We have embedded the importance of upholding and protecting human rights into our internal management standards. Our "Code of Conduct" clearly delineates the behavioural norms and foundational principles that govern our business interactions with stakeholders. It serves as a guiding compass in our selection of business partners. We explicitly reaffirm our dedication to respecting human rights, vehemently denouncing any violations of human rights, prohibiting child labour, and all forms of forced or compulsory labour, and upholding and safeguarding the fundamental rights of our employees. This code pertains to our direct enterprises and wholly-owned or controlled subsidiaries and establishes a significant benchmark for our project investments and supplier selection.

Our "Supplier Corporate Social Responsibility Code" stipulates that all suppliers must acknowledge and adhere to compliance standards in order to establish a business relationship with the company. Any breach of the code will impact the business relationship and may result in the termination of cooperation. We require our business partners to strictly prohibit the use of forced labor and all forms of modern slavery and human trafficking, including bonded labor or involuntary confined labor. Additionally, we expect our partners to ensure that their employment relationships with their employees are based on voluntary principles and that employees have the option to terminate their employment within a reasonable notice period.

We are fully committed to upholding the UN Guiding Principles on Business and Human Rights (UNGPs) as well as our company's human rights standards. These standards mandate that all projects gradually establish procedures for identifying and managing human rights risks, and integrate human rights assessments into their impact or risk evaluations. We carefully monitor human rights risks such as child labor, forced labor, workplace harassment, and discrimination, particularly in high-risk areas. GCL Tech has not identified any significant human rights risks related to child labour, forced labour, or violations of freedom of association and collective bargaining at our operational sites or major suppliers.

We are firmly committed to opposing the use of child labour and any other form of hidden exploitation. We do not engage with any suppliers, contractors, or partners that pose a risk of employing child labour. Our company and its subsidiaries have established and upheld policies and procedures to prohibit child labour, protect minors, and take timely remedies to support child labourers. GCL Tech has not experienced any incidents of child labour.

• Health Checks

  The HR department will send any child labourers who were inadvertently hired to occupational health examination institutions for health checks to determine whether their health has been impacted. If so, we will cover all related living and medical expenses.

• Wages and Benefits

  No improper deductions will be made when paying mistakenly hired child labourers; wages will be calculated and paid in strict accordance with the laws and regulations set by us, the country, or the regional government.

• Safe Return

  We are obligated to contact the parents or guardians of the mistakenly hired child labourer to ensure their safe return home. Upon their return, we will cover all transportation and lodging expenses.

• Compulsory Education

  We will investigate whether the mistakenly hired child labourer has finished their required compulsory education. If necessary, we will assist those who have not completed their compulsory education by covering their education costs.

• Providing Support

  We will prioritize providing job opportunities to individuals in the families of mistakenly hired child labourers who have reached the legal working age and are eager to work.

We are vehemently opposed to any form of forced labour in all of our business operations, including our subsidiaries, joint ventures, affiliated companies, suppliers, contractors, and partners. This includes forced labour, labour trafficking, human trafficking, and all other forms of modern slavery. GCL Tech prohibits the use of forced labour by conducting background checks prior to hiring and requiring signed labor contracts after verifying new employee information. If any form of forced labor is discovered, management will be interviewed, and disciplinary action will be taken in accordance with applicable regulations. GCL Tech has not encountered any cases of forced labour.

All of our recruitment activities are based on the principles of free, prior, and informed consent (FPIC). All employees are freely recruited through the market using mutual selection, sign employment contracts based on voluntary principles, and have the right to terminate the contract after the legal notice period.

GCL Tech highly values every employee's right to associate and collectively bargain freely. To support this, we have put in place the "GCL Tech Union Charter" to provide guidance for employees to actively participate in democratic decision-making, management, and supervision within the group. Employees have the freedom to join or leave the union voluntarily. In 2023, GCL Tech conducted an employee representative assembly, where employee representatives were elected, and a "Collective Bargaining Agreement" was signed with a coverage rate of 100%. To ensure transparent communication, GCL Tech has established various communication channels and implemented systems such as the "Employee Relations Management Standards" to clearly outline the mechanisms for two-way communication with employees. All complaints and reports will be treated with strict confidentiality, and no organization or individual will engage in retaliation or discrimination against those who report, thus ensuring that employees "can communicate," "are willing to communicate," and "dare to communicate."

We maintain a stringent non-negotiable stance against all forms of discrimination, bullying, intimidation, and harassment. Our commitment is to treat all employees with equal respect, irrespective of their nationality, race, ethnicity, gender, religious beliefs, or cultural background. Our objective is to cultivate an inclusive and diverse work environment where every employee feels esteemed and supported. Additionally, we provide comprehensive education and training on legal compliance and establish proactive and disciplinary measures to address workplace harassment. We rigorously enforce a zero-tolerance policy towards discrimination, harassment, and breaches of employee privacy to uphold a just and equitable workplace.