CODE OF CONDUCT

Purpos

• This code contains the basic guidelines for the business implementation of Pulling Energy. If this Code requires higher standards than those required by commercial practice or applicable law, regulation or regulation, the Company will comply with such higher standards.
• The code of conduct contains an overview of key information, including business codes and regulations, that are relevant to all employees. A code of conduct describes what we are and how we should work. At any time, difficult ethical and legal issues are addressed in accordance with our code of conduct.

Code of Conduct Guarantee

• We establish an effective procedure to ensure that any worker, acting individually or with other workers, can submit a grievance without suffering a prejudice or retaliation of any kind.

Commitment to the Principle of Honest and Trustworthiness

• Our Code of Conduct applies to all our directors, officers, and employees, as well as representatives throughout the world and provide the framework for positive behavior to help prevent any activity that may harm the interests of Pulling Energy. This Code of Conduct includes topics as further described below and in addition, supplements (but does not replace) any existing Pulling Energy policies and procedures.
1) Bribery and any form of unethical business practices are strictly prohibited.
2) Employees should avoid conflicts between personal/financial interests and those of the company.
3) All business activities conducted by employees in the name of Pulling Energy Group shall be conducted in accordance with the accounting principles of the Company and local laws. And the business activities shall be accurately and completely recorded to the company, and be audited at any time.

Prohibition of Corruption and Bribery

• We do not tolerate any form of corruption or bribery be it by employees, third parties or agents, including any payment or other form of benefit conferred on any government official for the purpose of influencing decision making in violation of law.
• We fully understand and commit to obey all applicable domestic and oversea laws and regulations on anti-corruption and bribery, as well as LPulling Energy Group’s corruption-free policies and requirements.
• We do not provide false information for the purpose of transaction.
• We do not provide anything of value, either directly or indirectly (including through third parties) to Pulling Energy Group employees or other stakeholders to obtain or retain business or otherwise achieve transaction purposes; anything of value including but not limited to the following:
a) Providing presents or money as gifts (for instance, during birthdays, weddings, and holidays);
b) Providing loans, red envelopes, sales rebates, bonuses, etc;
c) Providing cash equivalent benefits such as gift cards, bank cards, oil fuel cards and securities;
d) Providing services for entertainment, physical exercise, cosmetics, banquets, medication, training, housing furnishing, vehicles for personal purposes and traveling, etc.

Respect for the basic human rights of all internal and external workers

• We do not employ workers under the age of sixteen (16). If local law requires a higher age limit, local policy shall be followed.
• We provide equal opportunities and treatment to our employees. We must recruit, select and promote employees based on objective and nondiscriminatory principles. Any form of harassment and discrimination, such as discrimination based on race, color, sex or religion, is strictly prohibited.
• We are committed to providing a safe working environment with an emphasis on anti-harassment compliance that prohibits gestures, language and physical contact that are sexual, coercive, threatening, obscene or exploitative;
• We provide fair compensation and ensure that it meets at least the applicable legal minimum wage;
• We comply with applicable wage, hour and benefits laws;
• We are committed to respecting the dignity, privacy and individual rights of our employees in the workplace, and protecting our employees from any form of discrimination, harassment and abuse;
• We do not use any forced labor or buy raw materials for products produced by forced labor;

Health and safety & environmental protection

• The company undertakes not only to comply with all relevant health and safety laws, but also to conduct its business in an appropriate manner to protect the safety of its employees
• We provide training to ensure that employees are properly educated on safety and health and act in accordance with all applicable statutory or international standards relating to environmental protection;
• We encourage our sub-suppliers to comply with local laws and regulations (e.g. compliance with environmental regulations, etc.) and promote corporate social responsibility.

Protecting Confidential Information

• Pursuant to employment agreement and agreements with third parties, we protect Pulling Energy Group confidential information and additionally protect confidential information of third parties including but not limited to customer and suppliers. We agree no confidential
information will be shared without first entering into an appropriate legal arrangement such as an NDA.

Protecting Intellectual Property

• We protect our Company’s intellectual property from misuse, misappropriation, destruction, and loss. We take action to prevent the misuse, misappropriation, destruction, impairment, or loss of others’ intellectual property. We follow applicable laws and regulations in the regions where we operate relating to the protection of proprietary information and other intellectual property.

Trade Regulations Compliance

• We operate with fairness and honesty in order to comply all applicable export and import control laws and regulations. We take responsibility for understanding and complying with all international trade compliance (ITC) laws and regulations that apply to us worldwide.

Competition Law Compliance

• We compete vigorously and legally. We conduct business compliance with all competition (or "antitrust" or "anti-monopoly") laws wherever we do business.
• This Code of Conduct is written in both English, and both languages shall be of equal power.