Employee Code of Ethics

General

In order to establish as a reputable and internationally standardized corporate environment for the sustainable development of the Company and realize the Company’s vision of “leading trade and consulting services provider in Myanmar”, Personnel of the Company must adhere to the ethics and code of conduct in respect to their honesty, credibility and sense of responsibility, and endeavor to maximize the interest of customers, shareholders, employees and the society. All of the above serve as the basis of this Employee Code of Ethics (the “Code of Ethics”).

Prohibitions of misconducts The following misconducts (not limited to) are strictly prohibited by the company and punishable in accordance with Myanmar Penal Code:

Performance of Duties

Employees of the iCTS (Myanmar) LTD must report any fraudulent behavior or behavior that violates this Code of Ethics to the board of directors of the Company in accordance with the related reporting and processing policies and procedures; The Company will provide appropriate channels, such as posting this Code of Ethics on the Company’s website, producing it prior to any business activity or incorporating it into commercial contracts, to ensure that parties that have business relations with the Company, such as suppliers, customers, agents, investors, creditors and debtors, are able to understand the principles and spirit of this Code of Ethics in an accurate and timely manner.

Righteousness and integrity are the essential values of moral characters of the Company and all Personnel. All Personnel shall endeavor to uphold righteousness and integrity in their line of work. Personnel shall be honest and credible to customers, fellow tradesmen, partners, colleagues, shareholders, the country and the society.

Realization of accountabilities is an important approach for all Personnel to achieve the values of righteousness and integrity. Personnel must be responsible and self-disciplined, adhere to principles, be loyal to their duties, serve customers with enthusiasm and efficiency, handle the duties of their positions with a sense of responsibility, safeguard the interest of the Company as well as the rights and benefits of the shareholders and should not be concerned only about their own reputation or financial gains.

Personnel should develop honesty and credibility as part of their fundamental professional ethics and reflect the same in their work, faithfully carrying out their commitments. Honesty and credibility should be fundamental to the Company’s development and success and instrumental to the realization of the Company’s core values. Personnel are prohibited from providing any false or misleading information, documentation either printed hard copies nor soft electronic copies on behalf of the Company or accept documentation from third party without an independent review of the documents. The information disclosure and documentation review procedures shall be strictly followed.

Reporting and Sanction

Any Personnel who has breached this Code of Ethics is subject to Company sanctions, which include, but are not limited to, administrative sanction, termination of labor contract and transfer to judicial branch. Every Personnel is obligated to timely report to the board of directors for such violations and can report via any of the following means:

The company encourages Personnel to report any violation of laws, policies or regulations and welcome comments and suggestions on operations and management of the Company through various communication channels including weekly meetings. Management at each level should treat employee comments seriously. Company shall provide appropriate level of anonymity to whistleblowers and maintain information and records of such whistleblowing confidential.

Personnel responsible for receiving, recording and processing or having access to reported information should sign additional confidential agreements specifying their obligations with regard to confidentiality.

The Company safeguards Personnel reporting violation of laws, policies or regulations. Personnel who leak information or retaliate against whistleblowers shall be subject to removal from position or termination of employment. Personnel that violate the laws will be handed over to prosecution.

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No.47, 4th Floor, Maupin Street, Kyun Daw Quarter, SanChaung Township, Yangon, Myanmar.

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