Code of Conduct

As a wholly state-owned company, with the mandate to invest and manage China's foreign exchange reserves, CIC has identified four core values: responsibility, synergy, professionalism and aspiration, with the goal of growing into a world-class and respected sovereign wealth fund. To achieve this goal, CIC requires its employees to strictly comply with all applicable laws and regulations and to maintain the highest standard of professional ethics and integrity.

As an important rule of the company and the foundation of our culture, the Code of Conduct explains the basic principles of important matters and puts forward detailed requirements regarding the protection of the company's reputation, interests, assets and information. All employees shall comprehend, accept and follow the Code of Conduct upon joining CIC. Requirements include:

• 1. Employees shall understand and comply with all applicable laws, regulations, and social and moral standards, to avoid damaging the Company's reputation and interests caused by any inappropriate behavior.
• 2. Employees shall carry an honest and sincere attitude and abide by basic professional ethics and integrity.
• 3. Employees shall comply with the best interests of the Company. Employees shall, in performing their duties, identify and report any possible conflicts of the Company's interests and take necessary measures to avoid or eliminate external activities or personal relationships that could affect their business judgment or duties, such as having part-time jobs and conducting similar business and related-party transactions.
• 4. Employees shall correctly handle gifts and hospitality received from business partners. Generally, employees shall not accept gifts and hospitality provided by enterprises or staff that have a business relationship with the Company, to avoid any interference in the employees' normal business judgment.
• 5. Employees shall refrain from any form of commercial bribery and corruption when conducting business in any country or region.
• 6. Employees shall properly keep and use Company's assets and refrain from occupying and disposing these assets. Employees shall report to relevant departments when the Company's assets are at risk.
• 7. Employees shall properly protect, use and process all Company information. Employees shall refrain from forging information, abusing insider information and disclosing information without authorization.
• 8. Managers at all levels shall take the lead in implementing the Code of Conduct and help other employees understand and comply with its requirements. Employees can report any violation of laws, Company regulations or the Code of Conduct to senior management or the Department of Institutional Integrity.

See CIC Code of Conduct for the full version.

Guidelines on Preventing Conflicts of Interest

The Guidelines is formulated to guide employees to identify and prevent the occurrence of conflicts of interest (COI) in performing his or her duties, to promote integrity and compliance at workplace and manage ethics risks and reputation risk of the institution as a whole. Key excerpts of the Guidelines are as follows:

The Guidelines apply to all the staff on valid employment contracts with China Investment Corporation (hereinafter referred as "CIC" or "the Company"), including its overseas affiliates. Every department is obliged to inform, educate and monitor seconded staff, temporary staff and third party staff representing the Company regarding the terms and conditions of the Guidelines. In addition to the Guidelines, CIC's expatriate staff should also comply with applicable laws and regulations of the residing country or jurisdiction.

I. Receipt of gifts, cash or hospitality

• 1. Employees should not accept cash benefits (including gift cards and vouchers) or other property interests.
• 2. Employees should not possess or privately divide discount fees, intermediary fees or commission occurred in business activities.
• 3. Employees should not solicit gifts, explicitly or implicitly, by taking advantage of their positions at work.
• 4. The Company encourages employees to decline gifts in business activities.
• 5. When attending social events or festive celebratory functions in official capacity, employees should avoid suspicious lottery (where the value of the prize may exceed the conforming amount and could be deemed as gift in disguise).
• 6. Employees should not solicit or accept entertainment and hospitality that may interfere with impartial conducts in business activities.
• 7. Without permission, employees should not accept entertainment or hospitality offered by any institution or individual who is in direct business connection with the Company.
• 8. Without prior approval of the Company, employees should not solicit or accept any business trips or training programmes.
• 9. Employees should not participate in any high-level entertainments or sporting activities (nightclub, karaoke bars, concert, high end competition, golf, etc.) targeted at specific employees, arranged by sell-side organization or individual.
• 10. Employees should not demand or accept any domestic or abroad travel (travel in form of conference or training, etc.), vacation, fitness or other expensive activities targeted at specific employees or his/her immediate families, arranged by sell-side organization or individual.
• 11. Employees should not involve in gambling activities or games with individuals having business contact with the Company.

II. Part-time job and acquiring business opportunity

• 1. Without prior approval, employees should not engage in part-time employment with other companies or provide paid products or services. Part-time employment with social groups or academic institutions should be reported to the Company for approval. These part-time positions should not affect employees' daily work. Employees should timely report or terminate these part-time positions taken before entering into employment with the Company.
• 2. Without prior approval, employees should not charge for part-time jobs or mediation activities.
• 3. Without prior approval, employees should not be employed, work as a consultant or charge fees in the Company's rivals, partners or associated institutions.
• 4. Employees should not utilize the Company's resources or the position to promote business activities beyond the Company, or take part in other activities that compete with the Company.
• 5. Employees should not take advantage of the position to run business similar to that of the Company for themselves or others.
• 6. The business opportunities employees found by virtue of the Company's asset, information or their positions belong to the Company. Employees should not conceal such information from the Company intentionally and instead seek profits for themselves, their immediate families or individuals of specific relationship.

III. Insider information

• 1. Employees should not trade or transfer benefits through personal securities, futures and its derivatives and other illegal profit-making activities by utilizing insider information gained from the Company or other agencies.
• 2. Employees should not agent, suggest, assist or imply others to trade securities, futures and its derivatives transaction by utilizing insider information.
• 3. Employees should not reveal inside or non-public information to non-related institutions or individuals. Employees should not inquire insider information or non-public information.
• 4. The coworkers, immediate families and other associated individuals of an employee in investment departments should not involve in portfolio transactions executed or managed by any individual employee in the department.

IV. Related-party transactions and profiting for individuals of specific relationship

• 1. Employees should not transfer the Company's assets and profits outwards for personal needs via related-party transactions. Employees should not dispose the Company at cost and risk that are unmatched with the earnings.
• 2. In activities of overseas investments, principal-agent, intermediary services procurements, employees should not involve in the negotiation or voting process with transaction object having significant financing or personal relations, he/she should not exert influence on relevant decisions either.
• 3. Employees should not have business contact with immediate families, individuals of specific relationship or financial-related companies with above-mentioned individuals, providing preference or interests by utilizing their posts.
• 4. Employees should not seek personal interests for immediate families or individuals of specific relationship in recruitment, salary distribution, posts transferring and reward evaluation.

V. Information security and disclosure

• 1. Employees should not violate regulations on confidentiality management, external publicity and information disclosure by revealing state's or Company's confidential information.
• 2. Confidentiality rules must be strictly abided by. Any information theft or espionage is prohibited and offenders will be held accountable.
• 3. Employees should not violate regulations on confidential protocol or contract confidentiality clauses by revealing the Company business partner's commercial secrets.
• 4. Employees should not give speech or viewpoint which damages the Company’s image or is inconsistent with the Company's position in public, including media, Internet, public academic conferences and other publications.
• 5. Without prior approval, employees should not reveal any un-released information, business report, investment report, important decisions, discussion agenda, suggestion, etc. Employees should not make personal surmise, being interviewed or making remarks on above-mentioned matters.
• 6. Without prior approval, employees should not publish work related materials on personal title, or accept interviews, write articles or make remarks publicly on behalf of the Company.
• 7. Without approval, any department or employees is forbidden to release relevant information about investment project.
• 8. Before approval, employees should not make commitment on donation to media, society or specific recipient on behalf of the Company, avoiding do harm to approval process or Company's image.

VI. Utilizing Company’s property

• 1. The Company owns the intellectual properties (information system, investment research report, etc.), which is researched and developed in the process of working or utilizing the Company’s funds, equipment and information. Employees should not use and dispose privately.
• 2. Employees should not use public funds to pay personal expenses.
• 3. Official business card is forbidden to use for personal expense. If conditions allow, employees should pay by official business card when performing their official duties.
• 4. When using business entertainment costs, it should not exceed business entertainment standard.
• 5. In principle, taking public transportation and accommodation should not exceed standard set by the Company. Otherwise, employees need to undertake the exceeded part.

VII. Personal investment and finance

• 1. Employees, immediate families or other specific individuals should not invest in Company's rivals, partners, manage objects and suppliers. Employees are allowed to invest shares of listed company if they are unaware of any inside information.
• 2. Employees, immediate families or other specific individuals should not invest securities, futures and its derivatives in Company’s rivals, partners and manage objects. Gaining unmatched income in other form of trust management is also not allowed.

VIII. Activities after retirement

• 1. Employees in retirement or those who resigned are still stipulated by the laws or labor contracts to accept non-compete restriction and should not utilize information and resources gathered in the Company to compete in the similar business line.
• 2. Without prior approval, employees who resigned for less than a year should not work for or provide consultation for the counterparties, partners, or relevant institutions that they cover on their duty.
• 3. Employees should not participate in activities that damages the Company's reputation and interests, or leak or utilize the confidential information.
• 4. Without the Company's consent, employees should not make public remarks or accept interviews on the relevant issues of the Company. As for the above-mentioned behaviors conducted by the retired employees and severely impacting the Company’s reputation and interests, the Company retains its right of legal action

As for reports on any behavior involving interests conflicts or commercial bribery,

please contact +86 (10) 6653 3363 or 12380@china-inv.cn.