Zhanxing has always attached great importance to corporate compliance and honest operation, and is committed to conducting business on the basis of fairness, impartiality, and openness. In the process of conducting business both domestically and overseas, Zhanxing adheres to the applicable anti-corruption and anti bribery laws and regulations of various countries, and firmly opposes any form of corruption and bribery. To this end, Zhanxing has formulated the "Compliance Code of Conduct for Zhanxing Overseas Business Employees" (hereinafter referred to as the "Code of Conduct"), which provides comprehensive requirements for Zhanxing overseas business employees to conduct business from six perspectives: basic principles, internal behavior compliance requirements, external behavior compliance requirements, other personal behavior standards, management's compliance responsibilities, and consultation, reporting, and violation handling. At the same time, in order to attach absolute importance to overseas anti-corruption and anti bribery related matters, Zhanxing has formulated this "Haimuxing Anti Corruption and Anti Bribery Policy" (hereinafter referred to as the "Anti Corruption Compliance Policy") to further regulate matters not covered in this field.

This anti-corruption compliance policy applies to all employees of Zhanxing and those acting on behalf of the company. All relevant parties should abide by and maintain the anti-corruption and anti bribery policies formulated by Zhanxing. If this anti-corruption compliance policy is inconsistent with local laws and regulations, the stricter requirement shall prevail.

Zhanxing is committed to establishing its own anti-corruption and bribery compliance system from five dimensions: leadership, support, process, supervision, and optimization

Leadership level

The senior management of Zhanxing attaches great importance to the anti-corruption and bribery compliance work within the company. Zhanxing has established an internal supervision department responsible for anti-corruption and bribery compliance within the company, and has also set up an audit committee for the company. The company's leadership has made the "Executive Anti Corruption Compliance Commitment" and implemented this anti-corruption and bribery compliance system and supporting policies within the company, clarifying the company's attitude and goals towards corrupt and bribery behavior, and making the "Zhanxing Anti Corruption Compliance Commitment", committed to laying a solid foundation for the development of the enterprise in compliance and integrity management, and establishing an effective, supervised, and continuously optimized anti-corruption and bribery management system.

Support level

In order to support the establishment and sound operation of the company's anti-corruption and bribery management system, Zhanxing provides sufficient resource support to relevant departments within the group, conducts anti-corruption and bribery related training and publicity for executives and employees, and is committed to enabling every member of the company to learn and grasp the red lines in their own work process, and to be the first line of defense in anti-corruption and bribery work.

Process level

In specific areas such as the signing of employment and declaration documents for suppliers and other third parties, hospitality and travel, procurement transactions, etc., Spreadtrum has established clear and specific process approval requirements and steps. Through clear rules to ensure the effective implementation of the system, the possibility of corruption and bribery is reduced from the top-level design, and the second line of defense for anti-corruption and bribery work is done well.

Supervisory level

The Supervision Department of Zhanxing conducts regular compliance audits to identify risky behaviors within the company and evaluate the implementation of company policies. At the same time, Zhanxing encourages relevant personnel to provide relevant clues through clear reporting channels and relevant responsible departments, making effective supervision and regular evaluation the third line of defense for Zhanxing's anti-corruption and bribery work.

Optimization level

For the problems discovered through the supervision system, Zhanxing adheres to the attitude of holding those who have problems accountable. Through investigation and research, relevant facts and problems will be clarified, and relevant measures will be taken based on the investigation results. Through continuous supervision and improvement, Zhanxing optimizes its shortcomings in the field of anti-corruption and bribery compliance, and continuously iterates, updates, and improves its compliance system.

Legal red line

Zhanxing strictly prohibits bribery in both commercial and public domains. In the public domain, this anti-corruption compliance policy prohibits relevant entities from directly or indirectly providing, promising, authorizing, or giving any valuable items or benefits to "public officials" and their families in order to obtain or retain business or improper benefits. The above-mentioned "public officials" not only include officials serving in foreign governments and their departments, but also personnel of enterprises, public international organizations owned or controlled by foreign governments and performing government functions, and even individuals acting on behalf of these entities and other people engaged in public services.

In the business field, Zhanxing also prohibits company employees from providing, promising, authorizing or giving anything of value to any personnel and their families of private enterprises, in order to improperly influence the recipient to make or not make any behavior that violates their duties in such private enterprises, and thus obtain improper benefits. At the same time, Zhanxing also prohibits its employees from accepting valuable items provided, promised, authorized or given by any entity with the above-mentioned corrupt purposes

Similarly, Zhanxing strictly prohibits relevant entities from evading the supervision of the company's anti-corruption and bribery compliance system through illegal means such as providing false materials, fabricating and concealing facts, and concealing the source of funds to cause discrepancies between accounts and reality