We go to great length to ensure our employees adhere to business ethics at the highest standard. In December 2001, NetDragon released the <Employee Disciplinary Action Measures>, which provides a full set of code of conduct, including comprehensive rules related to business ethics. This policy is now at its 7.3 version and has undergone 15 rounds of updates in the past two decades. Apart from providing trainings to all our employees, we actively communicate our relevant business ethics principles to employees of suppliers and business partners. Leveraging our unique technological capability, we have also developed functions in our internal OA system to collect, handle and resolve “complaints and compliments for middle to senior-level employees” and so called internal “BUG”. These two functions are intended to collect anonymous complaint reports towards unfair policies and rules, or any unethical behavior by employees. The whistleblower’s privacy is also strictly protected. To ensure proper execution, we have a dedicated Internal Audit Department that works together with our Human Resources Department to implement the program. Over the years, this robust governance measure has served to extensively detect problems within our operations, leading to creation of internal process and procedures to prevent the same problems from happening.

In addition to the above, NetDragon strictly requires all subsidiaries to follow relevant regulations globally, such as <Prevention of Bribery Ordinance> in Hong Kong, <Foreign Corrupt Practices Act> in the US, and have also adopted relevant aspects of OECD Anti-Bribery Convention rules into our policies.

Employee Training and External Audit

We have robust policies and programs to ensure all employees are properly trained. New employees in China have to pass relevant exams that cover contents in our <Employee Handbook> and <Employee Disciplinary Action Measures> in order to be formally employed. We also run periodic programs to “test” all employees in our OA system (covering over 90% of all employees in the Group) through the ‘three quizzes a day’ feature in our corporate IM to assess their understanding of relevant policies. Those who fail the business ethics quizzes are required to take another round of training and exam. In addition, our overseas subsidiary Promethean also utilize the Skill Soft Platform to conduct extensive employee training that cater to our overseas operations.

The business ethics policies, together with all other internal control polices, are subject to external review and assurances twice a year. We constantly revise and update the policies based on recommendations by our external consultants.

Subsidiary Level Policies

Our subsidiaries in China have fully adopted the NetDragon self-developed OA and IM systems, and are regulated by policies and guidelines set forth in the and its appendices.

Promethean is a global company with its headquarter located in Seattle, Washington, USA. Promethean is in full compliance with all applicable laws in the countries where it does business. Promethean has also implemented internal policies, procedures and standards that cater to its global operations, and are in line with the Group level principles.

Promethean's revenue represents 92% of our education segment revenue and 39% of our total group revenue in 1H 2021.

Edmodo is a U.S. company based in San Mateo, CA which has adopted the same or similar policies, procedures, and standards as Promethean.