1. Introduction

The purpose of this Responsible Procurement Policy for the company's international business (hereinafter referred to as "this Policy") is to promote the fulfillment of social responsibility, environmental protection, employee rights protection, and the sustainability of the supply chain in CEEC's international business. This Policy applies to all subsidiaries and production sites of China Energy Engineering Corporation Ltd. (collectively referred to as "CEEC") located outside of China, as well as all suppliers in international business (including subcontractors and other business partners). CEEC will periodically update this Policy based on its implementation and changes in relevant legislation.

2. CEEC's Commitment

This Policy sets out sustainable procurement requirements for products and services. A thorough understanding and strict compliance with this Policy are essential for fostering healthy development, establishing reliable and sustainable partnerships, and reducing operational risks for all involved parties. CEEC is committed to complying with all aspects of this Policy and expects all of its international business suppliers to do the same.

3. Our Requirements for Suppliers

We require suppliers to follow the principles and standards of responsible business conduct, including but not limited to the following 13 principles:

- Principle 1: CEEC protects the freedom and dignity of workers, prohibits forced labor and any other forms of involuntary labor, illegal detention, slavery, or any arbitrary deprivation of workers' freedom.

- Principle 2: CEEC prohibits the employment of child labor. No one under the age of 16 is allowed to work, and employees under 18 are not permitted to engage in night work, hazardous work, or any work that may affect their education or be harmful to their physical or mental health. If local laws have stricter regulations, those regulations should be followed.

- Principle 3: All employees should be treated fairly and with dignity. Suppliers must not engage in or allow physical, verbal, or psychological abuse or coercion of employees, including threats of violence, sexual harassment, or unreasonable restrictions on access to workplaces and dormitories.

- Principle 4: Suppliers must always adhere to the principles of equal employment opportunities and treatment. Discrimination in employment or treatment based on race, color, gender, age, religion, political opinion, nationality or social origin, disability, or other status is prohibited.

- Principle 5: Suppliers must comply with the labor laws and regulations of the host country, establish legal labor relationships with employees, and provide employees with clear, understandable employment contracts in a language they can understand, specifying the terms, conditions, and other necessary information.

- Principle 6: Suppliers must comply with the labor standards and working time regulations of the host country, provide reasonable wages and overtime pay, work breaks and leave, living facilities, and other working conditions. The wage levels must at least meet the basic needs of employees and their families.

- Principle 7: Suppliers must provide a safe and healthy working environment for their employees, educate employees on safety procedures, and minimize inherent risks in the working environment through physical, technical, and managerial measures to prevent work-related injuries or health damage.

- Principle 8: Suppliers must respect employees' rights to participate in and organize trade unions and engage in collective bargaining, and must not punish, harass, or intimidate employees for exercising these rights lawfully.

- Principle 9: In conflict-affected and high-risk areas, CEEC does not assist or support any party in committing human rights violations, nor does it provide direct or indirect support to non-state armed groups. If suppliers engage in purchasing from or are associated with serious human rights violators, CEEC will immediately suspend or terminate cooperation with them.

- Principle 10: Suppliers must not engage in bribery or any other form of corruption, including offering or providing illicit financial or other benefits directly or through third parties to public officials, individuals, or entities in business relationships with the company.

- Principle 11: Suppliers must establish effective grievance mechanisms and ensure that employees do not suffer any form of retaliation, harm, or damage for using such mechanisms.

- Principle 12: Suppliers must comply with the environmental laws and regulations of the host country, consider the negative impact of their operations on the environment, and take effective measures to protect the environment, minimizing the adverse effects of their operations.

- Principle 13: Suppliers must closely cooperate with their own suppliers to implement the principles set out in this Policy. Suppliers are required to include due diligence and requirements into their policies and risk management systems. If any issues are identified, suppliers should notify CEEC and work with CEEC to resolve these issues and mitigate potential or actual risks or problems.

4. Organizational Framework

CEEC's ESG management framework for international business suppliers includes the following:

a. Consideration of ESG requirements in the screening process for new suppliers.

b. Contracts signed with suppliers must include clauses requiring compliance with this Policy and CEEC’s Supplier Management Measures, and compliance by existing suppliers will be monitored.

c. Regular and ad-hoc reviews and audits.

d. In the event of non-compliance, different measures will be taken depending on the severity and level of the issue. These will be detailed below.

4.1 Selection of New Suppliers

When considering whether to establish a partnership with new suppliers, CEEC screens for any violations of human rights, environmental, or social policies and assesses the risks of forming business relationships with those suppliers. CEEC clearly communicates the content of this Policy to suppliers and includes it as part of the contract.

4.2 Existing Suppliers

For existing suppliers, CEEC conducts due diligence using various channels such as ESG questionnaires, publicly available information, media reports, social media, international organizations, NGOs, expert opinions, and technical documents to identify risks in the supply chain. Existing suppliers will also undergo regular audits. If CEEC receives reports of ESG violations by suppliers, or becomes aware of violations through other means, it will conduct ad-hoc audits.

4.3 Supervision

CEEC regularly audits suppliers’ compliance with ESG requirements, which may include audits of workplaces and employee dormitories and confidential interviews with employees. During the audit process, suppliers must be transparent and allow timely access to their facilities, relevant records, and employee interviews. If any problems or non-compliance are identified during the audit, CEEC will require suppliers to take corrective actions and will monitor the progress of these actions. A follow-up audit will be conducted to assess the effectiveness of the corrective measures.

4.4 Execution/Actions in Case of Non-Compliance

If suppliers encounter minor compliance issues, they must create a remediation plan and implement it within a reasonable and clear timeframe to ensure that the issues are resolved promptly and effectively. If suppliers are unable or unwilling to correct the situation within the agreed time, CEEC reserves the right to suspend or terminate the business relationship. If suppliers are found to have serious compliance violations, CEEC may choose to terminate the business relationship directly. Serious violations include:

a. Refusal to cooperate with audits (e.g., refusing audits, refusing to provide required information for the audit, etc.);

b. Intentionally providing CEEC with false, misleading, or forged documents or information;

c. Serious violations of relevant ESG requirements, such as using child labor, forced labor, or severe violations of environmental protection policies.

All supplier reviews, due diligence, and audits conducted under this Policy will fully comply with relevant applicable laws, such as those regarding confidentiality, antitrust, privacy, and labor laws.

5. Reporting, Awareness, and Training

CEEC will ensure that all personnel responsible for managing CEEC’s international business suppliers are familiar with the content of this Policy, the contract terms with suppliers, and other relevant ESG management matters. When necessary, training will be organized for supplier management personnel.

6. Reporting Procedure

6.1 Complaints and Reporting  

To ensure strict adherence to the above obligations, CEEC has established a comprehensive reporting procedure. Through this procedure, affected individuals, NGOs, and any other stakeholders can submit reports to CEEC, including those related to CEEC suppliers. Reporting channels can be found on our official website (www.ceec.net.cn). The specific details are as follows:

- Mailing address: Petition Office, China Energy Engineering Corporation Ltd., No. 26, Xidawang Road, Chaoyang District, Beijing, China (Postal Code: 100022)

- Hotline: 010-59099938

Reports can be made anonymously, and all reports will be handled with strict confidentiality. CEEC will treat these reports with the same diligence and caution as other forms of reports and will not tolerate any form of retaliation, retribution, harm, or damage resulting from the use of the reporting channels.

6.2 Questions or Opinions  

If any stakeholders have any questions or opinions regarding the content of this Policy, please contact us for more information. Communication can be made through the contact details provided on our website.