April 22, 2025
Anker Innovations Supplier Code of Conduct

Anker Innovations is a global smart hardware technology company with ultimate innovation, dedicated to conducting its global business in a responsible and sustainable manner.


Anker Innovations believes that compliance and sustainable development are the cornerstone and important embodiments of an enterprise's own development, brand value and corporate social responsibility. Guide by this belief, Anker Innovations is committed to upholding the United Nations Sustainable Development Goals and simultaneously, requires all its suppliers to conduct their activities with a strong sense of corporate social responsibility. Suppliers are expected to actively identify, assess, and prevent potential risks related to human rights and labor, health and safety, environmental protection, responsible procurement of minerals, and business ethics throughout their operations and supply chains, while striving to create a safe, inclusive, diverse, and harmonious workplace.


This Code of Conduct consists of seven sections: Compliance, Human and Labor Rights, Health and Safety, Environmental and Resource Protection, Supply Chain and Procurement, Business Ethics, and Management Systems.


Compliance

Suppliers, including their subsidiaries and affiliates that they own or control, shall conduct business activities in compliance with all applicable laws and regulations issued by the United Nations, the European Union, the United States, the countries or regions in which they operate, and any other relevant jurisdictions (“Applicable Laws”). Suppliers shall ensure that their products, services, procurement, and shipments comply with all applicable international trade, human rights, and related regulatory requirements. They shall also ensure that neither themselves nor any subsidiaries or affiliates they own or control are designated as prohibited or restricted entities under any such laws or regulations. In the event that a supplier or any of its supply chain partners is listed as a prohibited or restricted entity, the supplier shall immediately notify Anker Innovations.


Suppliers shall ensure safe and healthy working conditions, treat all employees with respect and dignity, and conduct their business in an ethical and lawful manner, fully complying with all applicable laws, regulations, and standards in the countries or regions where they operate.


Suppliers shall establish a comprehensive supply chain management system that ensure effective due diligence and continuous oversigh of their procurement activities and supply chain partners. They shall ensure that their procurement decisions and supply chain operations comply with all Applicable Laws, align with the principles of responsible business conduct, and include sound mechanisms for identifying, assessing, and mitigating risks. Suppliers shall provide Anker Innovations with accurate, complete, and traceable supply chain information, proactively disclose potential risks, and cooperate with Anker Innovations in implementing appropriate control measures to maintain transparency and compliance across the supply chain. Where a supplier’s business activities may have a material adverse impact on human rights, the environment, or society, the supplier is responsible for taking appropriate steps to prevent, mitigate, and remedy such impacts.


Suppliers further commit to communicating the compliance obligations set forth in this Code to their supply chain partners and to requiring such entities to assume compliance obligations no less stringent than those stipulated herein.

Human and Labor Rights

工Child Labor and Young Workers

Suppliers shall comply with all applicable local and national laws regarding minimum working age and shall not employ child labor.

“Child” is defined as any person under the age of 16, under the age for completing compulsory education, or under the national/regional minimum age for employment, whichever is the highest.

Suppliers employing minors above the applicable minimum working age but under 18 shall register or conduct health checks as required by law. Minors shall not be assigned to work that may jeopardize their health or safety, and shall not be required to work overtime or night shifts.

If student workers or apprentices are employed, suppliers shall ensure their proper management in accordance with applicable laws and regulations.

Wages and Benefits

Suppliers shall pay employees at least the locally mandated minimum wage and provide any legally or contractually required benefits.

Overtime compensation shall be paid in accordance with legal requirements.

Suppliers shall clearly communicate wage structures and pay cycles to employees and provide clear and understandable pay statements for each pay period.

Deduction of wages as a disciplinary measure is strictly prohibited.


Suppliers shall comply with all applicable laws regarding working days and rest periods.

Except in emergency or exceptional circumstances, suppliers shall establish standard working hours in accordance with legal requirements and ensure that total weekly working hours, including overtime, do not exceed 60 hours. Employees shall have at least one day off per week.

No Forced Labor

No form of forced labor is permitted, including bonded labor, involuntary prison labor, slavery, or human trafficking. This includes the transport, harboring, recruitment, transfer, or receipt of individuals through threat, force, coercion, abduction, or fraud for the purpose of labor or services.

Suppliers shall not withhold government-issued identification, passports, travel documents, or work permits. Where possession of such documents is required to comply with local law, employees shall be allowed to access their documents at all times.

Suppliers shall provide employees with written labor contracts in compliance with legal requirements, clearly stating the terms of employment in a language understandable to the employee.

Suppliers shall not unreasonably restrict employees’ freedom of movement in the workplace or, if applicable, within employee housing or living areas.

Suppliers and their recruitment agencies are prohibited from charging recruitment or similar fees to workers.

Temporary, agency, or outsourced labor shall be employed in accordance with local law, and any third-party recruitment agencies used shall comply with this Code and Applicable Laws.

All work, including overtime, shall be voluntary. Employees shall be free to leave or terminate employment at any time, provided reasonable notice is given as defined in the employment contract, without incurring any penalties. Relevant records shall be retained for departing employees.

Human Treatment


Suppliers shall treat all employees with respect and dignity. The workplace shall be free from harassment and abuse. Employees shall not be subjected to harsh or inhumane treatment, including sexual harassment, psychological harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public humiliation, or verbal abuse.

No Harassment


Suppliers shall ensure employees are free from harassment. Employees’ rights to privacy, family life, housing, and communications shall be respected, and personal information or communications shall not be arbitrarily accessed, interfered with, or disclosed.

Non-Discrimination


Suppliers shall not discriminate in employment practices, including wages, promotions, benefits, or training opportunities, based on race, color, age, gender, sexual orientation, gender identity or expression, ethnicity, disability, pregnancy, religion, political affiliation, membership in organizations, veteran status, genetic information, or marital status. Suppliers shall provide reasonable accommodations for employees’ religious practices. Employees or prospective employees shall not be subjected to medical tests or examinations with discriminatory intent.

Freedom of Association and Collective Bargaining


Where local law permits, suppliers shall respect employees’ rights to freely associate, form, join, or refrain from joining trade unions or organizations of their choice, and to engage in collective bargaining. Employees shall not face interference, discrimination, retaliation, or harassment, and all applicable local laws regarding freedom of association and collective bargaining shall be followed.

Where formal representation is not established, suppliers shall provide appropriate mechanisms to facilitate open communication between employees and management and allow employees to raise concerns regarding working conditions and management practices without fear of retaliation, intimidation, or harassment.

Healthy and Safety

Occupational Safety

Potential workplace hazards that employees may encounter, such as electrical and other energy sources, fire, vehicles, or fall hazards, shall be controlled through proper design, engineering and administrative controls, preventive maintenance, safe work procedures (including lockout/tagout), and ongoing safety training. Where such hazards cannot be effectively controlled by these measures, suppliers shall provide employees with appropriate, well-maintained personal protective equipment and educational materials regarding the risks associated with these hazards. Suppliers shall also encourage employees to raise safety concerns.

Emergency Preparations


Suppliers shall identify and assess potential emergency situations and incidents, and implement emergency plans and response procedures to minimize their impact. Such measures shall include emergency reporting, employee notification and evacuation procedures, employee training and drills, appropriate fire detection and suppression equipment, sufficient emergency exits, and recovery plans. These plans and procedures should aim to minimize harm to people, the environment, and property to the greatest extent possible.

Work-related Injuries and Diseases

Suppliers shall establish procedures and systems to prevent, manage, track, and report workplace injuries and illnesses. These procedures shall include encouraging employees to report incidents, classifying and documenting cases, providing necessary medical services, investigating incidents, and implementing corrective actions to eliminate their impact. Suppliers shall also support employees in returning to work following an injury or illness.

Industrial Hygiene


Suppliers shall identify, assess, and responsibly control the effects of chemical, biological, and physical factors on employees. Engineering or administrative controls shall be implemented to limit excessive exposure to hazards. Where such measures cannot effectively control risks, appropriate personal protective equipment shall be provided to employees at no cost to safeguard their health.

Strenuous Physical Work


Suppliers shall identify, assess, and control the impact of physically demanding work on employees. This includes manual material handling, repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks.

Machine Safeguarding


Safety hazards associated with production equipment and other machinery shall be assessed. Suppliers shall provide and maintain appropriate physical guards, interlocks, barriers, or other necessary measures to prevent employee injuries.

Public Health, Food, and Housing


Suppliers shall provide employees with clean restroom facilities, safe drinking water, and hygienic food preparation, storage, and dining areas. Employee housing provided by suppliers or labor agencies shall be clean and safe, with adequate emergency exits, hot water for bathing, sufficient heating and ventilation, and reasonable private space that is easily accessible.


Suppliers shall provide workplace health and safety training in employees’ native language or a language they can understand. Health and safety information shall also be clearly posted in the workplace.

Environmental and Resource Protection

Conserving Natural Resources and Protecting Biodiversity

Suppliers shall actively conserve and protect natural resources, including energy, water, forests, soil, and various minerals, through improved production, maintenance, and facility processes, the use of alternative materials, reuse, conservation, recycling, and other methods. Suppliers shall also make every effort to ensure that their business activities do not negatively impact natural resources and biodiversity.


Climate Protection

Suppliers shall establish and report clear enterprise-wide greenhouse gas reduction targets. Energy consumption and significant Scope 1, Scope 2, and Scope 3 greenhouse gas emissions shall be tracked, recorded, and publicly reported. Suppliers shall identify ways to improve energy efficiency and minimize energy consumption.

Suppliers shall use renewable/clean energy to reduce greenhouse gas emissions.


Water Resources

Suppliers shall implement a water management program that records, classifies, and monitors water sources, usage, and discharges, identifies opportunities for water conservation, and controls sources of contamination.


Hazardous and Restricted Substances

Suppliers shall identify, label, and manage dangerous goods, chemicals, hazardous waste, and other substances or materials that pose a hazard to humans or the environment, and ensure their safe handling, movement, storage, use, recycling or reuse, and disposal.

Suppliers shall comply with all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of the use of specific substances in products and manufacturing processes, including recycling and disposal labeling.


Waste, Wastewater, and Air Pollutants Treatment

Suppliers shall prevent and minimize the leakage or dispersion of harmful substances or active ingredients into the environment, ensure the safe and compliant handling, storage, transportation, reuse, recycling, and disposal of all types of solid and liquid waste, and avoid soil, air, water pollution, as well as noise and light pollution.


Compliance with Environmental Laws

Suppliers shall comply with all applicable environmental laws, regulations, and standards. Suppliers shall also comply with any other specific environmental requirements related to the products or services provided by Supplier, as specified in the design and product specifications and contract documents. Suppliers shall obtain, maintain, and comply with all necessary environmental permits, approvals, registrations, and other requirements, and comply with the reporting requirements of applicable permits and regulations.


Supply Chain and Procurement


Responsible Sourcing

Suppliers shall establish a sound internal management system, strictly abide by applicable labor and environmental protection laws and regulations, as well as recognized international standards or relevant principles in the industry, proactively identify and prevent risks of unethical procurement or production processes, effectively identify, prevent, mitigate, and ultimately eliminate potential negative impacts on labor rights and the environment, ensure that they do not purchase or use products or raw materials that violate labor protection principles, and guarantee that the products and services they provide to Anker Innovations do not involve any unethical procurement or production processes.


If suppliers discover risk signals in the supply chain that may violate the above commitments, they should report them to Anker Innovations in a timely manner and immediately initiate an investigation to determine whether the delivered products contain unethical procurement or production ingredients, and provide Anker Innovations with relevant supporting materials.


Conflict Minerals

Suppliers shall comply with all applicable laws and regulations related to conflict minerals and take reasonable actions to prevent the mining, use, and trading of metals contained in their products — including tantalum, tin, tungsten, gold, and cobalt — from directly or indirectly contributing to illegal armed conflicts, or supporting activities involving human rights abuses, environmental harm, or health and safety hazards. Suppliers shall commit to adopting and widely promoting Anker’s internal responsible mineral sourcing policy. Suppliers shall ensure that the sourcing and supply chain of these minerals comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains, or equivalent and recognized due diligence frameworks. Suppliers shall conduct due diligence on their supply chains, proactively share relevant information with Anker Innovations, and provide due diligence results or implement supply chain control measures as required by Anker, in order to prevent and mitigate the risk of minerals in manufactured products directly or indirectly providing funding or benefits to groups associated with severe human rights violations, significant environmental damage, major health and safety hazards, or serious corruption in high-risk regions.


Origin Compliance

Suppliers shall strictly comply with all applicable laws and regulations regarding origin, tariffs, and trade, and establish and continuously improve effective management mechanisms to ensure that the origin information provided to Anker Innovations is complete, accurate, and traceable. Suppliers guarantee that all products they provide meet the origin certification standards for both the production location (including assembly location) and the export destination, and are capable of obtaining official certificates of origin issued by the relevant authorities at the production location (including assembly location) upon request. To assist Anker Innovations in fulfilling its compliance obligations and meeting customs declaration requirements, suppliers shall ensure the integrity of information and, upon request, promptly provide all documents and records related to origin certification and provide necessary cooperation.


Business Ethics


Honesty and Integrity

The highest standards of integrity shall be observed in all business interactions. Suppliers shall adopt a zero-tolerance policy and prohibit any form of bribery, corruption, racketeering and embezzlement. All business transactions shall be transparent and accurately reflected in supplier’s business accounts and records. Monitoring and strengthening procedures shall be implemented to ensure compliance with anti-corruption laws and regulations. See the Agreement on Joint Integrity Construction for details.


Intellectual Property Rights

Suppliers shall respect intellectual property rights and shall transfer technology, experience, knowledge or information in a manner that protects intellectual property rights, and shall protect customer information.


Fair Transaction, Advertising and Competition

Suppliers shall uphold standards of fair transaction, advertising and competition.


Anti-money Laundering, Counter-terrorist Financing and Convenient Payment Duty of Care

Suppliers shall strictly comply with all relevant anti-money laundering and counter-terrorist financing laws and regulations, regulatory guidelines, and industry standards (including but not limited to the Anti-Money Laundering Law of the People's Republic of China, the Financial Action Task Force's recommended standards, and the anti-money laundering and counter-terrorist financing implementation rules of various jurisdictions) of the countries/regions in which they operate, as well as relevant international organizations and cross-border businesses, to prevent money laundering crimes. Suppliers shall keep the identity information and real transaction records of the transaction objects, and give active and reasonable cooperation to the financial institutions or law enforcement agencies in the investigation of suspicious transactions or high amount transactions. Supplier shall use convenient payment with caution to avoid facilitating and assisting criminal activities of money laundering.


Information Disclosure

Suppliers shall disclose information on its labor, health and safety, environmental practices, business activities, organizational structure, financial condition and performance in accordance with applicable regulations and major industrial practices. Falsifying records or misstating conditions or practices in the supply chain is not allowed.


Identity Protection and Non-retaliation Policy

Unless expressly prohibited by law, procedures shall be in place to protect upstream suppliers and employee whistleblowers and ensure the confidentiality and anonymity of their identities. Suppliers shall develop communication procedures so that employees can raise concerns without fear of retaliation.


- Privacy

Suppliers shall undertake to protect reasonable privacy expectations for the personal information of all business-related persons, including sub-suppliers, customers, consumers and employees. Supplier shall comply with the laws and regulations on privacy and information security when collecting, storing, processing, transmitting and sharing personal information.


Management Systems


Corporate Commitment and Management Responsibilities

Suppliers shall publish a corporate social and environmental responsibility policy statement signed by management, stating their commitment to compliance and continuous improvement, and shall publish and communicate it to employees in the local language through channels accessible to all employees.


Suppliers shall clearly designate a senior manager to be responsible for CSR, identify and control risks thereof, conduct regular internal audit and management review, establish an internal assessment and accountability mechanism, and promote continuous improvement.


Risk Assessment and Risk Management

Suppliers shall, in accordance with applicable laws and regulations and customer requirements (including the requirements herein), identify CSR risks and possible impacts related to supplier’s operations, and implement appropriate procedures and substantive control measures according to the relative importance of risks to control and minimize risks and eliminate impacts.


Internal Audit and Management Review

Suppliers shall regularly audit their own plant and their upstream suppliers that provide goods or services to Anker, and conduct internal upstream supplier management to ensure compliance with laws and this Code of Conduct.

Suppliers shall allow Anker or a third party designated by Anker to conduct regular audits and assessments of their plant to evaluate whether the suppliers comply with the applicable principles and requirements of this Code.


Training

Suppliers shall develop and always operate a program for training managers and workers to implement supplier’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.


Employees’ Feedback, Participation and Grievance

Suppliers shall establish and consistently operate processes, including employee feedback, engagement and grievance processes, to assess employees’ understanding of violations and obtain feedback from them, as well as conditions covered by this Code of Conduct and to promote continuous improvement.


Reporting and Correction

Suppliers shall promptly report any deficiencies or violations discovered through internal and external audits, assessments, inspections, investigations, or reviews, and implement corrective action plans to correct the violations within a specified timeframe.


Documentary Recording and Keeping

Suppliers shall create and maintain documents and records to ensure compliance and conformity with corporate requirements and appropriate confidentiality to protect privacy. Suppliers' adoption and compliance with this Code of Conduct shall be documented and shall share relevant information with Anker Innovations in a timely manner in accordance with Anker Innovations’ requirements.


Supply Chain Management

All suppliers that have a business relationship with Anker Innovations shall require, support and monitor the compliance of sub-suppliers with this Code of Conduct, and provide relevant information and results to Anker Innovations truthfully and transparently. For any violation of this Code in the supply chain, Anker Innovations may work with suppliers to develop and implement a corrective plan after assessing the risks and impact, or it may result in the termination of the business relationship between suppliers and Anker Innovations.


This Code sets forth Anker Innovations' mandatory requirements for its suppliers. Anker Innovations will regularly assess suppliers' compliance with this Supplier Code. Any violation of this Code may jeopardize suppliers' business relationship with Anker Innovations. Potential consequences of violations include compensation for losses and contract termination.

This Code applies to suppliers who provide raw materials, products, and/or services to Anker Innovations and its directly or indirectly controlled subsidiaries and affiliates worldwide (collectively, "Anker Innovations").

Anker Innovations reserves the right to interpret these guidelines.



Anker Innovations Technology Co., Ltd.

Version: 3.0

Effective Date: April 22, 2025