HONOR Code of Conduct

The Importance of This Code

The Code of Conduct (the “Code”) outlines the fundamental principles that guide our interactions with employees and business partners, and reflects our determination to always comply with all applicable laws, rules and regulations. By strictly observing the Code, we strive to build trust and respect among employees, partners and communities, and to fulfil our core company values: Consumer Focus; Hard Work and Dedication; Simplicity and Efficiency; Openness and Innovation; and Striving for Excellence.

Who Must Follow This Code

This Code applies to Honor Device Co., Ltd. and its direct or indirect subsidiaries and branches (collectively, “HONOR”). We hold ourselves—including all directors, managers and employees—to these principles in our daily work. We also require our partners (such as suppliers, customers, distributors, and consultants) to adhere to certain requirements in our Code, and to make joint efforts to foster an open, just, and fair environment with mutual trust.

Reporting Concerns

We encourage our employees and partners to report any potential violations of this Code. If you suspect or are aware of any behavior or situation in violation of laws and regulations or this Code, you can contact the reporting email account at bcgcomplain@honor.com.

No Retaliation

HONOR is committed to keeping the informant’s identity and reported content strictly confidential. Retaliation is strictly prohibited in any form against informants. Anyone who retaliates will be subject to disciplinary action or possible termination of employment.

Chapter 1

Consumer Focus

Consumer Focus is an unchanging belief of HONOR. All we are doing is striving to bring our consumers better experience with our products and services. With a strategic focus on innovation, product quality and service, HONOR strives to provide quality products based on continuously updated technology and our insightful understanding of consumer needs. In the meantime, we continue to invest resources to build one-stop centers offering consumers high-level and reliable services and experience.

Providing High-Quality Products and Services

More

It is our mission to provide consumers with high-quality products and services. Product quality is the lifeline of HONOR, and without it, there will be no future for HONOR. We encourage all employees to participate in improving product quality. Quality concerns not only our Product Line, R&D, Procurement and Supply chain, but it is a matter that everyone at HONOR should take seriously. Every employee is responsible for the quality of their own work.
We should reach a shared understanding about quality and consumer experience, and embed our requirements for quality and consumer experience in our culture.
To practice our values of “Consumer Focus” “Quality Comes First; Winning by Experience”, we expect our employees to always implement the following guidelines:
· always strive to provide consumers with reliable products and services;
· take quality seriously from the very beginning, focus on preventing and avoiding problems before they occur;
· take NPS (Net Promote Score) as the core to build key capabilities to provide end-to-end user experience; and
· build and enhance world-class user experience on all consumer interfaces, including but not limited to sales and service interfaces.

Protecting User Privacy

Privacy is a fundamental user right, and protecting user privacy is essential to any product and service we provide. From product design to service provision, we never cease to consider how to better protect user privacy and how to give users full control over their personal data. We consistently strive to enhance the user experience, including protecting users from online harassment and activity tracking, and preventing user data from misuse and leakage.
HONOR has achieved the ISO/IEC 27701 Privacy Information Management System Certification issued by the British Standards Institution (BSI). ISO/IEC 27701 is the world’s first international standard for private information management and the most credible and widely-recognized privacy information management system in the industry. This certification is a testament to HONOR’s commitment to achieving global standards in privacy protection.
We have also developed a series of courses on privacy protection for all employees in efforts to build a culture that genuinely values privacy protection. We require each employee to strictly adhere to our policies and procedures with an accurate understanding of privacy protection.

Protecting User Security

As the cornerstone of creating a new intelligent world for everyone, security is key to earning the trust of users. We comply with all applicable laws, regulations, standards and norms in various countries and regions, learn from the industry’s best practices, and continuously improve the security of our products and services by building a comprehensive cybersecurity assurance system. We strive to build brand trust by working closely with our supply chain and ecosystem partners and taking effective measures to manage cybersecurity risks throughout the entire lifecycle of our products from design and development to sales, services and operations.

Listening to Our Users

Serving consumers with respect is a commitment that guides us to truly practice our value of “Consumer Focus.” We strive towards this commitment through offering differentiated services for user groups and actively listening to consumer feedback to gain a deeper understanding of how they think and feel.
We expect each employee to take an active part in the enhancement of our product quality and service experience, and we hope each employee genuinely develops a passion for HONOR’s products. For instance, we encourage employees to introduce our products to their families and friends as HONOR “brand ambassadors”, and to offer solutions to their questions as customer service providers.

Chapter 2

Respect and Cherish Every Employee

Employees are our most valuable asset. We cherish every one of our employees, and care about their working experience. We fully respect employees’ diversity and listen to their voices. Our employees enjoy sufficient facilitation and support to work under a healthy and safe working environment. We have opened areas for psychological and health consultation to take care of employees’ health. We also set up associations that regularly organize various cultural and sports activities to enrich the lives of our employees.

Prohibiting Discrimination

HONOR is an equal employment opportunity provider and treats every employee fairly. We evaluate and promote our employees based on their ability and performance. We prohibit discriminating against employees for any reason (including but not limited to ethnicity, race, religious belief, nationality, age, gender, or sexual orientation), and prohibit verbal or physical bullying or derogation. We make sure that female employees enjoy maternity and parental leave in accordance with applicable local laws and regulations. It is strictly forbidden to arrange for female employees to engage in prohibited work during pregnancy. We also guarantee medical treatment period and sick leave for employees who are ill or injured due to non-work-related reasons in accordance with the law.

Prohibiting Harassment

HONOR prohibits any form of harassment, including sexual harassment. Sexual harassment refers to unwelcome sexual or gender-related behaviors against the will of someone in the form of words, images or physical acts, etc. Such behaviors offend, threaten or humiliate the person, which puts them in a difficult situation and creates disharmony at work. We regularly organize training sessions and publicity for sexual harassment prevention based on typical social cases to raise employees’ awareness of sexual harassment prevention. Any employee that commits sexual harassment or other similar behaviors will be subject to disciplinary action.

Valuing Diverse Talents, Ideas, and Contributions

More

HONOR is devoted to hiring and cultivating outstanding talent, giving full play to the advantages of each employee, and enabling them to make their own contributions to the company as best as they can. We encourage our employees to innovate and express their ideas, and we set the stage for every one of them to display their skills. We sincerely listen to the opinions of every employee and adopt the opinions which are beneficial to HONOR.

Employment and Human Rights

HONOR strictly complies with all applicable labor laws and regulations. We fully respect and protect human rights and require our partners to do the same. We prohibit violence, abuse, and any other forms of behavior that violates employees’ human rights. We will always adhere to the following requirements:
· recruiting and implementing equal pay for equal work on the basis of legality, fairness, equality, voluntariness, consultation, honesty and integrity;
· prohibiting child labor under any circumstances and protecting the legitimate rights and interests of juveniles;
· paying labor remuneration in full and on time, and complying with laws and regulations on minimum wage;
· standardizing employees’ attendance time and ensuring reasonable time for rest and vacation;
· prohibiting forced labor by means of violence, threats or illegal restrictions on personal freedom;
· paying employee social insurance in accordance with applicable laws and regulations;
· purchasing commercial insurance (such as accident insurance, critical illness insurance, business travel insurance, etc.) for employees to further increase their welfare; and
· respecting and protecting employee privacy.

Environment, Health and Safety

HONOR is committed to building a healthy, safe, and green workspace, and prohibits any behavior that affects or may affect the health and safety of employees. We have built an EHS (Environment, Health and Safety) management system, and are making continuous efforts to protect the environment, improve our working conditions, protect employees’ legitimate rights and interests, and to enhance the company’s cohesion and internal management.
Any employee aware of a situation that may threaten or has threatened our work environment should promptly report the situation to their supervisor or the HR representative. In the case of an emergency or a life-threatening situation, we will prioritize the health and safety of the employee and promptly seek help from our EHS team.

Chapter 3

Protect HONOR’s Benefits and Assets

Avoiding Conflicts of Interest

Conflicts of interest can influence employees’ ability to act in best interests of HONOR and can put risks on our partners. A conflict of interest can arise out of any personal activities or relationships. Each employee is expected to avoid situations that may lead to conflicts of interest. Such situations include, but are not limited to：
· Performing work for or holding a position at any entity outside of HONOR;
· Selling or providing products or services that compete with HONOR’s products and services;
· Conducting business with any related party with whom an employee has a significant personal relationship;
· Performing outside work unrelated to HONOR businesses during working hours or at workplace, or by using HONOR’s assets (including equipment, phones, resources and propriety information); or
· Receiving a salary, incentive or any other payment from a third party.
In addition, employees are not allowed to engage in any third-party employee stock ownership plan after joining HONOR. If any employee has participated in any third-party stock plan before joining HONOR, their income from such stock plan should not hinder their work performance nor their business decision making in the best interest of HONOR.

Safeguarding Confidential Information

One of HONOR’s core assets is its confidential information, as wrongful disclosure of such information will cause significant damage to HONOR. We require our employees to practice utmost prudence to protect HONOR’s confidential information. Each employee shall:
· not obtain, disclose, sell or steal company confidential information by improper means;
· not obtain confidential information unrelated to work with improper intentions or use confidential information for any purpose unrelated to HONOR’s business;
· not disclose HONOR’s confidential information without prior approval; and
· abide by company rules for the internal transmission of confidential information.

Safeguarding HONOR’s Assets

Our company assets are pivotal to HONOR’s development. Company assets include tangible assets (funds, equipment, facilities and materials) and intangible assets (patents, trademarks, software and IT systems). Every employee is obligated to protect our company assets, prevent wasting and improper use including unauthorized use and modification, and use it only within the authorized scope. Each employee shall:
· use company equipment, facilities and materials in a proper manner, and not use such assets for personal purposes;
· comply with rules and approval processes for company funds use, and prevent waste; and
· not use HONOR trademarks, logos or other company symbols for unauthorized purposes.

Protecting HONOR’s Reputation

As a unique resource of HONOR, a good reputation can enhance our competitiveness in all aspects. We should always watch our behaviors and fully respect consumers, our partners and their employees, because every one of our employees represents the company. During private activities or on social media, we still ought to keep in mind that we are HONOR employees and fully consider the impact that our words and behaviors may bring to HONOR. We expect our employees to refrain from conduct such as:
· Participating in public activities in one’s capacity as an agent of the company without prior approval, such as industry exhibitions, forums and summits, accepting media interviews;
· disclosing false information including exaggerated, distorted, fabricated information;
· posting or forwarding comments that conflict with the brand image of HONOR on personal social media; and
· discrediting partners and competitors by disseminating false information.

Prohibiting Insider Trading

Employees may access non-public information belonging to HONOR or its partners, which every employee should know is strategically significant to the development of HONOR and its partners (“insider information”). Employees in possession of such insider information shall keep the information strictly confidential and not use it improperly for personal gains. We expect our employees to refrain from conduct such as:
· trading based on insider information including investing in another person’s name or instructing others to engage in insider trading;
· manipulating markets by using insider information, such as driving up or down stock prices or spreading rumors and making falsified deals; and
· disclosing insider information to employees or non-employees who are not on a “need to know” basis.

Keeping Truthful and Accurate Financial Records

It is HONOR’s obligation to keep and disclose truthful and accurate financial information as required by relevant authorities or laws and regulations. It is also our duty to report this financial information to our investors and shareholders, and under certain circumstances, to our partners and other stakeholders. To ensure the authenticity and accuracy of our financial records as well as the security of our funds and assets, we expect each employee to abide by the following rules:
· ensure that our accounting policies are in strict accordance with the Accounting Standard and truthfully reflect our operations;
· ensure the authenticity, accuracy, and completeness of transaction-related information;
· timely archive financial documents in accordance with the requirements of applicable law and internal company procedures;
· prohibit the unauthorized altering of archived documentation; and
· prohibit the unauthorized destruction of archived documentation.

Chapter 4

Build a Mutually Beneficial Industry Ecosystem

HONOR is committed to working with our partners, including material suppliers, service providers, distributors, and consultants, to jointly build a sustainable and better world. HONOR cooperates and builds trust with outstanding partners around the world, which is the foundation of our business. We only maintain business relationships with reputable partners who abide by law, and we protect the interests of our customers by carefully selecting suppliers and other business partners and by adhering to the standards we set for our own behavior. HONOR cherishes the cooperative relationship with all partners and hopes to create a mutually beneficial industrial ecosystem with them.

Conducting Business with Fairness and Integrity

More

HONOR regards fairness and integrity as the basis of transactions, and is committed to cooperating with partners on such basis. HONOR selects suppliers through fair and just biddings which include comprehensive evaluation of price, service, quality and reputation, and HONOR does not discriminate against or deceive any supplier. HONOR earns customers’ trust through providing quality products and services and will not obtain business opportunities or advantages by illegal or unethical means. We expect that all employees of HONOR will uphold the values of fairness and integrity in business activities and abide by the following guidelines:
· evaluating suppliers with clear performance indicators, such as quality, price, service and reliability;
· promoting products truthfully in accordance with product features;
· focusing on improving the quality of products and services, rather than discrediting competitors; and
· treating all existing and potential customers and suppliers fairly regardless of transaction value.

Prohibiting Bribery and Corruption

HONOR is committed to upholding business ethics in its global business activities, and resolutely complies with any anti-corruption and anti-bribery laws applicable to the countries and regions where we operate. We adopt a “zero tolerance” policy towards bribery and corruption and have issued relevant policies and specific management requirements for HONOR employees and partners. We require all employees to strictly obey our policy and avoid behaviors including:
· providing or promising to provide to the personnel of any business organization money or monetary equivalent, as well as gifts and hospitality for the purpose of obtaining or retaining a business;
· providing money or any monetary equivalent, as well as any gifts and hospitality to government officials that may be suspected of violating relevant laws or government officials’ integrity regulations;
· directly or indirectly soliciting gifts, hospitality or any monetary equivalents from business partners; and
· directly or indirectly accepting kickbacks, commissions, referral fees, payments, money or any monetary equivalent, as well as gifts and hospitality that exceeds common business standards.

Protecting Third-party Trade Secrets

Respecting and protecting third-party trade secrets is a basic business principle of HONOR. We are well aware that wrongful disclosure of trade secrets may cause immeasurable losses to the right holders. Therefore, we must work with all our partners to do our utmost to respect and protect each other’s trade secrets. We require that all employees obtain, use, store, and dispose of third-party trade secrets in strict accordance with legal regulations and the requirements of partners, and abide by the following guidelines:
· not obtain third-party trade secrets by improper means;
· not disclose, use or allow others to use third-party trade secrets without permission;
· manage and store lawfully-acquired trade secrets in a proper manner; and
· strictly abide by signed non-disclosure agreements and prohibit misuse of third-party trade secrets.

Chapter 5

Comply with Laws and Regulations

Trade Compliance

HONOR respects and strictly complies with all applicable export control laws and regulations, including but not limited to the laws and regulations of the UN, China, the U.S. and the EU. HONOR is committed to responsible operations with integrity and will faithfully fulfill its export control obligations to earn the trust of partners and customers. We require all employees to strictly abide by the requirements of our compliance policy, including but not limited to the following guidelines:
· controlled items (including goods, technology, or software) shall not be exported, reexported or transferred in any form before obtaining any required export license;
· without a compliance assessment, it is forbidden to transfer items obtained under export licenses to third countries or third parties;
· for all technical cooperation, HONOR must make clear that the cooperation outcomes are for civil end-use only;
· for items obtained under export licenses, conditions specified in the license must be strictly fulfilled during use; and
· it is strictly prohibited to provide controlled items to sanctioned countries or entities in any way.

Competition Law Compliance

HONOR advocates for free and fair competition and opposes any anti-competitive behavior which eliminates fair competition. Free competition drives us to enhance efficiency and innovation and to deliver better products and services to customers. Employees should always follow the principles of voluntariness, fairness and integrity in business activities and refrain from anti-competition behaviors, such as:
· engaging in price control, which hinders the free movement of products;
· engaging in abuse of market dominance including restrictions of sales, tying and bundling of products, creating unfair trading conditions, etc.;
· engaging in false or misleading advertising, unfair prize-giving sales, business defamation, etc.; and
· engaging in collective boycott, price collusion, market division, etc.

Financial Sanctions and Anti-Money Laundering

HONOR strictly abides by all applicable laws and regulations on financial sanctions, anti-money laundering and anti-terrorist financing, and strictly prohibits behaviors that violate the laws and regulations on financial sanctions, anti-money laundering and anti-terrorist financing.
Employee shall avoid:
· Involving U.S./EU individuals/entities or conducting fund transactions or settlements through U.S./EU financial institutions in transactions where U.S./EU citizens are prohibited from participation;
· conspiring with relevant personnel to conduct fund transactions or settlements aimed at evading relevant laws and regulations; and
· providing false information or materials to financial institutions, or withholding truthful information or materials.
When working with customers or suppliers, we must pay additional attention to potential money laundering risks. Supporting materials must be submitted and reviewed to ensure the legality and compliance of transactions in the following situations where:
· customers make payments through underground banks, casino exchanges, shell companies, etc.;
· customers or suppliers make or receive payments through a third party without reasonable grounds or supporting materials; or
· customers or suppliers make or receive cash payments in amounts of 50,000 RMB or 10,000 U.S. dollars or above.

Chapter 6

Sustainable Development

Protecting the Environment

More

HONOR is committed to complying with international standards and applicable laws and regulations on environmental protection. We will integrate environmental considerations in the process of product development, reduce resource waste, and decrease negative impact on the environment, including but not limited to: reducing the use and emission of harmful substances, using technologies to improve energy efficiency, recycling and reusing waste, extending the product life cycle, and implementing a circular economy to benefit the environment. HONOR is also committed to reducing carbon emissions and lessening the impact on climate change by increasing the use of clean energy in our own premises as well as the premises of our partners.

Carbon Neutrality

We have integrated carbon emission reduction in our company strategy and will continue to reduce carbon emissions by optimizing company operations and supply chains. We strive to achieve carbon neutrality in our operation by 2045 and will increase investment and strengthen innovation to promote supply chain transformation, and work with partners to build a low-carbon ecosystem.

Responsible Sourcing and Procurement

HONOR is committed to the responsible sourcing and procurement of raw materials including but not limited to the tin, tantalum, tungsten, gold, cobalt and other mineral raw materials used in our products. HONOR will also continue to encourage our suppliers to establish policies in accordance with relevant international regulations to improve their working conditions and EHS management, increase supply chain transparency and enhance supply chain management.

Social Responsibility & Corporate Citizenship

As a responsible corporate citizen, HONOR will earnestly fulfill its social responsibilities. We will develop more products aimed at helping teenagers, seniors and people with disabilities to adapt to the digital world. Apart from continuing to faithfully fulfil our obligations to pay taxes in accordance with the law, we will also make continuous efforts to create more job opportunities, contribute to the development of local communities, and respect local cultures and customs.

ABOUT HONOR

Events