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Code of Integrity

Dear colleagues

      Integrity is at the core of Madeown. The trust our customers and stakeholders place in us is key to the success of our company and individuals.

      As an industry facilitator, we should demand ourselves with the highest standards of professional conduct. Our Code of Integrity is a reflection of the shared values of Madeown's businesses.

      To achieve our goals, we want to attract and retain employees who work enthusiastically, fairly, and honestly. We believe that we must adhere to the principle of integrity to both individuals and customers.

      We are the defenders of the Madeown brand and reputation, and we work unswervingly to preserve the value they bring to the market. We insist on working honestly and transparently to achieve this goal. As part of our commitment, we encourage an open corporate culture, free exchange of our ideas and information, boldly soliciting opinions, asking questions, and discussing together. This enables us to fight for the interests of our customers in the markets we choose to cooperate with, provide opportunities for employees, and create sustainable returns for investors.


Introduction

      Madeown is an independent, honest and trustworthy organization with inspection, testing, auditing and certification. It is a trusted independent and professional third party such as brands, traders, manufacturers, customers and governments. Madeown's success stems from the trust it has gained from customers, employees, and other social groups with whom it does business. This trust is attributed to the collective efforts of Madeown employees. Madeown is committed to maintaining this trust through the effective implementation of the Code of Integrity.


Application of the Code

      This Code applies to all employees, managers and ethics commissioners. All content of the Code is not only for Madeown employees, but also for Madeown contractors, partners, agents, subcontractors and anyone who works for Madeown or anyone who represents Madeown.


Understanding the Code

      It is the responsibility of every employee to read and understand the Code and to adhere to its principles. We require employees to attend regular integrity training. Managers must ensure that employees who report to them are properly trained, fully understood and able to comply with the Code.


Seek guidance

      Madeown is committed to creating an open cultural environment in which integrity and ethics issues can be raised and discussed openly. Employees can be mentored and supported to understand the Code and help them make the right decisions when they face ethical dilemmas.


No retaliation against anyone who reports in good faith

      We encourage employees to speak up and report any concerns or suspicions about violations of the Code. Madeown guarantees that no one will be subject to any form of retaliation or adverse consequences for seeking advice or reporting violations of the Code. Retaliation against those who report violations of the Code in good faith will be subject to disciplinary action by the company and the circumstances will be severely dealt with in accordance with the law.


Culture of Integrity

Madeown's Principles of Integrity  

Trust: This is our most valuable asset and the foundation of our brand and reputation. Customers trust our integrity. This trust must be nurtured and maintained day after day.

Honesty and transparency: We must be honest and trustworthy with ourselves, our customers, and our colleagues in everything we do. Under no circumstances can there be dishonest acts such as lies or deception.

Responsibility: We should accept the consequences of our choices, take our own mistakes, and not blame others for our actions.

Principle: Our behavior should be standardized, treat others fairly and respectfully. Our decisions depend on respect for principles and good codes of conduct, not blind choices or personal preferences.


Ask yourself the right questions

Do I suspect that the behavior may be illegal or unethical?

What happens if the decision is reported, or if I talk to friends and family about it?

Are there any lies or dishonesties in the actions to be taken?

Will the actions to be taken endanger personal safety or health?

Will the actions to be taken damage Madeown or its reputation?

Is the transaction for legitimate business purposes?

If the action to be taken involves any of the above-mentioned situations, you should seek advice and reconsider your decision.


Zero tolerance for violations of the Code

      Any violation of the Code, regardless of the seriousness of the circumstances, would damage Madeown's reputation and brand and would not be tolerated. Violations of the Code are subject to disciplinary action, transfer of position, such as termination of contract, and, in severe cases, criminal prosecution, and reports to the local police in accordance with the judicial process.


Seek guidance or ask questions

      We strongly resist. This is a response to the state's call for corruption, and it is our responsibility as citizens of society.


      Employees should talk to their supervisor, manager, human resources, or Madeown Law if they have any questions about the specifics of the Code or its use in a particular situation. Employees can also talk in depth to internal auditors about the Code.

      If an employee feels that he or she cannot ask a question with his or her immediate supervisor, or that it is not convenient to do so, he or she may also contact the Integrity Compliance Manager at any time. If an employee discovers or suspects that anyone has violated the Code, the Company encourages employees to report to the Integrity Compliance Manager in a timely manner.

      With regard to the Code of Integrity, current or former employees, customers, and suppliers, or third parties, can contact the Integrity Compliance Manager in any of the following ways:

Mail: MADEOWN SA; Integrity and Compliance Manager (received);

Address: Room 1403, Sanxiang financial business center, No.3 Zhenhua Road, Sanxiang Town, Zhongshan City, Guangdong Province, China.

E-mail: info@madeown.com

Madeown Integrity Hotline: (24-hour toll-free) 86 760 8795 6108

      Madeown's Integrity Hotline is run by an ethics commissioner who specializes in compliance and ethics issues. In most cases, people who call the Integrity Line can talk to the operator one-on-one and get feedback in their own language. Questions reported to the Integrity Hotline are kept confidential, and if required, they can be anonymous when reporting to the Integrity Compliance Manager.

      When a person contacts an Integrity Compliance Manager, Human Resources Manager, Internal Auditor, or internal company lawyer because of the Code of Integrity, all the information they provide will be kept confidential or used only to answer or resolve questions raised. We encourage people who reflect issues to leave their names and contact details, but they can also choose to keep their identity confidential. In this case, we can design appropriate communication methods so that the caller can receive feedback without revealing his / her identity.

      Those who are suspected of violating the Code of Integrity and brought to the attention of the Integrity Compliance Manager are subject to an impartial investigation. When appropriate, the results of the investigation will also inform the person who complained or reported.


Service integrity

      All Madeown services must be professional, honest and consistent with established standards and policies. Madeown reserves the right of independent judgment. In the face of pressure and temptation, Madeown will not budge, not issue false results, or modify the results of its inspections, tests, certifications and audits. All findings must be recorded in detail, and no false or misleading reports or certificates can be issued.

      All findings and results must be accurately recorded and improper modifications should not be made. Madeown reports or opinions are supported by true and correct working documents and activity reports implemented in accordance with the company's policies.


Financial record integrity

      The information recorded in Madeown's financial records must be true, fair, timely, and accurate. All transactions must be recorded correctly and accurately, and the books of account must be supported by appropriate supporting documents issued by others. All records must be archived in accordance with relevant laws and Madeown's policies.


Conflict of interest

Conflict of interest:General

      Any conflict of interest or potential conflict of interest should be avoided. When Madeown employees realize that their personal or family and friends' interests conflict with Madeown's interests, Madeown hopes that they will notify their direct supervisor or integrity and compliance manager of the situation as soon as possible.

      A conflict of interest arises when an employee's access to private benefits affects his judgment, objectivity, independence, or loyalty to Madeown.

      The same applies when the behavior or interests of a relative or friend of a Madeown employee conflicts with Madeown's interests.

Conflicts of interest can come in many forms. If in doubt, you should seek help.

      When employees are affected by a potential conflict of interest, they should immediately explain in writing to their manager all of these potential conflicts of interest and abstain in the decision-making process.


Close relatives: Definition

      Close relatives of employees include: spouse or life partner; children, grandchildren; grandparents; siblings; siblings, son-in-law, daughter-in-law in the legal sense; or anyone living with them. When appropriate, Madeown can also issue its own policies based on local customs to include other relatives within the scope of close relatives.


Circumstances requiring prior approval

Some potential conflicts of interest faced by Madeown employees can be resolved through prior approval or appropriate processing. These include:

Director of a company other than Madeown

Directors of companies other than Madeown, directors of other professional or trade associations, or acceptance of political appointments at the local or national level require prior approval from the Madeown Professional Conduct Committee.

Working outside of Madeown

Acceptance of a second job or appointment outside Madeown requires prior written approval from the company's Integrity Compliance Manager and Human Resources Manager. However, the following conditions are not allowed:

(1) Provide services to Madeown's clients privately when he / she has an employment relationship with Madeown;

(2) Work for a Madeown competitor;

(3) Work for Madeown's suppliers.


Hire Close Relatives

      Close relatives of existing Madeown employees require prior written approval from the company's Integrity Compliance Manager and Human Resources Manager. Madeown employees are never permitted to hire close relatives, manage close relatives, or affect terms and conditions of close relative employment.


Prohibited items

Madeown employees are prohibited from situations involving conflicts of interest, including:

False public welfare

• Individuals provide or participate in professional or consulting services to Madeown clients or potential clients in various forms.

• Compete with or work for Madeown's competitors.

• Personal gain for individuals or close relatives through abuse of authority or theft of Madeown information.

Personal investment in suppliers, competitors and customers

• It is strictly forbidden to use services provided by the following suppliers or Madeown subcontractors: employees or their close relatives have direct or indirect significant shares; or have other financial interests with them, unless:

(1) A potential conflict has been reported to the employee's immediate manager;

(2) Employees affected by the conflict do not participate in procurement.

• Except through public stock transactions, employees are prohibited from personally investing in Madeown's suppliers, subcontractors, competitors or customers.


Use company assets and resources to maintain company assets and resources

      Madeown employees are responsible for the proper maintenance and use of company assets and resources. No use of Madeown's assets or resources for personal gain or for outside work is permitted.


Use of corporate information technology resources

     Company computers, network systems and electronic communication tools must be used for professional purposes in accordance with Madeown policy. When suspected misuse of resources occurs, Madeown may monitor and review the use of employees' email, Internet and other electronic communication methods, as permitted by relevant privacy laws.


Purchase

      Madeown employees who are responsible for purchasing goods and services from suppliers and selecting subcontractors, while giving due consideration to the quality and reputation of the supplier, must also fully consider the overall value of the service. When appropriate, competitive suppliers must be sought before selecting suppliers or subcontractors. Madeown does not contract with suppliers for personal preference. It is strictly forbidden to claim any private benefit from the supplier or anyone who wants to serve Madeown.


Bribery and corruption

      Madeown never bribes or corrupts in any form in any country where it is located. No employee of Madeown or anyone representing Madeown may directly or indirectly bribe, gift or entertain in order to influence the decision of a government official or encourage them to provide an improper advantage to Madeown. These codes also apply to the management and general staff of private companies. Any employee who reports a bribe must immediately report the matter to his / her line manager and / or integrity and compliance manager.


Cannot use money for business

Madeown does not pay bribes for business.


Agents and consultants

      Madeown never engages in third party services that provide bribes, illegal commissions or rebates.

      Madeown does not use the services of partners that may have corrupt or other illegal trading activities, such as intermediaries, agents, consultants, partners, joint ventures or subcontractors. No cooperation with intermediaries or sales agents is allowed until after proper due diligence and assessment of their feasibility and matching of remuneration and services provided. The request to hire an intermediary company must be supported by the company's top management and authorized by the Madeown Professional Ethics Committee. When they cooperate with Madeown, they must receive, acknowledge, sign a copy of this Code and agree to work in accordance with the principles of the Code in all aspects of their relationship with Madeown. Madeown employees who manage intermediary cooperation have a responsibility to regularly monitor their compliance with the Code.


Facilitation fee

      We strongly resist. This is a response to the state's call for corruption, and it is our responsibility as citizens of society.


Refusing to pay bribes will have no adverse consequences

      Employees without Madeown are punished for refusing to pay bribes, for engaging in corrupt practices, or for refusing to pay facilitation payments.


Political donations and charitable donations

No political or religious donations are allowed

      Madeown maintains a strictly neutral attitude in the political operation of any country in which it is located. Madeown does not donate funds and resources to any political group, any country official or candidate for public office, and does not support any political campaign. Madeown does not support any religious organization.


Charitable fundraising

      Madeown donations to charitable companies, or investments in non-profit projects in its community (including assistance for emergency relief efforts after natural disasters, or funding for education, medical, scientific research, or similar non-profit investments) require a Madeown highest Manager's written approval. Any charitable fundraising designed to influence government officials or third parties to provide Madeown with improper benefits will not be approved.


Gifts and entertainment

General

      Do not offer or accept gifts, entertainment or entertainment that have or may have an undue influence on business decisions.

      Gifts, entertainment and entertainment must not exceed the scope of normal business relationships. Any form of entertainment that is detrimental to Madeown's reputation is prohibited. The following rules set out the standards of conduct for Madeown employees.


Gifts for Madeown employees

Madeown employees must not accept:

• Gifts of cash, tips, loans, or cash equivalents from suppliers or customers.

• Personal gifts, favors, entertainment or entertainment for services provided by Madeown.

• Employees involved in purchasing decisions or supplier selection must not accept gifts from suppliers or potential suppliers to individuals.


Reporting and approval

      Employees must report to and obtain approval from the Integrity and Compliance Manager before accepting gifts worth over $10. Acceptance of gifts worth more than $50 must be approved by the Madeown Professional Ethics Committee.

      If the gift cannot be rejected or returned, and it does not violate the law, the person receiving the gift should choose a suitable method, such as donating it to a charity company.


Madeown gifts to business partners

      Gifts made by Madeown to customers or business partners worth more than $ 10 must be approved in advance by the Integrity and Compliance Manager. In addition, gifts worth more than $ 50 require approval from the Madeown Professional Conduct Committee.

      Attendance at government-sponsored or business partners for events hosted by Madeown or for travel and boarding in order to visit Madeown requires prior approval from the Integrity Compliance Manager. If travel and accommodation costs exceed $ 500, approval from the Madeown Professional Conduct Committee is required.



Fair competition

      Madeown conducts its business with fair market behavior. Madeown is not involved in any understanding or agreement with competitors regarding the use of improper means to influence the market in which it does business. Specifically, Madeown never participates in discussions about pricing, contract terms, market allocation, geography or customer segmentation. Madeown will not discuss the bidding process with competitors. Madeown will not sell its services and capabilities in a deceptive or misleading manner, nor will it make defamatory or dishonest charges against competitors. Madeown will not obtain competitors' confidential information through illegal or unethical means. The laws governing competition are complex and have different regulations in different jurisdictions. Advice must be sought from Madeown legal resources.


Employee Relations

Prohibition of discrimination

      Madeown only evaluates the work ability, seniority, behavioral performance and job performance of all employees. Regardless of race, color, gender, religion, political affiliation, union membership, nationality, sexual orientation, social origin, age or disability, Madeown treats employee relations based on the principle of equal opportunity and will not tolerate discrimination in these areas.


Bullying and sexual harassment

      Prohibit any form of abuse, harassment and bullying. Unwelcome sexual advances, requests for pleasure or inappropriate physical contact are intolerable. All employees should respect other colleagues, and at all times with the staff, colleagues, and management in an honest and respectful manner. The same goes for Madeown's customers, suppliers, and their employees and management.


Prohibition of child and forced labour

      Madeown does not employ children under the age of completion of compulsory education or children under the age of 16. Minor workers who are employed at least 16 years of age or less than 18 years of age may not be assigned to work in positions that may be detrimental to their health, welfare, safety or education. Madeown never enslaved or trafficked children in any form, nor did it allow debt bondage, serfdom, forced or involuntary labour. Under no circumstances will Madeown use forced, debt-relief or prison-forced labour.


Freedom of association

      Madeown recognizes the right of its employees to form and participate in union and collective bargaining. In cases where the right to freedom of association or collective bargaining is restricted by law, Madeown promotes the right to freedom of association and negotiation in a similarly independent manner. Employee representatives must be given the time and facilities necessary to perform their representative functions.


Code of Suppliers and Subcontractors

      Madeown does not work with suppliers or subcontractors that use forced or child labor. At the same time, Madeown uses reasonable due diligence and oversight to ensure that suppliers and subcontractors comply with this provision.


Environment, Health and Safety

Environment

      Madeown strives to reduce the environmental impact of its activities by promoting the efficient use of natural resources, reducing and preventing pollution, and reducing emissions of hazardous substances and greenhouse gas emissions.


Health and safety

      The Company must provide employees with a safe working environment, conditions, equipment and appropriate treatment to prevent injuries and occupational diseases.

      In accordance with Madeown policy or relevant legal requirements, Madeown employees should promptly report and record any work-related accidents or pollution accidents. No employee will be punished for reporting a work-related accident or pollution accident. We will deal with it in a timely manner to give our employees maximum security.


Confidential

      Madeown respects and protects confidential information that is entrusted by a customer or third party in the course of its cooperation and will take appropriate action to prevent the disclosure of confidential information.

      Madeown respects the privacy and confidential information of its employees. Madeown requires and retains personal, customer and business partner information only where business operations or legal requirements apply. No employee may attempt to access personal or confidential information except for legitimate business purposes.

      Employees must keep Madeown's confidential information, personal data of colleagues confidential and not disclose or discuss any sensitive information about Madeown's financial situation, investments, strategic layout, scenarios, or customer circumstances. This provision remains in effect after the termination of the employment relationship.


Intellectual property

      Madeown protects its intellectual property and respects the intellectual property of others.

      The efforts and innovations of our employees have resulted in Madeown's valuable ideas, valuable services, and sound business processes and strategic planning. Such intellectual property rights play a vital role in creating competitive advantage and must be protected from abuse.

      Madeown's intellectual property takes many forms, such as processes, designs, methods, operating procedures, business and marketing strategies, customer information, pricing, and cost models. Employees may not disclose, reproduce, or use the intellectual property unless used for a specified purpose.

Employees must also follow this principle when treating their customers' intellectual property rights.

      Madeown does not knowingly infringe the intellectual property rights of third parties. Prohibit the use of unauthorized software, unauthorized use or reproduction of copyrighted material, and intentional violation of valid patents.


External Communication

      Madeown provides consistent, accurate, transparent and clear information to its stakeholders, investors, markets, the entire community, and its business activities. Only authorized persons can communicate with stakeholders, investors, the media and the public regarding Madeown's business and finances.

      All employees must not speak on behalf of Madeown, and must not discuss or disclose any information about Madeown with the media and other social groups. No public statement may be made on behalf of Madeown without authorization.

      Religious, politically related personal opinions or other forms of objections should not be published in Madeown stationery, mail, or any other situation that could be mistaken for Madeown's opinions.


Internal Transactions

      Employees must not make any personal investment or pursue related business opportunities based on non-public information involving MADEOWN and its customers or suppliers.

      In the course of MADEOWN's business, important but nonpublic information about the customer or third party is sometimes received. Employees are prohibited from using these confidential information to trade the stock of customers or third parties.

      It is prohibited to pass on such information on the basis of inside knowledge acquired in the course of MADEOWN's work, or to disclose investment tips to third parties or close relatives.


Discipline

      MADEOWN complies with the laws of the countries in which it operates. The laws involved in MADEOWN activities are complex. Employees need to know the rules that apply to MADEOWN and their individuals. If you have any questions, you must seek advice through MADEOWN's legal resources. Not knowing the law can be an excuse.

      When the provisions of the MADEOWN Code or Policy are more stringent than the provisions of applicable law, employees must comply with stricter standards. Employees should seek guidance when there is confusion about the contradiction between the Code and applicable law.

      In the course of MADEOWN's work, supervisory companies or government officials may contact MADEOWN employees because they are involved in the investigation. In the event of a non-routine request for information or documentation, employees must seek advice on MADEOWN's legal resources. Under no circumstances shall anyone attempt to mislead, conceal evidence, destroy documents or otherwise obstruct any lawful investigation on behalf of MADEOWN.


Implement

      The Code of Integrity was approved by the Madeown Professional Conduct Committee. The Company's Integrity and Compliance Department will be responsible for checking regular reports of violations and monitoring the implementation of the Code. This code came into effect in 2016.


Contact information

Compliance Contact

Address: Room 1403, Sanxiang financial business center, No.3 Zhenhua Road, Sanxiang Town, Zhongshan City, Guangdong Province, China.

Tel:86 760 87956108

E-mail: info@madeown.com

Website: www.madeown.con

Many thanks to all employees and people who have made a constructive contribution to our Code of Integrity.


Madeown China

1403, Sanxiang financial business center, Sanxiang, Zhongshan,Guangdong, CHN

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Madeown USA

36 South 18th Avenue, Suite A Brighton,CO USA 80601

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