SAVIC Vendor Code of Conduct

Introduction

Being a trusted partner for our customers, partners, suppliers, and colleagues has always been at the heart of our business. Ethical business builds trust and helps the world run better. We are committed to the highest ethical business standards and expect the same from our ecosystem. Our Codes of Conduct for employees, partners, and suppliers are cornerstones of this commitment to integrity.

The SAVIC Supplier Code of Conduct ("Supplier Code") summarizes the ethical principles of the SAVIC Global Procurement Organization. It builds on SAVIC's commitment to the International Labour Organization's (ILO) Core Labour Rights Conventions, the United Nations Global Compact, and the International Bill of Human Rights. We take guidance from international frameworks such as the United Nations Guiding Principles (UNGPs) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct to integrate human rights considerations into our standard business practices, policies, and processes.

The following guidelines set forth the framework of acceptable conduct SAVIC expects from its contractors, consultants, suppliers, vendors, agents, and all other third-party companies that comprise SAVIC's supply chain ("Suppliers"). Therefore, SAVIC's Suppliers must implement the requirements of this Supplier Code in their operations, as well as in their supply chains.

All work performed for SAVIC must be in full compliance with this Supplier Code and all applicable laws, rules, regulations, and policies. For Suppliers who have employees contracted to work directly for SAVIC, these guidelines must be reviewed with all employees and subcontractors working on SAVIC matters.

We expect our employees and our Suppliers to conduct themselves in an upright, safe, and professional manner, to treat others with respect, fairness, and dignity, and to refrain from any action that may be considered a conflict of interest while working for and on behalf of SAVIC. We regard our supplier base as a critical and necessary extension of our operations and future success, and we thank you for continuing to make compliance and integrity a top priority as you work with SAVIC. Failure to comply with the Supplier Code during business with SAVIC will lead to your disqualification as an accepted Supplier and will eliminate you from consideration of new business with SAVIC. You also commit to the obligation of reporting to SAVIC any (suspected) violation of this Supplier Code and any law or regulation, as you become aware of it. You can do so confidentially and, if desired, anonymously (see the "Reporting Channel" section below). We expect our Suppliers to confirm that all subcontractors are equally compliant with our policies and Supplier Code.

SAVIC has the right to conduct various types of risk-based due diligence on any Supplier at any time, which may include requesting information about the Supplier, requesting copies of its compliance policies and programs, and gathering certifications and other documentation. SAVIC Suppliers are expected to comply fully with any information requests required by SAVIC to carry out due diligence checks, including due diligence renewal and audit requests. In addition, SAVIC may request Suppliers to conduct training or interviews with relevant personnel and to include any specific provisions in the applicable contract with SAVIC. If any remedial measures are agreed upon between SAVIC and a Supplier to achieve the necessary level of compliance, the Supplier is required to commit to these in writing via a contract or an amendment to a contract. Any change in a Supplier's ownership, senior management, corporate structure, business lines or model, key personnel, subcontractors, or any other factor that might reasonably affect SAVIC's risk evaluation must be communicated promptly. Failure to supply information upon request or not meeting due diligence requirements may lead to application rejection or delays.

All work performed for SAVIC must be in full compliance with this SAVIC Supplier Code of Conduct and all applicable laws, rules, regulations, and policies.

Compliance With Laws, Rules, And Regulations

As a Supplier, you agree to abide by the terms of SAVIC's Supplier Code and acknowledge that compliance with this Code is required to maintain your status as a SAVIC Supplier. You agree that all business conducted on behalf of SAVIC shall be accomplished in full compliance with applicable laws, rules, regulations, and policies. If local laws are less restrictive than the principles set forth in SAVIC's Supplier Code of Conduct, Suppliers are expected to, at a minimum, comply with the Code. If local laws are more restrictive than SAVIC's Supplier Code of Conduct, Suppliers are expected to, at a minimum, comply with applicable local laws.

Bribery and Corruption

SAVIC has zero tolerance for all forms of bribery and corruption. Suppliers shall not make, authorize, or offer any bribes, kickbacks, or payments of money or anything of value to anyone, including officials, employees, or representatives of any government or public or international organization, or to any other third party (public or private sector) to obtain or retain business, or influence any other favorable business decision, that is related in any way to SAVIC. This includes giving money or anything of value to anyone when there is reason to believe that it will be passed on to a government official or the decision maker at a customer or potential customer's company for this purpose. Suppliers are required to comply with the German Criminal Code, the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and all applicable local anti-bribery laws.

Fair Competition

Antitrust and competition laws are designed to protect consumers and competitors against unfair business practices and promote and protect healthy competition. SAVIC is committed to observing the applicable antitrust or competition laws of all nations or organizations, and SAVIC expects its Suppliers to comply with all applicable antitrust or competition laws as well. Antitrust or competition laws vary from country to country, but generally such laws prohibit agreements or actions that unreasonably restrain trade, are deceptive or misleading, or unreasonably reduce competition without providing beneficial effects to consumers. Such agreements or actions are against the policy of SAVIC.

Securities and Insider Trading

SAVIC expects Suppliers to comply with applicable insider trading and securities laws governing transactions in the securities of SAVIC. Securities include common stocks, bonds, options, futures, and other financial instruments. Suppliers that possess or have access to material and/or nonpublic information gained through their work with SAVIC may not use that information to trade in SAVIC securities or the securities of another company to which the information pertains. Employees of such Suppliers may not engage in any other action to take advantage of, or pass on to others, material information gained through work with SAVIC until a reasonable time after full public disclosure has occurred. These restrictions also apply to family members, friends, and associates. Material information includes any information that a reasonable investor would consider important in a decision to buy, hold, or sell securities. Such information may include financial and key business data; merger, acquisition, or divestiture discussions; award or information related to the cancellation of a major contract; changes in key management; forecasts of unanticipated financial results; significant litigation; or gain or loss of a substantial customer or supplier.

Human Rights

Suppliers are expected to respect internationally proclaimed human rights according to the expectations of the UNGPs and all relevant applicable national and international laws, in particular as they apply to supply chains and operations. Suppliers must also comply with all applicable employment and related laws (including those aimed at eradicating modern slavery) and are expected to meet in full their obligations under such laws and, at minimum, Suppliers need to comply with the provisions of this Code.

Export Control and Trade Sanctions

End-User Restrictions: Suppliers shall ensure that the provisioning of products and services to SAVIC is not supported by entities and individuals with whom transactions are prohibited under applicable export control and sanctions laws, including those listed on any applicable sanctioned party lists (e.g. European Union Consolidated Sanctions List, U.S. Specially Designated National (SDN) lists, U.S. Denied Persons List, BIS Entity List, United Nations Security Council Sanctions).

Covered Telecommunications Equipment or Services: Suppliers will not supply SAVIC with any "covered telecommunications equipment or services" as more specifically described in the United States Federal Acquisition Regulation clause 52.204-25, "Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment".

Regulations for Specific Substances: Suppliers must adhere to all applicable laws and regulations regarding the prohibition or restriction of specific substances, including labeling laws and regulations for recycling and disposal. Suppliers are also to adhere to processes to comply with each agreed-upon customer-specific restricted and hazardous materials list.

Software with Artificial Intelligence (AI) Capabilities: If SAVIC is supplied with software that has embedded AI capabilities, the Supplier should adhere to all relevant local laws related to ethical and responsible AI while developing, deploying, and selling the software. If there are no locally applicable laws, the Supplier should have a policy based on the guidelines from international institutions (e.g. the Institute of Electrical and Electronics Engineers, the Organization for Economic Co-operation and Development, Council of Europe). The same applies to the Supplier's supply chain: if the Supplier is using third-party software with embedded AI, the Supplier should ensure that local laws and/or policies for ethical and responsible AI have been considered while procuring, deploying, and using the software.

You agree to abide by the terms of SAVIC's Supplier Code and acknowledge that compliance with this Code is required to maintain your status as a SAVIC Supplier.

Labour and Human Rights Standards

Suppliers are committed to upholding the human rights of workers and treating them with dignity and respect as understood by international human rights law. SAVIC respects and upholds the values of the International Bill of Human Rights and the International Labour Organization's (ILO) Core Labour Rights Conventions and takes guidance from international frameworks such as the United Nations' Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. Suppliers are expected to enforce these labour and human rights standards in their own operations and ensure that they are passed on to their downstream partners in the supplier network. Suppliers must take all reasonable measures to avoid and/or mitigate any labour and human rights risks and must provide access to remedy in case of human rights abuses.

Modern Slavery and Freely Chosen Employment

Suppliers must not use any form of modern slavery or forced, bonded, or indentured labour. All work must be voluntary, and workers should be free to leave or be terminated from employment with reasonable notice. Worker freedoms must not be forfeited, such as by withholding documents or restricting movement. Suppliers or third parties must not charge illegal fees and deductions during recruitment and employment. Suppliers will not participate in human trafficking or use slave labour or prison labour in any part of their supply chain. All workers (including migrant workers and their family members) shall not be threatened with denunciation to authorities to coerce them into taking up or maintaining employment. Suppliers are expected to take all reasonably practicable steps to ensure that participants in their supply chains do not engage in conduct amounting to modern slavery.

Child Labour Avoidance

Child labour is not tolerated at any stage of the supply chain. Child labour refers to a person working under the statutory minimum age set by the International Labour Organization, which is 15 years. Suppliers must avoid any sort of child labour in their operations as defined by the International Labour Organization (ILO Convention No. 138). If local minimum age law specifies a higher age for work, the higher age applies. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Young workers must not do work that is mentally, physically, socially, or morally hazardous and must be restricted from night shifts, with consideration given to educational needs.

Working Hours

Workweeks should not exceed the maximum set by local law and by ILO Standards (ILO Convention No. 1). Further, a workweek should not be more than 60 hours per week including overtime, which must only be voluntary. Exceptions apply to emergency or unusual situations. Workers shall be allowed at least one day off per seven-day week (ILO Convention No. 14).

Wages and Benefits

SAVIC expects its Suppliers to adhere to minimum wage laws. All benefits required by local laws must be provided. Payments must be made regularly and directly to workers, and overtime must be remunerated at a premium rate. Deductions from or withholding of payments must be in alignment with local laws only, and workers must have full understanding of the actions taken. The same applies to advances and loans. Workers must receive information about hours worked, rates of pay, and the calculation of legal deductions. Workers must retain full control over their earnings. Wage deductions as a disciplinary measure, or to keep workers tied to the employer or to their jobs, are prohibited. Holding workers in debt bondage, forcing them to work to pay off a debt, and deception in wage commitments, payments, advances, and loans are prohibited.

Harassment, Violence, and Inhumane Treatment

SAVIC takes a zero-tolerance approach towards harassment, violence, and inhumane treatment as defined in ILO Convention No. 190, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, or verbal abuse of workers; nor is there to be the threat of any such treatment.

Non-Discrimination

Suppliers are expected to be committed to a workplace free of unlawful discrimination. Suppliers shall not engage in discrimination based on culture, race, colour, age, gender, gender identity or expression, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.

Freedom of Association

Suppliers are to respect the rights of workers to associate freely, join or not join labour unions, seek representation, or join workers' councils in accordance with local laws. Workers shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.

Contracts of Employment

All workers, including migrant workers, shall be provided with an employment contract in a language they understand, clearly indicating their rights and responsibilities regarding all working and employment conditions before deployment, including but not limited to wages and working hours. Any changes to the employment contract and the working conditions agreed upon must be in alignment with local laws and fully transparent to the migrant worker.

Unlawful Eviction and Deprivation

There shall be no unlawful eviction and unlawful deprivation of land, forests, and waters in the acquisition, construction, or any other use of land, forests, and waters, the use of which secures the livelihood of a person.

Security Forces

SAVIC expects Suppliers that hire or use private or public security forces or personnel to provide instruction or control to avoid torture and cruel, inhumane, or degrading treatment; risks to life or limb; or impairment of the freedom of association.

Suppliers are committed to upholding the human rights of workers and treating them with dignity and respect as understood by international human rights law.

Health and Safety

Suppliers recognize that the quality of products and services, consistency of production, and workers' morale are enhanced by a safe and healthy work environment. Suppliers must take all reasonable measures to avoid and/or mitigate any health and safety risks. Suppliers also recognize that ongoing worker input and education are key to identifying and solving health and safety issues in the workplace.

Suppliers shall prevent worker exposure to potential safety hazards (for example, electrical and other energy sources, fire, vehicle, and fall hazards) and make sure that such hazards are mitigated through proper design, engineering and administrative controls, preventive maintenance, and safe work procedures (including lockout-tagout). Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate personal protective equipment. Suppliers must identify and assess emergencies and events and minimize their impact by implementing emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities, and recovery plans.

Procedures and systems are to be in place to manage, track, and report occupational injury and illness, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases, implement corrective actions to eliminate their causes, and facilitate the return of workers to work. Suppliers identify, evaluate, and control worker exposure to chemical, biological, and physical agents, as well as to physically demanding tasks including manual material handling and heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks. Physical guards, interlocks, and barriers are to be provided and properly maintained for machinery used by workers.

Suppliers provide workers with clean toilet facilities, access to potable water, and sanitary food preparation and storage facilities. Worker dormitories provided by the Supplier, or a labour agent, are to be clean and safe, and provide emergency egress, adequate heat and ventilation, and reasonable personal space.

Diversity and Inclusion

Suppliers are encouraged to provide an inclusive, healthy, bias-free work environment for their employees. Suppliers should, as applicable, strive to foster:

• Gender intelligence, by offering equal rights for all employees, regardless of gender identity.
• Cross-generational intelligence, by employing people of all ages and at every work and career stage.
• Cultural and identity intelligence, by empowering many voices to help gain strength from people's differences.
• Opportunities for differently abled people, by focusing on their unique abilities and providing a work environment that considers the special needs and skills of each employee. Suppliers are encouraged to engage with groups at heightened risk of becoming disadvantaged or marginalized (vulnerable groups).

Accessibility

Suppliers are encouraged to deliver goods and services that are accessible to everyone, including those with disabilities. Where accessibility standards — for example, Web Content Accessibility Guidelines (WCAG) 2.0 Level AA (included in US Section 508), the harmonized EN 301 549 including WCAG 2.1 Level AA, and Germany's Barrier-Free Information Technology Regulation (BITV) — are applicable to the goods or services delivered, Suppliers are strongly encouraged to consider and meet these standards.

Diverse and Inclusive Supply Chain

SAVIC strives to work with a wide range of high-quality social enterprises and diverse Suppliers to drive innovation in its supply chain. SAVIC is committed to buying directly from social enterprises and diverse Suppliers whenever possible. SAVIC expects Suppliers to commit to proactively subcontracting goods and services in their supply chain to a social enterprise or diverse supplier whenever possible. Suppliers are required to provide quarterly reports on their expenditures with diverse subcontractors, itemized according to the following categories: Women-Owned, Minority-Owned, Veteran-Owned, LGBTQ+ Owned, Small and Medium-Sized, Disabled-Owned Business Enterprises, and other acknowledged diverse groups. SAVIC will review reports for adherence to this Code and to identify improvement opportunities.

Suppliers are encouraged to provide an inclusive, healthy, bias-free work environment for their employees.

Environmental Standards

At SAVIC, our dedication to environmental responsibility extends beyond compliance. We continuously strive to mitigate our ecological footprint through our procurement practices. This section outlines the environmental standards and expectations we have for our suppliers. Adherence to these guidelines is crucial as it significantly contributes to our collective pursuit of a sustainable and environmentally conscious supply chain. Environmental responsibility is integral to producing world-class products. Suppliers must take all reasonable measures to avoid and/or mitigate any environmental risks.

In manufacturing operations, adverse effects on the community, environment, and natural resources must be continually reduced and minimized, and suppliers are expected to ensure that their operations safeguard the health and safety of the public. All required environmental permits (for example, discharge monitoring) and registrations are to be obtained, maintained, and kept current, and their operational and reporting requirements are to be followed. Suppliers are expected to contribute to our environmental objectives stated in the SAVIC Global Environmental Policy and collaborate with us to improve the environmental performance of SAVIC and our purchased products and services. Suppliers acknowledge the SAVIC Global Environmental Policy by accepting the SAVIC Supplier Code of Conduct.

Environmental Management System (EMS)

Suppliers are required to implement and maintain an EMS compliant with ISO 14001 or an equivalent standard. This system should encompass energy consumption metrics, waste management procedures, emission control measures, risk management and mitigation procedures, and periodic internal and third-party audits. Suppliers should continually improve their EMS by setting achievable environmental objectives and targets.

Greenhouse Gas (GHG) Emissions

SAVIC is committed to becoming net-zero by 2030 along the value chain, in line with the Science-Based Targets Initiative. To achieve our target and limit global temperature rise to 1.5°C to mitigate the adverse impacts of climate change, we must closely collaborate with our suppliers and rely on their contribution. Therefore, we require the following from Suppliers transacting over €1 million annually:

• Established GHG emission targets, or at least an ambition to implement one. This requires measuring, monitoring, and reporting by established standards such as the GHG Protocol. Minimum requirement: annual disclosure of Scope 1 and Scope 2 emissions, with continuous improvement of Scope 3 emissions accounting and reporting.
• An ambition or target to reduce energy consumption and use renewable energy in own operations through self-production, long-term Power Purchase Agreements (PPAs), or Energy Attribute Certificates such as Renewable Energy Certificates (RECs). This can be supported by an ISO 50001 Energy Management System, an RE100 commitment, or similar certificates, accreditations, and commitments. Minimum requirement: annual disclosure of renewable electricity share in the supplier's operations.
• Third-party verification of environmental data and reduction efforts is expected.

Waste

Suppliers are expected to have a lifecycle perspective and Extended Producer Responsibility (EPR) to manage resources and waste circularly. Suppliers must follow the Waste Hierarchy to properly manage waste: prevent, prepare for reuse, recycle, recover, and, as the last option, disposal. Hazardous materials, if released into the environment, are to be identified and properly managed. Wastewater and solid waste generated from operations, industrial processes, and sanitation facilities are to be monitored, controlled, and treated. Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting chemicals, and combustion byproducts generated from operations are to be characterized, monitored, controlled, and treated.

Environmental Standards with Impact on Human Rights

In light of the Minamata Convention on mercury, the Stockholm Convention on persistent organic pollutants, and the Basel Convention on the control of transboundary movements of hazardous wastes and their disposal, Suppliers must avoid causing harmful soil change, water pollution, air pollution, harmful noise emission, or excessive water consumption that would: (a) substantially impair the natural foundations for the preservation and production of food; (b) deny a person access to safe drinking water; (c) impede or destroy a person's access to sanitary facilities; or (d) harm the health of a person. SAVIC strives to eliminate the consumption of single-use plastics. Suppliers should therefore make every effort to eliminate unnecessary packaging components, replace plastic packaging materials with environmentally friendly materials such as certified recycled paperboard packaging (e.g. FSC), and eliminate Styrofoam material.

SAVIC will conduct periodic audits to assess compliance with this section. Non-compliance may trigger corrective action, up to and including potential termination of the supplier relationship.

We continuously strive to mitigate our ecological footprint through our procurement practices.

Management System

Suppliers shall adopt or establish a management system with a scope related to the content of this Code. The management system shall be designed to ensure compliance with applicable laws (including human rights), regulations, and customer requirements related to Supplier operations and products, as well as conformance with this Code and the identification and mitigation of operational risks related to this Code.

Suppliers should also integrate their supply chain into the management system, and it should facilitate continual improvement. Suppliers commit to the statements on corporate social and environmental responsibility, affirming compliance and continual improvement. Suppliers hold clearly identified company representatives responsible for ensuring implementation and periodic review of the status of the management system. Suppliers identify, monitor, and understand applicable laws, regulations, and customer requirements. Suppliers establish a process to regularly and, on an ad hoc basis, identify the human rights, environmental, health, safety, and labour practice risks associated with their operations and their subcontractors' operations.

Suppliers should also establish preventative measures for their employees and subcontractors. Suppliers determine the relative significance of each risk and implement appropriate procedural and physical controls to ensure regulatory compliance and control identified risks. Suppliers create and maintain written standards, performance objectives, targets, and implementation plans, including periodic assessment of Supplier performance against those objectives; results should be communicated to relevant decision-makers at the Supplier. Suppliers establish programs for training managers and workers to implement Supplier policies and procedures, and establish and monitor ongoing processes to assess employees' understanding of, and obtain feedback on, practices and conditions covered by this Code.

Periodic self-evaluations shall be conducted by Suppliers to ensure conformity to legal and regulatory requirements, the content of the Code, and requirements related to social and environmental responsibility. Suppliers are expected to establish and maintain a publicly accessible and anonymous complaint procedure for people to report workplace complaints, including human rights and environmental risks and violations. Suppliers must protect whistle-blower confidentiality and prohibit retaliation. Suppliers establish a process for timely correction of deficiencies and the creation of documents and records to ensure compliance and conformity, with appropriate confidentiality to protect privacy. Documents and records must be made available to SAVIC upon request.

The management system shall be designed to ensure compliance with applicable laws, regulations, and customer requirements related to supplier operations and products.

Responsibility for Company Resources

Suppliers are expected to safeguard SAVIC resources, which include property, assets, intellectual property, company technology assets (network, phone, internet, software applications, and email systems), trade secrets, and other confidential, proprietary, and/or sensitive information while performing work for SAVIC. Use of SAVIC resources without proper approvals, or for anything other than to perform SAVIC work activities, is strictly prohibited. The intellectual property rights of SAVIC must be protected, as must SAVIC confidential or sensitive information.

Suppliers may only possess such information if they need to do so to perform work activities. Suppliers should not use this information for gain or advantage and should never share it without appropriate SAVIC approval. All confidential or sensitive information obtained by the Supplier must have documented authorization in place. Inappropriate use of SAVIC internet or email is strictly prohibited. Suppliers are expected to safeguard confidential information by not reproducing copyrighted software, documentation, or other materials without permission, and by not transferring, publishing, using, or disclosing it other than as necessary in the ordinary course of business or as directed or authorized. Suppliers should observe applicable data privacy standards.

Materials that contain confidential information, or that are protected by privacy standards, should be stored securely and shared only internally with employees who "need to know." For example, SAVIC confidential information may include, but is not limited to, software and other inventions or developments (regardless of stage of development) developed or licensed by or for SAVIC, marketing and sales plans, competitive analyses, product development plans, pricing, potential contracts or acquisitions, business and financial plans or forecasts, and prospect, customer, and employee information. SAVIC retains the right to monitor its assets and work environments in compliance with applicable federal, state, and local laws, in order to promote safety, prevent criminal activity, investigate alleged misconduct and security violations, manage information systems, and for other business reasons.

Suppliers are expected to safeguard SAVIC resources, which include property, assets, intellectual property, company technology assets, trade secrets, and other confidential, proprietary, and/or sensitive information while performing work for SAVIC.

Business Conduct

SAVIC expects Suppliers to compete in a fair and ethical manner for all business opportunities. Suppliers' employees involved in the sale or licensing of products and services, and the negotiation of agreements and contracts with SAVIC, must ensure that all statements, communications, and representations to SAVIC are accurate and truthful.

Conflicts of Interest

While engaged in work for SAVIC, Suppliers must exercise reasonable care and diligence to avoid any actions or situations that could result in a potential conflict of interest or the appearance thereof. A potential conflict of interest arises when a Supplier's private or financial interests collide, or may be perceived to collide, with those of SAVIC. While there is no exhaustive list of such situations, potential conflicts of interest typically arise if a Supplier:

• Employs a current SAVIC employee, or someone with a close personal relationship to a SAVIC employee, to perform work for SAVIC.
• Is partially or fully owned or controlled by a current SAVIC employee, or someone with whom that employee has a close personal relationship.
• Has access to SAVIC's proprietary information while providing goods and services to SAVIC's competitors, and uses this information to benefit itself or a competitor.
• Provides services to develop a request for proposal (RFP) to be issued by SAVIC and seeks to bid on the work covered by that RFP.
• Is engaged or overseen by a SAVIC employee with whom it has a close personal relationship.

Suppliers shall not encourage or influence current or former SAVIC employees in any manner that would cause them to disclose or provide any confidential, proprietary, or other restricted information obtained while employed by SAVIC, in order to influence SAVIC's existing or proposed commercial transactions to gain a commercial advantage. To avoid any conflict of interest or appearance thereof, SAVIC may, at its sole discretion, decide whether former SAVIC employees (for a period of twelve (12) months following the end of their employment at SAVIC) who are engaged by a Supplier may act on behalf of the Supplier in SAVIC discussions or be part of the service delivered by the Supplier to SAVIC. Suppliers are expected to cooperate with SAVIC investigations and to provide reasonable assistance as requested. SAVIC expects Suppliers to prevent, or immediately disclose in writing, a conflict of interest or the appearance of a conflict of interest as soon as possible to SAVIC's Office of Ethics & Compliance. SAVIC may require the Supplier to correct any actual or perceived conflict of interest at any time during the agreement.

Offering and Accepting Anything of Value

Giving and receiving benefits (including money, gifts, meals, and invitations to events) can help build good working relationships and goodwill among companies and individuals. However, they may also be perceived as an improper advantage and raise concerns regarding integrity and independence. They can also create a conflict of interest (or the appearance of impropriety) and even violate laws. You may not offer, promise, receive, or give anything of value to improperly influence decision-making or an action. This requirement applies to every SAVIC employee, as well as individuals and companies working with or on behalf of SAVIC, including Suppliers and those with close personal connections to the recipient.

Suppliers should use discretion and care to ensure that any benefits, especially those offered to or received by any SAVIC employee, are reasonable, appropriate, consistent with applicable local laws, and cannot be construed or appear to be designed as a bribe or improper inducement to influence the recipient and secure unfair preferential treatment. Suppliers are strictly prohibited from offering or accepting benefits for or on behalf of SAVIC. Suppliers are strongly discouraged from offering a benefit to any SAVIC employee. A general guideline for evaluating whether a benefit is appropriate is whether public disclosure would be embarrassing to the Supplier or SAVIC.

The offering or acceptance of any expenditure in connection with SAVIC business must meet the following basic principles:

• Serves a legitimate business purpose (that is, encourages or improves a business relationship) without the intention of gaining an unfair advantage.
• Does not inappropriately influence, or appear to influence, any business decision.
• Must not be offered during any pending bidding or negotiation process.
• Is made in a transparent manner and ensures adherence to all applicable laws and relevant internal policies.

Providing cash, cash equivalents, or gift cards (for example, gift cards, vouchers, cheques, or gift certificates) to SAVIC employees is strictly prohibited. Discounts and other privileges offered to a SAVIC employee as part of private transactions with customers, suppliers, competitors, and partners of SAVIC may only be accepted if these are granted to all SAVIC employees.

Suppliers must adhere to the following value limits:

• Business lunch or dinner with a customer/partner: upper limit USD 50 per person (strictly adhere to a no-liquor policy).
• Festivals / New Year gifts: upper limit USD 50 per item.

Financial Integrity

Accurate and reliable financial and business records are of critical importance in meeting SAVIC's financial, legal, and business obligations. Suppliers must not have any false or inaccurate entries in accounting books or records related to SAVIC for any reason. Suppliers' business records must be retained in accordance with record retention policies and all applicable laws and regulations. Suppliers should not knowingly shift an expense to a different accounting period.

SAVIC expects Suppliers to compete in a fair and ethical manner for all business opportunities.

Contact

For vendor onboarding or compliance queries, please email compliance@savictech.com or contact us.