Tingyi (Cayman Islands) Holding Corp.

Supplier Code of Conduct

Preamble

Tingyi (Cayman Islands) Holding Corp. (hereinafter referred to as “Master Kong”, “the Company” or “We”) places the highest standards of business ethics and professional integrity at the heart of its operation and is committed to practice sustainable development concept. The ten principles of the United Nations Global Compact (UNGC) covering human rights, labor, environment and anti-corruption align with Master Kong’s core values.

This Code of Conduct is designed to ensure that all suppliers meet Master Kong’s requirements and are encouraged to follow UNGC principles: to safeguard fundamental employee rights and fair working conditions, to advance green manufacturing and resource circulation, and to prevent all forms of corruption. We look forward to working with our suppliers to build a transparent, responsible and sustainable supply-chain ecosystem that delivers shared value for business, society and the environment.

Part 1: Business Ethics

1. Anti-Corruption

Suppliers must strictly comply with all applicable laws and regulations and resolutely eliminate any form of corruption. This includes but is not limited to:

50. Prohibiting the act of directly or indirectly offering bribes or facilitation payments, engaging in fraud, extortion, collusion or money-laundering, or otherwise abusing authority for personal gain.
50. Prohibiting the act of offering or accepting gifts, loans, fees, rewards or other benefits to or from any individual or entity as an inducement to act contrary to principles of integrity or legal requirements.
50. Establishing internal control mechanisms and conducting periodic audits of high-risk business areas to ensure that corruption risks can be identified and controlled.

2. Avoiding Conflict of Interest

Suppliers shall proactively identify and avoid any conduct or relationship that could lead to a potential or actual conflict between their own interests (or those of their employees) and the interests of Master Kong. Should any such conflict arise, suppliers must:

50. Immediately disclose to Master Kong full details of the conflict and its potential impact.
50. Prepare a mitigation plan (e.g., recusal from decision-making, third-party oversight, etc.) that may be implemented only after review and approval by Master Kong.
50. Avoid exploiting the conflict of interest in any manner to obtain an improper business advantage.

3. Anti-Unfair Competition

Suppliers must ensure that all business activities comply with antitrust laws, anti-unfair competition laws and all related regulations, and are strictly prohibited from engaging in any conduct that restricts market competition. Master Kong’s requirements include but are not limited to: 

50. Suppliers are strictly prohibited from colluding with competitors to fix prices, divide markets, restrict output, or abusing a dominant market position to impose forced transactions, tie-in sales, or discriminatory pricing. 
50. Any manipulation of procurement processes through sham bidding, bid-rigging, or similar means is likewise forbidden.
50. Suppliers shall conduct regular assessments of their business models to ensure that no business activities involve anti-competitive, monopolistic, or other unfair competitive practices.

Part 2: Environment

1. Greenhouse Gas and Energy Consumption

Suppliers shall prioritize the management of greenhouse gas emissions from their operations, identifying and monitoring both direct and indirect emission sources. Renewable energy should be the preferred option, and equipment upgrades together with process optimization shall be implemented to improve energy efficiency and drive low-carbon production and operation.

2. Pollutant and Waste Management

Suppliers shall strengthen the management of pollutants and waste, control the generation of pollutants and waste in their operations, and handle all pollutants and waste in accordance with applicable environmental laws, regulations and policies. They must continuously monitor the discharge of pollutants and waste to ensure that all emissions remain within the limits set by the relevant standards.

3. Resource Utilization

Suppliers shall proactively identify areas within their operations where resource efficiency can be improved and adopt suitable measures such as implementing resource management systems, regularly evaluating resource consumption patterns, and exploring circular economy models to improve the efficiency of water, raw materials, packaging materials, and other resources.

4. Biodiversity and Ecosystem Protection

Suppliers shall minimize the impact of their operations on ecosystems and biodiversity and avoid any deforestation activities. They should adopt measures such as planting trees and turf on land suitable for greening to reduce the duration of soil exposure and protect the land.

Part 3: Human Rights and Labor Practice

1. Forced Labor

Suppliers must ensure that all employment is voluntary and shall prohibit any form of forced labor. They must not restrict employees’ freedom of movement or recruit or transfer workers through threats, coercion, or other compulsory means.

2. Child Labor

Suppliers shall strictly comply with all applicable laws and regulations on minimum working age and must effectively verify employees’ ages during recruitment. Any form of child labor is strictly prohibited.

3. Working Conditions

Suppliers shall provide employees with reasonable working conditions, including but not limited to working hours, work environment, leave, wages and benefits that comply with national legal requirements.

4. Occupational Health and Safety

Suppliers must establish an effective safety-management system, provide employees with a comfortable, healthy and safe working environment, and take measures to safeguard occupational health and ensure safe production.

5. Discrimination and Harassment

Suppliers must prohibit all forms of discrimination or harassment in recruitment and the workplace, including but not limited to physical, sexual, psychological or verbal harassment, abuse or other improper treatment. A robust supervision and reporting mechanism shall be established to ensure that employees can file complaints anonymously or by name and free from retaliation. Any suspected conduct must trigger an immediate investigation that is fair and transparent. Corrective action (such as penalty, training or system improvements) must be taken based on the findings to safeguard employees’ lawful rights and interests.

6. Freedom of Association and Collective Bargaining

Suppliers shall respect employees’ freedom of association and their right of collective bargaining. They must not interfere with workers joining or participating in trade union activities by any means. In collective negotiations, suppliers shall act in good faith and on an equal footing, and must strictly observe all agreements reached.

The ultimate right to interpret all the foregoing clauses is reserved exclusively to Master Kong. Suppliers are obligated to retain, to the fullest extent possible, all documents and records relating to these clauses to demonstrate their strict compliance with this Code and all applicable laws and regulations. Upon request by Master Kong, suppliers must agree to furnish such documents to Master Kong or to any auditor designated by Master Kong as conclusive evidence of their adherence. Where circumstances warrant, Master Kong reserves the right to conduct on-site inspections of suppliers’ workplaces and facilities to verify their compliance status.

Master Kong periodically reviews this Code of Conduct and revises it in line with the latest laws, regulatory developments and business conditions. Suppliers must keep themselves informed of any updates and ensure their conduct remains in full compliance with this Code.

Source: