One of the fundamental policies of Nanjing VisionICs Microelectronics Technology Co., Ltd. (hereinafter referred to as VisionICs) is to strictly implement the relevant international export control and economic sanctions adopted by the United Nations and imposed by certain multilateral treaty mechanisms, to practically fulfill its responsibilities and obligations under such export control and economic sanctions, and to establish an international image of integrity and responsibility so as to win the trust of partners and customers. At the same time, VisionICs firmly believes that consciously implementing relevant export control and economic sanctions laws and regulations can enable VisionICs to effectively avoid and reduce trade compliance risks, continuously improve VisionICs' competitiveness in the domestic and international markets, and provide effective guarantee for the long-term development of VisionICs.

VisionICs guides the establishment and implementation of VisionICs' internal trade compliance system with the principle of effecting comprehensive control, and puts VisionICs' trade compliance obligations above its commercial interests. If VisionICs believes that the tangible or intangible products, technologies and services to be exported by it may be used by customers or end users to develop or manufacture weapons of mass destruction, or the transportation tools of such weapons or other unauthorized conventional military equipment, which are detrimental to the peace and stability of the receiving country and region, or which might fall into the hands of terrorist organizations, VisionICs will implement strict export control measures in accordance with the principle of effecting comprehensive control and refuse the export of relevant products, technologies and services. In accordance with the principle of "deemed export", VisionICs will also carefully carry out internal monitoring and managing to prevent employees from contacting certain individuals or organizations that may maliciously use sensitive technology or information.

VisionICs also verifies intermediaries that may need to be employed in the course of business operations to avoid potential proliferation diversion and economic sanctions violations. VisionICs refuses to do business with illegal companies or individuals. VisionICs realizes that in accordance with the government's requirements to identify sensitive customers, distinguish product codes and product end uses in accordance with international and national standards, it is necessary to further establish and maintain close contact with relevant competent departments of the Chinese government, relevant non-governmental organizations and export control experts to obtain relevant technical information, seek professional guidance and authoritative suggestions.

In order to ensure the effective implementation of its own trade compliance system, VisionICs has established a compliance committee in its organizational structure under the general manager's office, whose members are composed of senior leaders of the company and heads of various departments, which are fully responsible for organizing, coordinating and guiding the company's trade compliance management, and reviewing, supervising and inspecting the compliance of the company's business management and business behavior. In addition, VisionICs has also designated more than one trade compliance managers in the company's trade compliance business related department, who shall be responsible for organizing and coordinating the trade compliance management within the department, and responsible for connecting with the compliance legal department for trade compliance management.

With respect to the bylaws formulation, VisionICs has formulated an internal control system for trade compliance, publicized and trained on trade compliance laws and regulations, strengthened internal audit, and substantialize the responsibilities of various departments involved in trade compliance.

All employees of VisionICs undertake to make efforts to achieve the goal of trade compliance and strictly implement the relevant trade compliance policies of VisionICs. All employees understand that failure to comply with these policies may result in criminal and/or civil fines and penalties, including imprisonment and fines, and at the same time, the violating employee will be subject to disciplinary action and/or suspension and/or termination. VisionICs rewards employees who actively participate in trade compliance work, and posting on a bulletin board and severely punishes employees who violate VisionICs' trade compliance policies. Employees who violate laws and regulations will bear corresponding legal responsibilities in accordance with the law.

This statement applies to all employees of VisionICs and its wholly-owned subsidiaries.

VisionICs will routinely review this statement and revise it in accordance with relevant laws and regulations.

Nanjing VisionICs Microelectronics Technology Co., Ltd.