Code of Conduct — Skymizer

Purpose and Basis
Skymizer is committed to upholding its core value of Integrity. These guidelines are established to promote high ethical standards among directors, managers, and all employees, and to safeguard the rights and interests of all stakeholders. The Code is formulated in accordance with applicable laws and regulations.
Scope of Application
This Code applies to all departments, business operations, and personnel of Skymizer, including directors, managers, full-time employees, and contract staff.
Core Behavioral Standards
All personnel of the Company must strictly adhere to the following ethical standards when performing their duties and engaging in business activities.
1. Integrity and Compliance
  1. Conduct all business activities with integrity, honesty, fairness, accuracy, and transparency.
  2. Comply strictly with all applicable laws, regulations, standards, and internal policies, ensuring business practices conform to trade standards and societal norms.
  3. Acts of corruption, fraud, extortion, unfair competition, waste, or misuse of Company assets are strictly prohibited.
2. Conflict of Interest
  1. Avoid any conflict between personal interests and the interests of Skymizer.
  2. Personnel shall not use their position to obtain improper benefits for themselves, their spouses, or relatives within the second degree of kinship.
  3. Personnel shall avoid using Company property, information, or their position to seek personal gain or to compete with the Company.
3. Confidentiality and Information Protection
  1. Maintain strict confidentiality of Skymizer’s proprietary information as well as that of clients and suppliers, except where disclosure is authorized or legally required.
  2. Confidential information includes any non-public information that could be used by competitors or that, if disclosed, could be detrimental to the Company or its clients (e.g., trade secrets, technical data, customer lists, and business plans).
4. Fair Dealing and Anti-Corruption
  1. Conduct all dealings with customers, suppliers, competitors, and employees fairly and transparently.
  2. Avoid gaining improper advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair practices.
  3. Skymizer maintains a zero-tolerance policy toward bribery, kickbacks, or other improper benefits. Offering, promising, authorizing, giving, or accepting such benefits is strictly prohibited.
5. Protection of Assets
  1. Protect and use Skymizer assets responsibly, ensuring they are employed efficiently and solely for legitimate business purposes.
  2. Acts such as theft, negligence, or waste of assets shall be avoided, as they directly impact the Skymizer’s profitability.
Implementation and Reporting
1. Reporting and Whistleblowing
  1. Skymizer encourages employees to report suspected or actual violations of laws, regulations, or this Code to their manager, the head of internal audit, or other designated personnel.
  2. A whistleblowing system allowing for anonymous reporting is established, and Skymizer is committed to protecting whistleblowers from retaliation.
2. Disciplinary Action
  For any confirmed violation of these guidelines, Skymizer will take severe disciplinary action, including but not limited to termination of employment, cessation of business relationships, and appropriate legal action.
3. Implementation and Disclosure
  These guidelines shall be implemented after approval by the Board of Directors and may be reported to the shareholders’ meeting. Amendments shall follow the same procedure.