1. Supplier shall maintain integrity in all business dealings. Any form of corruption, extortion, and bribery (including facilitation payments) is strictly prohibited.

2. Supplier shall not be allowed to give, offer or promise to offer any bribe (such as Rebates, gifts, red pocket etc.) to any of Espressif’s employees or their close associates under any circumstances (excluding reasonable business conducts, such as providing conference tickets, giving holiday gifts valued at RMB 500 or less, etc.).

3. Supplier‘s quotation(s) are to fairly and accurately reflect in the reasonable and fair offer to Espressif, without taking into account of any external factors that may affect such fairness or accuracy, such as any business entertainment expenses incurred with respect to or any rebates offered to any of Espressif’ s employees.

4. Except for information publicly disclosed by Espressif, Supplier must not seek commercial secrets or confidential information from Espressif staff in any manner. Supplier should avoid any behavior that involves collusion, bid-rigging, or other actions that violate laws, regulations, or Espressif’s management policies.

5. To avoid conflict of interest and ensure Espressif dealing with Supplier in an impartial manner, no employee(s) of Espressif is/ are allowed to receive any form of rebates, gifts, red pocket for any reasons from Supplier. In case of such situations, Supplier shall contact Espressif management team to report or file complaint immediately.

6. In order to ascertain the above situation, Supplier shall cooperate with the investigation carried by Espressif within reasonable bounds.

1. Once verified, Espressif reserves the right to immediately and unconditionally terminate all business dealings with Supplier, without incurring any liability.

2. Supplier shall pay Espressif a penalty, which will be the highest of the following: (i) ten times the bribe amount; (ii) 30% of the last 12 months' supply payments; or (iii) RMB 1,000,000. Supplier shall also cover other economic losses incurred by Espressif due to the breach, including negotiation and implementation costs, litigation fees, legal fees, travel expenses, and investigation costs.

3. Espressif has the right to directly deduct the penalty and other related costs from the payments payable of Supplier.

We urge suppliers to cooperate and comply with the above policy and encourage suppliers to promptly report any violations of this code or business ethics. Should you have any questions about this policy or have anything to tip off, please feel free to mail the contact below.

Mail Address: Floor 7, Block 3
No.235, Yubei Rd. Shanghai, China
Post Code: 201204
Audit department, Espressif

Email Address: ethics@espressif.com