Honest and Compliant Operation and Anti-commercial Bribery Statemen

Honesty and law-abidingness are among the cornerstones of SANY. As a Chinese enterprise that abides by the code of ethics and is committed to sustainable development, we know that honesty, transparency and compliance are the cornerstones for enterprises to win trust and achieve long-term success in the global market. In order to actively respond to global environmental, social and governance requirements, and strictly abide by anti-commercial bribery laws and regulations of various countries, the Company solemnly declares as follows:

We are firmly opposed to all forms of commercial bribery, corruption and the transmission of illegitimate interests. No matter whether it conducts business in any country or region, the Company will never offer, promise, solicit or accept any form of bribery or illegitimate benefits (including but not limited to cash, gifts, commissions, and improper services) to public officials, business partners, customers or other third parties directly or indirectly.

• Policy system: The Company has established anti-corruption and anti-commercial bribery policies in line with international standards, covering all businesses and employees around the world.
• High-level commitment: The Board of Directors and the management will set an example, incorporate anti-corruption into the Company's strategy and risk management system, regularly review the effectiveness of compliance, and ensure that resources investment and cultural construction are promoted simultaneously.
• Full responsibility:Every employee has the responsibility to study and abide by the anti-corruption policy and report suspicious behaviors proactively. Violations will face disciplinary action until legal accountability, and will not be treated differently according to the position or performance contribution.

• Third-Party Risk Management: Conduct rigorous due diligence on agents, suppliers, consultants, and other third parties, requiring signed anti-bribery commitments and explicit compliance clauses with liability terms in contracts.
• Financial Transparency:All transactions must be recorded truthfully, accurately and completely. It is not allowed to set up concealed accounts or cover up improper payments through false bills and fictitious services. The finance team needs to ensure that the accounts are traceable and auditable.
• Reporting and protection mechanism:The Company provides diversified reporting channels (e.g. compliance hotline and anonymous email address). It is strictly forbidden to retaliate against informants. All reports will be investigated independently and fed back in time to ensure fair procedures.
• Reporting and Protection Mechanisms:rovide multiple reporting channels (e.g., compliance hotline, anonymous email). Retaliation against whistle-blowers is strictly prohibited. All reports will undergo independent investigation with timely feedback to ensure procedural fairness.
• Global cooperation: The Company will respect the legal and cultural differences of different countries, maintain open cooperation with regulatory agencies, peer organizations and international initiatives, and jointly address cross-border corruption challenges.

Honest operation is the lifeline of the Company's global development. We call on all members to join hands with partners to implement this statement, promote sustainable trade in a zero-corruption business environment, and create shared value for society, employees and shareholders.

SANY Heavy Industry Co., Ltd.