities and Futures Institutions and their Staff, the Code of Professional Ethics for Securities Practitioners and other relevant laws, regulations and self-regulatory rules, and the CITIC Securities Professional Integrity Regulations, the Company has established a system of anti-bribery and integrity management to effectively manage and promote the integrity of employees.

The provisions of this policy summarize the relevant policies of the Company’s anti-commercial bribery and integrity management, which are disclosed herein and are actively subject to the supervision of all parties.

I. Integrity Requirements

i. Prevention of Improper Transfer of Benefits

In carrying out business activities, business departments and employees shall strictly comply with the Regulations on Integrity in the Conduct of Business by Securities and Futures Institutions and Their Staff and other related regulations. Personnel shall not take advantage of their positions to convey improper benefits to public officials, supervisory officials, clients, potential clients and other stakeholders. Personnel shall not obtrude, instigate or assist others to interfere with the work of supervisory and regulatory bodies or self-regulatory bodies. Improper acts of transferring benefits include:

(i)                         Providing gifts, gratuities, real-estate properties, automobiles, securities, equity, commission rebates and other property, or facilitating the above-mentioned acts by passing over or holding on behalf of others;

(ii)                      Providing benefits such as travel, recreation, and job placement;

(iii)                   Providing hospitality of a lavish nature that exceeds the Company’s marketing expenses, frequent hospitality, or hospitality that interferes with the proper exercise of authority;

(iv)                    Arranging transactions such as structured, high-yield, capital-protected financial products that deviate significantly from fair value;

(v)                       Providing insider information, undisclosed information, trade secrets or customer information, either expressly or by implication, to others to engage in related trading activities;

(vi)                    Other cases of transferring improper benefits;

ii. Prevention of Improper Benefits.

In carrying out  business activities, business departments and employees shall not seek to gain improper advantages through:

(i)                         Receiving or soliciting property or benefits from another person, either in a direct or indirect manner;

(ii)                      Directly or indirectly using insider information, undisclosed information, trade secrets and customer information for profit-gaining;

(iii)                   Gaining profit by inducing clients to engage in unnecessary transactions, using client fiduciary assets for unnecessary transactions, etc.;

(iv)                    Irregularly engaging in profit-making business activities, holding positions that may affect their independence or engaging in activities that conflict with the legitimate interests of the institution or investors;

(v)                       Illegally using one’s authority to facilitate the engagement of close relatives or other persons of interest in profit-making business activities;

(vi)                    Other cases of improper gain.

iii. Special Requirements of Regulatory and Self-Regulatory Bodies

Business departments and employees shall not engage in the following acts in the course of the supervision and management by the regulatory authorities, as well as in the course of conducting business with stock exchanges,  securities industry associations, fund industry associations, China Securities Depository and Clearing Corporation Limited, China Securities Finance Corporation Limited, investment funds, interbank markets,  foreign exchange trade centers and other institutions, or in the course of self-regulation:

(i)                         Conveying improper benefits to self-staff;

(ii)                      Improperly influencing a supervisory or self-regulatory decision;

(iii)                   Improperly influencing supervision and management, self-regulatory management arrangements, or improperly obtaining internal information on regulatory policy, supervision and management and self-regulation;

(iv)                    Refusing, interfering with, obstructing or failing to cooperate with the supervisory and regulatory authorities, self-regulatory bodies, and supervision, administration and management of self-regulation performed by company staff;

(v)                       Assisting others in interfering with the normal conduct of supervision and management and self-regulatory management by supervisory and regulatory authorities and self-regulatory bodies;

(vi)                    Other acts that affect the normal conduct of supervision and management and self-regulatory management by supervision and management departments and self-regulatory bodies.

In addition to the above provisions, the Company shall comply with the specific work requirements on integrity stipulated in the Company’s Integrity Regulations for each type of business when carrying out licensed businesses such as investment banking, asset management business and brokerage business.

II. Anti-commercial Bribery and Financial Discipline

Employees of the Company shall guard against commercial bribery and are not allowed to accept cash gifts, shopping cards, club memberships, gifts and other valuable securities from customers, subordinate organizations and colleagues in the course of their business activities; rebates, commissions and benefit fees received must be handed over in full. Employees are not allowed to accept arrangements for banquets, entertainment, and vacation activities that may affect the impartial performance of duties. In the course of business activities, gifts, shopping cards, club memberships, gifts and other valuable securities are not allowed to be given to clients.

The Company formulates financial management system related to expense management and procurement. All departments and employees of the Company shall strengthen the financial discipline, put an end to irregularities such as petty cash and off-book accounts. Personnel shall comply with the Company’s requirements on marketing and business hospitality expenses in business operations, and strictly follow the internal decision-making process and standards for expenses and ensure that the relevant expenses are legal and compliant.

The Company implements approval and management of paid payments to third-party institutions. When departments and employees engage third-party institutions to provide services such as investment advisory, financial advisory, product distribution, intermediary introduction, professional consulting and business activities, the qualification conditions of the third party shall be clarified, internal approval procedures shall be carried out in advance, and the service agreement shall be signed after approval. In addition, the service agreement shall clearly agree on the service content, service period and fee standards.

III. Training

In order to help employees understand the requirements related to anti-bribery and ethical standards, the Company regularly conducts training and education on ethical business conduct for employees, fosters a culture of integrity and ensures that employees are familiar with the relevant provisions of the Code of Conduct.

IV. Reporting

The Company accepts complaints and reports on violations and is obliged to keep the confidentiality of the complainants and whistleblowers. The Company’s departments and employees shall not disclose information to the person being reported or investigated. The Company prohibits retaliation against the whistleblower or those who hold different opinions.

V. Accountability

The Company shall hold violators accountable and deal with violations in accordance with its internal system and shall take disciplinary or auxiliary measures against employees in accordance with the severity of the circumstances.