Code of Business Conduct

Compliance with Laws

Comba Network has been always sticking to be compliant with laws and regulations, honest operation, commercial ethics which are business philosophy and footstone of our values.


Comba Network attaches great importance to and continues to create a culture of integrity and such basic value and principle have been embodied in the "Code of Business Conduct" of Comba Network, which requires each of our employees to abide by and to conduct all businesses within the framework of legal and ethical standards.


For the employees of Comba Network, ethical behavior is an essential part of the work instead of an "optional extra behavior".


Based on the "Code of Business Conducts", Comba Network insists that all personnel, including shareholders, directors, senior managers, interns, temporary workers, consultants, retired employees, part-time employees, and other personnel who conduct external business on behalf of the company, are required to comply with the applicable laws and regulations of the country or region where the business is launched as well as respect local culture and customs.


Meanwhile, Comba Network is committed to protecting the rights and interests of employees, personal dignity and privacy, providing equal opportunities for every employee. By establishing an ISO45001 certified occupational health and safety system, Comba Network aims to provide employees with a healthy and safe working environment that meets internationally recognized standards, and prohibits forced or compulsory labor, prohibits the employment of child labor, and regulates labor management. 


In order to better manage the company's compliance, Comba Network incorporates compliance assessment as elements of Key Performance Indicators (KPI) and establishes a reward and punishment mechanism to ensure that every employee abides by the company's Code of Business Conducts. 


Information Security Management 


Comba Network maintains a stringent policy of information security and confidentiality and an information security management system. In order to effectively safeguard the security of the company's information system and better serve for the company's production and operation, Comba Network has formulated the "Information Security Management System" and "Information Security Structure".


Aiming at ensuring information security and preventing data leakage, information security management is managed in an all-round way from six aspects: IT infrastructure guarantee, computer terminal management, application system management, data management, network management, data backup and disaster recovery system. 


Business Partners Due Diligence 


Comba Network continues to devote itself to the establishment of a compliance management system in various fields such as export control compliance and business partner due diligence and has established a series of internal regulations and online management procedures such as "Export Control Compliance Procedure", "Technology Control Plan for Controlled Items", "Business Partner Management Measures" and "Procedure for Business Partner Due Diligence", etc. With the implementation of these internal rules and regulations, Comba Network will regularly perform due diligence on business partners in accordance with the applicable laws and regulations of the country or region where the business is located, ensuring compliance with the business cooperation. Compliance management has been integrated into the company's business activities and processes. 


Business Ethics Training 


Comba Network requires every employee to abide by business ethics, and the company's regulations on integrity and anti-fraud system.


Comba Network strictly prohibits employees from any bribery to customers and other related interested parties or individuals in order to seek improper benefits either for the company or individuals; employees are strictly prohibited from, directly or indirectly, accepting any form of gifts from suppliers, or engaging in any form of fraudulent behavior. 


The company requires all employees to receive training on business ethics, anti-corruption and integrity. The company will annually conduct mandatory training for all new recruitment, and conduct training for all promoted cadres. 


Moreover, tailored by different business models of different business departments, the company regularly provides different topics of business ethics and fair competition trainings for senior management, staff from marketing center and domestic branches, personnel from procurement department, employees of Hong Kong subsidiaries, and sales personnel of overseas market. Such lectures are conducted either by external professional lawyers or legal Department of Comba Network. 


Anti-Corruption and Anti-Bribery 


Comba Network firmly believes that integrity and fair competitions are the foundations of the company's business operation. Within the framework of all applicable fair competition, anti-bribery/anti-corruption rules and regulations, Comba Network always puts the company's anti-bribery and anti-corruption obligations above the company's commercial interests to ensure that the company's business is established on a fair, just, and transparent basis. 


Auditing on internal business ethics: Comba Network has set up internal control procedures for all departments. To ensure the effectiveness and completeness of the company’s internal control process, the audit department tests and evaluates the implementation of internal control procedures quarterly; further, independent third-party audit experts will conduct testing on the Company’s internal control environment and issue semi-annual and annual audit reports.


Corruption risk analysis: To evaluate the internal control process and to identify any corruption risk, the company's audit department will conduct, on a quarterly basis, risk assessment of the company's internal control process in accordance with the company’s business environment, policies, and regulations, etc. Such assessment will include the type, degree, and scope of any risks to be rated, following with audit plan and correction procedures developed for any risks identified. 


Furthermore, in order to encourage employees to supervise each other and anonymously report any unethical or illegal behavior found at work, the company has set up various reporting and complaint methods, including hotline, email, and “direct line to the president”, to ensure unobstructed appeal and reporting channels. Upon receiving any complaint or report, the company's audit department will promptly and effectively conduct investigations in accordance with relevant laws, regulations, and company policies of the country or region where the business is located.

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