Code of Conduct

This Code of Conduct shall act as guidelines for our everyday business activities. This Code of Conduct cannot cover all
possible situations but to the best of ability, knowledge, and conditions in the business operation of Anacle. We shall act
according to the regulating laws, common sense, ethical principles, and moral principles, with sincerity and good faith, to
make the right decision in the event of unforeseen conflicts.


1.1 Compliance with law and social norms: We will comply not only with established rules and regulations but with
their underlying ethical and moral spirit. We will also act in compliance with Anacle’s Code of Ethics to
anticipate laws and regulations to take effect in the future.

1.2 Relationship with antisocial forces: We will resolutely oppose all antisocial forces and activities and will not have
any relationship with them. We will also take a resolute stance against unreasonable demands from antisocial
forces and will never use money for a solution.

1.3 Environmental preservation/ protection: Recognizing the impact of our production activities and products on
the global environment, we will continually strive to reduce the environmental impact and try to ensure an
optimal balance between management efficiency and environmental interests. We will not only comply with
environmental laws and regulations but also follow the Occupational Health and Safety Policy and the
Environmental Policy to prevent pollution and improve our environmental management.

1.4 Security trade control: For international peace and security, we will not only avoid committing violations of laws
and regulations on imports and export but also ensure that no illegal exports are made through our business

1.5 Government Initiatives: We actively support and/or participate in government’s initiated activities to promote
social, cultural, and/or economic well-being in the community


2.1 Operational safety: We will comply with laws and regulations on our operational safety and safety standards in all processes, including any activities that are within our responsibilities but outsourced to our trusted partners and suppliers. We will continually improve our process to attain the highest level of safety standards.

2.2 Compliance with antitrust laws: We will conduct fair business by complying with laws and regulations on antitrust and fair competition and trade that apply in Singapore and other countries and regions affected.

2.3 Appropriate transaction with suppliers: We will select suppliers fairly by objectively evaluating each potential supplier’s general business conditions, financial statements, quality control, cost efficiency, delivery schedule control, technological capability, and environmental management. We will implement fair procurement transactions without abusing our dominant bargaining position. This is also true in deciding whether to continue business with a supplier.

2.4 Confidential information of third parties: We will not illicitly obtain or misuse trade secrets and other confidential information of third parties when we duly obtain any trade secrets or other confidential information from our business partners. We will properly safeguard them to prevent leakage.

2.5 Gift-giving, business entertaining, and favor: We will keep the bounds of conventional wisdom and common sense in carrying out business entertaining, gift-giving, congratulatory and condolence payments, and relief money in the event of a disaster to our business partners. We will refrain from taking or giving money, items, services, and/or favor that might influence our work performance and fairness in favor of the giver.

2.6 Protection of personal information: Recognizing it as our responsibility to appropriately handle the personal information of our business partners and employees (information that enables personal identification) and to protect their rights and interests, we will ensure the appropriate management of the collection, storage, sharing, and use of such personal information.

2.7 Conflict of interest: To declare all conflict of interest when there is a clash between our self-interest and professional interest so that we maintain impartiality and objectivity in our professional judgement and business conduct.


3.1 Respect of human rights, prohibition of discrimination and harassment: In all our business activities, we will ensure that the fundamental human rights of our employees are respected and will eliminate things that lead to discrimination for reasons such as race, creed, sex, religion, age, nationality, physical disabilities, illness, and/or place of birth. We will not sexually or power-harass employees and will respond firmly to any form of sexual and power harassment.

3.2 Safety and health of employees: We will commit ourselves to ensuring our employees’ safety and health in the working environment and understand and comply with relevant laws and regulations. We will respond quickly and appropriately to work-related accidents and make all efforts to prevent a recurrence.

3.3 Compliance with labor laws: We will comply with labor laws and strive to maintain a healthful and comfortable working environment. Managers will always pay attention to their subordinates’ workload and health conditions to avoid excessive workloads or extreme overtime. At the same time, employees will take good care of their own health.


4.1 Behaviour as a corporate citizen: Recognizing that we are a member of society, we will maintain high ethical standards and act with a keen awareness of our responsibility in all our behavior.

4.2 Proper accounting process: We will perform our accounting process properly in compliance with the accounting standards and relevant internal rules based on applicable laws and regulations and pay taxes following relevant tax laws.

4.3 Political and religious activities: We will not conduct political, ideology-based, or missionary activities using company facilities without appropriate internal authorization. Neither will we conduct invitation activities that promote the interests of an individual or a specific organization.

4.4 Control of business secrets: We will appropriately control information that we can access in the performance of duty, information obtained from other internal divisions, and other information about matters related to technical or trade secrets. We will not publish, disclose, or leak such information in a careless manner or without appropriate internal authorization.

4.5 Appropriate use of company assets: We will control the company’s tangible and intangible assets (including its information network) to protect and use them effectively.

4.6 Respect for intellectual property rights: We will endeavor not to infringe the intellectual property rights of other individuals and organizations. Recognizing that intellectual property rights are our essential corporate assets, we will commit ourselves to create, protecting, and effectively using our intellectual property rights.

4.7 Anti-corruption and bribery: We have zero-tolerance towards any form of corruption, bribery, misconduct, and other malpractice.