The importance of the moral framework is reflected in many aspects. It lays the foundation for people's behavior of mutual respect. It can provide guidance for our daily life and eliminate doubts for us. The business ethics framework is equally important and more far-reaching. For GT and thousands of people gathered here to work, this ethical framework is reflected in our code of conduct

You are reading this & ldquo; Specification &; It is carefully formulated by us and aims to elaborate the standards of conduct that GT wants its employees to meet. Practicing such standards helps protect ourselves and others, as well as our businesses, stakeholders and customers

When we can distinguish right from wrong, we have no reason not to follow moral standards and do wrong things

In GT, this specification is the primary reference for judging whether there is deviation in behavior. Combined with common sense and experience, this specification introduces in detail the behavior standards that GT hopes you and every employee to abide by. This code shows you how to respond when you witness or suspect a violation of this code, and emphasizes the consequences that violators need to bear after the violation is confirmed

I hope you will learn and understand this code of conduct and not follow it only for contractual obligations. I hope you will take this code as a part of GT's daily work, clarify right and wrong, do good deeds, and become a member of a group of professionals who follow the highest ethical standards

Introduction

1.1 general provisions

GT code of conduct (hereinafter referred to as & ldquo; this specification & rdquo;) Set the company's values, which can guide us when we strive to achieve our career aspirations in the company. It applies to all employees, officers and directors of GT and to all actions we perform on behalf of GT worldwide. We require suppliers, agents and business partners to follow similar principles

Together, we abide by the highest standards of conduct and ethics, which has won the trust of our partners and customers. This is a proud tradition, which determines not only the way we conduct business operations, but also the way we treat people

This specification is a way to express who we are and how we want stakeholders to see us. We integrate this specification into our daily practice. All of us shall act in accordance with the content and purpose of this specification, and comply with all company policies and all applicable domestic and international laws and regulations. When in a moral or legal dilemma, we should solve the problem in accordance with this code

GT aims to be a responsible business partner and treat our customers and other business partners, our employees and the communities in which we operate in a responsible manner. It is the responsibility of the board of directors and the management team to ensure that this specification is correctly communicated to and followed by everyone in GT. The application of this specification is particularly important when making decisions on whether to establish or maintain relationships with business partners such as contractors, suppliers and distributors or whether to participate in joint ventures

This specification does not cover all aspects. It is the minimum requirement for our behavior on behalf of GT. Individual business units, operation management, enterprise departments and national management teams may, if necessary, separately formulate supplementary business codes or ethical behavior regulations in line with local conditions, provided that such rules are consistent with our values, our reputation and the contents of this code

All of us should maintain the integrity of this specification. We are responsible for reporting any activities that we believe may violate this specification, the company's policies or laws and regulations. We can inform our manager, any ethics liaison, ethics committee, or call the reporting hotline

If we fail to comply with or deliberately violate this specification, GT reserves the right to take disciplinary actions, depending on the specific circumstances, which may include dismissal. If someone reports an actual or suspected violation of this code, company policies or laws in good faith, GT will not retaliate or tolerate anyone to retaliate, even if it is finally proved that the reported suspected violation does not violate this code

GT is committed to continuous innovation for our customers, employees, communities and the whole society to create a better tomorrow

The norms set forth our principles in the process of realizing this mission and stipulated the standards of professional behavior. The main function of norms is to provide core guidelines and reference materials for our daily decision-making. It is also a practical tool to encourage employees to actively explore and help employees solve moral dilemmas and uncertainties in their work

We abide by the code of ethics in our work, so as to build a proud community through a series of daily decisions, and each of us can contribute to it and achieve our own development

In order to protect and promote the development of our valuable and honest community, we must:

Know the ethics and standards of the company's internal or external business behavior

Keep transparent: maintain open two-way communication through questioning and listening

Be prepared to do the right thing. If something is wrong, take action

Assistance and reporting

2.1 guide

In the process of understanding and applying this code, we should also abide by common sense and recognized code of conduct. Therefore, the problems in the decision tree can help us make the right choice

2.2 decision tree

We should always maintain good judgment. If we feel that an action is inappropriate, we should not implement it

If you are unsure whether a behavior meets GT's ethical standards, we recommend considering the following issues:

1.& nbsp; Is the act illegal

2.& nbsp; Will this behavior adversely affect GT

3.& nbsp; Does this behavior violate this code or company values

4.& nbsp; If implemented, will we feel like we have done something wrong

5.& nbsp; Would we hesitate to inform our boss (or our colleagues, spouses or partners) of this

If the answer to any of the above questions is yes, we should not carry out such behavior

2.3 ethics guide

All of us should comply with this specification, and all managers should ensure that this specification is complied with. If we don't know what to do in a situation, we need to consider the following behaviors to make the right decision

please refer to the compliance policy

GT has a specific compliance policy that supports the general principles described in this specification. For further information on the reasons and guidelines for compliance with this code, we can also refer to such policies on the GT code of conduct intranet site

take direct action

Solving problems on the spot is often the best practice. If we believe that there may be an ethical problem with an act, or find that someone is committing a suspicious act, we should pay immediate attention to it. Sometimes, it is an act of complying with this code to only discuss the problem

consult your manager

In general, if you have any questions about this specification, you can turn to our manager first. Our direct manager is familiar with our specific tasks and knows the local situation better than any other person. They can help us explore problems so that we can identify behaviors that meet the norms

contact your local ethics liaison

If for any reason we are unable or do not want to discuss an issue with our manager, we can also contact our local ethics Liaison Representative. It can help solve or answer any questions we may have. The ethics Liaison Representative has independent responsibilities and can also help us contact relevant departments, such as human resources, legal or internal audit

contact the ethics committee

The ethics committee is composed of competent leaders who are responsible for the application, interpretation, implementation and communication of this code, and for supervising the investigation activities of reported violations of this code. We can use Ruben Lichtenberg, e-mail: Ruben lichtenberg@GT.com ； Tel.: + 31655105606) contact the ethics committee

2.4 how to report

1. Manager

2. Ethics liaison

3. Ethics Committee 4 Reporting line

We welcome any questions or concerns you may have. If we know or suspect that there is a violation of the code or the main purpose of the code, we should immediately report the problem to our manager, ethics liaison or ethics committee. Or, if necessary, we can use the reporting hotline managed by a third party to report the problem to the ethics committee anonymously

Complaints involving GT accounting, internal control or audit issues will be communicated to the audit committee of GT board of directors

2.5 no retaliation

All employees who report suspected violations in good faith or participate in relevant investigations are entitled to protection against retaliation. GT shall not dismiss, demote, suspend, threaten or harass employees or treat them differently in the terms of employment because they report in good faith their legal acts suspected of violating the norms or participating in relevant investigations. The right of employees to be free from retaliation does not provide immunity for any violation of the code

2.6 disciplinary measures

Violations of the code of conduct may result in disciplinary action (including dismissal) and may lead to further civil or criminal proceedings. Disciplinary measures will be in accordance with applicable laws

business integrity

it is the policy of GT to comply with all applicable laws and regulations related to our business. In business, we may encounter various legal problems or question the legitimacy of certain acts. When this happens, the relevant behavior should be verified together with the manager and / or legal department. Everyone should shoulder the responsibility of observing discipline and law

3.1 bribery and misconduct

GT strictly prohibits unethical business practices aimed at acquiring or retaining business or influencing business decisions, such as bribery, providing rebates or making any other form of improper payment. This rule applies to all our businesses and covers every country / region where our business is located. We shall not offer, promise or authorize, directly or through a third party, the payment of gift fees or the provision of services without invoices in the following circumstances:

·& nbsp; To gain any commercial advantage

·& nbsp; To influence the policies of any government; Or

·& nbsp; Such payment or service may have improper appearance

Just proposing without actual payment will still violate GT's policies and laws

Facilitation fee refers to a small amount of money paid to the official in cash or in kind in accordance with well-known or widely followed local practices for the purpose of accelerating or ensuring the implementation of official routine acts, such as issuing permits, licenses or visas. GT policy strictly prohibits the provision of facilitation fees on behalf of GT

Anti bribery laws, such as the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. bribery act, and similar laws in other countries, prohibit us from proposing or providing bribes, kickbacks, or any other improper payments to government officials for the purpose of acquiring or retaining business or influencing business decisions. Such laws will apply wherever we operate

Government official means

·& nbsp; Public officials

·& nbsp; Official or party candidate

·& nbsp; Politicians or political candidates

·& nbsp; Employees of public international organizations (such as the United Nations or the European Union)

·& nbsp; Employees of organizations owned or managed by the government, such as public utilities or universities

Such laws apply to companies and individuals, including employees. Violation of anti bribery laws can lead to high financial penalties or even imprisonment

3.2 competition and antitrust

GT supports the principles of free enterprise and fair competition

GT competes in the market in a legal and ethical manner. We must comply with the antitrust laws applicable in the place where we operate. Failure to comply with such laws may have serious consequences for the personnel involved and our company. If there is any doubt or doubt about the competition law or whether the competition law is applicable, it is best to seek the advice of the legal department in time

In order to comply with the competition law, we must never agree with our competitors to restrict competition in any way. Any and all arrangements should follow the principle of fairness

3.3 accurate report

In order to ensure that our shareholders and other stakeholders have access to unified information, and to protect sensitive information, only a few employees have the right to make public statements on behalf of GT

In addition, all information published by GT (including its business units and / or national organizations) must be approved by the corresponding management in advance

Our industry and business are always supervised by the public, the media and the analyst community. When contacting us, we shall not release any information about GT's financial, social or environmental performance or any other information without consulting the corporate communication or investor relations department in advance

We are responsible for ensuring that GT's financial statements are complete, fair, accurate, timely and easy to understand. To this end, we must comply with legal regulations and regulatory requirements and be familiar with GT's internal control regulations and policies. We must not make false or misleading statements or statements in GT financial reports, supervision reports or other documents submitted to government agencies and investors or in any publications (including advertisements)

GT only conducts business with individuals who conduct legitimate business and whose identity we have confirmed. We must comply with all applicable anti money laundering laws around the world and report any suspicious activities to our manager or legal department

3.4 data protection, personal data, third party

GT attaches great importance to the protection of personal data of all business related parties, including employees, suppliers and customers. We believe that managing personal data in a responsible manner is the key to maintaining GT brand trust and an important part of ensuring that individuals believe that GT respects their privacy rights

3.5 sustainability, social responsibility, conflict minerals

GT is committed to achieving sustainable practices through our sustainability policies, thereby promoting ethical principles and respect for the environment, individuals and our communities. GT is committed to manufacturing products and packaging that do not contain minerals from conflict areas and ensuring transparency in the supply chain

3.6 trade compliance

At GT, we are committed to complying with applicable laws and regulations in all activities and in the global community in which we operate. Therefore, when we import or export products, services, information or technology worldwide, we must comply with the laws, regulations and restrictions of each country that may exercise jurisdiction over GT import and export business

personal integrity

4.1 gifts and entertainment

According to the scope of GT's work, sometimes the exchange of gifts and business entertainment can help us maintain a solid relationship with customers, suppliers and other business partners. However, we should follow the following principles and keep reciprocity within a highly professional scope:

value: do not give or accept personal gifts or favors of substantial commercial value to a third party. Gifts or favors of substantial value refer to those that may affect our business behavior or generate potential conflicts of interest or dependence

Regardless of the value of the gift, whether it is given or given by others, it must be reported to the manager or the ethics liaison

in line with convention:

The gifts or favors we provide or accept shall not violate the business practices of relevant regions and industries, and shall not put GT in a difficult position. Cash or cash equivalents such as gift cards or gift certificates are regarded as rebates or bribes and are strictly prohibited from being offered or accepted

legal: gifts or favors should be legal in the regions and circumstances related to gifts and should not violate any applicable anti bribery laws

request: we shall not provide gifts or favors prohibited by the recipient's policy. We must not offer gifts or favors at the request of others, as this may be regarded as bribery or kickbacks

We should make it clear to our business partners that gifts or personal favors may have a negative impact on business relationships

Moreover, our business decisions will only be made in the interests of GT, not based on personal considerations of past or future interests

government:

The acceptance of gifts or favors by public officials, regardless of their value, is subject to very strict policy requirements. We should always abide by such policies and act accordingly. Therefore, when offering gifts or favors (regardless of value) to public officials, we must always discuss with the ethics liaison. In particular, we must not offer any valuable gifts to government officials for the purpose of acquiring or retaining business or obtaining any benefits. Otherwise, it will expose us to the risk of violating relevant anti-corruption laws

4.2 conflict of interest

We should avoid any activities that are contrary to or conflict with GT's interests, or any activities that produce the above appearance. If one of us uses his position or function in GT to obtain personal remuneration or personal relationship that conflicts with GT's interests, it indicates that there is a conflict of interest

If we are not sure whether there is a personal conflict, the best way is to solve the problem in a transparent manner and inform the relevant management or ethics contact representative as soon as possible

4.2.1 personal relationships

Dual allegiance may occur when personal interests are inconsistent or suspected to be inconsistent with GT interests. Therefore, we must not carry out GT business with family members or other persons with important personal relationships. In addition, we shall not use our position at GT to approve any payment, promotion, remuneration or other preferential treatment for family members or any other person with important personal relationships. In case of potential conflict or appearance of potential conflict, we must disclose the relevant situation to the manager and shall not participate in the decision-making or evaluation of any individual or company with whom we have a personal relationship

4.2.2 external employment or business activities

Before accepting external employment (outside GT), including positions of customers, distributors, suppliers or other GT business partners, we must inform the manager and obtain prior approval. Any external activities must be distinguished from our work in GT and must not interfere with our performance in GT. In the case of external employment, we shall not use working hours, any GT assets or our position in GT to carry out other work or profit for other employers

4.2.3 Investment

We must not allow personal financial investments to affect or be suspected of affecting the judgment we make on behalf of GT. If we have direct investment in GT business partners (such as GT suppliers, customers, distributors or competitors), personal investment in publicly listed shares or private enterprises may create a conflict of interest (or appearance of conflict of interest). If we have doubts about how an investment will be treated, we must inform the manager or ethics liaison

4.2.4 personal business opportunities

We all have an obligation to promote GT's legitimate commercial interests. Therefore, if we use assets or information belonging to GT to identify any business opportunities, especially when such opportunities compete directly or indirectly with GT, we shall not develop such opportunities for personal benefit

4.3 insider trading

Due to the nature of our work at GT, we may learn about unpublished information involving GT or other companies. If any listed company (including GT) is involved, such information may have an impact on the stock price. The use of non-public material information involving GT or other companies is unethical and may also be illegal

Under the reasonable expectation, if the disclosure of non-public material information will have an impact on the trading price of shares or other securities of GT or other companies, we shall not buy or sell such shares or securities. Such acts are regarded as insider trading and are illegal. We shall not disclose such confidential information to colleagues or third parties except within the scope of normal work, occupation or responsibility and under the strict conditions that only the receiving party of such information shall bear the obligation of confidentiality. Violations of such principles may face criminal charges

Company assets

5.1 prudent and rational use

We must protect and secure any GT assets entrusted to us and will not be lost, damaged, abused or stolen. We can only use GT tangible assets (such as funds, products or computers) to carry out GT business. Any other use must be authorized by the relevant management personnel. GT assets must not be used for purposes that violate laws or company policies. At the end of our work in GT, we shall immediately return the GT property entrusted to us. We must also protect third-party assets entrusted to us in the performance of our duties. We must respect the rights of others. We expect our employees to become responsible citizens

5.2 intellectual property rights

We respect intellectual property rights. We must protect all types of GT intellectual property acquired or developed, such as patents, trademarks, copyrighted works and confidential technical or business information (trade secrets)

We should only disclose confidential information to other GT employees or external parties on a need to know basis. We can only disclose confidential information to third parties after obtaining the approval of management and signing a non disclosure agreement

We all have the responsibility to protect these assets, so we should take measures to avoid unauthorized disclosure of such information. Even after the termination of our employment with GT, we must continue to protect confidential information from unauthorized use or disclosure

5.3 keeping records

Accurate records are essential and form the basis for meeting GT's legal, financial and management obligations. In order to ensure that the financial statements truly reflect our assets and transactions, we are responsible for recording all financial transactions, such as payments, on the corresponding books in accordance with GT accounting principles and all applicable local laws

We must not register false or forged entries in the records, nor establish secret accounts or accounts outside GT. Anyone found to be involved in such activities will be subject to disciplinary action and civil and criminal liability

5.4. Protect confidential information

We must safeguard any confidential information entrusted to us and should therefore always treat confidential information accordingly. Confidential information is any information that is not generally known to the public or the industry

Even within GT, we should share confidential information only on a need to know basis

Unauthorized disclosure of confidential information may damage GT and subject the persons involved to criminal and civil liability. Even if our work at GT is over, we still have to protect confidential information

Working in GT, GT is responsible for creating a good working environment and advocating ethics, integrity and trust, not only among employees, but also for all our stakeholders, including the communities in which we operate and work. We support the goal of the International Labour Organization (ILO) to develop generally accepted labour standards, so we have implemented internal procedures and guidelines related to the topics described below

The procurement and operation management department is responsible for ensuring that major suppliers, contractors and distributors are aware of our standards

Employees should be able to communicate openly with management about working conditions without fear of retaliation, threats or harassment

6.1 prohibition of discrimination and harassment

We do not tolerate any kind of harassment or discrimination based on race, nationality, color, sex, religion, age, pregnancy, sexual orientation, physical or mental disability or political outlook. GT is committed to providing employees with an attractive working environment. We will only recruit, hire and promote employees according to their suitability for work and objective and non discriminatory standards

6.2 child labor

Child labour refers to the type and intensity of work that deprives children of the opportunity to receive education, may damage children's physical and / or mental health, or affect children's growth in the family

It deprives children of childhood and self-esteem. Under no circumstances will GT use child labour

We will always comply with the legal minimum age requirements in all countries where we operate and will never hire children under the age of 16. If we employ children between the ages of 16 and 18, we will ensure that the job does not affect or hinder their educational opportunities or obligations, nor endanger their health and safety

6.3 forced labor

Forced labour, bonded labour, indentured labour, involuntary prison labour, slave labour or traffickers shall not be employed. We will only hire people who work for their own will directly or through other third parties (such as labor agents). When employees start working for GT, they are not allowed to charge recruitment fees and related expenses, and they are not allowed to detain any employee's ID card. Unless otherwise provided by local law, individuals are free to terminate their employment with GT in accordance with any applicable notice requirements

6.4 rights of the organization

GT recognizes that employees have the freedom to establish or join an organization by themselves and respects this right. We will not hire employees on the condition that they must join or leave the union

GT respects the rights of trade unions and other employee organizations. Where appropriate, GT will participate in the negotiation process on its own behalf or through the employers' Association. In order to reach agreement on the terms and conditions proposed by employees, we fully respect local rights and joint decisions

6.5 remuneration

Our compensation shall comply with all applicable compensation laws, including those relating to minimum pay, overtime and statutory mandatory benefits. Before accepting employment, we should have a clear and detailed understanding of the composition of compensation and benefits

6.6 working hours

Our working week should not exceed the maximum time stipulated by local laws, and should not exceed 60 hours, including overtime, except in emergencies or exceptions that need to meet short-term business needs. We have the right to take at least one day off every seven days. Overtime work is voluntary unless it is agreed in a collective labor agreement or labor contract, or in emergencies or exceptions that need to meet short-term business needs

6.7 health and safety

GT is committed to providing a healthy and safe working environment, avoiding harm to us and promoting our healthy development. Health and safety plans, rules and regulations apply to all factories. We are responsible for following the health and safety plans, rules and regulations to maintain the safety of the workplace

GT will provide clean toilet facilities, drinking water and clean food preparation and storage facilities. GT or relevant third parties will provide clean and safe workers' quarters, which shall be equipped with emergency exits, adequate heating and ventilation facilities and reasonable personal space

It is our responsibility to immediately report accidents, casualties and any unsafe equipment, practices or conditions to our supervisor or other relevant resources

6.8 social media

When disclosing our relationship with GT, we should act on behalf of GT. We use social media in a responsible and respectful manner and do not use offensive or insulting language. We respect competitors, customers or other stakeholders and do not

Damage GT's reputation. We do not disclose, comment on or discuss confidential information, including financial information, business plans, intellectual property rights or other employees

external activities

7.1 lobbying and political activities

As part of our business, we need to interact with governments, government organizations, industry associations and other interest groups. To this end, we must abide by the laws applicable to political activities

We will never pay political candidates or support political activities on behalf of GT. As a general rule, we do not pay consulting fees, payments or donations to political parties, organizations or politicians in cash or in kind

In order to prevent deviation from this principle, such behavior should be clearly approved by the relevant management, in which case all requirements for public disclosure should be fully complied with

7.2 environment

As a company, we follow corresponding design, manufacturing, distribution and handling practices to prevent or minimize the impact of our activities and products on the environment. A number of environmental laws, standards, requirements and policies apply to our global business operation and management activities. It is our responsibility to understand and comply with such requirements

waiver

GT wishes to make this specification comply with all applicable laws and regulations. If necessary, the implementation and application of the provisions of this specification may be modified to ensure that certain local requirements are met. Although GT expects that there are no exceptions to this specification, there may be situations where a provision of this specification needs to be waived when appropriate or necessary. Waivers for GT executives and directors must be approved by the GT board of directors. It will then be publicly disclosed in accordance with the applicable listing requirements. All other waivers must be approved by the CEO and the chief legal officer