Code of Conduct

Cocan Graphite and its subsidiaries are dedicated to fostering a culture of professional and ethical conduct in their global business practices. This commitment is guided by a comprehensive code of ethics, which sets forth the standards and expectations for behavior of all executive officers, directors, financial managers, and employees. The code emphasizes responsibilities towards individuals, the company, the public, and shareholders, ensuring Cocan Graphite maintains its integrity across all operations.

Key tenets of the code include:

1.Ethical Obligations: Cocan Graphite commits to ethical dealings with all parties, ensuring fairness, respect, and a commitment to a safe and healthy work environment. The company pledges to be a responsible corporate citizen, prioritizing environmental stewardship and good community relations.

2. Positive Work Environment: The company values a respectful and inclusive workplace, free from harassment and discrimination. Cocan Graphite places a high emphasis on cultural diversity and seeks to foster an environment where all employees feel valued and able to contribute to their fullest potential.

3. Health, Safety, and Environmental Stewardship: Employees are encouraged to maintain a drug-free, safe, and healthy working atmosphere. The company is committed to minimizing its environmental impact and contributing positively to the communities it operates in.

4. Accuracy in Recordkeeping: Cocan Graphite insists on maintaining complete and accurate company records, adhering to accepted accounting practices and principles. The company has a zero-tolerance policy for the falsification of records.

5. Legal Compliance: The company is committed to conducting its business in full compliance with applicable laws and regulations. This includes strict adherence to competition laws, securities laws, and avoidance of insider trading.

6. Conflict of Interest: Employees, officers, and directors are expected to avoid any actions that could lead to, or appear to lead to, a conflict of interest with the company. Full loyalty to the company's best interests is paramount.

7. Fair Competition: Cocan Graphite competes for business opportunities ethically and legally, ensuring all business dealings are conducted with integrity.

8. Gifts and Favors: The company prohibits the giving or receiving of gifts that could influence or appear to influence business decisions, maintaining the integrity of its business relationships.

9. Integrity of Business Representatives: Agents and consultants representing the company must adhere to Cocan Graphite's values and ethical standards, ensuring fair and competitive practices.

10. Protection of Proprietary Information: Confidential and proprietary information of Cocan Graphite must be safeguarded, with access restricted to authorized individuals.

11. Responsible Use of Company Assets: Company assets, including property and information resources, are to be used wisely and solely for legitimate business purposes.

12. Political Contributions and Activities: Employees are encouraged to participate in civic and political activities on their own time and expense, adhering to laws prohibiting corporate political contributions.

13. Enforcement by Audit Committee: The Audit Committee is empowered to enforce the Code of Ethics, reporting on its effectiveness and company conduct to the Board of Directors.

14. Disciplinary Measures: Violations of the code will be addressed promptly, with disciplinary measures ranging from counseling to termination, depending on the severity of the violation.

Cocan Graphite's Code of Conduct is a testament to its commitment to ethical business practices, emphasizing the importance of integrity, responsibility, and respect in all aspects of its operations.