Foreword

Midea is a technology group operating in the fields of consumer appliances, HVAC systems, robotics and automation, and smart supply chains (logistics). The Group is committed to the principle of "Creating Value for Customers," with a continued focus on technological innovation and a mission to "Create a Better Life for Humanity."

All employees are expected to comply with applicable laws and ethical standards in the course of business activities, thereby ensuring Midea’s standing as a responsible corporate citizen. Each employee is required to thoroughly read and adhere to the provisions of this Code of Conduct. Any violations may result in disciplinary action.

This Code serves as a framework to guide employees in making appropriate decisions when representing the Company in business dealings. It is acknowledged, however, that no code can cover every eventuality. Where this Code does not provide specific guidance, employees are encouraged to consider whether their actions align with their moral conscience, comply with the law, and reflect Midea’s values.

1. Compliance with Laws, Regulations and Ethical Standards

1.1 Midea Group is a global enterprise. All business operations must be conducted in compliance with the laws and regulations of the countries or regions in which it operates.

1.2 All employees shall uphold the highest ethical standards, act with integrity, respect others, and conduct themselves with discipline and professionalism.

1.3 A culture of integrity and compliance must be led by example. Managers are expected to demonstrate ethical leadership at all times and fulfil their supervisory duties to ensure all personnel within their remit understand and comply with this Code and other Company policies.

1.4 Employees who violate this Code or other applicable laws and regulations may be subject to disciplinary action in accordance with the nature and severity of the misconduct, up to and including termination of employment.

2. Fair Competition

2.1 Midea’s long-term success depends on conducting business in full compliance with applicable laws and on the basis of fair competition.

2.2 The Company prohibits any form of monopoly agreements with individuals or entities, and strictly forbids abuse of market dominance. Midea opposes any mergers or acquisitions that could have an unreasonable or unlawful effect of excluding or restricting competition.

2.3 When conducting market transactions on behalf of the Company, employees must comply with relevant laws, act on the principles of voluntariness, equality, fairness, and good faith, and adhere to accepted standards of business ethics. Unfair competitive practices such as dumping, infringement of intellectual property, false advertising, collusion in bidding, defamation, or any other improper conduct are strictly prohibited.

3. Avoiding Conflicts of Interest

3.1 A conflict of interest arises when an employee’s family ties, personal interests, or external business relationships may interfere with or appear to interfere with the best interests of the Company.

3.2 Such conflicts may stem from relationships with competitors, suppliers, customers, or from internal relationships within the Company.

3.3 Employees must promptly report any actual or potential conflicts of interest and are expected to always act in a manner that upholds the best interests of the Company.

4. Gifts, Hospitality, and Entertainment

4.1 Offering Gifts, Hospitality, and Entertainment:

4.1.1 It is acceptable to provide modest gifts, entertainment, or business meals in accordance with customary business practices to facilitate external relations and business cooperation. Prior to offering such gestures, employees must ensure they understand and comply with the relevant policies of suppliers and clients.

4.1.2 All gifts, entertainment, or hospitality must remain within the standards prescribed by the Company. Offering gifts or hospitality to obtain improper benefits is strictly prohibited.

4.2 Receiving Gifts, Hospitality, and Entertainment:

4.2.1 Employees may occasionally accept symbolic gifts or modest meals and entertainment in line with commercial customs and local traditions. All other offers must be declined.

4.2.2 Employees must not solicit or accept improper benefits from stakeholders such as suppliers or customers by taking advantage of their position or role within the Company.

5. Anti-Corruption

5.1 Prohibition of Commercial Bribery: Midea’s competitive edge is founded on its products. The Company is committed to operating within a fair, honest, and orderly commercial environment to improve product quality and services. We expressly oppose engaging in unfair competitive practices, such as providing money or other benefits to trading counterparties or any individual capable of influencing business transactions.

5.2 Prohibition of Bribery of Government Officials: Offering gifts, entertainment, or hospitality to government officials may breach applicable integrity regulations. Employees must not provide financial or non-financial benefits to government officials or their close relatives without prior approval and authorisation from the Compliance Department. Any such act carried out in the name of the Company or its employees may constitute a legal violation in the relevant or other jurisdictions, resulting in substantial fines or criminal liability, and may severely damage the Company's reputation.

5.3 Political Contributions, Charitable Donations, and Sponsorships:

5.3.1 The Company does not make donations to political parties, politicians, or political organisations.

5.3.2 As a socially responsible entity, the Company supports and participates in public welfare initiatives, contributing to education, healthcare, livelihood, disaster relief, and charitable causes.

5.3.3 Sponsorships may be offered to support legitimate business interests but must not be provided to gain unfair competitive advantages or serve improper purposes.

5.3.4 All donations and sponsorships must be transparent and subject to internal controls.

6. Anti-Money Laundering

6.1 Employees must not engage in money laundering activities that conceal or disguise the origin and nature of proceeds derived from criminal acts, including but not limited to drug trafficking, terrorism, smuggling, bribery, and offences against financial regulatory regimes.

6.2 The Company will periodically audit the implementation and effectiveness of its anti-money laundering practices. Suspicious transactions involving large amounts without clear shipment, sales records, or commercial rationale will be subject to internal investigation.

6.3 The Company follows the “Know Your Customer” (KYC) principle during client onboarding and transactions. Employees shall understand and verify customer identities and cooperate with financial institutions conducting KYC due diligence as required by law.

7. Compliance with Export Control and Customs Regulations

7.1 Midea complies with applicable export control and customs laws in jurisdictions where it operates. Export control laws may apply to cross-border transfers of goods, services, software, hardware, or technology, including via email or online access, or disclosure to certain individuals from sanctioned countries. Breaches may result in severe penalties such as termination of employment, fines, imprisonment, license revocation, trade restrictions, or travel bans.

7.2 Employees involved in import/export operations must comply with applicable economic sanctions, export control, and import laws, as well as any policies or procedures stipulated by their business units.

8. Prohibition of Insider Trading

8.1 Prior to disclosure of Midea’s confidential information—especially material non-public information affecting the price of its securities—employees must not trade on such information, provide investment advice, disclose such information to unauthorised persons, or participate in market manipulation. Breaches may constitute insider trading and may expose employees to legal liability.

8.2 In addition to the general prohibition of insider trading, all directors, supervisors, and senior executives are subject to further statutory restrictions on share trading, including limits on disposal during specified periods, maximum reduction percentages, and restrictions on short-swing and window-period trading.

8.3 Employees in possession of material non-public information must exercise particular caution in conduct and communication.

9. Protection of Company Assets and Reputation

Midea’s assets and reputation are critical to its growth and success. Every employee is responsible for safeguarding the assets within their control and for upholding and enhancing the Company's reputation in all jurisdictions.

9.1 Tangible Assets:

9.1.1 Tangible assets include cash, real estate, office supplies and equipment, machinery, inventory, company seals, vehicles, and computer hardware.

9.1.2 Employees shall protect Company property from theft, loss, damage, or misuse.

9.2 Intellectual Property: Intellectual property includes patents, trademarks, copyrights, proprietary technology, trade secrets, source codes, and software developed in the course of employment. As core assets derived from substantial investment, these must be safeguarded by all employees.

9.3 Trade Secrets: Employees shall maintain strict confidentiality over non-public business information encountered at work, including product plans, pricing, strategy, technical and operational data. Necessary and reasonable precautions must be taken, and unauthorised disclosure, reproduction, or use of such information is prohibited. Departing employees must return all such information and refrain from disclosing or exploiting it.

9.4 Reputation: Midea’s strong reputation has been built through innovation, service excellence, transparent communication, and social responsibility. It is imperative that employees avoid making public statements—whether in person, through media, or on social platforms—that may undermine the Company's image or commercial standing. Media inquiries must be referred to designated personnel in public relations or investor relations departments. Only authorised representatives may respond, especially in the case of financial analysts or financial media.

10. Adherence to Midea’s Delegation of Authority System

Delegated authority is central to Midea’s governance model. The principles of centralised control, orderly delegation, clear authorisation, and responsible use underpin our operations. To maintain organisational discipline and efficiency, the Company has implemented a unified approval and process management system, and all employees are required to strictly comply with relevant procedures.

11. Cooperation with Business Partners

Midea expects its suppliers, distributors, and other business partners to acknowledge and uphold the principles set forth in this Code of Conduct as well as Midea’s corporate values, to comply with applicable laws, and to adopt standards similar to those of the Company in areas such as stakeholder responsibility, environmental stewardship, anti-corruption, and fair competition.

12. Accuracy and Completeness of Work Records

12.1 Midea’s financial records, including accounting vouchers, financial ledgers, and reports, shall be clear, complete, accurate, and comprehensive. It is strictly prohibited to deliberately delete, alter, forge, or misrepresent any financial information.

12.2 Business operation records must accurately, promptly, and clearly reflect the nature and details of each transaction. All documents related to business dealings—whether in paper or electronic form—such as employee files, customer information, financial vouchers, and contractual documentation, must be properly retained.

12.3 Internal records, including meeting minutes and internal process applications, must be standardised. Employees shall preserve key correspondence such as important work-related emails and business communications for future reference.

13. Provision of a Favourable Working Environment

13.1 Midea is committed to full compliance with applicable labour and workplace laws and regulations in its countries or regions of operation. The Company respects employee rights and values, provides competitive compensation and benefits, ensures a healthy and safe work environment, establishes career development pathways, and offers training opportunities to enhance employee capabilities.

13.2 The misuse of drugs or alcohol can severely impair an employee’s ability to work safely, and may pose safety risks, lower productivity, and affect morale. The possession or use of prohibited drugs or alcohol on Company premises is strictly forbidden. Employees shall not work under the influence of drugs or alcohol during work hours. Limited alcohol consumption may be permitted during Company-sponsored events, provided that it complies with applicable legal drinking age requirements.

13.3 The Company maintains a zero-tolerance policy toward discrimination based on race, skin colour, culture, religious beliefs, political views, marital status, gender, or any other characteristic protected by law. Harassment, violence, or other forms of abuse are also strictly prohibited.

14. Protection of Privacy

14.1.1 Employee personal information obtained during recruitment or management processes shall not be disclosed to any third party unless authorised by the employee or required for legitimate business purposes. Prior to disclosure, the Company shall ensure that the third party has appropriate information security protocols in place. Employees are strictly prohibited from using internal networks or other means to unlawfully obtain, collect, or disseminate employee information, or from disclosing private employee data to unauthorised persons.

14.1.2 Documents, emails, videos, audio files, and other business-related information stored or transmitted via work on computers, telephones, or other business communication tools, including attendance and travel records, may be accessed, copied, or used by the Company. Employees are advised not to store private personal information on work devices, as such information will not be protected under the Company’s privacy protocols.

14.2 All user information obtained during business activities must be treated as strictly confidential.

15. Responsible Use of Resources, Environmental Protection, and Provision of High-Quality Products and Services

15.1 Midea complies with all applicable national and international environmental protection standards. As the home appliance industry advances towards greater environmental sustainability and smart technologies, Midea has consistently promoted energy-efficient products and worked to reduce resource consumption. The Company actively utilises clean energy in its manufacturing processes and is committed to minimising pollution and emissions. Employees are expected to demonstrate awareness of resource conservation in their daily work and to avoid wasteful practices.

15.2 Midea is dedicated to delivering products and services that meet or exceed customer expectations in terms of quality, reliability, safety, and value, thereby earning the trust of its clientele. The Company enforces strict quality control standards and systems to ensure that all products are designed and manufactured in compliance with applicable laws, regulations, and contractual requirements relating to product quality and safety. Furthermore, Midea actively collaborates with suppliers to implement quality improvement plans, thereby enhancing the overall quality and reputation of its products and services.

16. Enquiries and Reporting

16.1 This Code sets out the principles of lawful and ethical conduct expected of all Midea Group employees, but it does not address every scenario that may arise in day-to-day operations. Employees who are uncertain about how to apply or interpret the Company’s compliance principles, or who have other related queries, should seek guidance from the legal and compliance personnel of their respective business unit or the Group.

16.2 Employees who become aware of, or have reasonable grounds to suspect, any conduct that violates this Code are required to report the matter promptly through the appropriate Company channels. Midea encourages the use of real name reporting and undertakes to maintain strict confidentiality regarding the identity of the whistleblower and the contents of the report. The Company has a zero-tolerance policy for any form of retaliation or retribution against individuals who make reports in good faith. If an employee believes they have been subjected to retaliation, they may escalate the issue to their local management team or to the Group Compliance Department.

16.3 When reporting actual or suspected violations of laws or this Code, employees may pursue multiple channels:

Direct Supervisor: Employees may report concerns to their immediate supervisor, or, if preferred, escalate to higher-level management.

Legal and Compliance Officers: Employees may contact the compliance team of their business unit or the Group via the Midea Compliance Hotline, email, or telephone.

Additionally, employees may report concerns through the following contact channels:

Compliance Hotline: +86 757 2660 5599

Email: Compliance@midea.com