In order to the conduct of employees in China Communications Construction Company Ltd.(hereinafter referred to as CCCC) whoinvolved in overseas business and guarantee that the overseas business activities are carried out legally, this Code of Conduct is formulated in line with the compliance management requirements of CCCC.


I. Code of Conduct


CCCC Code of Conduct for the Employees in Overseas Business (hereinafter referred to as the “Code of Conduct”) is the basic principle and ethical standard that CCCC has to observe in legally conducting business activities, and is also the important foundation for sustained success of the Company.

The Code of Conduct is applicable for all employees of CCCC International Operations and the divisions involved in overseas business, overseas offices, as well as any Third Party who is engaged in operation of overseas businesses (hereinafter referred to as “Employees”). All those employees who are involved in or engaged in overseas business shall observe the value criterion of “Advocating morality and learning, and seeking progress”, and comply with the compliance requirements of “Adhere to honesty and compliance, maintain fair competition, prevent corruption and bribery, avoid conflicts of interest and keep business secrets”.


A. Insist on Honesty and Compliance


1.Employees shall put the Company’s interests on top priority, identify the Company’s culture and objectives, earnestly perform their own duties, and make efforts to maintain the Company’s social image and good reputation.


2.Employees shall be fully aware that they will be subject to civil or criminal liability for any violation of laws, regulations, or compliance requirements, and any such violations would cause damage to the Company’s reputation.


3.Employees shall not conduct any unethical behavior that is prohibited and may lead to the Company’s involvement in any unlawful or proscribed unethical practices.


4.Employees shall treat all colleagues and visitors with respect and humility.


5.Employees shall communicate with their colleagues and supervisors in the manner of trust and collaboration, and work together with them to complete the tasks.


6.Employees shall be honest and fair to all clients, and ensure that the information communicated with or introduced to clients is true and accurate. Employees are prohibited from gaining business by misleading the existing or potential clients.


7.Employees are prohibited from stealing or abusing the Company’s property or any rights authorized by the Company.


8.Employees shall not forge or alter work records, bidding documents, or other materials.


9.  Employees shall not conduct any action that may impair, harm, or threaten to impair or harm anyone or their property or improperly influence any colleague, client, competitor, or any other party. 




B.  Maintain Fair Competition


1.Employees shall comply with all applicable Competition Law, Anti-Monopoly Law, and other applicable laws and regulations on maintaining fair competition in the market.




2.Employees shall not collude with competitors or jointly participate in any action with an improper intent or effect, such as bid rigging, formation of price alliance, violating bidding processes, dividing markets, or limiting production.




3.Employees shall not exchange sensitive information with competitors againstCompetition or Anti-monopoly Laws.






C.  Guard against Commercial Bribery and Corruption


1.Employees shall fully understand that the Company’s success in business must be based on market competitiveness, performance, quality of products, services, and technologies. No in any circumstances shall the employeesseek success in any operation activity through any form of bribery or corruption or other improper activities of the same nature.


2.Employees shall not offer, promise, authorize, give, or receive any type of bribes, commercial or propertyinterests, cash payments or gifts in order to influence any commercial behavior or business decision, obtain any improper benefits, or interfere independent judgment. Employees are also prohibited from conducting the above acts indirectly through relatives or other trustees.


3.Employees shall not offer, promise, authorize, or give money, services, gifts, or other valuable items (including hospitality) in order to obtain or retain business opportunity or other benefits. Employees are also prohibited from conducting the above acts indirectly through relatives or other trustees.


4.Employees shall not receive money, services, gifts, or other valuable items (including hospitality) from subcontractors or suppliers because they have given any business opportunity to an individual or organization. Relatives and other trustees of Employees are also prohibited from conducting the above acts.



5. Where any business is involved with government or any affiliated organization, especially seeking approval, permit, or relative review & approval from government, employees shall observe the moral standards compliance policies and requirements of the Company.


6.Giving or receiving cash or cash equivalents is prohibited. In certain social customs and cultures, employees could exchange symbolic gifts, non-cash courtesy souvenirs, or provide hospitality. If the ultimate goal is to improperly influence business decisions, however, employees shall not give, offer, promise, authorize, or accept any such gifts or hospitality (including money, loans, invitations, and expense payments or reimbursements) or any other form of special treatment. Employees are also prohibited from conducting the above acts indirectly through relatives or other trustees.



D. Avoid Conflict of Interests


1.Conflict of interests may distort employees’ business judgment. Employees must avoid undertaking any activities that may cause, or create the perception of, a conflict of interests between (a) themselves or any related or associated third party (including suppliers and subcontractors) and (b) the Company.


2.Employees’ business decisions and actions shall be based on the best interests of the Company. Independent judgment and reasonable decision -making shall not be influenced by any relationships with prospective or existing suppliers, subcontractors, representatives, contract employees, customers, competitors, or regulators.


3.To avoid conflict of interests, the Company may hire a former or the current governmental employee only if all the conditions comply with the Company’s compliance policies, procedures and requirements.




E. Keep Commercial Secrets Confidential


1.Employees shall adhere to CCCC’s Commercial Secrets Protection Policy.


2.Without internal communication or prior approval from the supervisor, employees shall not publish, discuss in public, disclose to unauthorized persons or organizations, or use without proper authorization, any commercial confidential information and proprietary information belonging to the Company or the related third party.


3.Confidential information includes, but not limited to, results, forecasts, and other financial data; human resources and personal data; and information with respect to acquisitions, divestitures, new products, and orders. Proprietary information includes, but not limited to, business strategies, technical information, product improvements, invention, information systems, trade secrets, proprietary technology developed or achieved by the Company, as well as matters covered by Confidentiality Agreement.


4.Employees who are responsible for the management, use, and delivery of confidential information and proprietary information (including client and supplier related information) shall not improperly disclose or abuse such information internally or improperly disclose or abuse it to an external third party.


5.Employees shall not benefit themselves or others by taking advantage of any Company business opportunity, property, information, or other resource.




II. Compliance responsibilities of the Management and Employees


The Company’s management personnel and employees shall take the following responsibilities when complying with this Code of Conduct


1.Management personnel’ duty to comply with the Code of Conduct ishigher than ordinary employees. Management must actively promote the implementation of the Code of Conduct and demonstrate its commitment to this Code of Conduct through actions.


2.Management personnel of all levels are obligated to directly demonstrate that all Employees shall abide by the ethical standards and compliance requirements as their top consideration in carrying out any production and business activities.


3.Management personnel must be vigilant at all time in order to prevent, detect, and respond to any violation of this Code of Conduct, and protect from the Employees who report the violations.


4.In addition to abiding by the applicable law and CCCC compliance policies and procedures that apply to their position and job activities, the Employees are obligated to be fully aware ofand implement this Code of Conduct in daily production and business activities.


 5. Employees are obligated to report any known or potential violations against the Code of Conduct. During reporting of the above, employees are required to submit the evidence proving the actual or any potential acts against the Code of Conduct to the Compliance Department or report such act according to the Company’s compliance policies and procedures.


III. Consulting, Reporting and Treating of Violation


A.Employees should consult with the CCCC International Compliance Department, or other relevant persons in charge as prescribed in the Company’s compliance policies and procedures, any issues that arise or questions they may have with regard to this Code of Conduct, the Company’s Core Values and compliance policies and procedures, and applicable law, including issues or questions regarding:


1.Any concerns involving ethical or compliance problems;


2.Any hesitation, in certain specific situations, on how to proceed in accordance with the Company’s Core Values and compliance requirements;


3.Any request from business partners, clients, or colleagues that might violate the Company’s Core Values, compliance requirements, or applicable law;


4 Any perceived or suspected activities of business partners, clients, or colleagues that might violate the Company’s Core Values, compliance requirements, or applicable law; or


5.Any other questions or circumstances involving compliance issues.


B. Employees who make good-faith reports of actual or potential violations of this Code of Conduct are protected from retaliation. If the reporting person is also involved in the reported compliance violation activity, he/she may still be subject to discipline, but the fact of his or her appropriately reporting of the misconduct will be taken into consideration in determining the discipline imposed.