CODE OF BEHAVIOR AND BUSINESS ETHICS OF THE ENTERPRISE - PHƯỚC THÀNH GROUP

One of the most valuable assets of our Company is our reputation. As CEO, I promise to lead the Company with the highest degree of honor and integrity, and will work to uphold the ethics and integrity of our employees and distributors. Maintaining this reputation is one of our most important tasks.

Our Code of Business Conduct and Ethics requires that we conduct business consistent with our values and in accordance with applicable law. The Code requires us to address the concerns of the communities in which we operate and to have the highest degree of integrity in our dealings with others.

These guiding principles are designed to help each of us understand our responsibilities and make the right choices. Their purpose is also to stimulate awareness of the ethical issues we may encounter in our day-to-day business activities. Doing the right things starts with basic integrity. More than ever, it also depends on our good judgment and sensitivity to how others perceive us and how they might interpret our actions.

Each of us is responsible for the reputation of Phuoc Thanh Group. At Phuoc Thanh Group, our goal is bold yet simple – helping the community gain a happier and more sustainable life. Since 2008, we have stepped on the mission of building a prosperous Vietnam, a happy community with construction projects. I trust that you will join me in maintaining integrity in business operations, which has made Phuoc Thanh Group not only become a leading Enterprise in the construction investment environment in Bac Ninh and Vietnam, but also where we can be proud to work.

Best regards,

TRAN LE DAT

General manager

OVERVIEW

Personal Responsibilities

Phuoc Thanh Group’s Code of Business Conduct and Ethics (“the Code”) is the foundation for how we will behave at Phuoc Thanh Group and wherever we do business. The Code is underpinned by the Company’s broader Ethics and Compliance Program, which includes, among other things, the policies referenced in the Code, awareness campaigns and training program.

All employees of Phuoc Thanh Group must comply with the Code, Company policies and must act in accordance with all applicable laws. Furthermore, those who are not employees but have a working relationship with Phuoc Thanh Group are also required to adhere to the supreme principles of integrity and ethical decision-making in the Code of the Company.

We all have a shared responsibility to uphold our Code. Any non-compliance with the Code will not only undermine the values of the Company, but may also result in disciplinary action, up to and including termination. For that reason, be sure to read and understand the entire text of this Code and to consider the following questions:

Additional Responsibilities for Leadership and Management

Managers at all levels at Phuoc Thanh Group are responsible for fostering a work environment that promotes ethical behavior. Every year, officers and employees at the Management level and above will be required to disclose information not discussed herein. Of course, there is no fixed formula for creating an ideal workplace. However, as a manager, you can help prevent misconduct before it happens—an important goal of any effective Ethics and Compliance Program.

We advise managers to be open and assertive when talking about the Company Code. Encourage your employees to ask questions and take their concerns seriously. If you are unable to answer, or are uncomfortable with it, ask for guidance from your supervisor, Human Resources or the Ethics and Compliance team, then return to your workgroup quickly and politely.

Please note that even a nefarious suggestion from management exposes the Company to the risk of violating its Code, resulting in brand damage and loss to the Company’s shareholders. For that reason, we recommend the following:

Model appropriate and ethical behavior in accordance with the Company Code. Employees will look at you as a mirror.
Treat the people you manage the way you would like to be treated.
Ensure that those you manage complete work-appropriate ethics and compliance training.
Regularly remind your working group of the Company Code and its requirements.
Whether it’s praising a job well done or criticizing performance, don’t make it personal. Focus on the employee’s accomplishments or shortcomings, not on who they are.
Show honesty in how you respond to employee performance. This will encourage honest and ethical behavior.
In all your messaging, inside or outside the Company, seek to inspire trust.

REPORT SUSPECTED VIOLATION

Responsibility for Reporting Unethical Conduct

You should immediately report any known or suspected unethical behavior, or conduct that violates the Company Code, including any violation of the law, regulations, Company policies or the Company Code, through any of the Ethics and Compliance Resources noted below. The responsibility to report misconduct applies to everyone, regardless of title or seniority. The Company Code cannot predict everything that may happen in the workplace. However, if you witness or are asked to engage in behavior that you find unethical or inappropriate, trust your gut and ask yourself the following questions:

Could this damage the Company’s reputation or cause Phuoc Thanh Group to lose credibility?
Would a reasonable person find this unethical or dishonest?
Would this give me or my colleagues a bad reputation?
If I don’t report it, will I feel guilty or regret it?
Do I need advice or help?

If you answered “Yes” to any of these questions, you should report questionable behavior through any of our Ethics and Compliance Resources as noted below. If you become aware of something that may violate the Values, the Code, Company policies or the law, you must speak up and report it so it can be resolved. Failure to report a known or suspected Code violation is itself a Code violation. In addition, any person who encourages or allows another person to violate the Code will be subject to disciplinary action, up to and including termination.

You have several resources if you want to ask for guidance or give a report:

Internet address:

phuocthanhjsc.vn

Toll-free security hotline:

+84.0968.201.6468

About the list of phone numbers

nationally and internationally, see

phuocthanhjsc.vn

Email: contact@phuocthanhjsc.vn

You should provide all information that you are comfortable providing. Information will be kept confidential unless necessary to conduct a full and fair investigation. You can remain anonymous if you wish, unless local law restricts this. Due to local privacy laws in some countries and the European Union, Integrity Line can only allow certain types of allegations such as accounting, financial, auditing and bribery matters. In these countries, contact your Human Resources Department to report other issues.

All reports will be immediately forwarded to the Ethics and Compliance team, who will then assign the matter to the appropriate investigation team. In addition, if you choose to provide your name, our investigators may contact you to obtain additional information. This helps ensure issues are investigated and resolved appropriately and quickly. To the extent permitted by law or in relation to other policy, investigators will notify them of the results of their investigation.

Reports should be submitted in good faith . Any person who submits a false report alleging misconduct will be subject to immediate disciplinary action, up to and including termination.

Compliance Investigation

All employees must cooperate fully with any and all investigative efforts. The investigation process will be as follows:

An issue has been reported
The Ethics and Compliance team will prepare a confidential report
The Ethics and Compliance Team will appoint a team to investigate the matter
The investigation team may contact the person who filed the complaint if he or she provides his or her name
The investigation team may interview others if necessary
The investigation team can try to solve the background problem
If a violation is found, appropriate remedial action will be taken
If no violation is found, the case will be closed
There will be no retaliation against anyone for reporting an issue in good faith – even if there is no violation.

Anti-Retaliation Policy

Phuoc Thanh Group has a zero-tolerance policy against actions or threats of retaliation against any person for reporting suspected violations of the Company’s Code in good faith. The Company prohibits any employee from penalizing or seeking to punish any person for reporting potential unethical behavior in good faith. This remains true even if the investigation concludes that there was no wrongdoing.

The Company’s non-retaliation policy similarly applies to threats, intimidation or explicit retaliation against those who have cooperated with the Ethics and Compliance Team’s investigation. Individuals who engage in retaliation, or threaten to retaliate, will be subject to disciplinary action, up to and including termination. We take retaliation complaints seriously. Allegations of retaliation will be investigated and appropriate action will be taken.

A SAFE AND RESPECTIVE WORKPLACE

Fair Employment Opportunity

Phuoc Thanh Group is a fair recruitment organization and is committed to a non-discriminatory environment. The Company will give equal employment opportunities to all by selecting the best qualified person for each job, regardless of race, color, sex, pregnancy status, gender orientation. gender, gender identity, religion, marital status, age, national origin, disability, veteran status, citizenship, union support or group membership other protections as required by applicable federal, state, county, or local law.

Appreciate Diversity

Phuoc Thanh Group acknowledges diversity as a strength. With distributors in more than 90 countries around the world, we support multiculturalism and promote equality and fairness for people of all backgrounds and beliefs. We value our differences. Each of us has a responsibility to create a workplace where everyone is treated with honesty, dignity, and courtesy.

Anti-Harassment Policy

The Company Code prohibits discrimination or harassment on the basis of race, color, religion, sex, age, national origin, veteran status, military service or status marital status, physical or psychological disability, sexual orientation, homelessness, medical condition, including genetic characteristics, or any other basis protected by law applicable federal, state, provincial or local law.

In addition, prejudiced thinking and discriminatory attitudes are not allowed or tolerated in the workplace. All actions taken by individuals such as those related to compensation, benefits, transfers, terminations, training, education, tuition assistance, and access to social and recreational programs must be managed. in accordance with the Company’s anti-discrimination and harassment policy.

While remaining committed to maintaining a professional and appropriate work environment, the Company Code prohibits harassment of any kind. While an individual’s interpretation of harassment is subjective, the Company’s Code defines it as any unwelcome verbal, physical or visual behavior that creates a hostile environment. threatening, hostile, or hostile behavior in the workplace. ¹ Sexual access or unwanted favors are clear examples of sexual harassment.

Furthermore, the Company’s Code explicitly prohibits bullying, media sharing, and written and verbal comments— including jokes —that could be construed as sexually suggestive, racist, or sexually suggestive. racial, threatening, offensive or obscene. Finally, the Code prohibits libel based on appearance or disability.

Harassment of any kind harms the work environment and interferes with overall performance. If you observe any harassment, do not ignore or stand there silently. If you encounter or observe harassment in the workplace, report it immediately. Those who discriminate or harass others will be subject to disciplinary action, up to and including termination.

Health and Safety

We are particularly interested in providing safe and healthy working conditions and an atmosphere of open communication for all of our employees, members and representatives. Become familiar with and follow all safety guidelines and immediately report any acts of threat of violence, unsafe working conditions, health hazards or workplace accidents. to your manager or Human Resources. If you witness any physical abuse, disorderly conduct or damage to Company property, immediately call security and Human Resources.

Phuoc Thanh Group strictly forbids employees to use drugs or drink alcohol that affects their health while at the Company. The Company Code also prohibits the illegal use, sale, transfer or possession of drugs or controlled substances in the workplace. The Company and its employees must maintain a commitment to take all reasonable steps to preserve and enhance the environment, public health and safety.

Facilities for People with Disabilities

The Company is committed to working with and providing reasonable accommodations for employees and candidates with disabilities. Any employee with a disability who needs assistance is encouraged to notify their manager or Human Resources.

Privacy Policy Personal

Phuoc Thanh Group respects and aims to protect the personal privacy of all employees, members and representatives of the Company. Any and all Personally Identifiable Information (“ PII ”) that the company collects—including personnel, medical and benefits records, is kept strictly confidential. Unauthorized access or unauthorized disclosure of any person’s PII violates the Company’s Code and is subject to disciplinary action.

Policy against Relative favoritism

It would be a conflict of interest to give preferential treatment to relatives or friends in the Company. For example, no employee will supervise or be supervised by, or work in the same sales room or shift as a member of his or her immediate family.

No employee or employee’s spouse may become a distributor. Also, employees must not have a cordial relationship with any of the Company’s distributors .

PROTECTION OF SHAREHOLDERS’ BENEFITS

Conflict of interest

A conflict of interest occurs if and when an individual’s private interests conflict — or appear to conflict — with the interests of the Company. If an employee, officer or director assumes a role that could affect his or her judgment or impede his or her performance in the Company, then the case is a conflict of interest. Any outside contact that impairs an employee’s ability to do the job objectively is considered a conflict of interest and a violation of the Company Code.

Assess your own situation and use your best judgment to avoid conflict. Here are a few examples of cases where Phuoc Thanh Group considers a clear conflict:

Working for or consulting for a competitor in any capacity, including as an outside consultant, while still working for Phuoc Thanh Group.
Act on behalf of or on behalf of Company suppliers or suppliers, or accept gifts, money or benefits from suppliers or suppliers for services you provide as an employee. member of Phuoc Thanh Group.
Performing non-Company work or soliciting such work on Company premises or while working for the Company, including during Paid Personal Leave.
You or your family member receive a financial interest in any entity with which the Company does business with or is a direct competitor of the Company and the interest will cause or would appear to cause a conflict of interest with the Company.

Notes on Suppliers and Suppliers: As an employee or representative of Phuoc Thanh Group, neither you nor your family members will receive a financial interest in any any supplier or supplier of the Company if such interest would cause or appear to create a conflict of interest with the Company. This restriction applies to suppliers and suppliers that are private or joint stock companies. Refer your supplier and supplier relationship questions to the Legal Department.

Corporate Communications and Investor Relations

Management believes that for the benefit of the Company’s shareholders and the investment community in general, all communication messages from the outside must go through a single channel. Any comments or statements that may be made public are subject to prior review and approval by the Company’s attorneys and Investor Relations and Communications specialists.

Unauthorized statements to the media or the investment community may harm the Company’s compliance with securities laws, damage the Company’s reputation and expose the Company to the risk of costly litigation. least. For that reason, the Company reserves the right to monitor any corporate communications and the Company Code requires the following:

External confirmations—including your email messages and social media posts—must not disclose any confidential information of Phuoc Thanh Group and may not make statements (whether express or implied). ) that you are speaking or communicating on behalf of the Company.
If you are invited to be a public speaker at any event, you must seek approval from both your manager and Corporate Communications.
If you speak at any public rally, even if it concerns only the local community, you must make it clear that your views and opinions are yours and yours alone. personally (not an employee of Phuoc Thanh Group).
If you are contacted by anyone from the investment community or any reporter, editor, producer or executive from the press or other media organizations, refuse to give comment and refer them to Corporate Communications.

If you have any questions about how to comply with the Company’s corporate communications and investment relations policy, ask a colleague, your manager or someone in Corporate Communications.

Policy Against Insider Transactions and Disclosure of Information

While working for or with the Company, you may have access to so-called “material non-public information” about Phuoc Thanh Group and/or other companies. The term “material non-public information” refers to inside information that, if disclosed, could affect the market value of the Company’s brand. Vietnamese law and Company policy prohibit you from trading on such information and from sharing it with others who may transact based on it (an illegal practice called is “revealed”). Any violation of this policy will result in immediate termination.

In general, any inside information that a reasonable investor would consider material in making a decision to buy, sell or hold the Company’s securities would be considered “material non-public information”. “. Trading this material non-public information or disclosing it would violate the Company Code and US securities laws, many of which apply beyond our borders. Penalties for trading based on material non-public information can include large fines and imprisonment.

The following are some examples of non-public information that could be considered material and, therefore, unlawful to disclose:

Financial results.
Earnings and dividend forecasts have not been disclosed.
Possibility of merger or acquisition.
Divestments.
New product announcement.
Advances in technology or research.
Other significant activities affecting the Company.

Legal proceedings and audit

Phuoc Thanh Group cooperates with the government upon request and responds appropriately to legal proceedings, and the Company’s Code requires you to do the same. You may never lie or make false statements in connection with such proceedings, or destroy, alter or conceal any material prior to or after a request for such documentation. . Similarly, never misrepresent or otherwise interfere with the work of the Company’s internal auditors, internal investigators or public accountants or external legal counsel.

Satisfactory Internal Control

Phuoc Thanh Group must have adequate internal controls, such as policies, procedures or systems, to prevent, detect, investigate and remediate misconduct. Not only are employees required to comply with internal controls, but managers must also make every effort to ensure that internal controls are fully implemented and followed.

CONFIDENTIAL AND EXCLUSIVE INFORMATION

Employees, officers and directors must maintain the confidentiality of information entrusted to them by the Company or its customers. The Legal Department reserves the right to authorize disclosures, whether for business or statutory reasons. Confidential and proprietary information includes, but is not limited to:

Plans and proposals.
Business strategies and research.
Formulas and technical data.
New product information.
Pricing information.
Financial information, goals or forecasts.
Profiles and personal documents.
Staff information.

Anyone entrusted with confidential information and proprietary data must certify that the information is secured, stored, labeled, accessed and transmitted in a manner consistent with Company policies and procedures. company.

Before leaving or leaving the Company for any reason, including retirement, any person who has been granted access to confidential information and proprietary data must return the information and data to the Company. Company. This provision applies to copies, pages or paragraphs in any and all documents and digital media (in any format). You have a personal duty and responsibility to protect confidential information and proprietary data of the Company within the framework of your business relationship with Phuoc Thanh Group. This obligation of confidentiality continues even after you resign or leave Phuoc Thanh Group for any reason.

If you have questions about confidential and/or proprietary information, contact the Ethics and Compliance Team. If you know or suspect any actual or attempted misuse or abuse, you must immediately report this through an Ethics and Compliance Resource.

Ownership of Intellectual Property

Whatever your relationship with Phuoc Thanh Group—through an employment contract or otherwise—you have assigned us all rights, title and interest in and to all intellectual property (IP) and outsourcing that you develop or help develop, regardless of your expertise. Under such agreements, you acknowledge and agree that the Company owns and has the rights to copyright, patent and trademark protections to anything you create for the Company. Ownership of the Company is maintained after you retire or leave for any reason, including termination or retirement.

Use of Personal Devices and Software

If you obtain software for your personal device, you may not copy that software onto any other development or work that you do for the Company. The software may not be downloaded or otherwise migrated onto any Company-owned computer system.

Protect Business Partners’ IP and Assets

From time to time, external businesses agree to share with the Company the rights to their IP. Typically, these agreements allow employees, officers or representatives of the Company to access certain confidential and proprietary information for a specific purpose.

Whenever an external party agrees to provide you with confidential or proprietary data, you must adequately safeguard that information in accordance with Company policy. In addition, you may only use, copy, distribute or disclose such information as specifically set forth in the relevant agreement.

Be especially careful when licensing or acquiring IP or copyrighted software from others. IP is not only protected by copyright law, but can also be protected by patent and trade secret law. You must strictly comply with all conditions of the license and acquisition agreement.

Company policy requires that you consult and obtain approval from the Company’s Legal Department before requesting, accepting or accessing the IP of any third party. We also require that all relevant terms be included in a properly signed agreement. The Company’s Code does not allow for verbal agreements, handshake agreements or side agreements.

Remember to properly certify and use all applicable trademarks, copyrights and brand names held by the Company and other affiliated businesses around the world in accordance with the relevant Company policies. to the use of other trademarks and IPs. Branded logos, names, symbols or devices that identify and differentiate products and services are the most valuable assets of the Company. Inappropriate use of another person’s IP, trademark, copyright or trademark name may subject you and the Company to claims, civil and criminal penalties.

Information about Competitor

In the normal course of business, it is not uncommon to obtain information about many other organizations, including competitors. This is a normal business practice and is not unethical. In practice, the Company still collects this type of information in a manner suitable for purposes such as credit extension and supplier evaluation. We also collect competitor information from various official sources to assess the comparative advantage of their own products, services and marketing methods. This activity is normal and necessary in the highly competitive global market.

On the other hand, theft or unauthorized access to competitor data is a violation of the Company’s Code of Business Ethics and Code. The following rule should not be subject to any exceptions: Under no circumstances should any person working for or on behalf of the Company seek—through any means—to gain unauthorized access to the proprietary data or confidential trade secrets of a competitor.

If a third-party information source offers to share with you sensitive and non-public information about any business, competitor or not, you must promptly alert the French Department regime.

BUSINESS PROFILE AND COMPANY RESOURCES

Accuracy of financial and other records

As a joint stock company, Phuoc Thanh Group must submit quarterly and annual reports to the Board of Directors and the State Tax Agency of Vietnam. These reports must present a fair, accurate and understandable description of the Company’s overall business, financial position and results of operations. Information must also be provided in a timely and complete manner. To ensure full compliance with all applicable regulations, it is imperative that all internal reporting is also accurate, truthful and timely. The Company Code requires it. Regardless of your role within the Company, whether you are a report maker, researcher or accountant, you must make every effort to submit timely, accurate and complete reports.

The law also requires the Company’s financial accounting to be up-to-date, accurate and to include an easy-to-understand explanation of all pertinent information. Therefore, employees involved in financial reporting must fully understand and comply with the Accounting Principles of Vietnam and all other applicable standards, laws and regulations regarding accounting and reporting. financial transactions, estimates and forecasts.

Anyone who knows and still reports inaccurate or misleading information in an internal or external report or notice will be immediately removed from office and subject to civil, criminal, and possible fines. incarcerated.

Retain Profile

Phuoc Thanh group has procedures regarding how and when business records are kept and destroyed. You must be familiar with the Company’s Records Retention Policy.

Please note that regularly scheduled destruction of documents may be halted in whole or in part as circumstances require. Sometimes, the law requires that events such as litigation, government investigations and certain audits require the Company to maintain records that may be relevant. If you have any questions about the Company’s records management and retention policies, contact the Legal Department.

Use of Company resources

We all have a responsibility to protect Company assets. As such, you should make every effort to prevent loss, theft or unauthorized use of Company property.

All Company assets, whether tangible (equipment, computers, laptops, systems, facilities and supplies) or intangible (IP and confidential and proprietary information) ) should only be used for legitimate business purposes.

We acknowledge that sometimes people may need to make a phone call or private message while at work, but we ask that you do not abuse this privilege. Please don’t waste your work time chatting, texting or communicating about your personal issues. Abuse of this privilege may result in disciplinary action, up to and including termination.

GUIDELINES RELATED TO EXTERNAL ACTIVITIES

Social Media

Phuoc Thanh Group acknowledges that social media has become a favorite way to instantly share one’s thoughts, ideas and opinions, and we respect the right to participate in such platforms. your.

However, certain forms of social media activity have the potential to damage the Company’s reputation—one of our most valuable assets—and negatively affect public perception. back to comity. To protect the Company, our brand as well as your personal reputation, it is wise to exercise reasonable judgment in all such social media activities. In this regard, we ask that you adhere to the following social media guidelines:

Never use the Company’s computer, phone or email system when posting on social networking sites.
Do not engage in any public discussion or make any comments that could be perceived as statements or opinions of Phuoc Thanh Group.
Be professional in your choice of words and must respect the opinions of others and their right to freedom of speech.
Never disclose, comment on or describe confidential or proprietary information about Phuoc Thanh Group.

If you have questions about how the Company Code applies to social media, please contact the Legal Department.

Civil Relations

The Company encourages its employees, members and representatives to be active in civil relations, provided that their participation does not cause any conflict of interest. For example, as a committee or board member of a civic organization, you may be faced with a decision regarding the Company. It may be a decision to purchase products from Phuoc Thanh Group, or it may be a decision of a Taxation or Planning Commission affecting the Company’s assets.

In such cases, your interests in the Company and your obligations to civil society may put you in opposing directions of action. While the choice of how to resolve these conflicts is entirely up to you, you should seek advice from the Legal Department or the Ethics and Compliance Team, who can quickly advise you on the matter of conflict. .

Political Activities

If you choose to support any political, religious or cause issue, you may only do so as an individual. The Company does not care about your political views and politics has no place in the Company work environment. In fact, it may be against the law to use Company resources to engage in political activities.

Accordingly, it would be inappropriate to ask your subordinates or colleagues to attend a political or religious event . With regard to political contributions, the Company Code strictly prohibits:

Use the Company’s email system, mailing list or other business resources to support a political issue or religious cause.
Ask the Company to reimburse you for personal political contributions.
Working for any political purpose while in the Company
Asking or pressuring a colleague, supplier, customer or partner to contribute or, otherwise, support a political cause.

BUSINESS ACTIVITIES

Competition law

Most countries in which the Company does business have laws designed to prevent unfair competition. Broadly speaking, these antitrust, monopolistic or fair trade laws aim to protect the welfare of consumers by preventing interference with the functions of a competitive market. . Phuoc Thanh Group makes every effort to comply with competition regulations and the Company Code requires all employees, members and representatives to do the same.

Almost all competition laws prohibit the following:

Fixed price agreement.
Manipulating a product supply chain.
Collusion with a competitor or other business entity to provide a product at a set price, also known as “collusion in bidding”.

Competition law can be complex and confusing. If you are unsure of how to handle an issue that arises or if you perceive any potential violation of these laws, alert the Law Department.

Sales, Marketing and Advertising

Phuoc Thanh Group sells its products and services solely on their benefit. The Company’s sales and marketing practices prohibit giving false, misleading or libelous information about competitors and their products or services.

In all competitive advertising, you must confirm that all comparisons between the Company and competitors are warranted. Any comparative advertisement must certify that all language is reasonable, accurate and not misleading. Keep in mind that some countries do not allow comparative advertising. Accordingly, you must consult the Legal Department before launching any comparative advertising campaign.

Working with a supplier

When deciding between competing suppliers, you must weigh all relevant information and weigh the pros and cons of each. Analyze the capabilities of prospective suppliers in an unbiased manner.

This requirement applies to the Company as a whole—whether it’s a small repair job to a local office or the purchase of millions of dollars worth of materials. The Company’s policy prohibits the conduct of trading on exchange conditions . Therefore, an employee or representative should never tell a prospective supplier that the Company will decide to purchase their goods or services provided the supplier agrees to purchase the company’s products or services. Company. The Company strictly prohibits such “paid” actions.

Finally, as stated earlier in the section on Conflicts of Interest, no employee, officer or representative shall have a financial interest in or investment in any of the Company’s suppliers. If you have any questions, please contact the Legal Department for guidance.

Export control

Import and export laws vary in the countries where Phuoc Thanh Group does business, and the Company seriously considers its obligation to satisfy all of the Client’s requirements.

If you are involved in the movement of products between countries, make sure you consider all Customs related issues that may affect your timeframe. The marketing, manufacturing, labeling, and pricing of a product can influence the rapid release of a product to market.

Tax and foreign exchange control law

Any and all employees, officers and representatives whose work requires compliance with tax and foreign exchange control laws must understand and comply with the rules relevant to all jurisdictions where the Company is located. work.

Knowing but still executing a deal for Phuoc Thanh Group without complying with the laws on tax control and foreign exchange would be a violation of the Company’s Code. If you have any questions, please contact the Legal Department for guidance.

Environmental protection

The company conducts its operations globally in a manner geared towards the protection of the natural environment. If you become aware of any environmental law violations for which the Company may be responsible, or know of any actions that might mask such a violation, notify us via any resources you may have as outlined above, under Report Suspected Violation.

Fraud, Bribery and Corruption

Herbalife strictly prohibits any form of fraud, bribery or corruption. Fraud refers to the act of intentionally deceiving or declaring false information for the purpose of profit. Examples of fraud include stealing money, checks or property, manipulating accounting records.

Bribery or kickback is the giving or receiving of money, fees, commissions, bonus points, gifts, favors or anything of value that is offered directly or indirectly in exchange for preferential treatment. treat. For more information, refer to Policy 15.06 Unfair Payments.

Gifts and Favors

While gift giving may be a normal part of business relationships, a favor or gesture of courtesy should never interfere with your decision-making or present the appearance of a conflict of interest. It must be clear when offering or accepting gifts, including accompanying meals or entertainment, that you are bound by these restrictions.

Gifts between employees of different companies are generally acceptable, provided that the costs involved are in line with business practice, not luxuries, and the gift is legal. Acceptable gifts include widely advertised gifts and physical goods of face value as well as services, promotions, and discounts. You can also give or receive reasonably priced meals and entertainment.

Gifts of excessive value have the appearance of a conflict of interest. If you receive such a gift, notify your manager. The company will arrange to return or donate this gift and will politely explain the reason to the gift giver.

It is strictly forbidden to give or receive cash or to engage in any form of bribery. If you have any questions, please contact the Ethics and Compliance Team or the Legal Department for guidance.

Gifts for government employees

Many countries have laws that prohibit government employees or representatives from accepting gifts. Courtesy as is customary in the commercial business in Vietnam are often not similarly applied, for example, when traveling to Europe, China, Southeast Asia and Africa. Laws in some countries prohibit government employees and others working for the government from accepting gifts, even as small as gestures like transportation or free lunches.

You must therefore be aware of and comply with the relevant laws and regulations governing relations between government employees, members and suppliers in every country in which you do business.

Phuoc Thanh Group absolutely prohibits all employees, officers and representatives from giving to a government official or employee belonging to a government-owned entity any money, gift or anything else. valuable that could reasonably be construed as having a nefarious purpose. Gifts or entertainment given to a government official are subject to other stringent requirements and will also require prior approval.

Lobbying

Lobbying is a term commonly used to refer to efforts to influence a government official’s position on a proposed or considered law or regulation. A company’s involvement in lobbying is often an expansive effort involving marketing and procurement issues.

If you engage in lobbying, you must know and comply with all relevant laws—including any gift laws and associated compliance requirements.

Since the reporting and compliance requirements in this regard can sometimes be confusing and confusing, you should check with the Law Department from time to time to make sure you are complying with all the latest reporting requirements. You should also obtain appropriate approval before using parties outside the Company to lobby on behalf of the Company.

Hire government employees

In connection with the hiring of employees or former government employees or members of their families, the Company Code requires that you consult your manager, Human Resources and the Legal Department before . Even before starting a preliminary discussion about hiring a government employee or former employee, the Company’s Legal Department should consider any legal and ethical issues that may affect hiring decisions.

For more information on the Company’s Corporate Policies, please visit the Policy Library.

End

The Code is the roadmap to our purposeful mission to improve people’s lives and make the world a healthier and happier place. To fulfill this mission, we must work together to do what is right and lead with personal and professional integrity. We must speak up when we see or hear of violations of the Code.

Together and in keeping with the letter and the spirit of the Code, we will fulfill our mission in line with our goals.