Guotai Junan International

Staff Code of Conduct

Guotai Junan International Holdings Limited (the “Company”, together with its subsidiaries collectively referred to as the “Group”) has a comprehensive policy, setting out in various manuals, outlining the staff’s code of conduct. The manual is applicable to all staff. Here is the summary:

1.  Mission: The mission is to foster a culture of integrity and compliance within the Group, adhering to legal, regulatory, and ethical standards. Compliance is everyone's responsibility, with the ultimate responsibility lying with the board of directors of the Company.

2.  Public Communication and Information Provision: Unauthorized individuals are not permitted to act as spokespersons, conduct media interviews, or handle media inquiries of the Group.

3.  Client Data Protection: All staff must comply with various laws, rules, and codes on maintaining the confidentiality and secrecy of its clients and business information.

4.  Custody of Client Assets:All staff must ensure that client assets are accounted for properly and promptly, and adequately safeguarded. Policies are in place to protect client's money and assets.

5.  Prohibited Activities: Various activities are prohibited under the Securities and Futures Ordinance (SFO), including but not limited to insider dealing, false trading, price rigging, stock market manipulation, disclosure of information about prohibited transactions, disclosure of false or misleading information inducing transactions and illegal short selling etc.

6.  SFC’s Code of Conduct: All licensed staff must comply with the Securities and Futures Commission’s (SFC) Code of Conduct of Persons Licensed by or Registered with the SFC and/or the Fund Manager Code of Conduct etc.

7.  Anti-Money Laundering and Counter-Terrorist Financing: All staff must strictly comply with the Anti-Money Laundering And Counter-Terrorist Financing Manual, Customer Due Diligence Manual and Client Identity Rule Policy of the Group.

8.  Gifts, Benefits, and Fees:All staff must strictly comply with the Anti-Bribery and Corruption Policy and Manual of the Group.

9.  Record Keeping: All staff must maintain effective record retention policies and comply with all legal and regulatory requirements, varying retention periods for different types of records.

10.  Internal Complaints on Staff Misconduct & Malpractice: The Group encourages staff to report any suspected misconduct or malpractice and provides protection for those who do so.

11.  Grievance: The Group adopts a zero-tolerance approach to any form of unlawful discriminatory behavior, including but not limited to bullying, harassment.

12.  Disciplinary Action:Any violation of the above can lead to disciplinary actions, including but not limited to written reminder, warnings, dismissal, and report to the regulatory authorities and enforcement agencies. The Company provides channels for staff to report any misconducts he/she may have identified.