Code of Ethics

We are trying our best to become healthy members of the company by abiding by applicable rules and policies. However, gaining and maintaining trust of our consumers require us to have more tasks on-hand.

We need to conduct business by obeying and following our values. Adhering to the Code of Ethics, the Health Credo, will serve as the foundation as we look to maintain trust and good reputation from our consumers. If we do not abide by our Code of Ethics, this could lead to lawsuits, fines, product recalls or forfeiture, closure of production facilities, or even criminal sanctions or fines to the company and its employees. We need to keep in mind that good business results are not more important than the laws or the Health Credo.

Managers have additional responsibilities when abiding by the company’s core values, as follows:

- Fostering a culture that obeys rules
Managers should set an example to foster and maintain a faithful, talent-oriented, and obedient company
culture. Outcome-oriented culture should be implemented, however, managers should never enforce employees to bend the company rules.

- Prevention of Rules Violation
Managers should assist the team members to obey the company rules and policies.
It is especially important for managers to assume that the new employees are not fully aware of their tasks, and that they may need extra set of eyes/assistance.

- Detection of Rules Violation
Appropriate control measures should be implemented to detect any potential violation of company rules. Managers should foster an open environment and encourage the team members to speak up or ask questions about the company rules, policies, and the Health Credo.

- Handling the Rules Violation
All employees should be allowed to openly discuss the company rules, policies, and the Health Credo, and further report any violations without the fear of retaliation. Managers should never accept or approve exceptions to the application of the company’s code of ethics.

All business related to subsidiary material, products, services, and labor should be managed in a fair manner.

- Employees shall not give preferential treatment to certain individuals or companies when selecting or
dealing with a supplier, which would go against the company’s profit.
- All business conducted on behalf of the company shall not be affected by individual or
family relationships. One shall not receive gifts, treatments, or cash from potential business partners under any circumstances.
- Employees should not offer direct/indirect bribe, cash, or gifts to suppliers.

All regulations must be adhered to with regard to competition. All competitions must be fair and open.

Competitors Related Matters
- Price fixing or illegal sharing of products, business or customers is strictly prohibited.
- Employees shall not obtain or exchange information from competitors with regard to price, profit, product cost, bid, market share, distribution channel, sales condition or information specific to certain clients or
companies.
- Engaging in a corporate action without prior consultation with the company is strictly prohibited.

Consumer Related Matters
- Employees should not offer unfair benefit or advantage to certain consumers.
- Employees should not request or make an agreement with consumers to affect their distribution of our
products’ cost, sales conditions, and their clients.

Employees should adhere to the highest standards of trust and accuracy when dealing with government officials and abide by various regulations.

Business with Government Officials
- Adhere to the highest standards of moral and abide by various regulations when dealing with government officials.
- All reports submitted to the government entities/departments must be always complete and accurate.
- Employees shall not meet with government officials on behalf of the company when the duty falls outside of his/her normal course of business.

Illegal Pay
- Employees shall never offer direct/indirect gifts or cash to government officials with the intent to further a business deal.

One shall not trade the company’s
stocks using insider information. One shall not share any company information with anyone other than those who have the needs to the company information.

What is insider trading?
- Insider trading happens when an investor makes his or her buy/sell decision of certain stocks based on non-public information. The non-public information can be any information that could affect the company’s stock price.

Information Sharing
- Do not advise on stock transactions even if a co-worker or friend requests you to share the company information. It is against the law to share any information that could affect one’s decision to buy or sell stocks.

All forms of assets including physical assets and intelligence assets must be protected and used according to the company rules. Company assets shall only be used for the purposes of conducting business.

- Physical assets include company products, equipment, gear, vehicles, computers, software, stocks, bonds, bank accounts, credit cards, telephones, files, and any other records.
- Intelligence assets include all information that were developed by company employees and that have not been made available for the general public. This includes information received from suppliers, clients, or
business partners. For example, this includes organization chart, process map, manufacturing process, clinical trial records, marketing, advertisement, business development research and plans.
- Physical assets should be properly treated so that they would not get lost, stolen, or damaged. One must get permission from his/her senior and/or HR personnel before taking any physical assets out of company’s premise.
- Intelligence assets should not be discussed in public as they may contain sensitive information. For example, please refrain from discussing intelligence assets at airports, restaurants, elevators, restrooms, and
cafes.

Employees shall record all expenses in an accurate and complete manner and maintain proper records.

General
- Company records should be recorded in a accurate and complete manner. Company records include
experiment & research, clinical trial, general accounting, employee information & salary information, production & manufacturing records, purchase order, expense report, and any other draft documentation.
- Those in charge should sign off documents that are accurate and complete after appropriate level of
review.

Accounting Records
- All transactions must be recorded in the period that were incurred along with appropriate supporting
documentation.
- No information (documents, records, and accounts) shall be withheld or hidden from internal auditors for auditing/investigation purposes.

We strive to create a family like atmosphere in the workplace. We shall not use seniority or tasks to cause
any harm to other employees.

Unacceptable Behaviors
- Unfair treatment based on nepotism, school ties, gender, or level of education
- Verbal abuse that includes hostile or offensive words, humiliation, threat or slander
- Violence or unwanted physical advances
- Sexual harassment at any time (inside and outside of the workplace) or any behaviors that are sufficiently severe or intense to be perceived as harassment by a reasonable person
- Lending money between employees or acting as guarantor of loans
- Being offered a guarantee or lease of assets for convenience or for profit
- Using family members or relatives to deal with company and/or company clients (acceptable if it has been declared)
- Executing a contract or act of dealing by a member or third-party

Code of Ethics Violation - Reporting
Employees must report any and all suspected instances to their immediate senior, HR representative, or
directly to CEO. It is important to report a potential problem before it becomes a serious problem.
This allows the right individuals to resolve any issues in a timely manner.

Code of Ethics Violation - Discipline & Punishment
Anyone who violates company laws, policies or The Health Credo may be disciplined, up to and including termination, including
the following:
- Approval or participation in the violation
- Failure to report violation or any suspected violation
- Refusal to coordinate to an investigation relating to violation
- Retaliation against employees, and other persons who make, in good faith, allegations of suspected
violation