Business Code of Conduct丨SHINING 3D

Shining 3D Tech Co., Ltd. is founded in 2004, has been focused on the research & development, manufacturing, and application of high-accuracy 3D digital products for over 20 years, with the values of pursuing excellence, pragmatism, innovative and achieving collaborative success. In view of the fact that Shining 3D Tech Co., Ltd. or its affiliated companies (hereinafter collectively referred to as “Shining 3D”) have been operated in good faith according to law, in order to regulate the market operation behaviors of all staff, clients and suppliers, maintain the fairness, justice, legality and compliance of various business cooperation, and effectively prevent violations of regulations and disciplines or infringement of the legal rights during the business cooperation, Shining 3D understands and agrees that unethical business behaviors will bring serious business risks, destroy the corruption-free internal environment and good public image of Shining 3D, and seriously disrupt the fair competition in the market and the business purpose of honest operation, so that Shining 3D has issued this code and all Employees (“Employees”) shall strictly abide by it. This Code applies to all Shining 3D’s clients, suppliers, agents and contractors (hereafter referred to as “Partners”).

Human Rights

Shining 3D is opposed to all forms of human trafficking, slavery, servitude, forced or compulsory labor, child labor, we are committed to preventing such practices in our business activities and supply chain. Furthermore, our policies prohibit the employment of anyone under the age of 18 because of the nature and demand of work. Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains. Our recruitment procedures and personnel management are designed to ensure that no abuse or coercion occurs. We expect our Partners to meet the aforementioned expectations.

Working Conditions

Shining 3D is committed to comply with all applicable laws and regulations to secure legal interests of local Employees. We value the fairness and legality of employee compensation and social benefits, and we encourage Employees to complete their work within regular working hours; excessive overtime is not advocated.

Shining 3D provides equal job opportunities for all job seekers and employees, discrimination and harassment are not allowed. All Employees shall report any unsafe risks, harassment, violence and accidents immediately to the supervisor.

Shining 3D respects the Employees' freedom to associate and the right to collective bargaining.

We respect the free exchange of ideas and viewpoints. We encourage Employees to raise issues or concerns as early as possible through the processes established by our company when they identify problems in their work.

Occupational Health and Safety

Shining 3D cares about the occupational health and safety regarding to every Shining 3D’s employee, is committed to preventing accidents, violence and work related illnesses.

We have adopted comprehensive measures to ensure the healthy and safe environment, promote healthy working conditions, such as formulating working rules, trainings and setting up report system. We have obtained ISO45001 occupational health and safety management system.

Shining 3D has established an emergency management system for safe production, providing Employees with safety device and training on safe production and fire safety, and regularly conducting fire emergency evacuation drills. All Employees shall adhere to health and safety regulations and use the required personal protective equipment, participate in the training and drills carried out by Shining 3D.

Environment Protection and Sustainability

Our global business operations, practices, and products comply with applicable environmental regulations, standards, requirements, and policies. We have obtained ISO14001 environmental management system and we understand and adhere to these requirements, including: conserving energy, water, raw materials, and other natural resources; properly handling materials and waste; complying with environmental permits, as well as health and safety standards.

Shining 3D focuses on the efficient use of materials and energy, prioritizes the use of renewable energy sources, and to the greatest extent possible under technological and economic conditions, adopts renewable energy. Employees are expected to consider the environmental impact and work in a sustainable manner.

We pursue the long-term goal of sustainable development. We expect our Partners to comply with all applicable environmental, health, and safety regulations and standards in their operations.

Protecting Shining 3D’s Assets

All Employees are responsible for protecting all the physical assets, information assets and other invisible assets in the possession of Shining 3D. Shining 3D’s assets shall be treated and used for the intended purpose and required manner, and shall not be used for personal purposes. All Employees are required to report to their supervisors immediately if there are any loss, damages or infringements to the Shining 3D’s assets.

Physical assets includes, such as, machinery, tools, facilities, office equipment, vehicles, computers, mobile phones, documents, and all information and communication systems.
Information assets includes, such as, any data, information, knowledge, software, hardware, IT service, data storage. Confidential Information is any information that Shining 3D has not disclosed or require to keep confidential, including but not limited to inventions, financial and sales data, new product launches, pricing, strategic and business plans, technical specifications. All Employees are required to keep Confidential Information pertaining to the Shining 3D private and shall not share it with unauthorized party. Even after the termination of the employment, Employees shall continue protecting the Confidential Information.
Other invisible assets. One of our most valuable assets is Intellectual Property. We protect Intellectual Property rights and also respect others legal interests. All Employees must observe Shining 3D’s confidentiality policies, protect and use Shining 3D’s intellectual property rights according to internal guidelines and respective laws only.

Partners shall lawfully access, acquire or use the Shining 3D’s assets, and perform contractual and legal obligations to protect the above assets.

Continuous Innovation

Leading technical innovation is SHINING 3D's critical competitive strengths. SHINING 3D has established a continuous innovation mechanism to ensure the sustainable resolution of technical challenges. Additionally, SHINING 3D is committed to converting technological achievements into industrial applications. By continuously optimizing product performance and enhancing technical service levels, SHINING 3D promotes innovation and upgrades of high-precision 3D vision technology and products. This approach strengthens market competitiveness and solidifies our leading position in the industry.

Quality Management

SHINING 3D complies with applicable standards, regulations and customers’ requirements, continues to improve the product quality control system based on global standards. At the moment, we have obtained ISO9001 quality management system, ISO13485 medical device quality management system, Korea Good Manufacturing Practice (KGMP), and Medical Device Single Audit Plan certification (MDSAP). It has also been certified and registered by international product standards such as CE, FDA or FCC.

In order to ensure the stability and reliability of product accuracy, we have passed CNAS certification, established a set of testing and calibration laboratory capacity system according to international standards, and has the technical ability to “independently carry out dimensional accuracy calibration services”.

And the management system has also integrated the "Criteria for Performance Excellence" (GB/T19580-2012), an internationally recognized management quality evaluation standard.

Employees are required to adhere to their job responsibilities and assist in guaranteeing that our offerings, including products, solutions, and services, achieve peak performance and stick to the strict criteria.

Fair Competition

1. Anti-bribery and Corruption

Shining 3D upholds a zero-tolerance policy towards bribery and corruption. Shining 3D are committed to comply with all applicable laws and regulations, standards, and principles relating to anti-bribery in countries where Shining 3D conducts business. All Employees shall conduct business activities in an ethical and lawful manner all the time.

All Employees shall understand that it is a severe illegal behavior to give or receive bribes, engage in corruption, or accept kickbacks, which may lead to imprisonment, fines, and reputational damage for Shining 3D. They are referred to Ten Red Lines (which is published on OA Portal and updated from time to time) and Employee Handbook for further guidance.

All Employees shall not offer anything to a government official or business partner, directly or indirectly, in return for favorable treatment. Any employee who is found to be giving or taking bribes or any other acts of corruption, will be subject to disciplinary action which may lead to dismissal on the grounds of gross misconduct and, may even be subject to criminal proceedings.

Partners shall comply with all applicable laws and regulations, standards, and principles relating to anti-bribery and build a fair market together with Shining 3D.
Employees and Partners are required to report any actual, suspected, or requested bribes to Shining 3D through the appointed contact: legal@shining3d.com.

2. Gifts and Hospitality

Shining 3D acknowledges that occasional acceptance or offer of modest gifts and hospitality may be a legitimate contribution to good business relationships. Gifts and hospitality must be for legitimate purposes, such as promoting, demonstrating, or introducing the Shining 3D's products or services, and must not impose any obligations on the recipient. They should not be intended to influence the recipient to act in any way that would benefit Shining 3D or any third party, or to affect the objectivity of the recipient in making business decisions, by providing, promising to provide, or giving any valuable items.

Gifts and hospitality must be open, transparent, and reasonable, appropriate for business relationships and local customs. Employees are required to secure the appropriate authorization before extending or accepting any gifts or hospitality. Additionally, they must record any gifts or hospitality that they offer or receive to maintain transparency and adhere to Shining 3D’s policy.

3. Anti-money Laundering

Shining 3D adheres to applicable law regarding anti-money laundering in the relevant areas. We require all relevant facts of all business transactions are recorded timely, clearly, correctly and completely. The acts of filing false records under any circumstances are strictly prohibited. We hire external auditors to ensure that all business and records complies with relevant accounting standards.

4. Conflict of interests

Employees shall make every effort to avoid any activities that may exist or potentially exist that conflict with the interests of Shining 3D. Employees must not engage in activities that are in competition with Shining 3D or that would hinder their normal performance of job duties. They must not use company confidential information, company assets, or their role or position at Shining 3D to seize personal benefits. All Employees are required to disclose in writing to their superiors any actual or potential conflicts of interest between themselves and Shining 3D.

5. Promotions and Statements

Employees and Partners who are involved with advertising and marketing should make sure that promotional literature is accurate and truthful in regards to the promotion of the Shining 3D’s product and services.

Only authorized representatives may make public statements to the media on behalf of Shining 3D. Employees shall not at any time make any comments and statements that damage the reputation of Shining 3D and violate applicable laws and regulations.

Trade Compliance

Shining 3D operates a global business that imports and exports goods in many countries around the world. We have passed the AEO Certification to ensure trade security, which is an important guideline for SHINING 3D to follow in serving the global market. Employees and Partners shall familiarize themselves with all applicable import and export laws and regulations, and must abide by all of these laws and regulations. Failure to do so can result in fines, loss of import or export privileges, and/or even criminal liabilities for Shining 3D.

If Employees and Partners become aware or have reason to believe that the activities they are participating in may violate applicable export control laws and regulations, they must promptly notify Shining 3D.

Data Protection

As a digital technology provider, SHINING 3D abides by the laws and regulations and the international standard systems on data security and personal information protection. The company has obtained the certification of Level 3 Classified Protection of China Information Security, Trusted Information Security Assessment Exchange (TISAX), ISO/IEC 27001:2013 (GB/T 22080-2016) Information Security Management System, ISO/IEC 27701:2019 Privacy Information Management System, ISO/IEC 27017:2015 Practical Rules for Cloud Service Information security controls, and ISO/IEC 27018:2019 The Personally Identifiable Information（PII）Protection Management System in Public Clouds.

To every individual with whom we conduct business (including Employees and Partners), we are committed to protecting their reasonable expectations of privacy. Our commitment to privacy protection is reflected and explicitly stated on our official website: https://www.shining3d.com/privacy-policy. Every employee is responsible for adhering to our privacy and security requirements. Should you have any questions, issues, or concerns, please consult dp@shining3d.com.

Whistle Blowing

Employees or Partners who have a reasonable belief that a person or entity has failed, is failing or is likely to fail to comply with a particular legal, obligatory or regulatory obligation regarding to this Business Code of Conduct, they shall raise the matter to the following addresses: legal@shining3d.com.

All genuine concerns about potential violations of laws and company policies will be handled with seriousness and confidentiality. Whistle blowers need not worry about facing disciplinary actions or penalties, regardless of whether the alleged wrongdoing by the accused is substantiated.