Employee code of conduct

ASIA AURORA INVESTMENT CO., LIMITED, as a wholly-owned company mainly engaged in foreign exchange capital investment and management business, adheres to the core values of "responsibility, cooperation, professionalism, and progress", and is committed to becoming a respected international first-class professional investment institution. In order to achieve this goal, the company requires all employees to strictly abide by all applicable laws and regulations, and implement the highest standards of professional ethics and conduct.

As an important system of the company and an important element of corporate culture building, the Code of Conduct for Employees of ASIA AURORA INVESTMENT CO., LIMITED not only comprehensively describes the basic principles of the company on major issues, but also sets out detailed requirements for the protection of the company's reputation, interests, assets and information. Every employee is required to understand, recognize and consciously act in accordance with it when joining the company.

1. Employees shall correctly understand and strictly abide by all applicable laws, regulations and social and ethical standards, and avoid damaging the reputation and interests of the Company due to any improper behavior.
2. Employees shall abide by the basic requirements of professional ethics and ethics such as honesty and trustworthiness, equal treatment and loyalty to duty.
3. All actions of employees shall be in the best interests of the company. Employees are obliged to identify and report all possible conflicts with the interests of the company, and take necessary measures to avoid or eliminate part-time jobs, inter-bank operations, related party transactions, business opportunities and any other external activities and personal relationships that may affect business judgment or performance of duties.
4. Employees should correctly handle gifts and entertainment that occur during official interactions. Generally, they are not allowed to accept gifts and entertainment from companies or personnel that have business relations with the company, so as not to affect employees' normal transactions and business judgments.
5. Regardless of the country or region in which the business is conducted, employees are strictly prohibited from engaging in any form of commercial bribery and corruption.
6. Employees should properly keep and use company assets reasonably, and it is strictly forbidden to occupy and dispose of company assets without authorization. When risks and hidden dangers are found in the company's assets, employees are responsible for reporting the situation to relevant departments in a timely manner.
7. Employees shall properly protect, correctly use and process all kinds of information of the company, and shall not create all kinds of false information, shall not disclose confidential information, shall not abuse inside information, and shall not disclose information without authorization.
8. Managers at all levels of the company should take the lead in complying with this specification, and urge and help other employees to correctly understand and strictly abide by the requirements of this specification. Employees of the company may report the situation to their superiors and the department they belong to if they violate laws and regulations, the company's system regulations and this code of conduct, or file a complaint with the Disciplinary Inspection and Supervision Department.