Weichai (hereinafter referred to as "the Company" or "we"), as an international company operating across multiple fields and industries, is committed to leading by example and complying with high standards of the Code of Business Conduct. We formulate and continuously improve a set of sound and transparent policies and standards to guide all business operations with uniform standards. This Code applies to Weichai, its domestic and overseas subsidiaries, and all employees (including directors, senior management, full-time employees, part-time employees, dispatched workers, and interns). Overseas subsidiaries and independently listed subsidiaries shall formulate and issue separate codes of conduct based on the requirements of the laws and regulations of their operating or listing jurisdictions, which shall be consistent with the basic principles of this Code. This Code also serves as an important standard for the Company in selecting partners.

I. Core Principles

1. Mission — Tech Empowered, Future Equipped

2. Vision — Building a world-class multinational high-end equipment group featuring technological leadership and green development

3. Three Core Values

(1) Focus single-mindedly on the core business

(2) Never slacken efforts, always stay at the forefront, and strive for the best

(3) Prioritize integrity, master craftsmanship, and achieve results through action

II. Code of Conduct

(I) Uphold Integrity and Compliant Operations

1. Lawful Compliance

Every employee has the obligation to comply with the laws and regulations of the countries and regions where the Company operates, as well as international business practices and recognized standards, including investment, trade, import and export, foreign exchange, labor, environment, contracts, consumer protection, intellectual property, accounting, and taxation. Employees are required to understand and comply with all laws, regulations, and rules applicable to their positions within the Company. If there is any doubt as to whether an action is legal, employees shall immediately seek advice from compliance personnel.

2. Anti-Corruption and Commercial Bribery

Weichai opposes any direct or indirect offering or acceptance of bribes, and the Company and its directors, senior management, employees, shareholders, and agents comply with all applicable laws related to anti-corruption and commercial bribery. Bribery can take many forms, including but not limited to:

-- Cash, gifts, and giveaways;

-- Securities;

-- Travel or entertainment;

-- Kickbacks;

-- Items or services of any value.

The Company adopts a "zero tolerance" attitude toward any corrupt practices and commercial bribery by any employee, strictly prohibits any form of bribery and acceptance of bribes, requires employees to strictly abide by the Company's regulations on gift giving and business hospitality, strictly prohibits any bribery under the guise of donations or sponsorships, and strictly prohibits the payment of any so-called "facilitation fees, hush money, or payoffs"

3. Business Gifts and Hospitality

Weichai employees shall not offer or accept gifts and business hospitality exceeding nominal value, and frequent acceptance of hospitality may impair employees' objective judgment. Gifts refer not only to physical items, but also to services, favors, and discounts. Employees must handle external banquets and social engagements with caution to ensure that the business gifts and hospitality provided or accepted are appropriate and will not be reasonably interpreted as bribery or improper intent to secure an unfair advantage or violate applicable laws and regulations. Employees and their families shall avoid acts of accepting bribes or giving rise to suspicions of bribery, shall not accept any gifts that may affect business relationships with Weichai, and are strictly prohibited from paying or reimbursing travel expenses or the like in order to exert improper influence on a third party to secure or retain a business advantage for the Company or for any other corrupt purpose.

4. Fair Competition

Weichai complies with the fair market competition order and applicable fair competition laws and regulations in the jurisdictions where it operates. Every employee shall strive to maintain fairness in their interactions with the Company's customers, suppliers, competitors, and employees; They shall avoid entering into formal or informal agreements with competitors regarding pricing, production, customers, or markets; Sales strategies or arrangements with customers or suppliers that unreasonably restrict or prevent competition between competitors or customers will be deemed as attempts to undermine fair competition and consumer interests, such as exclusive dealing agreements, bundling or tying, and minimum resale price agreements.

Weichai prohibits any competitive behavior that violates laws and regulations, breaches business ethics, or disrupts market order, including but not limited to predatory pricing, false advertising, misappropriation of others' brands or improper use of others' influence, damaging the reputation of competing products, infringing upon others' trade secrets, and engaging in coercive trading practices.

5. Conflicts of Interest

Weichai prohibits employees from having any conflicts of interest with the Company, including but not limited to holding positions in external companies without the Company's permission, conducting business with Weichai through personally owned companies, having conflicts of interest with companies where employees or their close relatives hold shares or positions, usurping corporate business opportunities, and misuse company resources or influence. Employees shall comply with relevant company regulations and are prohibited from abusing their authority to seek illegal benefits for themselves, thereby causing undue impact on the Company. The Company requires employees to fully disclose any circumstances that normally can be expected to give rise to conflicts of interest. If any situation is discovered that may cause a conflict between Weichai's interests and personal interests, please disclose the conflict of interest to compliance personnel. If an employee suspects that a conflict of interest exists, or in circumstances that would normally be perceived by others as a conflict of interest, the employee must immediately report the matter to compliance personnel.

6. Prohibition of Insider Trading

Due to their engagement in related business, Weichai employees may become aware of or access undisclosed inside information regarding Weichai or other companies. Weichai employees and their family members shall not use such inside information to seek economic benefits, including trading in stocks or securities using inside information of Weichai or other companies; Investing under the names of others to circumvent the policy prohibiting insider trading; Disclosing inside information to other unrelated persons, including Weichai employees, etc.

7. Trade Compliance

Weichai shall comply with export controls, economic sanctions, and counter-sanctions laws and regulations of China and applicable countries and regions required for its business operations, foster national security awareness, conduct relevant trade compliance risk assessments before providing goods, software, technology, or services externally, apply for required export authorizations or licenses in accordance with the law, and ensure the compliance of transactions.

All Weichai employees shall conduct trade compliance risk assessments, including sanctions blacklist screening, in accordance with the compliance guidance of each department prior to conducting business. If risk indicators are identified, they shall report promptly in accordance with compliance procedures and conduct subsequent business in accordance with compliance guidance.

8. Antitrust

Weichai shall comply with antitrust laws and regulations of China and applicable countries and regions required for its business operations, ensure fair competition with other competitors, including prohibiting engagement in or participation in monopoly agreements or monopoly transactions, prohibiting abuse of market dominance, and prohibiting non-compliant concentration of undertakings.

9. Financial Integrity and Tax Compliance

Weichai complies with accounting systems, accounting standards, and other applicable laws and regulations regarding financial accounting and reporting. The Company's accounting records and statements shall genuinely and accurately reflect transaction information, and employees must prevent and promptly report the possibility of inaccurate or incomplete financial reporting.

Employees shall ensure that financial records and financial statements relating to Weichai's business are accurate and reliable. They shall not assist others in improper bookkeeping or making false or misleading financial information reporting; They shall accurately and completely record and report all information, and shall not assist anyone in recording or reporting any inaccurate or potentially misleading information; They shall not provide any person outside Weichai (including customers, suppliers, or partners) with advice on how they should record and report their own income, expenses, costs, and other assets and liabilities.

Weichai strictly complies with national tax policies, strictly fulfills tax obligations in accordance with the law, truthfully reports the Company's financial status to tax authorities, maintains a "zero tolerance" approach towards tax evasion, and ensures the completeness, accuracy, and authenticity of materials related to tax filing. All Weichai employees shall also strictly fulfill their personal tax obligations in accordance with the law.

Weichai and its employees shall retain the Company's financial documents completely and comprehensively in accordance with the law, including but not limited to invoices, accounts, and accounting documents, and eradicate any non-compliant practices.

(II) Protecting Company Asset Interests

1. Protecting Company Assets

Company assets include tangible assets and intangible assets, which are the foundation of the Company's sustainable development. Tangible assets include plants, equipment, systems, products, materials, buildings, and supporting facilities, while intangible assets include brands, reputation, digital assets and user assets, land use rights, software systems, patent rights, trademark rights, and copyrights. The loss, theft, or misuse of assets will jeopardize the future of the Company, and employees shall carefully and properly custody, use, and dispose of company assets.

It is strictly prohibited to use the Company's funds or assets for any illegal or improper purposes (whether for personal gain or not). Company employees have the responsibility to protect all tangible assets, intellectual property, technical secrets, trade secrets, and other intangible assets of the Company. Meanwhile, they shall remain vigilant against potential security hazards involving company assets and report any abnormal situations immediately to their direct supervisors or corresponding management departments.

2. Data Protection

Weichai attaches great importance to the protection of data and information, strictly complies with relevant laws and regulations such as the Trade Secret Protection Law, Personal Data Protection Law, and Cybersecurity Protection Law, adopts effective control measures for information and data of customers, related parties, employees, and the Company, and integrates data protection requirements into the management processes of daily business activities.

Weichai employees shall strictly abide by the Company's data protection policies and systems as well as relevant laws and regulations, collect, process, store, and transmit data strictly in accordance with the law based on business needs, and take appropriate protection measures to prevent unauthorized use and disclosure of data information.

When collecting and using personal information, the principles of lawfulness, legitimacy, necessity, and minimum scope shall be followed, the consent of the information subject shall be obtained, and the rules, methods, and scope of personal information collection and use shall be explained. Personal information refers to all kinds of information related to an identified or identifiable natural person, either alone or in combination with other information, or that reflects the activities of a specific individual.

In the process of externally disclosing employees' personal information, Weichai shall comply with relevant laws and regulations, obtain the consent of relevant personnel in advance, disclose relevant information in a timely, accurate, truthful, and complete manner, and make relevant filings and records. No employee may externally disclose personal information without authorization.

Weichai shall formulate manuals and guidelines related to data protection, conduct regular communication and implementation for all employees, carry out cybersecurity assessments, and optimize cybersecurity measures to ensure the Company's data security. Employees shall understand the Company's data protection policies, receive training provided by the Company, refrain from undermining the Company's network security, and not disclose the Company's data information.

3. Intellectual Property and Trade Secrets

Weichai attaches importance to the creation, protection, and use of its intellectual property, and respects and avoids infringing upon the intellectual property of others. All employees of the Company shall protect the Company's intellectual property and have the responsibility to prevent the Company's intellectual property assets from being misused. The intellectual property rights of inventions and creations developed by company employees using company resources in the course of performing their duties shall belong to the Company. Third-party partners shall respect Weichai's intellectual property rights such as patent rights, trademark rights, and copyrights, comply with Weichai's restrictions and prohibitions on the use of its intellectual property, and use Weichai's information and assets only for specific authorized purposes.

Weichai's intellectual property includes, but is not limited to, patents, trademarks, copyrights, trade secrets, and other information. Employees shall comply with the Company's intellectual property and information security policies, protect and lawfully use the Company's intellectual property, and have the obligation to protect Weichai's trade secrets. They shall use such trade secrets within a reasonable scope by authorized personnel in accordance with Weichai's relevant regulations and based on relevant agreements with Weichai. Weichai's trade secrets include technical information such as designs, programs, formulas, production processes, manufacturing methods, test information, and technical know-how, as well as business information such as overall strategic planning, functional planning including product technology and various business plans, management methods, business models, capital operations, financial information, compensation information, business policies, resource reserves, customer information, and bidding and tendering matters.

4. Brand Reputation and External Communication

Brands are of great strategic significance to Weichai and have a positive impact on all of Weichai's business activities. Weichai's brand value and brand assets require the active maintenance of every employee and related party, and any behavior that damages Weichai's brand and reputation by any person in any form shall be resolutely stopped.

Weichai's business activities will involve government departments and subordinate agencies at all levels. Weichai shall attach importance to mutual support and cooperation with government departments and comply with laws and regulations related to government transactions and business handling. When conducting business with the government, Weichai shall provide government authorities with timely and accurate data and materials in accordance with the law. In transactions with the government, it shall be ensured that project participants understand the detailed terms of the transactions and perform obligations on schedule. Weichai employees shall not, without approval, participate in political activities or make political statements, nor shall they accept requests for information, interview requests from the media or the general public, or engage in any community activities in the name of Weichai or Weichai employees.

(III) Helping Employees Realize Their Self-Worth

The company respects the growth needs of everyone in the enterprise, creates a proactive, efficient, pragmatic, and mutually respectful working atmosphere, and helps employees unleash their personal potential and realize their self-worth.

1. Health and Safety

As an enterprise that complies with laws and regulations and possesses a sense of social responsibility, Weichai is committed to providing employees with a healthy and safe working environment, continuously pursuing the maximization of human value, striving to provide a fair and just platform, and encouraging the promotion of entrepreneurial and innovative spirit. Weichai employees shall actively maintain and participate in co-creating a healthy and safe workplace. Third-party partners providing products and services or participating in projects within Weichai's workplace shall consciously abide by relevant national and regional laws and regulations as well as Weichai's health and safety standards, provide health and safety training for their respective employees, and ensure a healthy and safe working environment. We hope that employees share our philosophy and adhere to the following basic principles:

-- Prohibit discrimination, retaliation, harassment, any form of abuse, and violent behavior, including inappropriate comments, jokes, and behaviors;

-- Ensure fair compensation and benefits in accordance with local laws and culture;

-- Have zero tolerance for human rights violations (such as forced labor and child labor);

-- Respect employee privacy and ensure personal information security;

-- Prohibit alcoholic beverages, and refrain from drinking alcoholic beverages in Weichai's office premises;

-- Give priority to business partners who share the same values as Weichai.

2. Harmonious Labor Relations

As an enterprise that strictly complies with China's labor laws and regulations as well as the international labor treaties on lawful employment ratified by the Chinese government, Weichai strictly implements the requirements of laws and regulations, enters into, modifies, terminates, or rescinds employment contracts with all employees in accordance with the law, strictly follows voluntary, fair, equitable, and compliant labor and employment policies, and resolutely opposes illegal and irregular practices such as forced labor and child labor employment.

In the process of hiring employees, the company adheres to the basic principles of voluntariness, equality, and fairness, and strictly prohibits unequal employment based on race, ethnicity, nationality, gender, religion, etc. At the same time, it ensures employees' free choice of employment upon hiring, and makes labor remuneration, wages and benefits open and transparent to workers.

In safeguarding employee rights and interests, the company earnestly protects the lawful rights and interests of employees, strictly enforces relevant labor laws and regulations as well as the provisions of employment contracts, pays wages and related benefits on time and in full in accordance with the commitments made during recruitment, fully protects employees' leave entitlements as well as freedom of action and personal freedom, and provides employees with comprehensive talent development resources to support their career development. Actively support the work of trade unions, fully listen to the suggestions of trade unions and employees regarding major events involving employees, and protect the lawful rights and interests of employees.

The company encourages employees to handle disputes between both parties in accordance with the law, ensuring the lawful rights and interests of both employees and the company. When employees believe that the company has harmed their lawful rights and interests, they may report to the human resources department and other relevant departments of the company, adhere to equal consultation, and seek solutions that reflect the interests of both parties.

(IV) Building a better society of harmonious coexistence

Adhere to green development and innovation, provide solutions for the sustainable progress of social life, and jointly promote the harmonious coexistence of man, industry, and nature.

1. Environmental protection

Weichai drives efficient development through scientific and technological innovation, integrates green philosophy into various aspects such as product research and development, production and manufacturing, and operations management, promotes the low-carbon transition of the industry, and leads industry progress and transformation. Continuously increase r&d investment in green and low-carbon products, promote green and sustainable products and services, deliver excellent products and services to all parts of the world, help partners achieve sustainable growth and mutual benefit and win-win results, and meet the demand of global users for green and efficient power solutions; Increase the proportion of renewable energy utilization, systematically promote energy conservation and emissions reduction, build a sustainable supply chain, and achieve net-zero emissions across the value chain as early as possible; Practice circular economy, improve resource utilization efficiency, protect biodiversity, and promote the harmonious coexistence of enterprises and nature.

2. Community development

Weichai conducts operations in a responsible and sustainable manner, and actively prevents, mitigates, and remedies any impacts on the community caused by the company's business activities. The company attaches great importance to community concerns, maintains close communication with local government departments, communities, and residents, participates in community development, provides local employment opportunities, and is committed to building a long-term relationship of harmonious coexistence with the community. Meanwhile, the company actively fulfills its obligations and responsibilities to the community, supports local educational development and public welfare initiatives, and supports community development through donations, volunteer service activities, and other means.

III. implementation

1. Complaints and reports

Weichai encourages employees, customers, suppliers, contractors and other cooperative personnel, as well as government and regulatory authorities, to file complaints and reports against any company, department and employee at all levels of Weichai for violations of the Code of Business Conduct, such as lacking integrity in business conduct, unfair competition, and abuse of authority.

Reporting channels:

Reporting hotline: 0536-2102388

Reporting email: 2102388@weichai.com

Official website supervision and reporting module:

https://www.weichai.com/mtzx/gysjb/jubao/

Reporting QR code:

Upon discovering any behavior violating this Code, Weichai shall accept and handle the violations in accordance with relevant regulations based on the severity of the circumstances. The Company encourages real-name reporting, strictly keeps the whistleblower's personal information and reporting contents confidential, sets access permissions for the reporting information, and strictly prohibits disclosing relevant information to the reported person and irrelevant personnel. The Company prohibits any acts of threatening, attacking or retaliating against whistleblowers, and will provide legal support and protection to whistleblowers when necessary.

2. Training

Weichai regularly provides training on the contents of this Code, anti-corruption and business ethics standards for all employees (including full-time employees, part-time employees, dispatched workers, interns, etc.), suppliers and contractors, to maintain a healthy, safe and efficient working environment.

3. Audit

Weichai conducts regular audits of all business segments, business ethics standards and policies based on actual needs.

This Code shall take effect and be implemented as of the date of issuance. Weichai shall review this code at least annually and revise and update this code in a timely manner based on changes in national laws, international conventions, and other factors.