CODE OF ETHICS AND CONDUCTS

1. INTRODUCTION TO THE CODE OF CONDUCT

The Code of Ethics and Conduct [“the Code”] sets out the standards on core values and responsible conduct for everyone working at the VAS System. We believe that these core values are crucial to the success of the business, and this responsibility lies not only with the Leadership but also with every member of the organization.

CORE VALUES

We are all required to clearly understand and fully embrace the following principles:

❖ Corporate Culture

Corporate culture is the integration of values, ethical standards, business philosophy, scope of compliance, business ideas, management methods, and rules of conduct that are collectively acknowledged and followed by all members of the organization.

VAS emphasizes human values, aiming at the comprehensive development of its people as the ultimate goal, while contributing to the community and society.

❖ Vision

The aspiration to become one of the leading economic organizations in Vietnam, developing sustainably, delivering the best returns for investors, and providing the best living conditions for all employees.

❖ Business Philosophy

For nearly 30 years of formation and development, the VAS System has never separated from its business philosophy. The philosophy below serves as a compass guiding the sustainable growth of the organization.

✓ Always listen, learn, be creative, improve, and collaborate to bring the best benefits to the company and its partners;
✓ Be transparent, act with integrity, and uphold reputation in business management;
✓ Build a professional working environment that fosters long-term commitment for employees;
✓ Take responsibility toward the community.

❖ Brand

A brand is an asset, a reputation, and the trust of customers and partners in the company. Among these, human resources are the most important foundation for brand development. VAS always considers each employee as a brand ambassador in interactions with customers, partners, and other members.

❖ Integrity

Integrity is our foundation to build trust and to make appropriate judgments in all situations. Integrity means working honestly, diligently, and responsibly.

❖ Objectivity

We must ensure the highest level of objectivity in handling all situations without being influenced by conflicts of interest between individuals, groups, and the company’s benefits, or being pressured to act against the true nature of the matter.

❖ Empowerment

Recognizing that employees are the key factor for success, the company allows individuals to take responsibility for their decisions, while trusting in their actions and results that benefit the company.

❖ Confidentiality

We must respect the value and ownership of received information, and not disclose any information without authorization from competent authorities or when required by law.

❖ Professional Competence

We must perform our work with the necessary knowledge, skills, and experience. Always strive to improve knowledge, skills, and capacity to adapt to changes in the working environment.

❖ Workplace Equality

Provide opportunities and respect for all employees in a safe and supportive working environment that benefits everyone.

❖ Compliance with Law

We must uphold the spirit of respecting the law. Live and work in accordance with the law.

GUIDELINES

❖ Respect everyone
❖ Align with goals
❖ Focus on processes
❖ Ensure quality from the start
❖ Strive for quality
❖ Deliver value to owners

PARTIES REQUIRED TO COMPLY WITH THE CODE OF CONDUCT

All individuals, departments/units, and organizations under the VAS system are required to read, strictly comply with the Code of Conduct, and report to the Company’s leadership any violations of the Code.

We expect all individuals and organizations, including partners, to agree to comply with the Code of Conduct whenever carrying out any work or service for the VAS system.

RESPONSIBILITIES OF THE LEADERSHIP

The leadership of the VAS system – including the Members’ Council | Board of Directors, the Executive Board, and heads of departments/units of member companies – are especially responsible for thoroughly understanding, practicing ethical conduct, and adhering to the core principles of this Code of Conduct.

Leaders must set an example, establish an absolute spirit of compliance, and must not overlook any suspected or potential violations of the Code of Conduct, regardless of how minor they may seem. At the same time, the highest-level leadership and the Audit Division must be promptly informed of any suspicions of potential violations of this Code so that the VAS system can take appropriate corrective actions.

RESPONSIBILITIES OF THE AUDIT DIVISION

The Audit Division, authorized by the VAS Chairman, is responsible for communicating the contents of this Code of Conduct, thoroughly disseminating them throughout all activities of each individual,  department, and unit within the VAS system. Independence, objectivity, and integrity are fundamental principles to ensure that the Audit Division fully fulfills its assigned mission in a fair, transparent, and unbiased manner.

VIOLATION OF THIS CODE

The VAS system will apply disciplinary measures to actions that do not comply with the Code of Conduct, including termination of labor contracts. In addition, without exception, contractors, consultants, individuals, and other organizations may be suspended from work or from providing services if they fail to comply with this Code of Conduct.

REPORTING NON - COMPLIANCE WITH THE CODE OF CONDUCT

All of us have a responsibility to report any suspected signs of potential violations of the Code of Conduct, company policies, or legal regulations. Information can be sent directly or indirectly to the Company’s Board of Management, the Audit Division, or through other reliable sources. Such reports will be forwarded to the Board of Management to ensure timely disciplinary or corrective action.

NON - RETALIATION POLICY

It is important that everyone feels safe when raising questions and concerns. The company will take all questions, concerns, and issues seriously, confidentially, and in compliance with the non-retaliation policy. Any retaliatory actions against suppliers or individuals who raise concerns in good faith will not be tolerated. Good faith means reporting honestly, sincerely, and based on accurate facts. Conversely, providing false or misleading information that harms the reputation or credibility of individuals or organizations will be considered a violation of the Code of Conduct.

2. BEST ACTIONS FOR THE BENEFIT OF THE VAS SYSTEM

RECOGNIZING AND AVOIDING CONFLICTS OF INTEREST

Conflicts of interest may potentially arise when the interests of an individual or organization affect thecommon interests of the System. We must avoid conflicts of interest so they do not cause difficulties inperforming work objectively and making sound decisions. If there is any potential or actual conflict of interest, the individual is responsible for immediately reporting it to their direct supervisor or the designated point of contact.

RELATIONSHIPS IN THE WORKPLACE

Overly close personal relationships with others in the workplace can create risks of improper behavior or unprofessionalism, especially if involving colleagues in positions of control, influence, or decisionmaking over another’s work. Friendships or close relationships must not influence fairness and objectivity, and must avoid conflicts of interest. Such relationships should be transparently reviewed and assessed to ensure compliance with standards.

BUSINESS RELATIONSHIPS

We must not have any interests or private business relationships with any suppliers, agents, customers, or competitors of the VAS System. Such interests or relationships may influence decision-making related to activities that negatively impact the organization’s interests.

OUTSIDE ACTIVITIES

We must not work for or provide services to any third party that may compete with or supply goods and services to the VAS System. At the same time, all outside work must be disclosed so that the Management Board has the basis to properly arrange personnel for each specific position or project, ensuring that no conflicts of interest exist during implementation.

PROTECTION OF ASSETS AND INFORMATION

❖ Physical Assets

To perform our work, we need access to appropriate resources, including equipment, facilities, vehicles, materials, and goods of the VAS System. These resources are only to be used for authorized activities. We are all responsible for protecting these assets from loss, damage, theft, misuse, and waste.

❖ Intellectual Property

We are also responsible for identifying, managing, and protecting the intellectual property of the VAS System. Intellectual property includes patents, trademarks, copyrights, trade secrets, processes, and production know-how. All intellectual property created during work belongs to the organization and must not be used for personal purposes. In addition, we must respect the intellectual property of others, including competitors, and not infringe upon their rights.

❖ Confidential Information

Confidential information is data that ensures the VAS System maintains its competitive business advantage and could be harmful if disclosed externally. Confidential information includes financial data not publicly available, technical data, proprietary software, and personal information about customers or suppliers. It also includes information collected from third parties that we are obligated to keep confidential. We are entrusted to protect confidential and sensitive information at all times and in all places.

If we lose devices, documents, or any items containing confidential information of the VAS System [e.g., laptops, mobile phones, or storage devices], we must immediately report to the IT department or our direct manager for appropriate protective measures.

MEDIA AND SOCIAL NETWORKS

Media has changed the way we share information, and these actions can create new opportunities but also bring responsibilities and risks.

Social networks include Facebook, Twitter, blogs, image-sharing sites, videos, forums, chat rooms, and many other platforms. If the Company requires us to post on these networks, we may only share information that complies with regulations. In personal interactions on media and social networks, we must be extremely careful to protect the reputation and confidential information of the VAS System.

EXTERNAL COMMUNICATIONS

The way we communicate with the public is very important – it must be honest, accurate, and consistent. Public information about the VAS System is the responsibility of senior management and authorized spokespersons. We are all responsible for ensuring that information not authorized for disclosure is not shared on news sites, media channels, or any other forums that may lead to the release of Company information. We are not allowed to disclose information about the organization unless authorized to do so. If this rule is violated, it may cause damage to the Company’s reputation or interests. All media requests or inquiries must be directed to the Company’s Management.

PROPER USE OF ASSETS

We must also use assets, including production equipment, computers, telephones, and information systems, in a legal, appropriate, and efficient manner. The use of these assets for personal purposes must be limited, reasonable, and not affect our ability to perform work or violate the policies of the VAS System or legal regulations. We must return all assets or equipment when work assignments are completed or upon termination of employment with the VAS System.

3. COMMITMENT TO EMPLOYEES

EQUALITY AND RESPECT IN THE WORKPLACE

Each of us plays an important role in creating a work environment that actively promotes fairness and mutual respect. The VAS System highly values dedicated and energetic employees, who, through their daily efforts, create superior value for customers, owners, and business partners. The diversity of skills and perspectives of each individual helps us better understand customer needs and adapt to the everchanging business environment. By working together, we ensure that our workplace remains one of commitment and effectiveness.

We are committed to maintaining a workplace free from any form of unlawful discrimination and in compliance with all current labor regulations. Furthermore, the VAS System is an organization that values equal employment opportunities and makes all employment-related decisions based on the individual’s abilities and the requirements of the position.

We are committed to equality throughout all stages of employment, including recruitment, training, promotion, compensation, benefits, transfers, termination, and other opportunities based on performance.

PRIVACY IN THE WORKPLACE

We are all responsible for protecting privacy and ensuring the confidentiality of personal information that individuals provide or that is collected about them. We must respect the principle that confidential information does not include data owned by the VAS System but refers only to personal information in the workplace.

Personal information may include names, phone numbers, addresses, email addresses, identification numbers, passport numbers, or any information linked to an identifiable individual.

We only collect, access, or use personal data for lawful and legitimate purposes. We may not disclose this information to anyone, inside or outside the Company, without proper authorization. Additionally, we must comply with legal requirements and internal policies to prevent unauthorized access to personal data.

HARASSMENT AND INTIMIDATION IN THE WORKPLACE

Everyone has the right to work in a safe and respectful environment, free from harassment or intimidation. Any inappropriate behavior, harassment, or threats that damage the dignity, values, and direction of the organization are strictly prohibited.

We do not tolerate any form of harassment or intimidation in the workplace, including verbal, written, visual, or physical conduct that harms or demeans others. Sexual harassment and any form of harassment based on gender, race, religion, or other characteristics are absolutely prohibited. Offensive language and behavior are strictly forbidden.

WORKPLACE SAFETY

Promoting and maintaining a safe workplace is essential. Therefore, all aspects of our operations must be carried out in compliance with laws, applicable regulations, industry standards, and company policies related to occupational safety. Our goal is to prevent harm to employees’ health and safety. We never compromise on safety and compliance in exchange for productivity or business results.

All employees are expected to understand and comply with legal requirements and workplace safety regulations applicable to their work area. Following these requirements helps ensure that we do not put ourselves or others at risk. If any unsafe working conditions, damage, or occupational illness related to work are discovered, they must be reported immediately to management or the Safety Committee.Everyone is encouraged to report errors or suggest improvements to enhance our safety programs.

In addition, we are responsible for ensuring that facilities remain secure at all times. This means that we may only access facilities with proper authorization. If we believe someone is attempting to access a part of the VAS System without permission, or if we suspect any illegal or unsafe activity, we must promptly report it to the Security Department or relevant authorities.

WORKPLACE VIOLENCE

All employees have the right to work in a safe environment, without fear or threats of violence. To ensure employee safety, the possession of firearms, explosives, or other dangerous weapons is strictly prohibited within workplace premises.

All threats and acts of violence must be reported to a manager, supervisor, human resources representative, or the security department. In cases where someone is believed to be in immediate danger, we must contact the local law enforcement authorities.

Any act of violence or threat against employees or colleagues is strictly prohibited. All threatening or violent behavior will be subject to investigation, and appropriate disciplinary actions, including termination of employment, will be enforced. Threats or violent acts may manifest in various forms, including:

❖ Direct or indirect threats, whether written or verbal, intended to cause harm or injury;

❖ Words, gestures, or shouting that cause emotional distress or physical injury;

❖ Stalking an individual;

❖ Physical intimidation or assault.

SUBSTANCE ABUSE AND ALCOHOL IN THE WORKPLACE

As part of the organization’s commitment to maintaining a safe and healthy work environment, that prohibits the abuse of illegal substances and alcohol beverages. Being under the influence of such substances may impair performance and violate established safety standards. The use, solicitation, sale, or possession of illegal substances within workplace premises is strictly prohibited.

The consumption of alcoholic beverages on workplace premises is prohibited unless explicitly authorized by the Company’s Management Board. If permitted, alcohol consumption must be conducted responsibly, including off-premises. Violations of this policy will result in disciplinary action, up to and including termination of employment.

4. COMMITMENT TO OWNERS

FINANCIAL REPORTING AND DISCLOSURE

Owners entrust us to maintain accurate and complete corporate books and records, which are critical for evaluating operations and making significant business decisions.

The Board of Directors, Chief Accountant, Audit Division, and accounting personnel are required to understand and comply with accounting policies and applicable financial laws and regulations. Periodically, member companies must submit financial statements and other documents to State regulatory authorities, and we are responsible for preparing and submitting these reports in accordance with legal and regulatory requirements. It is imperative that these reports are prepared with honesty, accuracy, and promptness.

The integrity of financial statements is critically important. Accounting and financial reporting regulations must be fair, reasonable, and compliant with generally accepted accounting principles.

Financial statement fraud is strictly prohibited. Although it is challenging to provide a comprehensive definition of financial statement fraud, in general any intentional act or non-compliance, whether by omission or by commission, that results in a misstatement or an unreasonable presentation of financial statements may be considered fraudulent. Transparent, coherent, and continuous communication between management and employees regarding financial and operational matters significantly reduces the risk of issues in accounting and financial reporting while supporting the achievement of operational objectives.

RECORD KEEPING

We are obligated to maintain comprehensive records to ensure a true and accurate reflection of the organization’s financial position. Records may be stored in paper or electronic format and must include all legal, financial, accounting, tax, personnel, and other documentation as required by the organization’s internal policies and applicable laws.

AUDIT ACTIVITIES

All employees are responsible for cooperating with both internal and independent auditors. Individuals, departments, and organizations must provide auditors with the information they are authorized to access. If there are questions or a need for clarification regarding the information to which auditors are permitted access, we may seek guidance from the Management Board before complying such requests. Strict adherence to the VAS System’s confidentiality policies is required.

We must not engage in actions to coerce, mislead, distort, or unduly influence auditors involved in auditing or reviewing financial statements. Prohibited actions include any direct or indirect conduct that an individual knows or should reasonably know could result in an inaccurate audit report or material misrepresentation of information in financial statements.

ANTI - CORRUPTION AND BRIBERY

All transactions with customers, suppliers, and business partners must be impartial, objective, and free from personal interests or external coercion. We will neither offer nor accept illicit payments. Illicit payments may include cash, gifts, favors, remuneration, travel, entertainment, or other valuable assets used as tools for bribery, kickbacks, or inducements. Such payments expose the Company and individuals to risks, including potential legal violations.

If anyone requests or suggests a bribe, kickback, or inducement, it must be firmly rejected, and the incident must be immediately reported to the Company’s Management Board. Likewise, no one may request or coerce others to pay bribes, inducements, or kickbacks for personal gain, nor ignore signs that someone may be engaging in such misconduct. If there is belief or evidence that someone is offering or accepting illicit payments on behalf of the Company, it must be reported immediately to the Management Board.

In exceptional circumstances where an individual’s health or safety, or that of their loved ones, is threatened unless illicit payments are made, the health and safety of employees and their families are the Company’s priority. As this Code cannot anticipate every scenario, employees must use their best judgment to prioritize their health and safety, even if it involves making an illicit payment. Any such incident must be immediately reported to the Management Board, with an explanation of the circumstances leading to the situation.

GIFT - GIVING AND RECEIVING POLICIES

Maintaining and fostering positive business relationships with customers, suppliers, and partners is critical to the organization’s growth. Reasonable gifts or benefits are courteous exchanges that promote goodwill and strengthen relationships. However, giving or receiving gifts or benefits may create the perception that business decisions are influenced by factors other than fair and objective business criteria. Therefore, we must exercise caution and thorough consideration when giving or receiving gifts in a business context.

We are responsible for ensuring that any gifts or benefits given or received are appropriate and comply with the VAS System’s policies. Avoid gifts or benefits that may compromise, or appear to compromise, the objectivity of the parties involved. Ensure that giving or receiving gifts or benefits does not influence critical decisions. Consult the Company’s Management Board when considering whether to give or receive gifts or benefits to ensure compliance with organizational policies.

Giving or receiving gifts or benefits in a business context raises legal and ethical concerns when done with expectations of reciprocity. We will not suggest or require anyone to provide gifts or benefits in exchange for business opportunities with the Company. Gifts or benefits should not be exchanged during contract negotiations, as they may influence business decisions or undermine the fairness of negotiations and business relationships. Cash or loans must never be given or received as gifts under any circumstances. If uncertain about whether to give or receive a gift or benefit, employees must 

5. COMMITMENT TO CUSTOMERS, SUPPLIERS, AND COMPETITORS

GENERAL PRINCIPLES

The VAS System values fairness, transparency, and integrity in all relationships with those we collaborate with, including customers, government agencies, suppliers, distributors, and competitors. We choose to work with those who, like us, operate with integrity and uphold high ethical standards. We are committed to avoiding and not tolerating any form of forced or bonded labor in our supply, production, or distribution chains. We comply with labor laws in the jurisdictions where we operate and expect our partners to do the same. Our business activities must not intentionally harm individuals, communities, or support human rights violations. We strive to protect the environment and expect our partners to act similarly.

PROVIDING QUALITY PRODUCTS AND SERVICES

We are dedicated to delivering high-quality products to our customers. To achieve this, we adhere to internal and external quality control standards governing our business activities, emphasizing safety throughout the product manufacturing process.

RELATIONSHIPS WITH CUSTOMERS

All transactions with current and prospective customers must be fair, transparent, and lawful. The VAS System has built a strong reputation with customers over the years through ethical, high-quality, reliable, and safe products that meet their needs.

RELATIONSHIPS WITH SUPPLIERS

Decisions to procure goods and services from suppliers must be based on quality, service, price, and suitability. The VAS System seeks to establish mutually beneficial, long-term relationships with suppliers based on these factors. We must not accept or expect personal benefits from business transactions with suppliers. We value supplier relationships and aim to procure the best goods and services at competitive prices. Accordingly, we hold suppliers and business partners accountable for the quality and pricing of their products and services.

We are responsible for avoiding conflicts of interest or reporting any perceived conflicts when selecting or purchasing from suppliers. We expect all suppliers to comply with this Code’s provisions on labor, human rights, health and safety, the environment, and fair competition. If we know or suspect a supplier is violating policies or laws, we must immediately notify the Company’s Management Board.

RELATIONSHIPS WITH DISTRIBUTORS AND SALES AGENTS

Our distributors and sales agents are integral to the VAS System’s operations. We acknowledge that distributors are independent businesses and sales agents are not our employees, and we must treat them accordingly. We expect distributors and sales agents to understand and comply with all applicable laws and this Code. If concerns arise about a supplier or sales agent, contact the Management Board of the member company to address those concerns.

FAIR COMPETITION

We believe fair competition benefits businesses, customers, suppliers, distributors, sales agents, and the market. Under no circumstances do we tolerate offering or accepting kickbacks, illegal bribes, or similar illicit payments in exchange for business transactions. We uphold fairness by gathering competitive information through honest and lawful means. If a new employee joins the VAS System from a competitor, we welcome the joining into the workforce but do not accept any confidential information they may have about their former employer’s business. Likewise, we must protect sensitive and confidential competitive information, even after leaving the VAS System.

PROTECTING CUSTOMER INFORMATION

Customers may share confidential information with us to enable us to provide the best goods and services. It is our responsibility to use, store, and protect this information securely in compliance with all applicable legal regulations. We must take necessary steps to safeguard customer information and ensure it is used solely for approved business purposes.

6. COMMUNITY RESPONSIBILITY

MINIMIZING ENVIRONMENTAL IMPACT

We prioritize environmental protection and endeavor to safeguard the environment through our operational processes. We ensure that the workplace is energy-efficient, stable, and environmentally sustainable while complying with legal regulations in the regions where we operate. We dedicate significant resources and important efforts to designing and producing high-quality products that meet customer needs in the most effective and efficient manner. Alongside these efforts, we develop products that adhere to environmental regulations, minimize environmental impact, and promote sustainable use of natural resources. The VAS System complies with Vietnam’s environmental protection laws and regulations. All activities must consider environmental impacts and risks when making business decisions, and it is essential to establish an environmental management system.

POLITICAL, RELIGIOUS, AND CHARITABLE ACTIVITIES

The VAS System and its employees are committed to supporting community programs through financial and other contributions. Employees are free to participate in political, religious, and charitable organizations as individuals based on their personal choices, provided they do not represent the views or actions of the VAS System. When engaging in community activities, we must not use the Company’s confidential information, commercial secrets, or data from customers or suppliers.

Personal external activities must not interfere with job performance at the VAS System. No employee is allowed to coerce others to participate in or support any actions contrary to their personal beliefs regarding political, religious, or charitable events.

7. ENFORCEMENT

This Code of Conduct takes effect from the date of issuance.

All individuals and entities within the VAS System must comply with the provisions outlined in this Code.

Any amendments or supplements to this Code require review and approval by the VAS Chairman.

During performing assigned duties, if we encounter situations that may require us to take actions that violate the provisions of this Code of Conduct, we are responsible for immediately reporting such situations to the Company’s Management Board before taking any action, to ensure that the Company’s interests are always prioritized.

Any individual or entity violating the provisions of this Code will face disciplinary action based on the situation and severity of the violation, in accordance with the labor regulations of the member companies.

HUMAN RIGHTS STATEMENT

COMMITMENTS AND PRINCIPLES

1. Human Rights Declaration

At VAS Group, we believe that the greatness of a business is not only measured by financial figures but also by its steadfast commitment to human dignity. Guided by the philosophy of “Steel Spirit, Strong Heart”, we declare: Respect for Human Rights is an inviolable principle and a core foundation in every decision and action of VAS Group.

This Human Rights Declaration is our formal commitment to building a safe, fair workplace and a sustainable value chain where every individual is treated with respect and fairness.

2. Management Principles

We are committed to complying with and going beyond internationally recognized human rights standards, including the Universal Declaration of Human Rights [UDHR], the United Nations Guiding Principles on Business and Human Rights [UNGPs], and the core conventions of the International Labour Organization [ILO].

These principles are embodied in our Code of Ethics and Conduct [2nd issuance, May 24, 2019] and serve as the compass for VAS Group's People-Centered philosophy.

ORGANIZATIONAL STRUCTURE AND RESPONSIBILITIES

To ensure that Human Rights commitments are implemented consistently and responsibly, VAS Group has established a strict management structure aligned with the Organizational Chart issued under Decision No. 028A/QĐ.22/VASG-HĐQT.

Human Rights Management Council: A dedicated body consisting of leadership representatives from the following Divisions | Departments:

• Human Resources Division [Headed by HR Director]

• Legal Department [a qualified representative, preferably a licensed lawyer].

• Safety Standards Department [a representative from the Technical Division].

• Employee Representatives [the Union Chairperson and two randomly invited employees to ensure objectivity].

The Council is responsible for strategy development, oversight, and promotion of human rights initiatives across the Group.

• Implementation Unit: The Human Resources Division serves as the standing unit responsible for daily activities: including training organization, consultation handling, and initial investigation of harassment or discrimination cases.

• Reporting and Monitoring Mechanism: The Human Rights Management Council reports quarterly to the Executive Board on activities, due diligence results, and complaint handling. Strategic issues, critical risks, and annual summary reports are presented to the Board of Directors to ensure top-level oversight and guidance.

OPERATIONAL AND IMPLEMENTATION SYSTEM

1. Fostering a Culture of Respect for Human Rights

We believe that building a culture of respect for human rights must start with individual awareness and be reinforced by consistent systems.

• Employee Commitment: All employees, including temporary staff, are required to make an annual electronic pledge of ethical conduct and mutual respect when re-signing internal regulations and the “Code of Ethics and Conduct.”
• Mandatory Human Rights Training: Training programs are compulsory for all employees, including: 
  • In-person training on human dignity, labor rights, and content from the Code of Conduct.
  • Online modules on workplace harassment prevention and anti-discrimination
• Awareness Campaigns: Internal communication campaigns are periodically conducted on specific human rights topics and disseminated through company channels.

2. Human Rights Due Diligence [HRDD]

VAS Group systematically implements HRDD to proactively identify, prevent, and mitigate negative human rights impacts arising from its business operations.

2.1 VAS Human Rights Assessment Framework [8 Focus Areas, 30+ Indicators]:

• Management System Establishment

• Prohibition of Discrimination

• Ensuring Freedom of Association

• Prohibition of Forced Labor

• Prohibition of Child Labor

• Ensuring Health & Safety

• Preventing Harassment

• Supply Chain Management

2.2 Due Diligence Process:

• Risk Identification & Assessment: Based on the Assessment Framework, we use methods such as anonymous surveys, in-depth interviews with employees and managers, HR document reviews, and dialogues to identify and assess actual and potential risks.

• Remedial & Preventive Actions: For units with low scores or high risks, we conduct on-site inspections, root-cause analysis, and propose targeted improvements such as policy revisions, specialized training, or awareness campaigns.

• Monitoring & Supervision: The effectiveness of improvements is periodically monitored and evaluated to ensure risks are thoroughly addressed.

• Reporting & Communication: HRDD results are reported to top management and transparently communicated to stakeholders.

3. Grievance and Remediation Mechanism

We operate safe, confidential, and accessible grievance channels, enabling all individuals to report concerns without fear.

3.1 Response Process

3.2 Remedial Measures and Victim Support

• Confidentiality Agreement: All involved parties must sign a confidentiality agreement.

• Comprehensive Support: Upon request, victims receive legal support from the Legal Department, medical cost coverage, and psychological counseling arranged with professionals.

• Anti-Retaliation: Any retaliation against complainants or victims is strictly prohibited and subject to disciplinary action under the “Code of Ethics and Conduct.”

4. Training and Awareness Raising

We believe that fostering a culture of human rights respect begins with individual awareness.

• Employee Commitment: All employees, including temporary staff, must renew their annual electronic commitment to ethical behavior and mutual respect.

• Mandatory Training: All employees must complete online anti-harassment modules and in-person training on human dignity and labor rights.

• Awareness Campaigns: Regular internal communication campaigns on specific human rights themes are widely disseminated via company channels.

MONITORING AND CONTINUOUS IMPROVEMENT

Sustainable development is a never-ending journey. We are committed to continuous improvement through clear and measurable objectives.

Human Rights Governance Targets for 2025 – 2027

STAKEHOLDER IDENTIFICATION TABLE

I. EXTERNAL INTERESTED PARTIES

II. INTERNAL INTERESTED PARTIES

GUIDELINES

FOR RISK AND OPPORTUNITY ASSESSMENT

I. GENERAL PROVISIONS

1. PURPOSE

Provide standardized guidance on responsibilities, procedures, and methods for reviewing risks and opportunities related to activities at VAS Group Nghi Son Joint Stock Company, with the aim to:

• Ensure the quality management system operates effectively.
• Enhance opportunities to achieve the company’s objectives and targets.
• Prevent or reduce undesired impacts and potential errors within the activities of the quality management system.
• Achieve continual improvement within the system.

2. SCOPE OF APPLICATION

• This guideline applies to all departments and units involved in the activities of the quality management systems at VAS Group Nghi Son Joint Stock Company.

3. REFERENCE DOCUMENTS

• ISO 9001:2015 – Quality Management Systems.
• ISO | IEC 17025:2017 – General requirements for the competence of testing and calibration laboratories.
• ISO 14001:2015 – Environmental Management Systems.
• ISO 45001:2018 – Occupational Health and Safety Management Systems.
• TCVN 31000:2018 – Risk Management – Guidelines.
• TCVN 31000:2013 – Risk Management – Risk Assessment Techniques.

4. ABBREVIATIONS

5. EFFECTIVENESS

• This guideline shall take effect from the date of issuance.
• Any non-compliance or violation of any provision of this guideline will be handled in accordance with the Company’s Labor Regulations and applicable laws.
• Any amendment, supplementation, or annulment of this guideline must be approved by the Board of General Directors [BTGD].

II. CONTENT

1. FLOWCHART

2. EXPLANATION

2.1 RISK ASSESSMENT CONTENT:

2.2 ESTIMATION LEVELS:

• The formula for quantifying Risk and Opportunity Levels is as follows:
  • For Risks

                                                 RR = K1 x H

Where:

                           RR: Risk Level      

 K1: Probability of occurrence

                                       H: Impact consequence when occurring

• For Opportunities

CH = K2 x L

                             Where:

CH: Opportunity Level        

K2: Opportunity feasibility

L: Level of opportunity benefits

• With five application levels assigned to the factors K, H, and L in the above formulas, their products shall be classified into selected ranges for evaluating risk and opportunity levels.

Table 1a- Likelihood of Occurrence

Table 1b- Opportunity Feasibility

Table 2a- Consequence Level

Table 2b- Level of Opportunity Benefits

• After determining the K and H factors, apply the Risk and Opportunity Level Quantification Formula and refer to the Risk and Opportunity Level Correlation Table below:

                                           For Risks:                    RR = K1 x H

                                           For Oppotunities:       CH = K2 x L

Table 3- Risk Level Evaluation

• Thus, with four distinct color zones, the Risk & Opportunity Levels can be categorized into the following groups:
  • Very high [Red 15-25]
  • High [Yellow 8-12]
  • Medium [Green 3-6]
  • Low [Blue 1-2]
• For reviewing risk treatment and opportunity exploitation, the levels of risks and opportunities may be classified as shown in Tables 4a and 4b below:

Table 4a- Risk Treatment Priority Levels

Table 4b - Opportunity Exploitation Priority Level

3. FORMS

PRODUCT TRACEABILITY STATEMENT

Date 01st Jan 2026

At VAS Group – VAS Steel, we ensure that all sourcing information is managed and made available in a clear and transparent manner, enabling customers to trace the origin of the components used in our products.

To enhance transparency and quality control, each production batch of billet and rebar is assigned a unique charge | heat number. Upon delivery, customers are provided with a Material Test Certificate [MTC], which includes full details on chemical composition, mechanical properties, and production origin. Through the heat number, the complete production history of the product can be traced.

In addition, VAS Group – VAS Steel attaches a product label to each bundle, displaying comprehensive product information and traceability data, ensuring identification and traceability throughout the supply chain. The company is progressively implementing digital traceability solutions, such as QR codes and internal data management systems, to improve accuracy and accessibility of information.

Through these measures, VAS Group – VAS Steel enables customers to confidently trace the origin and production history of its products, thereby enhancing transparency, building trust, and meeting industry standards as well as certification requirements such as CARES.

Note: Raw materials are sourced from multiple suppliers and accumulated at the same location. During production, the plant uses raw materials randomly based on operational conditions; therefore, it is not possible to determine exactly which scrap has been used for each specific production batch.