I. Statement

1. Shanghai Sunrise Polymer Material Co., Ltd. (hereinafter referred to as the "Company" or "Sunrise") is committed to advancing Corporate Social Responsibility (CSR) as well as Environment, Social and Governance (ESG). It guides all business entities within Sunrise Group and all employees to standardize the Company’s business activities in accordance with the tenets set forth in this Code.

2. In formulating the Code of Conduct on Corporate Social Responsibility (hereinafter referred to as the "CSR Code of Conduct"), Sunrise incorporates the following requirements: local legal requirements of the countries, provinces and municipalities where Sunrise operates; requirements of industry associations and relevant organizations that Sunrise participates in; as well as Sunrise’s internal commitments, namely that the Company bears corresponding responsibilities and commitments to various stakeholders including employees, customers, shareholders, suppliers and local communities.

3. By assessing the commonalities and differences among the above requirements, Sunrise commits to self-regulation under high standards. All corporate decisions and activities must comply with applicable local laws. In addition, the Company will benchmark its Code of Conduct against evolving requirements of relevant parties in a timely manner and carry out revisions and updates accordingly.

4. The Company’s CSR policies shall comply with applicable laws, industry norms, human rights standards, environmental protection requirements and product safety rules in regions where all group entities operate. The Company takes integrity as the fundamental principle of operation and requires suppliers to actively align with the Company’s CSR policies.

II. Purpose

Sunrise issues this Code of Conduct on Corporate Social Responsibility to ensure corporate operations comply with ethical, legal and professional standards, so as to safeguard corporate assets, interests, as well as the hard-earned brand reputation. The Company will enforce this Code under stringent standards to continuously enhance stakeholders’ trust in Sunrise and elevate its social image.

III. Responsibilities

This CSR Code of Conduct establishes a set of standards governing Sunrise’s business activities, clarifying responsibilities and implementation criteria for each entity under Sunrise.

The Board of Directors serves as the highest guiding body for this CSR Code of Conduct. It oversees the overall implementation of CSR policies, reviews implementation outcomes and drives continuous improvement. The Chairman acts as the primary initiator of CSR policies, systems and relevant management guidelines. The Board Secretary’s Office takes the lead in advancing the implementation of CSR management improvement initiatives.

The Company’s Internal Control & Audit Department and lead departments for management systems are responsible for monitoring compliance with CSR policies, and submitting inspection findings and evaluation comments on actual operations to the Board of Directors and the Chairman.

Furthermore, the Company may conduct specific reviews on CSR implementation covering labor practices, ethics, environment, health & safety and management systems based on management needs. Such reviews may be performed by internal professional staff, or entrusted to external professional organizations and experts.

Sunrise respects the rights and interests of stakeholders. On the basis of identifying stakeholders, the Company adopts appropriate communication channels to understand their legitimate expectations and demands, and effectively respond to their concerns and requirements.

IV. Scope of Application

This CSR Code of Conduct applies to all operating entities that are legal persons, subsidiaries or branches of Sunrise, including but not limited to: Shanghai Sunrise Polymer Material Co., Ltd., Nanjing Rigoo Polymer Co., Ltd., Jilin Rigee Special Chemicals Co., Ltd., Rigoo New Energy (Shanghai) Materials Technology Co., Ltd., SUNRISE POLYMER MATERIAL (MALAYSIA) SDN BHD. (This list is non-exhaustive and only covers major operating entities), as well as all employees of affiliated operating institutions, including direct and indirect employees.

V. Standards of the CSR Code of Conduct

This CSR Code of Conduct covers seven modules: (1) Ethical Standards; (2) Labor and Human Rights; (3) Health and Safety; (4) Environmental Protection; (5) Management Systems; (6) Responsible Sourcing; (7) Anti-Corruption Policy, together with the Company’s policies and statements corresponding to the above seven modules.

(1) Ethical Standards

Upholding the corporate mission of Empower the World with Chemistry, Sunrise shall adhere to high ethical standards to fulfill social responsibilities and achieve sustainable development. Sunrise’s ethical standards are specified as follows:

1. Integrity in Operation All commercial activities shall abide by integrity standards, with zero tolerance for dishonest conduct. Any form of bribery, corruption, extortion and embezzlement is prohibited. The Company shall immediately terminate cooperation and initiate legal proceedings in case of such violations.

2. Transparency of Information All business transactions shall be transparent and accurately recorded in financial books and accounting records. The Company discloses information on labor practices, health & safety, environmental performance, business activities, organizational structure, financial status and operational results in accordance with applicable laws and prevailing industry practices.

3. Prohibition of Unlawful Gain No party shall promise, offer, grant, give or accept bribes, or conduct any form of benefit transfer to obtain illegal or improper advantages.

4. Conflict of Interest Avoidance During business activities and daily work, employees shall avoid conflicts of interest that may negatively affect their judgment, objectives or loyalty to the Company, and properly handle any conflicts of interest that arise.

5. Anti-Money Laundering Sunrise and its employees are strictly prohibited from participating in any money laundering activities associated with illegal crimes. The Company makes every effort to conduct business only with customers and partners that operate legitimate businesses with lawful sources of funds, and fully complies with all applicable anti-money laundering laws and regulations.

6. Fair Trading and Fair Competition The Company adheres to fair trading and fair competition. Exaggerated or false advertising is forbidden. The Company strictly protects the trade secrets of itself and relevant parties.

7. Protection of Whistleblowers & Anti-Retaliation Policy The Company protects supplier and employee whistleblowers and safeguards the confidentiality and anonymity of reports. Anonymous complaints are accepted (submissions shall provide clear information including involved persons, time, location, incidents and evidence). The Company establishes communication procedures enabling employees to raise concerns without fear of retaliation.

8. Intellectual Property Protection The Company respects intellectual property rights, technologies and know-how, and strictly protects information security of customers and suppliers.

9. Personal Data Protection The Company undertakes to protect personal information of all parties cooperating with Sunrise, including suppliers, customers, consumers and employees. The collection, storage, processing, transmission and sharing of personal information shall comply with laws and regulations governing privacy and information security.

10. Community Engagement The Company respects local communities where it operates, actively contributes to local development to boost social and economic progress, and minimizes potential disturbances or adverse impacts.

(2) Labor and Human Rights

Sunrise safeguards employee rights in line with internationally recognized standards and treats all employees with dignity and respect. This clause applies to all employees, including temporary workers, apprentices, interns, contract workers, direct hires and all other types of staff. Sunrise’s labor and human rights standards are as follows:

1. Free Choice of Employment No forced, bonded (including debt-bonded), indentured labor, involuntary or exploitative prison labor, slavery or human trafficking shall be employed. The Company guarantees employees’ freedom of movement within the workplace. All employment shall be voluntary. Employees are free to resign or terminate employment at any time. Employees who provide reasonable notice in accordance with contracts may terminate employment without penalty.

2. Prohibition of Child Labor & Protection of Minors Child labor shall not be used at any stage of the Company’s operations. Appropriate mechanisms are implemented to verify employee age. Employees under 18 years of age (minors) shall not be assigned work that may endanger their health or safety.

3. Protection of Female Employees The Company commits to protecting the rights and health of female employees by providing occupational health protection, maternity leave, social welfare and breastfeeding breaks. Female employees shall not be dismissed or discriminated against due to pregnancy. Any unlawful termination or discrimination against female employees during pregnancy, maternity leave or breastfeeding is prohibited. In accordance with applicable laws, female employees shall enjoy maternity benefits no less than statutory requirements and be entitled to return to the same or equivalent position with equal benefits after maternity leave. In addition, the Company takes appropriate measures to prevent pregnant or breastfeeding women from exposure to high-risk working environments, carries out targeted post risk assessments, and eliminates or reduces health and safety risks for pregnant and breastfeeding employees at workplaces.

4. Diversity, Equal Opportunity, Anti-Discrimination & Anti-Harassment The Company prohibits discrimination, harassment and retaliation. It strives to provide equal opportunities and fair treatment for all employees to build a safe, healthy and pragmatic workplace with diversified career development paths. No discrimination or harassment based on race, skin color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religious belief, political affiliation, marital status or other labels shall be practiced. The Company adheres to this principle throughout recruitment and employment, including salary, promotion, rewards and training opportunities.

5. Humane Treatment Violence, gender-based violence, sexual harassment, mental or physical coercion, bullying, public humiliation, verbal abuse and other inhumane harsh treatment of employees are prohibited, as are threats to impose such conduct.

6. Wages and Benefits Remuneration paid to employees complies with all applicable wage laws, including regulations on minimum wage, overtime hours and statutory benefits. Employees shall receive clear and understandable payslips containing sufficient details for employees to verify the accuracy of their compensation.

7. Working Hours Unreasonable excessive overtime is linked to reduced productivity, higher turnover and increased occupational injuries and illnesses. Except for emergency or extraordinary circumstances, regular working hours shall not exceed the RBA standard of 60 hours per week. Overtime work must be voluntary. Reliable and detailed records shall be maintained for regular working hours and overtime. Employees shall be entitled to leave, vacation benefits and statutory holidays in accordance with applicable laws and regulations.

(3) Health and Safety

Safe and healthy working environments improve product and service quality, facilitate production, raise employee retention and morale, and reduce work-related injuries and illnesses. Sunrise recognizes that continuous employee engagement and training are essential to identify and resolve workplace health and safety issues. Sunrise’s health and safety standards are as follows:

1. Occupational Safety The Company identifies, assesses and mitigates workplace health and safety hazards (including chemical risks, fire hazards, mechanical injuries, occupational noise, special operation risks, fall risks and accidents) through hazard elimination, material substitution, design optimization, engineering and administrative controls, preventive maintenance, safe operating procedures and ongoing safety training. Where hazards cannot be effectively controlled via the above measures, properly maintained personal protective equipment (PPE) shall be provided to employees free of charge, together with training on associated risks.

2. Emergency Preparedness Emergency drills shall be conducted at least once every year. Potential emergencies shall be identified and assessed, and emergency response plans and procedures implemented to minimize impacts, including incident reporting, staff notification and evacuation protocols, training and drills, adequate fire detection and suppression equipment, clear and unobstructed escape routes, emergency contact information, sufficient exit facilities and post-disaster recovery plans.

3. Infectious Disease Preparedness and Response The Company develops and implements structured plans to prevent and respond to potential infectious disease outbreaks among employees.

4. Occupational Injuries and Illnesses Systems and procedures shall be established to prevent, manage, track and report occupational injuries and illnesses, including encouraging employee reporting, classification and recording of incidents, provision of necessary medical services, incident investigation and corrective actions to eliminate root causes.

5. Industrial Hygiene The Company identifies, assesses and controls chemical, physical and other workplace hazards via hierarchical risk control. When potential hazards are detected, opportunities shall be explored to eliminate or reduce risks through design, engineering and administrative controls. Where hazards cannot be sufficiently controlled through such measures, properly maintained PPE shall be provided to employees free of charge. Adequate first-aid supplies and facilities shall be available on-site. Continuous training on hazard prevention and mitigation shall be delivered.

6. Machinery Safety Guards Risk assessments shall be performed on production and other machinery to minimize or eliminate mechanical injury risks. Change management and re-assessment of machinery safety risks shall be conducted for newly introduced or modified equipment.

7. Sanitation, Catering and Accommodation Clean restroom facilities, drinking water, food storage and tableware facilities shall be provided to employees. If staff dormitories are provided, they shall be kept clean and safe, equipped with proper emergency exits, hot water, adequate lighting, ventilation, private lockers for personal valuables and reasonable private space.

8. Health & Safety Communication Workplace health and safety information shall be provided to employees, and training delivered to ensure proper understanding of workplace hazard labels. Relevant health and safety information shall be posted visibly on-site. Employees are encouraged to raise health and safety concerns without fear of retaliation.

(4) Environmental Protection

All operational activities of Sunrise adhere to environmental protection principles, including managing the ecological impacts of products and production facilities. Sunrise’s environmental protection standards are as follows:

1. Material Restrictions The Company complies with laws, regulations and customer requirements governing prohibited or restricted substances contained in products and manufacturing processes.

2. Hazardous Substances Chemicals, waste and other materials hazardous to humans or the environment shall be identified, labeled and managed to ensure safe handling, transportation, storage, use, recycling, reuse and disposal.

3. Solid Waste Systematic approaches shall be adopted to identify, manage, reduce, responsibly dispose of, recycle and reuse solid waste.

4. Air Emission Management Volatile organic compounds, aerosols, corrosive gases, particulates, ozone-depleting substances and combustion by-products generated during operations shall be sampled, routinely monitored, controlled and treated prior to discharge. The operational status of air emission control systems shall also be monitored.

5. Environmental Permits and Reporting All required environmental permits, approvals and registrations shall be obtained, maintained and updated, and all operational and reporting obligations under such documents shall be fulfilled.

6. Pollution Prevention and Resource Conservation Measures shall be adopted to reduce or eliminate pollutant emissions and waste generation at source, such as upgrading pollution control equipment, optimizing production, maintenance and facility processes. The Company shall use natural resources responsibly, including water, fossil fuels, minerals and timber, via process improvement, material substitution, reuse, conservation and recycling strategies.

7. Water Resource Management All wastewater shall be sampled, monitored, controlled and treated as required before discharge or disposal. The operation of wastewater treatment and control systems shall be monitored continuously.

(5) Management Systems

Sunrise establishes a management system covering the scope defined in this Code. The system is designed to ensure compliance with applicable laws, regulations and customer requirements for supplier operations and products; compliance with this Code; timely identification and mitigation of operational risks relevant to this Code; and promotion of continuous improvement. The corporate management system includes the following elements:

1. Corporate Commitment A CSR policy statement confirming the Company’s commitment to compliance and continuous improvement.

2. Management Roles and Accountability Appointed corporate representatives responsible for implementing the management system and related programs. Senior management shall conduct regular reviews of system performance.

3. Legal and Customer Requirements Procedures to identify, monitor and understand applicable laws, regulations and customer requirements.

4. Risk Assessment and Risk Management Procedures to identify legal compliance, environmental, health & safety, labor and ethical risks associated with operations. Prioritize risks, implement appropriate procedures and substantive controls to manage identified risks and ensure compliance.

5. Improvement Targets Written performance objectives, indicators and implementation plans. Regular evaluation of progress to improve CSR and EHS performance.

6. Training Training programs for management and employees covering Sunrise’s policies, procedures and improvement targets, as well as statutory requirements. New employees shall receive induction training including core courses on this CSR Code of Conduct, treated as mandatory knowledge for all staff.

7. Communication Clear and accurate communication of corporate policies, practices, expectations and performance to employees, suppliers and customers.

8. Employee Feedback, Participation and Grievance Mechanisms Sustained procedures (including effective complaint channels) to assess employee understanding of practices and clauses under this Code, collect feedback, receive reports of violations and drive continuous improvement. The Company creates a safe environment for employees to voice grievances and provide genuine feedback without fear of retaliation.

9. Audits and Evaluations Self-assessment through internal and external audits to verify compliance with laws and regulations, this Code, and CSR-related clauses in customer contracts.

10. Corrective Actions Timely rectification of deficiencies identified during internal/external assessments, inspections, investigations and audits.

11. Documentation and Records Establish and maintain documents and records to satisfy regulatory requirements, internal corporate standards and privacy confidentiality obligations.

12. Supplier Accountability Communicate the requirements of this Code to suppliers and monitor supplier compliance.

(6) Responsible Sourcing

Sunrise declares strict compliance with relevant international and industry regulations. The Company rejects and prohibits the use of conflict minerals originating from the Democratic Republic of the Congo and surrounding countries and regions. Furthermore, Sunrise requires its suppliers to comply with applicable laws governing conflict minerals.

(7) Anti-Corruption Policy

Sunrise upholds a culture of integrity and honest operation, and commits to unconditional compliance with anti-bribery and anti-corruption laws and regulations. The Company adopts a zero-tolerance policy for any violations. It is strictly prohibited to directly or indirectly offer, demand, receive or promise improper benefits to customers, suppliers, public officials, foreign officials or other stakeholders, or engage in corruption, bribery, extortion or embezzlement.

VI. Implementation of the CSR Code of Conduct

Upon formal issuance by the Company, this Code serves as the fundamental principles and standards governing Sunrise’s relations with all stakeholders (employees, customers, shareholders, suppliers, communities, etc.). All Sunrise employees shall strictly abide by the spirit and guiding principles set out in this policy. Commitment to and actual compliance with this Code shall be an important consideration in performance appraisal.

The Company promotes the requirements specified in this Code to employees through multiple channels, including employee handbooks, employment contracts and other communications to ensure effective delivery of proper implementation practices. Meanwhile, Sunrise establishes a CSR implementation verification mechanism to review enforcement and track continuous improvement progress.

In addition, all systems provide grievance and feedback channels. Whistleblower mechanisms and complaint channels shall be maintained and continuously optimized.

VII. Reporting and Procedures

1. Reporting To detect, prevent and avoid any violations of this Code, Sunrise encourages all employees and third parties to report any suspected or potential breaches. Any discovered violation, suspected violation or situation likely to lead to a violation may be reported via official reporting channels with supporting information.

2. Procedures Sunrise adopts a zero-tolerance policy for any violations of this Code. All reports submitted in good faith shall be fully investigated and handled promptly. All Sunrise employees must cooperate with internal investigations into improper and unethical conduct. Where violations are confirmed through investigation, disciplinary actions will be imposed in accordance with employment contracts, internal disciplinary regulations and procedures.

3. Anti-Retaliation Sunrise prohibits any form of retaliation against individuals who submit good-faith reports or complaints regarding violations of this Code. Whistleblowers and report contents shall be kept confidential and protected to avoid retaliation or unfair treatment.

This Code of Conduct shall take effect on June 1, 2023.

Shanghai Sunrise Polymer Material Co., Ltd. May 28, 2023