Code of Business Conduct and Ethics

                                                                                       Code of Business Conduct and Ethics 

This Code of Business Conduct and Ethics (the “Code”) contains general guidelines for conducting the business of Camelot Technology Co., Ltd. and its subsidiaries and affiliate entities (collectively, "Camelot" or the “Company”). Directors and officers shall lead by example to help and promote the understanding and application of this Code. All Camelot employees shall observe and practice this Code. Employees shall consult senior management or the HR department regarding any questions or objections to the Code.

                                                                                                         General Guidelines

Dedication

Established in 1994, Camelot has advanced into a world-class IT service provider, focusing on high-end business solutions. Our extensive service network covers mainland China, Hong Kong and Japan, providing technical services to the world's top 500 enterprises and financial institutions. Camelot employees shall maintain strong professionalism in their work and duties and a sense of pride and loyalty to Camelot, and strive for excellence and dedicate to their work duties.

Integrity

The integrity of our employees is the cornerstone of Camelot's reputation. Camelot employees shall act and perform their contractual duties, as set forth in the employment contract, in good faith. Camelot employees shall ensure all work material and information being handled or provided are true, accurate, and complete. Employees are prohibited to alter, forge, conceal or destroy any, in all or part, of the original artifacts thereof. Camelot employees shall truthfully report their work duties to supervisors. When required, Camelot employees shall not provide false information regarding their identity or personal information.

Conscientiousness

Conscientiousness is the fundamental way for employees to progress their career. In accordance with the Code and Camelot's policies and procedures, employees shall perform their work duties diligently. Employees shall scientifically manage time and continuously improve efficiency of their work. Employee shall not neglect or delay their work duties, handle work beyond the scope of authority, nor argue with each other. In the case of rotation or change of post, all product of work shall be properly transferred. Employees shall not take Company assets, product of work, and client information upon leave without authorization. Shirking is strictly prohibited.

Compliance

Any violation of the Code may bring risks to Camelot. Employees shall maintain a level of legal and compliance awareness, and understanding of compliance requirements relevant to their role and duties, highest ethical standards. Under no circumstances should employees pursue personal interest at the expense of Camelot or the Code.

                                                                                                     Policies and Procedures

Confidentiality

Camelot employees shall be on guard for any state or business secrets that may be acquired during their involvement. Employees shall protect client information and transaction information. In case of a breach, employees shall follow relevant protocols to remedy and report to their supervisor immediately. Employees are strictly prohibited to pursue personal interests by using any state or trade secrets and client information that may be obtained at work. Employees are not allowed to accept public media interviews and/or distribute or release company management information without authorization.

Conflict of Interest

Camelot employees shall be on guard and avoid any behavior or performance that may cause a conflict between personal and Camelot's interests. Employees are not allowed to engage in credit granting, capital transaction, asset disposal, procurement, infrastructure projects, nomination, selection, or appointment of management positions with any Affiliated Parties. Employees are prohibited to seek personal gains from the benefit of their position to facilitate investment, operations, transactions, and any other activities. Employees are not permitted to seek part-time jobs or remuneration in other for-profit organizations without the Company's authorization. In case of potential conflict of interest, employees shall report to their supervisor to request approval. Employees who are unsure whether their actions constitute a conflict of interest or have questions about how to handle a conflict of interest should seek professional support from the company's internal operations management department.

Client Relations

Camelot employees shall respect all customers and ensure the quality, professionalism, and efficiency of services rendered to Camelot's customers to establish a long-term cooperative relationship between Camelot and its customers.

Camelot employees shall handle customer complaints and provide feedback promptly.

Fair Transaction

The Company’s business conduct is founded on the principle of “fair transaction.” Therefore, no employee may receive kickbacks, bribe others, or secretly receive commissions or any other personal benefits. Employees are not permitted to use any improper means to solicit business, and/or slander competitors. Bribery of any kind to customers, partners, regulators and their staff strictly is strictly prohibited.

Discipline and Anti-Corruption

Camelot employees shall strictly adhere to anti-bribery laws and regulations. Employees shall not accept or give gifts without written permission from the Company. Employees may not consume high-end entertainment of any form on the Company's funds. Banquets or gifts of any form are not allowed between superiors and subordinates. Staff meetings, business trips, and other business activities shall be kept simple in an efficient manner.

Colleagues

Employees shall respect each other, live in harmony, and treat each other in good faith. Employees shall respect the privacy rights of colleagues: no offense, harassment, defamation, intimidation, or disclosure of confidential information with each other. Employees shall cooperate and help each other to create a harmonious, united, and enterprising work environment. Managers shall respect and care for their staff and set an example for them; employees shall respect and act on the instructions of their supervisors. Employees shall proactively provide any necessary assistance for cross-functional work.

Daily Work

Camelot employees shall follow the guidelines as set forth in the employee manual and shall not be late, leave early, or absent without proper authorization. Requests for vacations and leaves should be approved by supervising bodies and such vacation or leave shall not disrupt the regular flow of business. Employees shall be on guard for job safety and personal hygiene to keep the work environment clean and tidy. Employees shall cooperate with relevant agencies for fire, theft, and epidemic prevention. Employees shall use and take care of Company's property and may not damage, or waste it for private use.

Professional Image

In public places, employees shall behave in a civilized and stable manner, dress neatly and gracefully, and their personal image should be commensurate with their professional identity, job position and environmental requirements. Employees shall actively participate in cultural and sports activities that are beneficial to the body and mind, and maintain strong energy to work. Gambling activities are strictly prohibited.

Supervision and Whistleblower

Employee shall cooperate with regulatory authorities and internal compliance inspections of the company if any. Employees have the right to report any kind of violation of the Code to their superior or the compliance department, but may not abuse the right to report or make false accusations against others. No one shall suppress or retaliate against the whistleblower. Employees have the right to refuse to follow instructions from their supervisors if such instructions violate the Code of relevant policies or procedures of Camelot.