Sabre

Code of Conduct

Sabre Code of Conduct

Knowing that the product we produce brings effective, efficient, economic and modern technology to a relatively untouched industry to others with an eye for the future, is a source of great pride and satisfaction. But with this privilege comes responsibilities: as employees and directors of Sabre we must maintain high ethical standards, meet social compliance expectations, and consistently deliver a safe and trusted product, while returning value to our shareholders. To meet these goals requires daily effort and focus. To maintain our reputation and high standards, we must work hard to make good decisions; and we must never lose sight of the fact that the choices we make can have an impact on many others our customers and also our fellow employees, shareholders, and our community. To help us make good choices, our Code of Conduct (“Code”) is designed to serve as a resource when we need additional information about policies and standards, or when we need help to address a difficult ethical situation. Our Code covers many of the ethics and compliance topics that we are likely to face in our work, but no code can cover every possible situation. That is why it is important to remember that you have other resources in addition to our Code that can help make good decisions.

· The most important resource is you. Rely on your experience and good judgment in our business dealings. But remember, in order to make informed decisions you must know and understand the policies, standards and rules — especially those that apply to your job within Sabre.

· If you have a question or concern, talk to your co-workers, your manager, any member of management or use one of the resources listed in our Code.

Since we operate globally in many countries around the world, there may be times when laws and customs conflict. Whenever there is a conflict or a difference between a legal requirement and our Code, we will apply the strictest standard. Who must follow our Code Our Code applies to all employees of Sabre, regardless of position. Our Board of Directors and certain business partners serve as an extension of Sabre and their conduct can have an impact on our Company. They, too, are expected to follow our Code as well as any applicable contractual provisions when working on behalf of Sabre. If you are in a position to supervise our business partners, you are responsible for ensuring that they understand our ethics and compliance standards. We expect all our contractors and their employees to act in a way that is consistent with our Code. We will take the appropriate measures where we believe they have not met our high standards or their contractual obligations. Employee responsibilities:

· Act in a professional, safe and ethical manner that is consistent with Sabre’s values.

· Be familiar with the information contained in our Code as well as applicable laws and company policies. Pay particular attention to the policies that pertain to your job responsibilities.

· Promptly report concerns about possible violations of laws, regulations, our Code or policies to your manager or to any of the resources listed in our Code.

· Fully cooperate when responding to an investigation or audit.

· Remember: pressure or demands due to business conditions are never an excuse for violating the law or our Code.

Sabre Helpline:Shandong, China+86 132 8061 3915OR WRITE [email protected] Asking questions or raising concerns Each of us has a responsibility to help protect the reputation and integrity of Sabre. If you see or suspect any illegal or unethical behavior — whether it relates to you, your manager, a business partner, or anyone else — or if you have a question or need help making an ethics or compliance decision, you have several options. You can contact any of the following at any time:

· Talk it through with your manager.

· Discuss it with any other member of Sabre management. We have an open-door policy, which means you can contact any management personnel with whom you feel comfortable, the Legal Department, or the Human Resource Department.

· Telephone the Sabre Helpline at +86 132 8061 3915 or contact [email protected]

· Report any urgent problems (i.e. safety or health hazards) locally in order to obtain the fastest response.

· You may also report a concern regarding any accounting, internal accounting control, or auditing matters directly to the Audit Committee of the Board of Directors:Chair, Audit Committee Board of DirectorsSabre P.O Box 342 Zibo City, Shandong, China

· In addition, should you have specific concerns, and are uncomfortable with any of the resources above, you may directly contact the Chief Legal Officer:Chief Legal OfficerP.O. Box 454 Zibo City, Shandong, China 

Sabre is committed to investigating potential violations and will deal with each report fairly and reasonably. Remember: an issue can only be addressed if it is brought to someone’s attention. Using the Sabre Helpline The Sabre Helpline is a confidential way to get answers to your questions and concerns about ethics. You may contact the Sabre Helpline 24 hours a day, 7 days a week; if your call goes into voicemail, you may leave a message. Employees or customers, partners, may choose to remain anonymous when reporting concerns and we will protect that anonymity to the extent permitted by local law. When an employee contacts the Helpline, the operator will listen to the concern or question, ask clarifying questions if necessary, and then write a summary report of the call. The summary will then be provided to Sabre leadership for assessment and further action, if necessary. Any report made to the Helpline will be kept confidential, to the extent possible, and will remain consistent with the law and good business practices. We will not tolerate retaliation Sabre does not tolerate retaliation against anyone for raising or helping to address an ethics or compliance concern. We consider acts of retaliation to be acts of misconduct. Threats, intimidation and violence undermine everything we stand for as an ethical company and will not be tolerated. If you think that you or someone you know has suffered retaliation, contact the Helpline or the Legal Department. Making the right choice — guidelines for ethical decision-making Making the right decision is not always easy. There may be times when you are under pressure or unsure of what to do. Always remember that co-workers and management are available to help but if you are not comfortable, you may contact the Legal Department, the Human Resource Department, or any of the resources listed in our Code. When faced with a difficult decision, it may help to ask yourself these questions:

· Is it legal?

· Is it consistent with our policies, our values, and our Code?

· Have I considered all of the possible options?

· Have I thought through the consequences and the risks involved?

· Would I still be comfortable with the decision if someone found out about it?

If the answer to any of these questions is “No,” or if you are uncertain, stop and ask for guidance. strong>Accountability Violations of laws, our Code or other Company policies may result in disciplinary action up to and including termination of employment. Certain actions may also result in legal proceedings, or penalties against the Company and possibly you. Waivers and exceptions No part of our Code can be waived without prior written approval from the Chief Legal Officer or Board of Directors. Waivers will only be granted in exceptional circumstances and all appropriate reports and disclosures will be made. Our Code does not alter the terms and conditions of employment or create a contract of employment.