CONSTITUTION AND APPLICATION SCOPE

Shinhan Vietnam Finance Company Limited (hereinafter called “SVFC”) operates with policies and procedures which are consistent with the Shinhan Financial Group (hereinafter called “Group”), Group and SVFC’s core values standard conducts and ethics.

Based on Group’s Code of Ethics as well as Group’s Code of Conduct for all employees of the Group, this Code has been designed for SVFC in order to provide all employees with the standards of ethical decision-making or conducts in the specific situations related to their daily work, lives and duties. In addition, vendors of SVFC, such as suppliers and services providers are recommended to operate in accordance with this Code or have and operate its own equivalent code of ethics.

GENERAL PRINCIPLES

This Code is applied through out of the SVFC including all of employees of SVFC.

The “Acknowledgement and Declaration” of the Code on receiving, reading, understanding and complying with the Code must be signed by all employees when onboarding and on annual basis, as well as forwarded to Human Resource Division for filing and monitoring. Acknowledgement and Declaration may happen in either manual or electronic basis applied by SVFC from time to time.

If an employee becomes aware of any violation of this Code, he or she should report it without a delay to his or her line-managers or relevant departments/divisions, such as Legal & Compliance Division, Human Resources Division.

Should an employee makes a decision and/or behaves in violation of this Code, he or she can be subject to SVFC’s disciplinary actions according to Internal Labor Rules and other internal regulations and/or additionally may be subject to investigation and legal proceeding in accordance with laws and regulations.

CHAPTER I. CONDUCTS AND ETHICS FOR EMPLOYEES

Compliance with laws and regulations and ensure the fair business

All employees of SVFC must respect market order, comply with relevant Vietnam laws and regulations in areas of SVFC’s operations and strive to conduct their work in a fair and ethical manner.

• Must comply with relevant laws and regulations and must respect tradition and culture of Vietnam.
• Must not commit or get involved in illegal money laundering or insider trading.
• Must not force or instruct a colleague or a subordinate to do unfair or unethical work and must not yield if given such a pressure or instruction.

Integrity and Honesty

All employees of SVFC shall refrain from excessive investment activities deviating from their own economic ability and shall maintain an appropriate level of liabilities by considering the ability to repay.

All employees of SVFC must have basic knowledge of ethics and law-abiding spirits required as members of SVFC, and they should not try to engage in the activities in contravention of laws and regulations. Activities in contravention of laws and regulations including but not limited to the activities below:

• Making extravagant consumption behavior deviating from their own economic ability or beyond their means.
• Illegally engaging in speculative gambling or visiting gambling houses.
• Habitually visiting harmful places likely to cause excessive drinking or social controversies, which give an inconvenience or a feeling of disgust to third parties.
• Driving under the influence of alcohol.
• Unreasonably using the SVFC’s budgets or expenses, including business trip expenses and business promotion expense, for any purposes other than the original purpose.
• Engaging in any other activities equivalent of the above activities.

All employees of SVFC must clearly recognize their own rights and duties, must not provide goods and services to SVFC’s customers (the “Customer”) without qualification or authorities and must communicate honestly in performing their duties.

Anti-Money Laundering (AML) and Countering Terrorist Financing (CTF)

Money laundering acts and terrorism financing are global criminal offences by both Vietnam laws and regulations and international practices. Breaches of AML/CTF Law and regulations can incur severe criminal and/or civil sanctions for corporations and individuals; seizure of money and other assets; substantial fines and imprisonment or permanent shutdown applied for the organization.

All employees of SVFC:

• Must comply with the internal policy on Anti – Money Laundering (AML) & Countering Terrorist Financing (CTF).
• Must enhance AML & CTF’s awareness by attending all compulsory training programs on AML & CTF.

Detailed information can be found in the internal policy on Anti – Money Laundering & Counter Terrorism Financing of SVFC. Should you have enquiries, please contact Legal & Compliance Division for further instructions.

Anti-Bribery and Corruption

Accepting or giving gifts, meals, entertainment, and travel may create an apparent or potential conflict of interest or a circumstance where these acts could be viewed as bribery under Vietnam anti – bribery, corruptions law and regulations and the SVFC’s policies.

All employees acting on behalf of SVFC must comply with the anti – bribery, corruptions law & regulations and SVFC’s internal policies.

• Prohibition from Inappropriate of Gift and Entertainment Acceptance

SVFC employees are not allowed to receive gifts, entertainment, or any form of benefit from customers, partners, or related parties if such acts may lead to a conflict of interest; are likely to be misinterpreted as influencing customer relations or work execution; or are in violation of the Anti-Corruption Law or SVFC’s internal policies. However, the receipt of small-value gifts or items within the scope of normal social interaction and customs may be acceptable, including but not limited to:

+ Business meals or receptions conducted during work and in accordance with general practices;

+ Souvenirs or promotional items distributed equally to all participants at professional events;

+ Advertisements, promotions, or mass-distributed gifts not targeted at specific individuals;

+ Other cases of a similar nature to those listed above.

• Prohibition of Offering or Proposing Gifts and Entertainment

SVFC employees are prohibited from giving, offering, promising, or proposing any form of gift, entertainment, or benefit to customers, partners, or related parties if such acts could be considered as bribery, inducement, or aimed at gaining undue advantages related to work. Exceptions may apply in cases where the gift or entertainment is socially customary, not contrary to relevant laws or internal regulations, and not intended to influence professional judgment; intra-staff gifting is not prohibited, provided that it is for the purpose of expressing care or support in cases such as condolences, congratulations, and team bonding, and that such acts do not exceed reasonable limits or aim for any direct or indirect benefit.

• Handling of Inappropriate Gifts and Entertainment

SVFC employees must not accept or provide any gift, entertainment, or benefit if its nature and value are unclear, inappropriate, or exceed the permissible threshold without prior approval from competent authority in accordance with internal regulations.

All employees are responsible for reporting and cooperating in resolving any acts related to bribery, corruption, or misconduct within SVFC. In cases where such violations are discovered or suspected, employees must report immediately to the Legal & Compliance Division.

Prevention of Conflicts of Interests (COI)

All employees of SVFC should not create a situation of conflicting between them and SVFC or customers and, if such a circumstance occurs, must put the interests of the SVFC and customers first. In general, all employees must:

• Avoid any activity that is apparently or potentially a conflict of interest with SVFC and customers.
• Avoid circumstances where personal, outside businesses and or related family interests apparently or potentially impair the sound decisions making process of SVFC.
• Not engage in activities that compete with SVFC or impair the performance of your responsibilities to SVFC.
• Not use SVFC’s confidential information, assets & property (unless being permitted by SVFC) and your authority, role or position to take personal gains.

All employees of SVFC must have duties and responsibilities to disclose any apparent and or potential conflicts of interest amongst parties to their line managers and relevant departments/divisions, such as Human Resources Division, Legal & Compliance Division.

Disclosure of conflicts of interest is compulsory for all employees of SVFC. Failing to disclose a conflict or a perceived conflict is a violation of this Code as well as SVFC’s internal policies.

Detailed information can be found in the internal Policy of Conflicts of Interest. All employees are required to understand and comply with this Policy; if there are any enquiries, please contact with Legal & Compliance Division for further instructions.

Information Confidentiality and Security

All employees of SVFC should strictly manage and protect all information of SVFC and customers that they become aware of in the course of conducting their duties, specifically:

• Must protect SVFC’s proprietary information and Customer information that require confidentiality (collectively referred to as “Confidential Information”) in accordance with laws and regulations, SVFC’s internal regulations and must not divulge nor use such information for personal purposes.
• Confidential Information may exist in any forms of recording or may have no record. All employees of SVFC should not ask another employee to provide or grant an access to Confidential Information not related to their own work.
• Should any SVFC employees who maintain or use Confidential Information are asked to provide or grant an access to information illegitimately by another SVFC employee or someone outside SVFC, they should refuse such a request and must keep Confidential Information separate from other general information for strict management.

Detailed provisions regarding information security and information safety can be found in the Information Security Code of Practice, the internal Policy of Information Risk Management, and other internal regulations of SVFC. All employees of SVFC are required to read, understand, and comply with these regulations. If you have any questions about these regulations, please contact the Legal & Compliance Division for further guidance.

Fraud awareness and prevention

All employees of SVFC must:

• Understand and comply with the internal anti – fraud and the reporting procedures of SVFC.
• Not engage in any fraudulent activities that apparently or potentially impair SVFC’s financial health, brand name and prestige.
• Prevent, support to detect frauds and report any suspicious cases to authorized person(s) or departments, such as

+ Your line manager;

+ Fraud Detection Department ;

+ Legal & Compliance Division.

Protect SVFC’s branding, domain names and websites guidelines

All employees of SVFC must:

• Understand and comply with all requirements set in SVFC’s internal policies related to domain names, agent websites and branding of SVFC.
• Ensure that all communications with the use of logo and company name of SVFC, such as leaflets, advertising, emails, etc. must be adhered to the template of and approved by Digital and Brand Division prior to their official release.
• Not use, demonstrate, and quote any of SVFC’s information or materials on their personal websites, or on social websites, such as Facebook, blogs and other equivalents forms.

Detailed information can be found in internal documents released by Digital and Brand Division. Should you have any inquiry, please contact Digital and Brand Division for further instructions.

Protect SVFC’s assets and business opportunities

All employees of SVFC must protect the SVFC’s assets with the duty of care and not use them for personal gains. They must neither take advantage of a business opportunity of SVFC they came to know of in the course of conducting their duties by themselves nor have a third party to do so.

Mutual respect among Group’s companies and prohibition of discrimination

All employees of SVFC must show respect for other Group’s companies and maintain organic collaboration to maximize Group synergy and not discriminate against those from other Group’s companies.

Prohibition of involvement in political activities

All employees of SVFC must neither engage in any political activities nor offer contribution or expenses directly or indirectly related to political activities.

CHAPTER 2. ETHICS ON CUSTOMERS, INVESTORS, EMPLOYEES AND VENDORS

Customers

Customers must be treated fairly, openly and honestly;

A range of products and services provided and promoted to customers must meet their needs, be easy to understand and be able to deliver real value;

Our Customer information must be kept confidential (except where the Law requires disclosure);

High standards of customer service must be provided and promoted; and these standards must be monitored rigorously;

Our complaints processes must be effective and fair means of balancing the interests of SVFC’s business and customers.

Investors and Economies

Communicate our business strategy, achievements, and prospects honestly.

Keep accounting records which accurately disclose the financial position of SVFC and issue financial statements to ensure transparency of information on SVFC's financial performance.

Respect legitimate requests and suggestions of investors to build the relationship of mutual trust.

Employees

All employees of SVFC are provided equal opportunities.

SVFC does not tolerate any form of discrimination whatsoever on the basic of educational, geographical backgrounds, age, gender, ethnicity, religion, marital status, physical disability or political affiliation.

All employees of SVFC must respect one another and not engage in any behaviors that undermine sound work environment such as sexual harassment, illegitimate monetary transactions, organization of private interest groups or violence.

SVFC provides appropriate remuneration to employees of SVFC and maintains performance objectives that reinforce SVFC’s core values and delivery of its long-term ambitions.

SVFC promotes training and opportunities for personal development.

SVFC creates a favorable employee relations environment with soundness in which the involvement of all employees is encouraged.

SVFC maintains effective processes to enable whistle-blowers to report instances where they believe malpractice has occurred within the business.

SVFC provides a healthy and safe work environment, stressing the obligation on all employees of SVFC to take every reasonable precaution to avoid injury to colleagues and members of the public.

Vendors

SVFC endeavors to build and retain the relationship of mutual prosperity with the vendors such as suppliers and services providers and expect them to fully understand and comply with the spirit and contents of the Code.

• Take into account alignment with SVFC and/ or Group’s philosophy and policies such as ethics and environmental protection when selecting vendors and maintaining transactions with them.
• Pursue fair transactions on an equal footing and refrain from engaging in unfair practices using a superior bargaining position.

CHAPTER 3. SOCIAL RESPONSIBILITY AND CONTRIBUTIONS

Environmental Protection

Environmental protection is an essential requirement for sustainable development for SVFC and the future generation, SVFC shall comply with relevant laws and/ or regulations and take part in activities for environmental preservation proactively, specifically:

• Observe relevant environmental laws and/ or regulations applicable in SVFC’s operating areas.
• Respect global standards and practices on environmental protection.
• Environmental protection as one a main consideration in developing SVFC’s internal policies, standards and procedures.

Respect for Basic Rights

SVFC shall respect basic rights of a human being in all areas of its operations and abide by international standards on basic rights.

Contribution to Communities

SVFC contributes to the social and economic wellbeing of those communities where SVFC is an employer.

SVFC encourages employees to participate in projects and initiatives that bring benefits to those communities.

SVFC minimizes the adverse environmental impact of SVFC business operations.

SVFC conducts our activities, so far as possible, in a manner sensitive to the cultural and social traditions of local communities.

Shinhan Finance