TRANSCOSMOS GROUP

We have established the transcosmos Group Code of Conduct to 1) meet all stakeholder expectations including clients, employees and shareholders, and serve society by integrating Environmental, Social and Governance (ESG) factors into the way we manage our business, and 2) to maintain and enhance enterprise value of our Group by raising awareness of compliance among officers and employees.

1. Compliance

1.1 We comply with the laws and regulations of the countries and regions where we do business.

1.2 We understand and comply with legal and fair customs and business practices approved in the countries and regions where we do business.

2. Human rights

2.1 We respect the human rights of each individual and do not engage in any form of discrimination, harassment, or other hostile words and actions.

2.2 We respect diversity and strive to create a fair workplace environment where employees from different backgrounds can achieve their full potential.

2.3 We do not employ children who do not meet the legal minimum age for employment set by the countries or regions where we do business. In addition, children under 18 years of age do not engage in work, including night shifts, that may harm their physical, intellectual, psychological or mental development.

2.4 We do not tolerate forced labor or modern slavery in any form.

3. Labor

3.1 We comply with the laws and regulations of the countries and regions where we do business and respect workers’ rights to freedom of association, collective bargaining, and collective action.

3.2 We comply with laws and regulations relating to occupational safety and health, and maintain and improve healthy, safe and hygienic workplace environments in consideration of the physical and mental health of each individual.

3.3 We prioritize respect for human life and health by preparing for and responding to emergencies, such as earthquakes, typhoons, infectious diseases, regional conflicts, terrorism and other unexpected events, and with a view to minimizing losses to stakeholders and the company.

4. Provision of services

4.1 We contribute to the development of our customers’ companies and society through our business and corporate activities.

4.2 We give due consideration to the quality and safety of the services we provide.

5. Fair trade practices

5.1 We conduct business in fairness and good faith with all of our business partners.

5.2 We comply with the terms and conditions of our transactions with business partners and adhere to relevant laws and regulations.

6. Anti-bribery

6.1 We fully understand and comply with laws, regulations and guidelines related to preventing bribery and corruption in the countries and regions where we do business, and have established a Group policy on anti-bribery and corruption.

6.2 We do not directly or indirectly provide or receive improper advantages from any partners or parties, including public officials, beyond the scope considered appropriate by the laws, regulations, guidelines or social customs of the countries and regions where we do business.

6.3 We maintain accurate and proper records of all relevant revenue and expenditures in accounting books and other documents to prevent bribery and corruption.

7. Information management

7.1 We comply with laws and regulations related to the management and protection of information.

7.2 We have established a Group information security policy to properly manage and protect the information we handle in our business operations.

7.3 We respect the ownership of information held by third parties and do not improperly use or acquire such information.

7.4 We continuously ensure the security of information in the company.

8. Protection of intellectual property

8.1 We recognize that the company’s intellectual property is a valuable asset and take appropriate measures to protect it.

8.2 We respect the intellectual property of third parties and do not improperly use or acquire such property.

9. Ethical behavior

9.1 We conduct proper accounting and tax procedures in accordance with the laws, tax regulations, and accounting standards of the countries and regions where we do business.

9.2 We accurately record the details of transactions, dates, monetary amounts and other information in full when recording entries in accounting books or documents and filling in vouchers in accordance with relevant laws, regulations and internal rules, and do not record false or fictitious entries or conduct off-the-book transactions.

9.3 We appropriately manage and use the company’s assets in accordance with internal rules and do not engage in the fraudulent misuse of these assets.

9.4 We do not engage in actions for personal gain at the expense of the company’s interests.

10. Environment

10.1 We strive to engage in actions to solve environmental problems on the planet and in society through our business and corporate activities and contribute to the continuous development of a sustainable and prosperous society.

10.2 We provide green services in compliance with applicable environmental protection laws, regulations, guidelines and other standards.

10.3 We continuously take action to achieve our targets with an understanding of the environmental initiatives promoted by the company, such as those addressing climate change. We also actively promote communication on environmental initiatives and policies with stakeholders inside and outside our Group.

10.4 We are committed to contributing to the creation of a closed-loop society by reducing our environmental impacts, such as by reducing energy consumption and waste, and making efficient use of resources.

11. Community initiatives

11.1 We strive to contribute to maintaining order and safety in civil society.

11.2 We actively engage in corporate social responsibility (CSR) activities in the countries and regions where we do business, and take actions to help resolve social issues and develop local areas and communities.

12. Whistleblower protection and prohibition of disadvantageous treatment

12.1 We will consult with or report any actions we are aware of that violate or may violate this policy through established reporting channels.

12.2 We will not treat any individual who consults or reports (whistleblower) potential misconduct or wrongdoing in an unfavorable manner based on the fact that they have consulted on or reported an issue.

TRANSCOSMOS VIETNAM

A. MISSION - VISION - CORE VALUES AND BUSINESS PHILOSOPHY

1. Mission

Our mission is to leverage customer insights to always be your most trusted partner.

2. Vision

As an Asian-originated company, our vision is to create a global society where everyone is equal and treated with respect.

3. Value

Customer-oriented: To be constantly chosen as the one and only trusted partner, we will put customers first and always value feedback from the GEMBA.

Employee-oriented: While working closely together to achieve business goals as one team, we will improve employee satisfaction and increase employee engagement.

Professionalism: To fulfil our responsibilities and take full accountability as professionals, we will work diligently with pride, confidence and passion.

4. Business Philosophy

Client satisfaction is the true value of our company, and the growth of each of our employees creates the value that shapes our future.

B. INTRODUCTION TO THE CODE OF CONDUCT

I. Purpose

The Code of Conduct (hereafter referred to as the “Code”) of transcosmos Vietnam (hereafter referred to as “TCV”) is established to define ethical standards and professional behavior, contributing to the creation of a transparent, fair, and respectful working environment.

The Code not only guides employees in making sound decisions but also helps preserve core values, ensuring integrity, accountability, and maintaining trust from clients and partners. Adherence to this Code helps the company minimize legal risks, protect its reputation, and promote sustainable development.

More than just a set of regulations, it serves as a foundation for fostering a professional, creative, and high-performance work culture, strengthening competitive advantages, and building a strong TCV brand.

II. Scope and Applicability

The Code applies across the entire company, including the headquarters office and all branches of the company.

All employees working in the departments, divisions, or projects of TCV at all job positions are responsible and obligated to comply with this Code.

This Code also applies to all other representatives acting on behalf of TCV, including: consultants, senior management, board members of companies within the Group, contractors, or third parties performing services for TCV.

III. Guidelines for using the code of conduct 

1. Employees

• Must read, thoroughly understand, and comply with the contents of the Code. When in doubt, seek guidance from the Company for clarification and direction during implementation.
• Must prevent and promptly report any violations or suspected violations of the Code.
• Must not conceal, collude in, or assist any violations of the Code.
• Will be held accountable according to internal regulations and legal provisions if they violate the Code.1

2. Management team

• As a manager at TCV, you are expected to set an example in ethics and professional behavior. This means not only complying with the Code yourself but also leading and ensuring your team understands and correctly applies the established principles. You are responsible for guiding and supporting employees in understanding the Company’s policies, procedures, and conduct standards.
• Additionally, you must take proactive action upon detecting violations, report them promptly as required, and seek support from the HR, Legal, or relevant departments when necessary.
• Managers are not only responsible for oversight but must also foster a transparent work environment where employees feel comfortable discussing ethical issues without fear of negative consequences. It is vital to build an open culture that encourages honesty and accountability, while providing appropriate guidance and support to ensure that all decisions are based on TCV’s values and principles.

3. Business Partners and Suppliers

• TCV is committed to maintaining high standards of business ethics, human rights, labor conditions, environmental responsibility, and anti-corruption across all activities. We expect our partners and suppliers to adhere to similar principles, ensuring transparency and sustainability in our collaborations.
• All suppliers working with TCV must comply with the Supplier Workplace Standards, aligned with the Company's core values and policies. We expect partnerships to be built on respect, responsibility, and compliance with common regulations, contributing to the creation of a healthy and trustworthy business ecosystem.

4. Guidance and Reporting in case of suspected violations of the Code

4.1 Guidance on Code violations

The Code cannot cover every situation involving laws, internal regulations, or ethical standards. Therefore, each individual must apply logical thinking and sound judgment to determine appropriate behavior in each specific case.

If you find yourself in a situation where you're unsure whether your actions are appropriate, ask yourself the following questions:

• Am I acting fairly and honestly?
• Is this action legal?
• Could my actions negatively impact the Company or a third party?
• Is this the right thing to do?
• If others find out about this action, would they view it positively or negatively?
• Do I believe my action aligns with ethical standards?
• If this information appeared in the media, how would I and the Company be perceived?

When facing a situation without a clear answer in the Code, timely consultation is crucial to protect TCV’s interests and ensure compliance. If you need guidance, proactively consult your direct manager, the HR division, or relevant divisions to find a suitable solution.

4.2 Reporting Code violations and whistleblower protection

Compliance with the Code is not only about following rules but also stems from individual integrity and responsibility.

Every employee is responsible for reporting any known or suspected violations of the Code by any individual or representative of TCV. The Company is committed to a strict non-retaliation policy, ensuring that those who report in good faith will not face any negative consequences in their employment.

If you witness any behavior that violates the Code or any policy within TCV’s Internal Regulations, promptly report it to your direct manager, the HR division, Legal, or other relevant units.

All reports will be handled seriously, confidentially, and promptly to protect whistleblowers’ rights and uphold transparency within the organization.

The Company encourages employees to follow official reporting procedures rather than spreading unverified information on social media, or unofficial channels. Miscommunication may harm personal reputations and negatively affect TCV’s operations, image, and credibility.

5. Legal compliance

TCV is committed to full compliance with all applicable laws and regulations in its operations, including but not limited to those related to labor, business conduct, data privacy, and personal data protection. All decisions and business activities must align with the Code, internal policies, and Company guidelines.

In case of any conflict between the Code and legal regulations, the Company will follow the applicable laws to ensure legality and transparency in all operations.

6. Responsibility in case of violations

Employees who violate the Code, TCV's policies, or fail to adhere to ethical standards may face appropriate disciplinary action. The level of discipline will be considered based on the severity of the violation. In serious cases, the Company may terminate the labor contract.

Additionally, many provisions in this Code and TCV’s internal policies are based on current laws. Therefore, legal violations may result in legal consequences for the individual, and the Company may also face legal implications.

C. CONTENT OF THE CODE OF CONDUCT

I. Internal code of conduct

1. General rules

1.1 Fairness

TCV ensures a fair working environment free from discrimination based on gender, ethnicity, region, religion, nationality, or any other personal factors. We apply transparency and fairness in recruitment, work assignment, performance evaluation, compensation, and benefits.

1.2 Work environment

• TCV fosters a professional, friendly, and safe work environment, free from discrimination, harassment, or any behavior that negatively impacts employees.
• We encourage employees to maximize their potential, be creative, and contribute to continuous improvement.
• We ensure job stability and provide sufficient infrastructure to support employees in working effectively.
• Clear, transparent, and fair compensation policies are established to ensure long-term employee benefits.

1.3 Business and financial records

Business records and financial reports must truthfully reflect the Company’s operations and serve as a basis for strategic decisions and legal compliance. Therefore, all employees in authorized divisions must be responsible for maintaining complete, accurate, timely, and truthful records within their scope of work.

• All transactions must be accurately and transparently recorded under the correct account, accounting period, and relevant department.
• All budgets, transactions, and profits must have complete and valid documentation.
• Reports submitted to authorities must be complete, accurate, timely, and clearly presented.
• Do not have falsification of records, distortion of information, or misrepresentation of transactions.
• Do not participate in or encourage activities that violate tax regulations or legal requirements in the country of operation.

Examples of actions that violate the accuracy and integrity of records: Quality reports are altered to conceal non-compliant data. Working hours are recorded inaccurately or do not reflect actual time worked. Operating expenses are misreported or incorrectly accounted for.

1.4 Training and development

• TCV always provides opportunities for employees to learn, develop skills, and enhance expertise, encouraging creativity and practical application of new ideas.
• Employees are fairly, transparently, and accurately evaluated based on performance and are also held accountable for their mistakes.
• TCV encourages each employee to build their career development plan and make the most of learning opportunities in the workplace. Appointments, recognition, and rewards are entirely based on capability and actual results.

1.5 Use and protection of company assets

Company assets include both tangible and intangible assets. Tangible assets may include cash/bank funds, furniture, office equipment, etc. Intangible assets include intellectual property, confidential information, work time, as well as network and software systems.

The use of company assets must follow these principles:

• Employees are responsible for using company assets for the right purposes and avoiding waste.
• For tangible assets: Do not use for personal purposes or bring company assets outside without permission
• For intangible assets: Do not engage in personal activities during working hours. Do not use company software or network systems for personal purposes. 
• Do not exploit relationships or access to company assets and information obtained through your role for personal gain.
• Strictly comply with all usage guidelines and protection requirements issued by relevant divisions.

2. Use and protection of information

Information is one of the most important assets of the Company, playing a critical role in decision-making, maintaining competitive advantage, and ensuring efficient business operations.

Protecting confidential information not only shields the Company from risks of leaks or breaches but also strengthens the trust of clients, partners, and employees.

Therefore, all employees must comply with the following requirements when receiving, using, and handling company information:

• Do not share confidential information with anyone outside the Company unless required by your job responsibilities, and only after applying appropriate safeguards - such as signing a Non-Disclosure Agreement (NDA) before disclosure.
• Only provide confidential information to internal personnel with a legitimate business need. Share information solely through official channels such as company email or approved internal platforms.
• Always safeguard the Company’s confidential information in all situations, including when working remotely or after leaving the Company.
• Stay updated and fully comply with all information security objectives set by the ISO Board.

2.1 Personal data protection

• Within the limits of the law, TCV collects and manages employees’ personal data related to employment status, including salary, health conditions, and benefits.
• TCV is committed to respecting the privacy and confidentiality of all employees, business partners, and clients.
• Personal data must be handled carefully, responsibly, and in compliance with the law. Individuals responsible for processing data must:
  • Collect, use, and process personal data in accordance with legal requirements.
  • Comply with confidentiality obligations outlined in contracts.
  • Use personal data only for legitimate business purposes and retain it for necessary periods.
  • Restrict access to personal data to authorized personnel only.
  • Ensure those with access understand and commit to confidentiality rules.
  • Allow data owners to review and correct their information as needed.
  • Prevent unauthorized disclosure of personal data
• In addition, personal data confidentiality obligations are specifically outlined in the Personal Data Protection and Processing Agreement, as well as in TCV’s Non-Disclosure and Non-Compete Agreement.
• For projects operated at TCV, depending on the specific nature of the project, employees may be required to sign additional confidentiality commitments beyond the ones signed with TCV. Therefore, strict compliance with all signed confidentiality agreements is required.

2.2 Public statements and media interviews

• In today’s digital landscape, anything shared on social media, forums, or public platforms can be easily monitored, copied, and spread—often beyond control and without time limits. Even unintentional posts can lead to long-lasting consequences for individuals and the organization.
• To ensure professional integrity and protect the company’s reputation, please follow these guidelines:
  • When making public statements or posting on media platforms, employees must speak solely in a personal capacity - unless formally authorized in writing to represent TCV.
  • Think carefully before sharing any information about yourself, colleagues, or the company. Avoid content that may be misleading, cause misunderstandings, or create reputational risks.
  • Always follow company policies when engaging with media or using social platforms. This ensures responsible communication and safeguards both personal and corporate credibility.

2.3 Business travel – Domestic trips

• Follow the approved schedule and assigned tasks diligently.
• Do not take advantage of business trips for any actions that violate ethical standards.

2.4 Business travel – International

• Comply with the laws and respect the cultural norms of the host country.
• Maintain professionalism at all times and represent the company with integrity.
• Fulfill assigned responsibilities and make the most of the experience to grow both personally and professionally.

2.5 Environment responsibility

• Foster a workspace that is environmentally conscious, tidy, and visually appealing.
• Abide by company regulations and environmental protection laws.

2.6 Resolving internal conflicts

• Remain calm and approach disagreements with objectivity, focusing on shared goals and the greater good.
• Engage in open, respectful dialogue; refrain from forming factions or behaviors that may undermine team unity.
• If conflicts escalate beyond resolution between individuals, direct managers or company leaders are responsible for addressing them fairly and constructively to preserve collaboration and a healthy working environment.

3. Code of conduct between managers and employees

• Empower and inspire employees to reach their full potential, elevate their performance, and make meaningful contributions to the company’s continued success.
• Foster an environment of active listening, offering guidance and timely feedback that enables employees to excel in their responsibilities.
• Create an atmosphere of growth, where employees have access to opportunities for skill enhancement, continuous learning, and career progression. Encourage innovation and the practical application of fresh ideas.
• Uphold fairness and objectivity in every decision, assessing employees based on their capabilities and achievements. Refrain from favoritism and ensure that personal biases never cloud managerial judgment.
• Set the standard by embodying the company’s values and policies. Never condone misconduct, misuse authority, or engage in unwarranted criticism.

4. Code of conduct between employees and managers

• Communicate with professionalism, respect, and courtesy. Complete assigned tasks to demonstrate personal responsibility and competence.
• Take the initiative to learn, improve skills, and propose practical ideas to enhance work efficiency.
• Respect management decisions, avoiding blind agreement or supporting views that are not constructive. When providing feedback, do so directly, openly, and with a spirit of collaboration.
• Strictly adhere to assigned duties and responsibilities. Do not take on tasks outside your authority unless given clear direction.

5. Code of conduct between colleagues

• Approach every interaction with humility, authenticity, and professionalism. Cultivate a respectful and friendly atmosphere to help foster a thriving workplace culture.
• Embrace teamwork and mutual support, both professionally and personally, to grow stronger together as a unified team.
• Stay open to learning from others and be generous in sharing your own experience. Offer feedback constructively, with the intention to help each other improve.
• In collaborative settings, engage proactively and focus on shared goals. When conflicts arise, escalate them appropriately to managers for fair and timely resolution.
• Demonstrate accountability in your role. Avoid shifting blame, shirking responsibilities, or contributing to internal division.
• Build relationships based on mutual trust, transparency, and respect. Avoid gossip, envy, or making remarks that undermine team cohesion.5

II. Code of conduct with external parties

1. In relation to Government authorities

1.1 Compliance with laws and regulations

TCV is committed to full compliance with all applicable laws, directives, and guidelines issued by the Government and relevant regulatory bodies. We adhere strictly to current legal frameworks in all business operations.

1.2 Cooperation with relevant Ministries and Agencies

TCV actively follows directives from relevant ministries and agencies, ensuring full cooperation in all aspects of operation. We maintain strong working relationships with authorities to ensure compliance, optimize operational efficiency, and facilitate timely administrative procedures.

1.3 Relations with local authorities

TCV pledges to comply with all regulations set forth by local authorities in the regions where we operate. We encourage employees to participate in meaningful local community initiatives and collaborate closely with security agencies to maintain a safe and orderly workplace.

2. In relations with partners and clients

2.1 To clients

• When interacting with clients, employees must maintain a friendly, professional, and respectful attitude, demonstrating agility, dedication, and a strong sense of responsibility in all situations.
• All transactions and communications with clients must strictly adhere to the company's policies. Employees must avoid making unauthorized statements, using inappropriate language, or creating unnecessary difficulties or demands beyond company regulations.2
• Employees are responsible for providing clients with accurate and up-to-date information about the company's products, services, and policies, ensuring transparency and clarity. Any form of deception or the provision of misleading information to clients is strictly prohibited.
• When clients raise inquiries or request assistance, employees must respond promptly and appropriately within their authority and follow up to ensure the matter has been fully resolved.
• Client confidentiality is a core principle at TCV. Employees are strictly forbidden from disclosing client information to third parties without the explicit consent of both the client and the company, unless required by competent state authorities.

2.2 To partners

• TCV builds partnerships based on mutual respect, equality, and a shared commitment to long-term, sustainable collaboration.
• All business dealings and partnerships must comply with legal requirements and mutually agreed-upon terms. In case of disputes or misunderstandings, both parties are expected to resolve issues with fairness, goodwill, and a focus on mutual benefit.
• Employees must maintain professionalism and courtesy in all interactions with partners, ensuring conduct that reflects positively on the company.
• When engaging with international partners or traveling abroad for business, employees must respect and comply with the laws, cultural norms, and behavioral standards of the host country.
• Any form of coercion, undue pressure, or exploitation of partnerships for personal gain is strictly forbidden.

2.3.2 In advertising

• All advertising activities must fully comply with applicable laws and company regulations.
• Advertising content must provide accurate and transparent information that supports TCV’s development strategy, business objectives, and brand promotion efforts in both local and international markets.

2.3.3 In recruitment advertising on media platforms

• Recruitment news must be clear, honest, and not misleading regarding job description, compensation packages, or working conditions.
• Sensationalized or deceptive content must not be used to attract candidates.
• All images, videos, and content related to recruitment must be reviewed and approved prior to publication.
• Employees must not post recruitment advertisements on unofficial channels without prior approval from the HR Division, Communications Unit, or the relevant recruitment team.

2.4 Conduct with the competitors

The collection, use, and disclosure of information regarding competitors must adhere strictly to applicable laws and recognized standards of business ethics.

• Under no circumstances should employees engage in unlawful practices - such as theft, eavesdropping, unauthorized recording, bribery, or any form of deceit - to obtain competitor information.
• Information acquired through breaches of confidentiality agreements between third parties and competitors must not be solicited, used, or disclosed.
• Any information concerning individuals, organizations, or other businesses must be treated with utmost discretion and responsibility. It should be used solely for legitimate business purposes and only shared with authorized personnel. When disclosure is necessary, care must be taken to avoid revealing the identities of the individuals or entities involved.

3. Conflicts of interest

• A conflict of interest arises when an employee’s personal interests or those of their relatives affect or appear to affect the interests of the Company.
• In all circumstances, employees must ensure that all decisions and actions are made objectively, independently, and in the best interests of the Company, free from influence by third parties, personal relationships, or any form of benefit.

3.1 Conflicts of interest with external activities

3.1.1 Relatives and friends

To ensure transparency and prevent conflicts of interest in the workplace, employees must declare and update personal relationships with relatives, colleagues, or partners engaged in business with TCV, as follows:

• New employees: Must inform the HR Division about any relationships with current employees or business partners of the Company on the first day of employment.
• Current employees: Must promptly update the Company if any relative (including spouse, parents, children, siblings, in-laws, or relatives on the spouse’s side) joins or works at the Company or is involved with a business partner.
• Job assignment principle: Individuals with family ties must not hold conflicting roles within the same workflow. If such a situation arises, it must be reported to the Head of Division and HR Division for appropriate handling.

3.1.2 Gifts, hospitalities and other benefits

BODs and Management as well as all employees are strictly prohibited from directly or indirectly soliciting or accepting commissions, fees, incentives, gifts, meals, or any other form of hospitality from clients, suppliers, or their representatives - whether for themselves or their relatives. Such actions may compromise the objectivity of decisions and violate the Group’s anti-corruption policies.

• Gifts
  • o Acceptable gifts may include symbolic items, trophies, certificates, or tokens commemorating business relationships; or promotional gifts/discounts offered to the entire employees or large groups (e.g., discounts for all female employees on International Women's Day).
  • o Accepting gifts in exchange for promises or favors, or accepting cash or cash equivalents (e.g., gift cards or vouchers), is strictly prohibited.
• Meals, hospitalities and other benefits:
  • o Employees must not accept meals, entertainment, or other benefits from clients or suppliers in exchange for taking or promising to take any action in their favor.
  • o If invited to large-scale trips, cultural, or sporting events by clients or suppliers, employees must consult with their direct manager to assess whether the participation serves a legitimate business purpose. If deemed appropriate, all related expenses must be covered by the Company - not by the third party.

In addition, employees must not directly or indirectly offer, promise, or provide any payment, gift, or benefit to a client’s or supplier’s employee or representative to improperly influence business decisions or to express gratitude for any act that benefits the employee or the Company.

3.1.3 Other external activities

Employees may engage in outside employment or activities provided that these do not negatively impact their performance at TCV. However, conflicts may arise if such activities interfere with work performance, risk disclosing confidential information, or damage the Company’s reputation. Employees are advised to consult recruitment policies and employment contracts for specific restrictions related to external work.

3.2 Conflicts of interest with the internal activities

3.2.1 Recruitment and Human Resource Management

The Company’s recruitment and human resource management activities must adhere to the following principles:

• Recruitment and staffing decisions must be based on the actual and legitimate needs of the Company.
• The recruitment and employment processes must ensure fairness and transparency.
• Recruitment criteria must be clearly defined, based on competence, experience, and skills relevant to the specific job requirements.
• Any form of interference or influence that may distort the integrity of the recruitment and employment process is strictly prohibited.
• Any behavior that violates or poses a risk of violating the above principles shall be considered a breach of Company policy and will be subject to disciplinary action in accordance with current regulations.

Furthermore, taking advantage of one’s position, title, or personal relationships within the Company to influence recruitment or personnel arrangements for personal gain or to show favoritism toward relatives or acquaintances is also deemed a violation and will be subject to disciplinary review in accordance with the Company’s procedures.

3.2.2 Procurement activities

• The procurement process for goods and services, including the selection of vendors, must be conducted based on clear and rational criteria such as actual needs, product/service quality, pricing, and other relevant factors.
• If you are assigned to coordinate or participate in the selection, evaluation, or negotiation with vendors, you must fully comply with the Company’s current procurement regulations and procedures. All decisions must be made objectively and transparently, free from the influence of personal interests or private relationships, to ensure that the Company’s overall interests are prioritized.

3.2.3 Other internal activities

All other internal activities within the Company must follow general principles designed to prevent and avoid the emergence of conflicts of interest in any form.

III. SPECIFIC CODE OF CONDUCT

1. Greetings and communication etiquette

1.1 Greetings etiquette

• Maintain a professional demeanor: Stand upright, make direct eye contact, and show respect when meeting colleagues, clients, or partners.
• Smile and display a friendly attitude when greeting; a nod is encouraged to convey openness.
• Proactively introduce yourself; do not wait for others to make introductions.
• Priority in greetings:
  • o Employees greet their superiors first, and the superiors return the greeting.
  • o Among peers, the younger person greets the elder first.
  • o If the person being greeted is busy, a smile or nod is acceptable in place of a verbal greeting.

1.2 Handshake etiquette

A handshake in a professional setting serves to greet, bid farewell, congratulate, or signify agreement. Therefore, it should be warm, friendly, and sincere.

• Shake hands with respect and friendliness: Make eye contact, smile, and use your right hand.
• Maintain proper posture: Stand straight, facing the other person directly.
• Priority order:
  • Follow the order of arrival or by seniority.
  • If you hold a lower position, wait for the other person to initiate the handshake
• Avoid inappropriate behaviors:
• Do not shake hands for too long, grip too tightly, or appear unserious.
• Do not bow excessively or use both hands unless culturally appropriate

1.3 Introduction and self-introduction etiquette

• When introducing others::
  • o Introduce the person of lower rank to the person of higher rank.
  • o Introduce your colleagues before introducing clients or external partners.
• When introducing yourself:
  • oProvide a brief introduction including your name and division at TCV.
  • Be polite and modest; avoid lengthy or excessive details.

1.4 Business card etiquette

• Always have business cards ready when meeting partners or clients.
• Ensure your cards are clean, untorn, and free from handwritten notes.
• Use the standardized TCV business card template.
• Business card exchange protocol:
  • The person introducing themselves gives their card first.
  • Present the card with both hands or the right hand, facing the recipient.
  • Nod politely and glance over the information before putting the card away.
  • If needed, ask for clarification on name pronunciation or unclear details.
  • When exchanging cards with a group, start with the most senior or eldest person.
  • When meeting multiple groups, start with the group leader of each.

2. Workplace etiquette

2.1 Dress code

• Employees must wear name badges during working hours and official business.
• Office attire or company uniforms must be clean, neat, modest, and not flamboyant.
• The following items are not allowed:
  • Bare feet, flip-flops, or patterned stockings.
  • Clothing that is overly thin or short (skirts more than 15cm above the knee for women; pants must reach the ankles for men).
  • Torn jeans, shorts, tight-fitting pants, or brightly patterned trousers.
  • Wrinkled shirts, low-cut tops, see-through garments, spaghetti straps, or sleeveless shirts.
  • Clothing displaying discriminatory or offensive symbols, slogans, or content against cultural norms.

2.2 Workplace environment

• Maintain a clean, tidy, and organized workspace; follow all company policies and rules.
• Arrange equipment and items systematically to ensure safety, hygiene, and fire prevention.
• Do not use others’ documents or personal belongings without permission.
• Refrain from snacking or smoking during working hours or in the workplace.
• Maintain order and avoid gatherings that cause noise or disturb others.
• Be courteous when entering or exiting rooms; knock before entering and close the door when leaving.
• Use electricity, water, stationery, and company assets efficiently and responsibly.

2.3 Working behavior

• Adhere to working hours; arrive and leave on time; be punctual for business trips.
• Notify your direct supervisor immediately if you must take sudden leave or will be late.
• Greet others politely upon arrival and departure from the office.
• Avoid alcohol, stimulants, or intoxicants during working hours or lunch breaks.
• Communicate respectfully: Speak calmly and concisely, and do not interrupt others.
• Maintain a professional attitude and be open to exchanging ideas and giving constructive feedback.
• Demonstrate responsibility, initiative, and dedication to your tasks.

2.4 Communication etiquette

• With partners:
  • Greet, introduce your name and position.
  • Act with courtesy, calmness, and follow proper etiquette.
• With clients: Always keep in mind the importance of appreciating clients, delivering services that exceed their expectations. At the same time, prioritize customer interactions, strive to improve service quality, and protect customer information and assets. 
  • Greet with a respectful and culturally appropriate attitude.
  • Communicate politely, with a warm and open demeanor, demonstrating friendliness and respect for the customer.
  • Provide clear explanations, avoiding ambiguity and shifting responsibility.
  • Refrain from expressing personal issues during communication
• With superiors: 
  • Be open to feedback and show sincerity.
  • Speak with respect and politeness.
• With subordinates: 
  • Listen actively and create a positive, comfortable environment.
  • Respect and support staff to help them develop their expertise.
• With colleagues: 
  • Be sincere, friendly, open-minded, and respectful.

3. Meeting etiquette

3.1 Punctuality

• For in-person meetings: Arrive at least 5 minutes early.
• For online meetings: Join the meeting link at least 5 minutes prior to the start time.
• In case of unavoidable absence or delay, inform the meeting organizer as soon as possible and before the meeting begins.

3.2 Active listening

• Ensure you understand the meeting content and your responsibilities. Don’t hesitate to ask for clarification if needed.
• Follow the moderator’s instructions.
• Avoid distractions (e.g., reading, using your phone) during the meeting.
• For online meetings, keep your microphone muted unless you are speaking.
• Respect differing opinions and maintain a positive attitude.
• Show engagement through eye contact and appropriate body language.

3.3 Speaking in meetings

• Signal the moderator when you wish to speak.
• Keep your comments concise and focused, and maintain a respectful tone.
• Do not interrupt others while they are speaking.

D. CONCLUSION

The Code of Conduct not only sets out principles to be followed but also helps shape a professional, responsible, and respectful workplace culture at TCV. Each employee, through personal accountability and commitment, contributes to building a transparent, fair, and sustainable environment.

Adhering to the Code of Conduct not only enhances individual reputation but also affirms the Company’s values and credibility in the eyes of clients, partners, and the wider community. More than an obligation, it is a shared commitment to building a strong organization where everyone has the opportunity to grow and succeed.