POLY INTERNATIONAL CORPORATE COMPLIANCE STATEMENT

Poly International Holdings, Co., Ltd (hereafter, “Poly International”), together with its subsidiaries and branches, strictly observes national and international trade compliance policies and practices. Our commitment to compliance includes China’s national laws, pertinent global trade compliance policies and practices, and relevant foreign countries’ laws and regulations. Poly International’s compliance program mitigates trade risks, builds a positive image as a responsible global company, and strengthens global partnerships. It also increases our access to and competitiveness in international markets and maximizes our long-term potential in international commerce.

Poly International is a subsidiary of the parent company “Poly Group.” We have a diverse portfolio specializing in defense products trade and R&D, civilian goods – ranging from mechanical equipment to luxury consumer products – overseas investments in natural and renewable resources (oil, gas, coal and new energy), international infrastructure projects and investment in energy and power facilities. We are keenly aware of the imperative to identify sensitive end-users, to distinguish product codes, and to keep abreast of ever-changing compliance standards. In addition to our defense products, we pay close attention to the management of dual-use products and technologies from our diverse product and investment portfolio. Poly International will refrain from exporting products, technologies, and services, whether physically or intangibly, when it has reason to believe that these items might be used by its customers or end-users for developing or manufacturing weapons of mass destruction, delivery mechanisms, for unauthorized military end-use, or fall into the hands of terrorist organizations. We have committed to employing an internal compliance program (ICP) to address these and related trade risks. We carefully monitor and regulate employee and partner access to sensitive technologies and data that some individuals or organizations may wish to use for malicious purposes. Additionally, Poly International verifies that intermediaries, such as customs brokers, freight forwarders, or shippers, represent no potential compliance risks. We will not engage in business with companies or individuals that present any manner of associated proliferation risk.

Pursuant to our compliance objectives, Poly International has established a Trade Compliance Committee (TCC) and a Trade Compliance Office (TCO) to ensure ongoing and effective implementation of its internal compliance system. The Trade Compliance Office is led by the Chief Compliance Officer and empowered with authority to veto any and all questionable transfers. To ensure a systemized approach to transaction screening, Poly International has developed and implements standard operating procedures (SOPs) for trade-related audits, recordkeeping, employee training, and transaction and order screening. We also utilize databases within our ERP system for sensitive products, customers, and countries in order to assist employees in performing end-user verification and product classification processes.

We employ a reward and penalty system to motivate our team to meet our trade compliance goals. We reward Poly International team members who successfully follow our compliance policies and practices and hold legally accountable any employee who violates them. We are continuously striving and working to enhance the effectiveness of our compliance program in response to international developments and regulatory changes.

Our commitment to compliance applies to our entire global organization, including all Poly International subsidiaries and offices.

Poly International leadership will review this Statement annually and revise as required.

Signed

Poly International

Signature