Compliance with Laws 

Comba has been always sticking to be compliant with laws and regulations, honest operation, commercial ethics which are business philosophy and footstone of our values. Comba attaches great importance to and continues to create a culture of integrity and such basic value and principle have been embodied in the "Code of Business Conduct" of Comba, which requires each of our employees to abide by and to conduct all businesses within the framework of legal and ethical standards. For the employees of Comba, ethical behavior is an essential part of the work instead of an "optional extra behavior". Based on the "Code of Business Conducts", Comba insists that all personnel, including shareholders, directors, senior managers, interns, temporary workers, consultants, retired employees, part-time employees, and other personnel who conduct external business on behalf of the company, are required to comply with the applicable laws and regulations of the country or region where the business is launched as well as respect local culture and customs. Meanwhile, Comba is committed to protecting the rights and interests of employees, personal dignity and privacy, providing equal opportunities for every employee. By establishing an ISO45001 certified occupational health and safety system, Comba aims to provide employees with a healthy and safe working environment that meets internationally recognized standards, and prohibits forced or compulsory labor, prohibits the employment of child labor, and regulates labor management. 

In order to better manage the company's compliance, Comba incorporates compliance assessment as elements of Key Performance Indicators (KPI) and establishes a reward and punishment mechanism to ensure that every employee abides by the company's Code of Business Conducts. 

Information Security Management 

Comba maintains a stringent policy of information security and confidentiality and an information security management system. In order to effectively safeguard the security of the company's information system and better serve for the company's production and operation, Comba has formulated the "Information Security Management System" and "Information Security Structure". Aiming at ensuring information security and preventing data leakage, Information security management is managed in an all-round way from six aspects: IT infrastructure guarantee, computer terminal management, application system management, data management, network management, data backup and disaster recovery system. 

Business Partners Due Diligence 

Comba continues to devote itself to the establishment of a compliance management system in various fields such as export control compliance and business partner due diligence and has established a series of internal regulations and online management procedures such as "Export Control Compliance Procedure", "Technology Control Plan for Controlled Items", "Business Partner Management Measures" and "Procedure for Business Partner Due Diligence", etc. With the implementation of these internal rules and regulations, Comba will regularly perform due diligence on business partners in accordance with the applicable laws and regulations of the country or region where the business is located, ensuring compliance with the business cooperation. Compliance management has been integrated into the company's business activities and processes. 

Business Ethics Training 

Comba requires every employee to abide by business ethics, and the company's regulations on integrity and anti-fraud system. Comba strictly prohibits employees from any bribery to customers and other related interested parties or individuals in order to seek improper benefits either for the company or individuals; employees are strictly prohibited from, directly or indirectly, accepting any form of gifts from suppliers, or engaging in any form of fraudulent behavior. 

The company requires all employees to receive training on business ethics, anti-corruption and integrity. The company will annually conduct mandatory training for all new recruitment, and conduct training for all promoted cadres. 

Moreover, tailored by different business models of different business departments, the company regularly provides different topics of business ethics and fair competition trainings for senior management, staff from marketing center and domestic branches, personnel from procurement department, employees of Hong Kong subsidiaries, and sales personnel of overseas market. Such lectures are conducted either by external professional lawyers or legal Department of Comba. 

Anti-Corruption and Anti-Bribery 

Comba firmly believes that integrity and fair competitions are the foundations of the company's business operation. Within the framework of all applicable fair competition, anti-bribery/anti-corruption rules and regulations, Comba always puts the company's anti-bribery and anti-corruption obligations above the company's commercial interests to ensure that the company's business is established on a fair, just, and transparent basis. 

Auditing on internal business ethics: Comba has set up internal control procedures for all departments. To ensure the effectiveness and completeness of the company’s internal control process, the audit department tests and evaluates the implementation of internal control procedures quarterly; further, independent third-party audit experts will conduct testing on the Company’s internal control environment and issue semi-annual and annual audit reports.

Corruption risk analysis: To evaluate the internal control process and to identify any corruption risk, the company's audit department will conduct, on a quarterly basis, risk assessment of the company's internal control process in accordance with the company’s business environment, policies, and regulations, etc. Such assessment will include the type, degree, and scope of any risks to be rated, following with audit plan and correction procedures developed for any risks identified. 

Furthermore, in order to encourage employees to supervise each other and anonymously report any unethical or illegal behavior found at work, the company has set up various reporting and complaint methods, including hotline, email, and “direct line to the president”, to ensure unobstructed appeal and reporting channels. Upon receiving any complaint or report, the company's audit department will promptly and effectively conduct investigations in accordance with relevant laws, regulations, and company policies of the country or region where the business is located.

Whilst accelerating its own development in a healthy and rapid manner, the Group is devoted to supporting social charity and proactively fulfills its social responsibilities and obligations. It has devoted many human and financial resources to various aspects including public welfare activities, poverty alleviation, donations for school, staff care and expressing greetings and concern to the injured and disabled. In 2020, the Group made a total donation of HK$768,000 in the PRC on aspects such as social charity, poverty alleviation, provision of financial assistance to poor students and social activities.

During the pandemic, the Group actively made deployment for prevention and control of the pandemic and realized zero infection case. The Group was among the first batch of enterprises in Guangzhou which resumed work and production after the Chinese New Year and has made good administrative preparation for resumption of work and production in the three bases. Related measures included daily disinfection in the bases, supply of catering service in canteens, virus testing for staff in relation to shuttle bus and gate entry. At the same time, quarantine rooms were set up in dormitories for employees returning to Guangzhou from high-risk regions hit by the pandemic. The work in relation to prevention and control of the pandemic after resumption of work has gained recognition from both the regional government and the municipal government.

During the preliminary stage of the pandemic, the Group has set up an emergency team for pandemic prevention and control to perform division of labour during the outbreak. The team promptly collected and purchased antipandemic items for employees’ use after the Chinese New Year holiday and for disinfection in the bases. An online platform on Corporate WeChat was also built to promptly release over 20 announcements relating to the related prevention and control, with a view to guiding the Group and various departments to implement prevention and control measures for employees. The schedules of employees during their holidays were also collected to timely keep abreast of their health conditions. Besides, the Group secured supply and timely transportation of antipandemic items, providing comprehensive support and security for resumption of work and production. In addition to a total of 520,000 boxes of meal distributed and 400,000 masks purchased and distributed, with relentless efforts of team in coordination and procurement, the Group has also provided its employees with anti-pandemic items such as Chinese herbal medicines, masks, forehead thermometers, hand wash, disinfectant alcohol, disinfectant, paper hand towel, paper for pressing lift buttons and protective gloves during 2020.

The Group also paid attention to personal care by implementing measures related to employment stabilization to safeguard employees’ benefits. During the fighting against the pandemic, employees who were not able to come to work as normal due to the pandemic in accordance with the requirements of the relevant guidance as promulgated by the government, or employees who were able to work from home were so arranged to work and remunerated as normal, while employees who were not able to work from home were given priority to take paid leaves and be arranged for leave. At the same time, shift of duty was also adopted to secure the income of employees.

The Group has been committed to achieving the sustainable development goal of environmental protection and energy saving. By implementing the Environmental and Quality Management System to manage the environment in a systematic manner, the Group strives to deliver the development strategy of balancing environment, society and economy. The Group has adopted the management concept of life cycle in all the business activities worldwide to minimize adverse effect on environment while producing and offering services, perform its compliance obligations and enhance environmental performance, thus contributing to the better prevention of environment pollution and the sustainable development of society.

(I) EMISSIONS

To implement relevant laws and regulations promulgated by the People’s Republic of China (“PRC”) such as Environmental Protection Law (《環境保護法》), the Law on the Prevention and Control of Air Pollution (《大氣 污染防治法》), the Law on the Prevention and Control of Water Pollution (《水污染防治法》), the Group sets a goal of environmental management to achieve pollution reduction and emission control and strictly monitor waste discharge during the course of production by setting up ISO14001 Environmental Management System and carrying out environmental control procedures as well as environmental monitoring and measurement control procedures pursuant to the working guideline of “standardizing the works of environmental management, taking precaution as the main task, fulfilling regulation requirement, satisfying the standards of emission to make sure that it is under control and continuing to save energy and reduce consumption”, with the aim to ensure the management and control of pollution at source.

The Group is committed to achieving environmental and social sustainability in its daily operations. In terms of environmental aspects of the 2020 sustainable development goal, we ensured zero fine in exhaust gas emission. Designated dumping areas in each production base segregated wastes by licensed waste collectors and the garbage in the bases was strictly sorted and recycled.

During production process of the Group, there is no emission of industrial wastewater, except for little air contaminant discharged by its administrative cars and standby generating sets. Wastes in each production area are discharged after treatment in accordance with the approved requirements based on the evaluation on the impact on the environment and the production areas shall perform annual review to ensure legal and compliant emission of exhaust gas. All the toxic waste generated by the Group, including batteries, bulbs and coolant oil, will be conducted professional recovery and processing by qualified waste recovery and processing companies. The Group has entered into contracts for hazardous waste treatment with companies that have obtained national qualification for hazardous waste treatment to carry out regular waste disposal. The Group has also signed treatment orders for hazardous wastes to be regularly reported on the government website for reporting hazardous wastes. Non-hazardous waste mainly includes domestic waste generating from daily office works and canteen of the Company, which has been treated in strict compliance with the sorting principle. Raw material wastes such as vegetables, roots and animal offal should be treated as domestic wastes; swills should be disposed into swill buckets as required; canteen garbage should be dumped into the garbage pool in a centralized manner and dumping at will is prohibited. Indirect emissions from external production of electricity and employees’ business trips are the major source of the Group’s greenhouse gas emission. In 2020, the equivalent amount of carbon dioxide (CO2 ) emission for sales revenue per ten thousand was 0.058 tonnes. The emission density of greenhouse gas increased comparing with that of 2019. The increase in hazardous waste was mainly caused by used coolant oil. Since historical data has not been sorted out from the data of the previous year, the data of this part is not available.

In 2020, the Group continued to optimize solutions and scope for using administrative cars. Administrative cars can only be used for important corporate business entertainments. The fleet arrangements during daily operation shall be reasonable and user-friendly to avoid unnecessary car rent. For non-essential business, staff are encouraged to take public transport or choose ride-hailing services via more affordable third party platforms. The Group also consolidated the frequency and route of the Company’s shuttle buses for many times based on the actual situation. The Group has carried out regular supervision over and assessment of the service quality of the outsourcing service companies, enhanced the degree of informationization of its documents, optimized offline working procedures, formulated online working procedures to encourage paperless office work so as to reduce paper consumption while printing, at the same time conscientiously implementing the relevant PRC laws and regulations and strictly implementing waste sorting system, thereby effectively controlling emission of pollution.

(II) RESOURCE UTILIZATION

The Group takes a careful consideration of environment factors throughout the life cycle of its products and services to provide its products with the characteristics of energy and natural resource saving and non-pollution in each procedure of R&D, production, sale, transportation, utilization and abandonment. Manufacturing base in Guangzhou Development Zone has been certified by the Green Manufacturing System (綠色製造體系) since 2018. The Company effectively manages the water consumption and waste water treatment to reduce environment pollution, actively promotes the concept of water conservation through publicity and educational activities, energy conservation column on the Company’s WeChat account and regular reporting and posting of wasting behaviours. To save water resources, the Group also sets water usage and conservation targets, striving to lower the usage by 6% year-on-year. The Group did not encounter any difficulties in seeking appropriate water sources. The Group also increases the frequency of daily inspection and perform around-the-clock regular and non-regular inspections on power and water utilization in each floor and each department of the base; maintains proper inspection records and publicly criticizes the departments with behaviours of wasting; reduces the utilization of hazardous and toxic substances in each procedure, proactively seeks, develops and uses new environmental technologies and materials and encourages recycling of all materials, while for resource and energy consumption, the Group promotes active application of energy efficient products, equipment and techniques to reduce energy consumption.

 During the year, the Group continued to optimize and reform its product packaging. The Group prioritized the adoption of environment-friendly technologies in the construction of new projects, during which an inspection report shall be submitted regarding the materials used so that all materials can meet national requirements for environmental protection and will not cause contamination to the surrounding environment when used. The Group also reduced the use of packaging accessories and packaging materials, at the same time planting more trees in the Knowledge City. During the year, the Group established 5G workshops by expanding the existing workshops and added production equipment with flow processes for certain production lines, resulting in an increase in power consumption but a decrease in water consumption.

(III) ENVIRONMENT AND NATURAL RESOURCES

The Group is proactive in enhancing staff awareness of and responsibility towards environmental protection. All the employees in each of its branches worldwide are required to comply with local laws and regulations in respect of environment, safety and health. In the absence of local laws and regulations, they are encouraged to provide assistance in solving environmental issues as possible as they can under relevant standards of the Group.

The Group has set up scientific goals in environment and energy consumption, and continuously evaluates, improves and consolidates the synergy among the Group’s operating activities, products and the environment. In addition, the Group communicates environmental information with stakeholders in a timely manner. Furthermore, the Group also focuses on environmental factors in selecting and managing suppliers and outsourcers.

The Group has reduced its negative impact on the environment and natural resources by pursuing high quality products, including the reduction of repair rate of products and reported damage rate of machines. The Group has implemented flexible layout and upgraded its intelligent manufacturing equipment in its production workshops during the reporting period. All pieces of equipment have been connected to optimize the intelligent deployment in the life cycle of products so as to improve operation efficiency of products, reduce the repair rate in the market, and increase the useful life of machines.

(IV) CLIMATE CHANGE

Mainland China, Hong Kong and other regions in PRC and abroad where the Group’s major sales offices located pay attention to major climate policies and comply with local laws and regulations related to environmental protection. Currently climate factors have no material impact on the Company’s production and operation. The Company will closely monitor the impact of extreme weather conditions, such as typhoons, strong wind, extreme cold and humidity, on the production and logistic processes, make corresponding predictions and take preventive measures such as upgrading and optimizing environmental protection products and enhancing product performance so as to reduce the impact of climate change on product performance and direct operation.

(V) CARBON NEUTRALITY

Achieving green and low-carbon development is a top-listed strategy at the national level and a necessary condition for the long-term healthy and sustainable development of our economy.

Comba continues to keep a close eye on the Intergovernmental Panel on Climate Change (IPCC) proposal on the 1.5 °C target and subsequent changes. Comba is committed to halving our total greenhouse gas emissions by 2030, in alignment with the 1,5°C ambition. Comba will adopt vigorous measures to constantly integrate the concept of low-carbon development into product design and all aspects of our operational activities. At the same time, we will work with partners, customers, and suppliers to seek a sustainable low-carbon business environment.

The Group has standardized labor management in accordance with national laws and regulations. It also strictly regulates the employment system including recruitment, resignation, promotion, staff salary and benefits, and resolutely eliminates the employment of child labor and forced labor.

The Group considers its employees as an important resource. Thus, the Group attaches great importance to safeguarding their interests, offers them competitive remuneration packages and contributes towards the relevant insurances. Apart from national statutory holidays, employees are also given an appropriate number of leaves or compensation depending on their entitlement under their respective employment agreements with the Group and in accordance with the relevant laws and regulations.

(I) HEALTH AND SAFETY

Striving to create a safe, healthy and comfortable working environment for its employees, the Group has established the ISO45001 Occupational Health and Safety System and SA8000 Social Responsibility System to protect employees’ health and safety. Such systems are operated in combination with quality management system to deliver the Group’s commitment to the community and its employees.

The Group has set up the “Safety First, Prevention Dominance and Comprehensive Governance” guidelines and paid close attention to work safety.

(1) Establishing safety management policies and procedures: The Group has established safety management policies such as the Management Procedure of Safety and Environmental Protection for Construction Project (《建設專案安全和環境保護管理程序》), the Fire Control and Safety Management Regulations 《消防安全管理規定》 ( ), the Safety Production Responsibility System (《安全生產責任制》), the Labour Protection Standards of Production Position (《生產崗位勞動保護標準》) and the Transportation Safety Management Regulations (《運輸安全管理規定》). At the same time, it has refined various safety management policies and safe operating procedures of all levels. Pursuant to which, the person in charge is required to sign the Safety Production Responsibility Paper (《安全生產責任書》), and all the division principals are directly responsible for safety performance of their respective areas.

(2) Continuing to put efforts to improve environmental safety: The Group creates a fine and safe working environment for its employees, provides them with comfortable accommodation, formulates the staff holiday system and the periodical medical check system, offers job skills training and establishes a labour union. Besides, the Group also attaches much value to staff care, health and safety as well as boosting their sense of belonging. With a lot of funds invested, apparatuses and equipment devoted, the Group keeps improving working environment and protects the personal safety and health of its employees with special positions equipped with corresponding appliances for labour protection. Also, its employees’ safety awareness and self-defense capability are strengthened through safety training.

(3) The Company continues to strengthen the publicity and promote training with regard to health and safety of all staff, with a view to developing a culture of health and safety, thereby promoting general improvement of health and safety awareness of all staff, so as to create a good atmosphere of production safety. Carrying out activities such as drills and inspections: A safety manual for production operation is formulated for staff compliance. The Group carries out fire drills every year to further enhance its employees’ emergency response capability. Also, a fire emergency team, which is responsible for urgent evacuation of personnel in emergency, is established to protect its employees’ life and property security. The Group has established special safety inspection system which covers a variety of measures, including daily safety check, seasonal safety check, and safety check before and after holidays. The Group was repeatedly awarded as “Advanced Enterprise in Production Safety (安全生產先進單位)” and “Enterprise with Qualified Work Safety Standardizations (安全生產標準化達標企業)” in Guangzhou City

(II) SUPPORTING EMPLOYEE DEVELOPMENT

The Group has been focusing on the cultivation of talents. On such basis, the Group advocates the talent concept of “promote the outstanding among flourishing talents” and establishes an effective and systematic talent training system, which is designed to enhance its employees’ knowledge, capability and skills. In view of the Group’s demand for talents arising from its development goals, the Group ensures effective implementation of training from the five aspects of training regulation system, training program system, training instructor system, training material system and training operation system.

(1) Orientation Training for New Employees

In order to help employees quickly integrate into the team and enhance the cohesion of the Group, the Group offers well-established orientation training programs to new employees, which cover training on occupational health and safety, corporate culture, rules and regulations, organization management, quality management, trade secrets and intellectual property rights, anti-fraud, process and IT know-how and the application of office software, information security, product and professional knowledge, job practice and other aspects.

(2) Building a Stronger Talent Pool of Operation and Management Staff

The management serves as the core strength in the operation and management of a corporate. To cope with the ever-changing market environment and enhance our management and operations capability, the Group has formulated and released the Comba Telecom Leader Competency Model and Comba Telecom Leader Management Manual to clarify the capability standards and management requirements of the management. The Group continuously nurtures management personnel and issued the Guidelines for Development and Management of Leadership Talent Team of Comba Telecom. It strengthens the leadership and management skills of its management team by optimizing the leader management mechanism, recommending high-quality strategies and management training courses and providing practical training. It also fosters a culture of continuous learning and focuses on cultivating the strategic, innovative and team skills of management, so as to ensure compliance with the position-specific requirements for Comba Telecom management and meet the demand for future development and challenges of the Group. Meanwhile, such training programs also boost management’s self-management skills, promote their career development in a more systematic way and better motivate and retain high-calibre management talents.

(3) Devoting Greater Efforts in Developing the Professional Competence of Employees

In order to enhance the expertise and skills of employees and to keep them abreast of the latest market changes and development trends, the Group provides technical, software, safety and compliance trainings in a timely manner. It has also provided external professional training, which is a good opportunity for experience exchange of ideas, knowledges and information with external customers.

(4) Establishing a Better Team of Internal Lecturers

The Group regularly organizes internal skill enhancement training and certification for lecturers in order to build a high-quality team of internal lecturers, improve their teaching skills, broaden their horizons and promote the accumulation and inheritance of its corporate culture. During 2024, there were 191 internal lecturers. In addition, the Group invites industry experts to provide its internal lecturers with full set guidance on curriculum development, teaching and presentation. Furthermore, the Group builds its branded lecturer team and delivers a series of excellent courses through after class practices and getting certification and approval of internal lecturers.

(5) Position-specific and Professional Knowledge Training and Competitions

In order to improve the competence of employees, the Company has continuously carried out position-specific and professional knowledge training and practices through a three-level training system and by ways of instructor coaching, internal training, training by external lecturers, external training and on-the-job practice. Extensive On the job Training (OJT) has been provided to better align the training with actual job needs. Various branches and subsidiaries have repeatedly held skills competitions to encourage employees to develop their personal professional ability based on the requirements of the Company and the position, laying the foundation for the Company’s stable business operation and employees’ career development.

(6) E-Learning Platform

In order to improve the competence of employees, the Company has continuously carried out position-specific and professional knowledge training and practices through a three-level training system and by ways of combining instructor coaching, internal training, training by external lecturers, external training and on-the-job practice. Extensive On the job Training (OJT) has been provided to better align the training with actual job needs. Various branches and subsidiaries have repeatedly held skills competitions to encourage employees to develop their personal professional ability based on the requirements of the Company and the position, laying the foundation for the Company’s stable business operation and employees’ career development.