1. Introduction

CCN Holding Companies aims to be a good corporate citizen in all operations.

For this reason, CCN Holding Companies is committed to consolidating its existing business principles into a framework policy under the heading of Corporate Social Responsibility (CSR).The principles included in this policy cover all areas of CCN Holding Companies' operations and have been developed in accordance with relevant corporate governance codes and international standards, which continue to be reviewed and updated accordingly.

The Board supports the principles set out in these codes and standards and the purpose of this policy is to translate this support into a set of guidelines and standards that establish a common approach for the group and provide practical guidance for our managers and employees in the field.

2. Compliance, Monitoring and Reporting

Compliance with this policy will be monitored on an ongoing basis and subject to review by the Board.
Each local manager is responsible for ensuring that the principles set out in this policy are communicated to all employees, understood and adhered to by employees to ensure compliance in their area of responsibility.
Employees who have reasonable suspicion of any violation of this policy should report it to their manager, senior management or other mechanisms established within the Group for reporting such violations.  Employees may be reluctant to report concerns for fear of retaliation and disciplinary action will be taken against any employee who threatens or engages in retaliation, retribution or harassment against anyone who has reported or is considering reporting a concern in good faith.
The Board will not criticize for any loss of business resulting from adherence to the principles contained in this policy.

3. Codes of Business Conduct

3.1. General Declaration

This Code of Business Conduct sets out the standards expected of CCN Holding Companies' employees in their internal and external relationships with colleagues, customers, stakeholders and third parties.

3.2. Basic Code Standards

We will conduct our business with honesty, integrity and openness in all aspects, respecting human rights and the interests of our employees, customers and third parties.
We will respect the legitimate interests of third parties with whom we have relationships in the course of our business.
We will uphold the highest standards of integrity - for example, we will not promise more than we can reasonably deliver and we will not make commitments that we cannot or do not intend to keep.

3.3. Employees

a)    We are committed to developing a workforce where there is mutual trust and respect, free from bullying and harassment, and where everyone feels responsible for the performance and reputation of our company,
b)    Respecting the rights, customs and traditions of individuals and their right to freedom of association and the right to decide whether or not to join a labor union; negotiating in good faith with duly elected representatives of our employees,
c)     Recruiting, employing and promoting employees in line with our Equal Opportunities Policy, based on objective criteria and the qualifications and skills required by the job to be performed,
d)    Maintaining good communication with our employees through our information and counseling procedures,
e)    Providing our employees with appropriate training and helping them fulfill their potential,
f)      Ensuring that the privacy and confidentiality of our employees' personal information is respected,
g)    Rewarding our employees appropriately for their contribution to the success of the business,
h)    Providing mechanisms through which employees can raise legitimate concerns about corruption and ensuring that no one is victimized for a report made in good faith,
i)      Providing employees with appropriate information and training to comply with this Code and related policies,
j)      Protecting our employees from third-party abuse that could be detrimental to their safety, health or well-being.

3.4. Business Integrity

We aim to build strong relationships with our suppliers, stakeholders and other stakeholders based on mutual trust, understanding and respect.
In these relationships, we expect those with whom we do business to abide by business principles consistent with our own.
We will conduct our business in fair competition and in compliance with applicable regulations.
CCN Holding Companies' accounting and other records and supporting documentation must accurately disclose and reflect the nature of the underlying transactions.
No unrecorded accounts, funds or assets shall be established or maintained.
We will comply with applicable laws and regulations wherever we do business.  Where necessary, we will seek legal advice to comply with this commitment.
We will review and monitor our business risks, including social and environmental risks.
CCN Holding Companies will not facilitate, support, tolerate or condone money laundering in any form.

3.5. Domestic and International Trade

CCN Holding Companies will seek to compete fairly and ethically under applicable competition and antitrust laws, and we will not prevent others from competing fairly with us.
When doing business across the globe, we will comply with all applicable export control laws and sanctions.

3.6. Individual Conducts

All employees are expected to act in accordance with the principles set out in this Code of Conduct.
Employees are expected to protect and not misuse company assets such as buildings, vehicles, equipment, money and purchasing cards.
Employees are expected to use e-mail, internet, IT and telephones for business purposes in accordance with the principles set out in this Code and any IT policies.

3.7. Bribes

No CCN Holding Companies employee or any entity working on our behalf should accept or give any bribe, facilitation payment or any other improper payment for any reason.
This applies to transactions with government officials, any private company or person anywhere in the world.   It also applies if the payment is made or received directly or through a third party.
The Group will ensure that adequate procedures are in place to prevent the risk of bribery and that they are effectively communicated and implemented.

3.8. Gifts, Hospitality and Improper Payments

It is unacceptable to accept or give any entertainment or gift (i.e., valued in excess of USD 150) that is or may appear to be designed to influence Business Decisions.  No employee should offer, give, solicit or receive, directly or indirectly, incentives or other improper benefits for business or financial gain.  If an employee is in any doubt as to whether they can accept an offer, the employee should discuss the matter with their manager or the Group HR Director.

3.9. Conflicts of Interest

While we respect the privacy of our employees, all employees are expected to refrain from personal relationships, activities and financial interests that conflict with their responsibilities to CCN Holding Companies.
Group employees and consultants must not seek to profit for themselves or others through their position or through exploitation of the company.
All actual and potential conflicts (including those arising from the activities or interests of close relatives or partners) must be disclosed and discussed with the employee's line manager.
Price-oriented information must never be disclosed to third parties in an unauthorized manner.

3.10. Confidentiality

Information obtained by any person in the course of his or her employment must not be used for personal gain or for any purpose other than that for which it was provided.
Where confidential information is obtained in the course of work, confidentiality must be respected at all times.

3.11. Health and Safety

We are committed to creating and maintaining a safe and healthy working environment for our employees, customers, and society.

3.12. Environment

We are committed to continuously improving the management of our environmental impact.
All employees are expected to comply with the local environmental management system and support the improvement of our environmental performance.

3.13. Customers

The Group is committed to providing safe, value for money, high quality, consistent, accessible and reliable services to its customers.
All employees are expected to act with respect and integrity in all dealings with customers and the general public, in accordance with the principles set out in this Code.
In particular, we will ensure and protect the welfare of vulnerable people who come into contact with our employees. Employees will be made aware that they are in a position of trust and must at all times maintain the highest standards of personal conduct reflecting that trust.
Customer Service: Keeping our promise to our customers is one of our core values. Our commitment is to provide safe, reliable, customer-oriented, innovative and sustainable services.

3.14. Supply Chain

We purchase a wide range of goods and services necessary for our business activities and rely heavily on our various suppliers for the delivery of our core services.  Good working relationships with our suppliers are therefore the key to the success of our business.
While we are committed to obtaining and maintaining competitive goods and services, we must also strive to ensure that they are from sources that do not jeopardize human rights, safety or the environment.
We expect our suppliers to follow business principles consistent with our own.  We expect them to adopt and apply acceptable safety, environmental, product quality, product stewardship, labor, and human rights, social and legal standards in line with our Supplier Code of Conduct.
We will endeavor to work with our suppliers to develop meaningful long-term relationships for the mutual benefit of both parties, with the goal of quality of goods and services, environmental performance and sustainability.

3.15. Social Participation

CCN Holding Companies' operations are in daily contact with all members of society, whether customers, neighbors, businesses or residents. We are committed to fostering good relations with the communities in which we work and building community partnerships to bring about positive change.

3.16. Implementation of the Code of Business Conduct

The Corporate Board of Managers shall be the highest decision-making authority in the implementation of this Code.
The Corporate Internal Audit Department shall resolve, under the supervision of the Company's senior management, any issues related to the application or interpretation of the Code that cannot be satisfactorily resolved at the ordinary audit levels.
The Human Resources Department shall implement rules and procedures to ensure full compliance with the Code. The Human Resources Department shall take all necessary measures to ensure that all staff, suppliers, subcontractors and consultants know and understand the provisions of this Code and how to apply it in their workplace environment.
Employees seeking further information beyond what is provided by their managers may contact the Human Resources Department.

4. Employment
4.1. Equal Opportunity and Diversity Policy

The Board is committed to equal opportunities, both in the provision of services to the public and as an employer. The purpose of this policy is to ensure that all employees, customers, contractors and others who come into contact with CCN Holding Companies are treated equally and in a fair and consistent manner at all times.
The Senior Management of CCN Holding Companies has a duty to ensure the followings:
a)    To create a productive and healthy working environment that encourages diversity and inclusion in their workforce;
b)    To actively evidence CCN Holding Companies' diversity policy and practices;
c)     To develop new practices to engage employees, contractors and customers;
d)    To demonstrate continuous improvement in diversity and equal opportunities for all.

4.2. Legislation and Codes of Practice

This policy complies with current international legislation and relevant codes of practice in the countries in which CCN Holding Companies operate.  CCN Holding Companies will continuously monitor this policy to ensure that it complies with the requirements of the relevant underpinning legislation; however, CCN Holding Companies aims to go beyond the requirements of legislation where possible.

4.3. Recruitment

All recruitment will be carried out in fairness, equality and consistency for all candidates at all times. Recruitment practices will be inclusive and any barriers to employment will be eliminated within the framework of the relevant legislation.

4.4. Personnel Training

To ensure that we are both an inclusive employer and service provider, guidance and training will be provided to staff to diversify awareness and equality.

4.5. Human Rights

CCN Holding Companies' Human Rights Policy forms the basis of this section. The policy contains all the necessary definitions.

a)    We will treat all employees fairly and honestly, regardless of where they work.  All employees will have agreed terms and conditions in line with local law or practice and will be provided with appropriate job skills training.
b)    We will pay a fair wage that reflects local markets and conditions. We will always meet any national minimum wage.
c)     Working hours will not be excessive. They will follow industry guidelines and, where available, national standards.
d)    Employment must be freely chosen. We will not use illegal child labor, forced or bonded labor, forced overtime, and we will not condone illegal child labor.
e)    We will comply with anti-discrimination laws in every country in which we operate.
f)     We will not use or condone the use of corporal punishment, mental or physical coercion or verbal abuse. We have disciplinary procedures for any member of staff whose behavior falls below the required standard.