（This policy is published in Chinese and English; where inconsistencies arise between the two, the Chinese version shall govern.）
JCHX Mining Management Co., Ltd. (hereinafter referred to as "JCHX" or "the Company") takes strict compliance with applicable laws and regulations as its bottom line and adheres to the highest ethical standards as its guiding principle. It upholds the core tenets of professionalism, honesty, and integrity in all business transactions and partnerships, and resolutely prevents any actions that may damage the Company's integrity image or brand reputation.
To fulfill the above commitments, we will implement the following policies:
1. Management of Work Environment
The Company is committed to building an inclusive and diverse work system and advocates mutual respect among employees. It resolutely resists any form of harassment or bullying. Decisions on personnel – including recruitment, hiring, training, promotion, compensation, and benefits – shall be strictly based on the qualifications, skills, performance, and competency of employees or applicants.
2. Anti-Corruption and Whistle-blowing Mechanism
The Company promotes a culture of integrity and adheres to the bottom line of honest, compliant business operations. All employees must strictly comply with laws, regulations, and internal policies, and bribery or corruption is strictly prohibited. Employees and related parties are encouraged to report illegal acts, regulatory violations, or improper conduct through secure channels. The Company commits to strict confidentiality of reported information and personal details; additionally, any form of retaliation against whistle blowers, investigators, or assisting parties is strictly forbidden.
3. Gifts and Hospitality
Employees may accept or offer normal hospitality (e.g., working meals) or low-value promotional items/souvenirs to external parties, provided they comply with business practices and meet all of the following criteria: legitimate purpose, reasonable frequency, moderate value, not during sensitive negotiation periods, non-recurrent nature, and strict compliance with laws.
4. Conflict of Interest
Employees must prioritize the Company's interests above all else. If a conflict of interest arises, they shall promptly disclose it to relevant leaders or departments and take the initiative to apply for recusal. They must also strictly adhere to the Company's system for declaring and recusing related parties.
5. Anti-Money Laundering
The Company explicitly prohibits participation in or assistance to any third-party money laundering activities. Employees must not engage in or facilitate money laundering acts.
6. Prohibition of Insider Trading
All employees must strictly comply with insider trading laws and regulations. They are prohibited from disclosing inside information or using it for illegal trading.
7. Community Relations
The Company actively engages in community cooperation, supports community development, helps improve local residents' quality of life, and contributes to regional prosperity. All employees must respect and understand the local community's culture, ethnic customs, and religious practices, and foster positive interaction with the community.
8. Political Activities
In principle, the Company and its employees shall not actively participate in political activities or make political statements. If political affairs are involved due to special needs, strict compliance with the laws and regulations of the host country (region) is required to ensure no harm to the Company's interests.
9. Accounting and Financial Reporting
Financial information disclosed to the public must be true, accurate, complete, concise, clear, and easy to understand. False records, misleading statements, or material omissions are strictly prohibited.
10. Confidential Information and Intellectual Property Rights
All employees are obligated to protect the Company's confidential information and intellectual property. The scope of protection includes but is not limited to core content such as exploration plans, acquisition proposals, work documents, internal materials, bidding documents, unpublished financial data, and undisclosed process technologies.
11. Promotion of Fair Competition
The Company firmly opposes monopoly and any form of unfair competition, and strictly complies with laws and regulations that maintain market competition order.
12. External Communication
External information disclosure follows the principles of truthfulness, accuracy, completeness, timeliness, and fairness. Relevant information is uniformly released and implemented only after authorization obtained.
Scope of Application
As a public programmatic document, this policy applies to all members (including board members and senior management personnel) of the Company and its subsidiaries (with operational control), and requires relevant suppliers, partners, and their long-term/temporary employees providing services to JCHX to strictly implement it. Additionally, the scope of the policy extends to all operating entities under the Company and its subsidiaries (with operational control), specifically covering mining service project departments/project companies, resource project companies, other business sector’s operating units, etc.
Regarding associated and joint venture enterprises, the Company will actively promote the alignment of their policies and practices with the requirements of these guidelines through the exercise of shareholder/board rights, ensuring that their policy orientation and practical operations comply with the core principles advocated by this policy.
JCHX Mining Management Co., Ltd.
October 29, 2025
