Nanointerface Inc. (the "Company") is dedicated to operating with a strong sense of social and environmental responsibility. We uphold a code of ethics ensuring employees are guaranteed a safe and ethical working environment.

This Code of Conduct applies uniformly and consistently to all employees of the Company. Additionally, it is mandatory for all suppliers who provide services or manufacture and assemble goods for the Company to adhere to this Code of Conduct.

The Code of Conduct is structured into four primary sections: Labor & Human Rights, Health & Safety, Environment, and Ethics. Each section defines specific standards, outlined as follows.

A. Labor & Human Rights

We strongly believe in our responsibility to ensure for all employees a fair and ethical workplace. It is our firm belief that workers should be treated with the utmost dignity and respect. Furthermore, we insist that all our suppliers prioritize human rights above all else.

1. nondiscrimination

① The Company shall not engage in discrimination against workers based on age, disability, ethnicity, gender, marital status, nationality, political bias, race, religion, sexual orientation, or union membership in new hires and other employment practices.

② The Company shall not require medical examinations of employees or potential employees, except as required by applicable law or regulation or when exercising discretion in the interest of workplace safety. Moreover, the company may not unfairly discriminate based on the results of such examinations.

2. No abusive behavior
The Company shall take proactive measures to eliminate abusive behavior in the workplace.
The Company shall neither intimidate nor submit workers to ① harsh or inhumane treatment, including but not limited to ② verbal abuse and violence ③ mental violence ④ mental and physical coercion or ⑤ sexual harassment.

① Unwanted behavior of a repeated or singular instance that can take place between a manager or supervisor and a Worker (vertical relationship), between a Worker and another Worker (horizontal relationship), between a manager and a contract or outsourced Worker, and between Workers and service providers, clients, or another Third Party

② Chronic use of implied or direct threats.

③ Humiliating or intimidating verbal or nonverbal behavior, including the throwing of objects.

④ Includes any physical contact with the intent to injure or intimidate (including the throwing of objects), as well as disciplinary measures that cause physical discomfort

⑤ • Unwelcome sexual advances, requests for sexual favors, and all other verbal or physical conduct of a sexual nature, when (a) submission to such conduct is made either explicitly or implicitly a term or a condition of an individual’s employment, (b) an employment decision is based on an individual’s submission to or rejection of such conduct, or (c) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance by creating an intimidating, hostile, or sexually offensive environment.
• Offensive sexual comments, jokes, innuendoes, and other sexually oriented statements.
• Display of pornographic materials or sexually explicit images.
The following shall not be construed as Sexual Harassment:
• Interaction based on mutual consent.
• Occasional compliments that are socially and culturally acceptable and appropriate unless they make an individual uncomfortable.

3. prohibit involuntary labor and prevent human trafficking

① The company is required to ensure that all work is voluntary. It is prohibited from buying or selling individuals or use slave labor, forced labor, bonded labor, indentured labor, or prisoner labor. Involuntary labor refers to the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threats, force, coercion, abduction, and fraud. Furthermore, this includes making payments to individuals who control others for the purpose of exploiting their labor.

② The Company shall not require or retain government-issued worker identification, travel documents, or work permits as a condition of employment.

③ The company shall clearly communicate the terms and conditions of employment to the worker in a language that they can understand when drafting a contract.

④ The company shall not impose unreasonable restrictions on workers' movement within the workplace or their access to company facilities.

⑤ If the Company engages with a third-party employment agency, the Company shall ensure that the employment agency also complies with this Code and its provisions. When the Company hires a foreign contract worker, whether directly or through a third-party organization, it shall bear all costs and expenses in excess of the worker's estimated monthly actual wage.

4. third-party employment agencies

If the Company engages with a third-party employment agency, the Company shall ensure that the employment agency also complies with this Code and its provisions.

5. No child labor

The company may only employ workers of the legal minimum age of employment. Under Article 6 of ILO Minimum Age Convention No. 138, the company may provide lawful workplace apprenticeship programs for educational purposes. Additionally, the company may also provide opportunities for light work as defined under Article 7 of ILO Minimum Age Convention No. 138.

6. Protecting young workers

In accordance to the ILO Minimum Age Convention No. 138, the company is permitted to hire individuals who are older than the legal minimum age for employment but younger than 18, provided that their work does not endanger the health, safety, or psychological well-being of individual. However, it is important to note that young workers cannot be required to work overtime or night shifts.

7. Protect student workers

The company must properly manage student workers in accordance with applicable laws and regulations, including proper maintenance of student records, due diligence of educational partners, and protection of student rights. The company must also provide all student workers with the necessary support and training.

8. hours worked

① The workweek is limited to 52 hours, including overtime. Workers are allowed to take at least one day off out of seven, except in emergency or unforeseen circumstances.

② Suppliers must comply with all laws or regulations regarding working hours and holidays.

③ All overtime work must be voluntary.

9. Wages and compensation

① The company must ensure that all workers receive at least the legal minimum wage and benefits.

② The company must provide time off for vacations and legal holidays.

③ The company must compensate workers who work overtime at the statutory premium rate.

④ The company must inform all workers of the pay structure and pay period, and pay them the correct wages on time.

⑤ Companies shall not use wage reductions as a disciplinary measure.

10. freedom of association and collective bargaining

① To the extent permitted by law, the Company will allow employees to organize themselves into associations of their choice, or not participate.

② Employees must be allowed to bargain collectively without interference, discrimination, retaliation, or abusive conduct.

③ The company allows workers to file complaints and communicate freely between management and workers.

④ You must provide a means to do so.

11. Grievance system

The company must have an effective means for workers to file complaints and for free communication between management and workers.

Code of Conduct for Nano Interface Co., Ltd

B. Health & Safety

The Company shall create and maintain a safe working environment and ensure that sound practices are maintained. Workers must be given the right to refuse dangerous work and to report unhealthy working conditions.

1. Maintain workplace health and safety and prevent hazards

① The company shall identify, assess, and control health and safety hazards in the workplace by prioritizing processes such as hazard elimination, engineering controls, or administrative controls.

② The company must provide workers with personal protective equipment in good working order and instructions for its proper use in connection with the work.

2. Prevent, prepare for, and respond to emergencies

① The Company shall identify and assess potential emergencies.

② Per situation, the company shall establish and implement emergency plans and response procedures to minimize harm to humans, plants, animals, the environment, and the land.

3. Incident management

① The company shall establish a system for workers to report health and safety incidents or crisis situations. Additionally, the company shall set a system for investigating, tracking, and managing such reports.

② The company shall implement a corrective action plan to minimize the risk and provide necessary medical treatments to help employees return to work.

4. ergonomics

① Companies shall identify, assess, and manage workers' exposure to tasks that may be ergonomically hazardous, such as excessive loads, improper lifting positions, or repetitive tasks.

② New or modified production lines, equipment, tools, and workbenches must consider ergonomic safety when determining eligibility.

5. working and living conditions

① The company must provide workers with clean restrooms and drinking water that is readily available.

② Company-provided dining, cooking, and storage facilities must be hygienic. Worker housing provided by the Company, or a third party, must be kept clean and safe, and the living space must be adequate.

6. Disclose health and safety information

① The company must provide workplace health and safety training to workers in their first language. Health and safety information must be posted in facilities in a way that is accessible for all.

7. Occupational Safety and Health Committee

① Companies shall create and support occupational health and safety committees to enhance ongoing health and safety training and encourage worker interest and participation in workplace health and safety issues and activities.

8. Safety management

① The Company shall obtain, keep current, and comply with all necessary health and safety permits.

C. Environment

The Company shall comply with laws and regulations and continuously develop, implement, and maintain its practices for environmental responsibility.

1. Manage and limit hazardous materials

① The Company shall systematically identify, manage, reduce, and properly recycle or dispose of hazardous substances.

② Company shall comply with Customer's controlled substance specifications for all products provided to the Customer.

2. Non-hazardous waste management

① The Company shall implement a systematic approach to identify, manage, reduce, and properly recycle or dispose of non-hazardous waste.

3. wastewater management

① The Company shall systematically identify, manage, and reduce wastewater generated by its operations.

② The company must continuously monitor the performance of the wastewater treatment unit.

4. stormwater management

① The Company will implement a systematic approach to preventing pollution from stormwater runoff.

② The Company will ensure that illegal discharges and runoff do not enter storm drains, public water supplies, or public waters.

5. Manage emissions

① The Company will manage and reduce emissions from operations that cause air pollutants in a good faith effort to control them.

② Companies must continuously monitor the performance of their emission control devices.

③ Companies should regularly set quantifiable goals, monitor progress, and reduce greenhouse gas emissions through environmental conservation, clean energy use, and/or any other means.

6. Manage boundary noise

The Company shall identify, control, and monitor equipment noise output to minimize the boundary noise levels.

7. Environmental permits and reporting

① The Company shall obtain, keep current, and comply with any required environmental permits.

② The Company shall comply with the reporting requirements of applicable licenses and regulations.

8. Manage resource consumption

The Company shall periodically quantify, set goals, monitor performance, reduce, conserve, reuse, recycle, replace, or otherwise take action to reduce its consumption of fossil fuels, water, hazardous materials, and natural resources.

Code of Conduct for Nano Interface Co., Ltd

D. Ethics

The company strives to be ethical in all aspects of its enterprise: relationships, work, procurement, and operations.

1. corporate integrity

① The Company shall not seek unfair or unjustified benefits through corruption, exploitation, embezzlement, or bribery.

② It shall comply with all applicable domestic anti-corruption laws, including, but not limited to the Foreign Corrupt Practices Act (FCPA) and applicable international anti-corruption conventions.

2. disclose information

The Company shall accurately record information about its business activities, labor, health and safety, and environmental affairs. All relevant parties shall be disclosed to such informations without falsification or falsehood.

3. Protect your intellectual property

① The Company shall respect intellectual property rights and secure customer information.

② Technology and know-hows must also be managed to ensure that intellectual property rights are not infringed upon.

4. Whistleblower protection and anonymous tipster protection

Companies shall provide a way for managers or workers to report workplace complaints anonymously. They shall also protect whistleblower confidentiality and prohibit retaliation.

5. Community contributions

The Company contributes to the sustainability of the communities in which it operates by participating in creating an atmosphere of social and economic development.

6. responsible sourcing of minerals

Companies must implement a duty of reasonable care for Covered Materials within their respective supply chains. Companies must develop specific duty of reasonable care policies and management systems to identify Covered Materials and take appropriate steps to mitigate Covered Risks. Companies must implement a duty of reasonable care at the material processing stage to ensure that Covered Materials are not sourced from high-risk areas, such as areas associated with conflict, child labor exploitation, forced labor, human trafficking, or large-scale human rights abuses, such as pervasive sexual violence, or areas that present significant health and safety risks or are otherwise objectively associated with high-risk activities, such as adverse environmental impacts.