China Resources Beverage (Holdings) Company Limited ("CR Beverage" or the "Company") upholds the principles of honest and fair transactions, and adheres to laws, regulations and ethical principles. The Company is committed to safeguarding the legitimate rights and interests of all stakeholders and building a business ecosystem with integrity as the cornerstone, transparency as the bond, and responsibility as the driving force.

1 Purpose

This Policy aims to guide the Company and the Company's stakeholders to consistently uphold the core values of integrity, fairness, transparency and responsibility in a complex and evolving business environment, in order to ensure that its decisions and actions not only meet legal and regulatory requirements, but also foster social trust, safeguard the interests of customers and nurture employee growth, thereby achieving the dual goals of long-term prosperity and social responsibility.

2 Scope of Application

This Policy applies to CR Beverage and its subordinate entities at all levels. All business partners, including cooperative partners, contractors and suppliers, are encouraged to comply with this Policy.

3 Applicable Laws and Regulations

The Company abides by relevant laws and regulations, including the Company Law of the PRC, the Criminal Law of the PRC, the Anti-Money Laundering Law of the PRC, the Anti-Unfair Competition Law of the PRC and the Anti-Monopoly Law of the PRC, etc. Meantime, the Company has formulated the CR Group Code of Business Conduct, thus ensuring that its business activities comply with the requirements of laws and regulations and industry ethical standards.

4 Anti-Bribery and Anti-Corruption

4.1 All employees and directors should strictly abide by applicable anti-bribery laws and regulations, and uphold the principle of anti-corruption and integrity. Any violations of anti-bribery and anti-corruption regulations will be deemed as serious crimes, regardless of time or place.

·  Receipt of Benefits: Relevant personnel are strictly prohibited from soliciting or accepting any form of benefits from any individuals or companies that conduct business with CR Beverage (including customers, suppliers and contractors). However, subject to the Policy of the Company, promotional gifts of symbolic value or voluntarily given gifts of value within the specified limit for traditional festivals or special occasions may be accepted. Any gifts which may affect personal judgment, harm the interests of the Company or raise concerns of bias or misconduct should be refused.

·  Provision of Benefits: Under no circumstances shall relevant personnel offer any benefits to any individuals or companies that conduct business with CR Beverage in an attempt to exert improper influence on the business. The selection of gifts ought to  reflect moderation and restraint, refraining from the use of cash, cash equivalents or loans, and refrain from providing overly valuable or frequent gifts to potential or existing customers;

·  Interaction with Government Officials: It is strictly forbidden to offer any kind of benefits to government officials or give prohibited benefits directly or indirectly through third parties. Gifts, entertainment or other offerings to government officials for holidays or special occasions for legitimate business purposes should be handled with extreme caution to avoid improper influence, and are subject to prior approval by the head of relevant business or functional department. Personnel with relevant authority must firmly decline any offer from a government official to trade perks and report it right away to the Company's management or compliance department;

·  Charitable Donations and Sponsorships: CR Beverage encourages and supports legal charitable donations and sponsorships, provided that such activities should strictly abide by relevant laws and regulations and ensure that no improper benefits are generated or may be generated;

·  Business Entertainment and Hospitality: Business entertainment should be conducted in the form of company activities rather than only for individuals. For meals and similar hospitality within reasonable limits, relevant personnel ensure compliance with the relevant policies of the Company and record the business purpose. It is prohibited to accept banquets offered by business-related entities or individuals, subordinate entities and suppliers, which may affect the impartial performance of duties. When accepting hospitality abroad, relevant personnel should be more cautious and avoid high-value, overly frequent invitations without clear business purposes. Any free travel or provision of travel expenses is deemed as benefits and should not be accepted without the consent of the Company.

4.2 The Company has formulated the CR Beverage Anti-Corruption Policy covering all partners, suppliers and contractors, which outlines the details of anti-bribery, anti-corruption and other relevant issues.

5 Anti-Monopoly and Anti-Unfair Competition

5.1 The Company strictly complies with laws, regulations and industry standards, including the Anti-Unfair Competition Law of the PRC and the Anti-Monopoly Law of the PRC, to ensure no occurrence of monopoly, bribery, fraud or unfair competition in its operations.

5.2 The Company firmly opposes and strictly prohibits any behavior that may damage the environment of fair competition, including but not restricted to:

·  Disclosing pricing strategies, information of business partners and business plans of the Company to the competitors;

·  Using theft, illegal intrusion, wiretapping, bribery, threats and other improper means to obtain competitive intelligence;

·  Maliciously slandering or spreading false information to harm competitors; participating in or implementing any form of monopoly agreement;

·  Abusing market dominance to engage in illegal operations;

·  Using trademarks and patents of competitors without authorization in the course of product design and promotion. 

5.3 The Company continues to strengthen the risk monitoring and internal control review, and enhance internal and external promotion and training on anti-monopoly and anti-unfair competition to raise the awareness of anti-unfair competition and anti-monopoly operations of the Company and its employees. The Company also comprehensively improves its risk management efficiency and solidifies the foundation for fair operations to ensure stable business operations.

6 Anti-Money Laundering

6.1 The Company strictly abides by domestic and international anti-money laundering laws and regulations, and adopts a zero-tolerance attitude towards money laundering, information leakage, obstruction of investigations and failure to report suspicious transactions.

6.2 The Company strictly prohibits any illegal acquisition, use or retention of criminal proceeds or any concealment of their illegal nature and sources by any means. In the meantime, the Company maintains high alert to the confidentiality of information that may disrupt anti-money laundering investigations, and prohibits disclosure to any transaction entities or third parties.

6.3 Any behavior that undermines the investigation (including fabricating, concealing or destroying documents and materials related to money laundering activities) or any failure to report suspicious cases promptly should be subject to investigation and severe punishment by the Company.

6.4 The Company encourages and advocates the employees to report abnormal transactions or suspected money laundering activities promptly, and to assist law enforcement entities in combating money laundering activities.

7 Conflicts of Interest

7.1 Directors and employees should strictly avoid any form of conflicts of interest (i. e. their personal interests should not conflict with the interests of the Company). If unavoidable conflicts of interest arise, the relevant directors or employees should submit a declaration to the Company in a timely manner before any potential or actual conflicts occur, and take active measures to properly resolve them.

7.2 Upon receiving a conflict-of-interest statement, the Company should promptly make an assessment and decide on appropriate countermeasures based on actual needs. This may include adjusting the scope of responsibilities of the relevant directors or employees, or allowing them to continue performing their duties after thoroughly assessing risks and business needs. In the meantime, the Company should inform relevant directors/employees of its decisions and issue clear guidance and instructions to ensure compliance with regulations of the Company and effectively avoid or mitigate conflicts of interest. All conflict-of-interest statements, management decisions and actions taken should be documented in detail for subsequent review.

7.3 "Insider trading" means any illegal act of buying or selling securities, leaking insider information, or advising others to buy or sell securities by any person who possesses or unlawfully obtains insider knowledge prior to its release to the public. Insider information includes financial performance, new product launches, major acquisitions and other information that has a significant impact on the stock price of the Company. The Company prohibits all directors and employees who are aware of insider information from trading shares, convertible bonds or other securities. Offenders are subject to severe penalties such as imprisonment and heavy fines.

8 Data and Privacy Security

8.1 The Company strictly abides by all applicable laws and regulations relating to privacy and personal information protection, consistently upholds business ethics and contractual spirit, and properly protects data and privacy security.

8.2 The Company attaches great importance to customer privacy and information protection, and strictly abides by laws and regulations including the Data Security Law of the PRC and the Personal Information Protection Law of the PRC. The Company continues to optimize its system construction, standardize and strengthen its own and its authorized dealers' protection of consumer personal information, and adds the "Data Security Commitment" to its dealer contracts to ensure legal and compliant sources and methods of providing personal information of the employees and end customers.

8.3 In recruitment, assessment, remuneration and other processes, the Company assigns dedicated personnel to manage employees' information of their personal resumes, family, salary and health condition, and strictly maintains confidentiality to protect their privacy rights.

9 Protection of Intellectual Property Rights

9.1 The Company strictly abides by the laws and regulations relating to intellectual property rights, and follows a series of internal systems of the Company, including the CR C'estbon Intellectual Property Rights Management System, the CR C'estbon Process Guide to Application of Intellectual Property Rights, the CR C'estbon Work Guide to Rights Protection and the CR C'estbon Process Guide to Evidence Filing for Trademark Use;

9.2 In order to protect its own intellectual property rights and respect others' intellectual property rights, the Company has established detailed processing procedures and control mechanisms for intellectual property rights management in respect of copyrights, trademark rights and patent rights of the Company and combating counterfeit and inferior products.

9.3 The Company continues to intensify the management of intellectual property rights awareness, strengthen promotion and training on the protection of intellectual property rights for the employees, and raise their attention to the protection of technological innovation achievements.

10 Environment, Health and Safety

10.1 The Company strictly abides by the requirements of national policies and regulations relating to environmental protection, health and safety, and has developed a number of internal environmental management systems, including the Identification, Risk Assessment and Control of Environmental Factors and the CR C'estbon Ecological Protection Guidelines. The Company has also formulated the CR C'estbon Quality, Environmental, Health and Safety  Management System and the CR C'estbon EHS Incentives Management Measures, which define the accountability mechanism for EHS incidents, so as to improve the supervision process and assessment system of EHS work and enhance the environmental protection and occupational health and safety management of the Company.

10.2 The Company strictly follows the occupational health and safety management system, identifies and controls potential risks, and creates a safe work environment for all employees. The Company also implements relevant preventive measures and actively carries out relevant training, promotion and education activities to effectively achieve the goals of ensuring occupational health and safety. 

11 Anti-Discrimination and Anti-Harassment

The Company respects the personality and dignity of the employees, and prohibits any form of discrimination and harassment. The Company will take discrimination and harassment seriously, provide appropriate complaint channels, and implement necessary punitive measures according to relevant laws, regulations and its internal policies, thereby providing strong protection for victims or complainants and ensuring effective protection of their interests.

12 Management of Reporting Non-Compliant Actions

12.1 The Company maintains a zero-tolerance attitude towards violations, and has established regular supervision and complaint reporting channels to accept real-name and anonymous reports. The Company will investigate the complaints of violations, and question and handle the involved personnel who fail to perform their duties based on investigation results. Whistleblowers may report any violations made by employees of CR Beverage and its subsidiaries through channels of email, hotline or letter, thus to ensure the sustainable, stable and healthy development of the Company.

12.2 Reporting Method: Whistleblowers may submit a complaint via email to the Company's dedicated email box for compliance complaint: yb_hgts@crbeverage.com

12.3 The Company encourages real-name reporting, and strictly maintains confidentiality of the personal information of whistleblowers and reporting information. The Company will set access permissions for reporting information, and prohibit disclosure to the person being reported and any irrelevant personnel. The Company prohibits all threats, attacks and retaliation against whistleblowers and will provide legal support and protection to them when necessary.

13 Revision and Review

The Company will regularly review this Policy and make appropriate revisions when necessary.