The VTech Group recognizes that its reputation and success are not determined by its business performance alone but also by its commitment to upholding important business ideals such as equity and integrity. The publication and distribution of the Code of Conduct emphasizes the standards of business ethical practices that apply to our employees, customers, suppliers and business community. It has been approved by our Board of Management and every VTech employee is expected to comply with the business ethics and principles set forth in this Code. The Compliance Committee will periodically review the content of the Code of Conduct and, when necessary or desirable, make recommendations to the Board of Management to ensure continuous improvement and compliance with changing laws.

It is the Group’s policy to comply with all applicable laws and observe local business practices. All directors and employees are expected to conduct themselves with the highest standards of business and personal ethics. The practices of honesty and integrity are required in every aspect of business dealing.

Conflicts of Interests, Gifts & Bribes: The Group requires that directors and employees avoid any perceived conflict between their own interests and the interests of the Group when dealing with vendors, suppliers, customers and other third parties as they relate to their personal affairs or actions taken on behalf of the Group. When a director or employee, or their immediate family, may have engaged or considers engaging in business, investments or other activities that have, or may, conflict with the Group’s interests, they must make full written disclosure of this real or potential conflict to the Group. Employees are prohibited from soliciting or accepting any favors from customers, vendors or any other person as it relates to their employment. Such favors offered in connection with employment should be declined, unless they are nominal in value and where refusal would be highly inappropriate. The term ‘favor’ is broadly defined, but includes gifts, loans, fees, rewards, employment, services, benefits or advantages. The Group prohibits bribery and corruption practices.

Suppliers: The Group encourages fair and open competition and aims to develop and secure long term relationships with suppliers and contractors based upon mutual trust. Procurement of supplies and services shall be conducted with the highest ethical standards that assure a quality end-product as well as the continued confidence of customers, suppliers and the public. The acquisition of services or the purchase of goods should be based solely upon necessity, quality and price. Those responsible for making selections or purchases from suppliers and contractors must not misuse their authority or engage in situations which could interfere, or appear to interfere, with their ability to make unencumbered and independent decisions regarding purchase and procurement.

Customers and Business Partners: In an effort to maintain customer satisfaction, the Group seeks to provide efficient and courteous customer service. The Group shall avoid misrepresentation, exaggeration and overstatement when informing its customers of its capabilities. The Group strives to provide quality products to their customers at prices that represent good value for their money.

Competing with Integrity: The Group is committed to a policy of vigorous lawful competition that is based upon the merits of our products and services which comply fully with antitrust laws of the United States, competition laws of the European Union, and other applicable competition laws in the countries in which we do business. The marketing of our products and services should be based upon quality, distinctiveness, brand recognition, fair pricing and promotional programs and honest advertising practices.

Equal Opportunities in Employment: The Group recognises that its success depends on the full contribution and co-operation of all employees. The Group ensures equal opportunities related to all employment matters including recruitment, training, promotion, transfer, compensation and benefits, dismissal, etc. without regard to sex, age, race, colour, religion, national origin, marital status, pregnancy, disability or family status. All employees are treated as individuals according to their abilities to meet job requirements.

Workplace Practices: The Group complies with all occupational health, safety and discrimination laws, and is firmly committed to providing a safe and harassment-free working environment. Both the Group and employees must take responsibility and exercise reasonable care for the health and safety of themselves and of others.

Environment: The Group is committed to conduct its business in a manner that is compatible with the balanced environmental and economic needs of the communities in which it operates. Efforts are continually made to improve environmental performance and ensure compliance with all applicable environmental laws and regulations. The Group’s commitment and respect for the environment, emphasises that its employees take responsibility for environmental performance through appropriate operating practices and training.

Handling of Complaints: Complaint channels are available to the Group’s shareholders, potential shareholders, customers, consumers, suppliers, contractors, directors and employees. The Chief Compliance Officer will ultimately receive and investigate complaints or allegations by employees for breaches of this Code of Conduct. Employees should immediately report breaches, or suspected breaches, of this Code of Conduct, or violations, or suspected violations, of applicable laws, to their supervisor, when appropriate, to the relevant Human Resources or Legal Departments. In fact, if the issues are related to employment, equal opportunity, harassment, health, safety, or Environmental Awareness, your supervisors, or the Chief Compliance Officer may refer these cases to the relevant Head of Human Resources or Legal Department. Reports may be made anonymously. If allegations are made with malice or an intent to harm, the complainant making such allegations will be subject to disciplinary action, and the Group may forward these matters to outside authorities for further investigation. To the extent possible, all information received shall be kept confidential and the complainants will be treated impartially and efficiently.

Disciplinary Measures: The Group does not tolerate any illegal or unethical behaviour. The Group shall enforce its Code of Conduct through various disciplinary measures. These disciplinary measures include, but are not limited to, counselling, verbal or written reprimands, warnings, suspensions without pay, demotions and, in some instances, termination of employment or criminal reports to the applicable legal authorities.

If you are an Employee or Director of VTech and have not already done so, please execute and submit the “Declaration of Compliance with the Code of Conduct Form” which may be obtained from your Human Resources Department.

Should you have any questions about our policies or their applications, please call (852) 2680 5132 or write to:

Mr. YW Chang
Chief Compliance Officer
23/F, Block 1
Tai Ping Industrial Centre
57 Ting Kok Road
Tai Po, N.T., Hong Kong
Email : yw_chang@vtech.com