CODE OF CONDUCT

(Applied to FPTS staff only - Amendment to the Code of Conduct issued according to the Decision 129-2017/QD/FPTS-FHR dated November 14, 2017)

CHAPTER I - GENERAL TERMS

Article 1: Definitions

1. "Code of conduct" refers to standards on corporate ethics and behavior such as honesty, discretion, professionalism and legal compliance upheld and appreciated by all employees of FPT Securities Joint Stock Company.

2. "Staff” refers to officials and employees of FPT Securities Joint Stock Company in all forms of labor, including but not limited to persons on probation, official employees, and temporary and contract workers.

3. "Investment advisor" refers to the staff of the FPTS Investment Advisory Division (FIA) and the staff of the FPTS Investment Analysis Division (FPA)

4. "Gifts" refers to any presents, bonuses, commissions or discounts in cash or otherwise, other privileges such as rights to buy stocks, bonds or fund certificates, and vacations or sightseeing trips.

5. “Related persons” refer to interrelated individuals or organizations specified by the Law on Securities and the Law on Enterprises.

6. “FPT Securities Joint Stock Company” is abbreviated as FPTS herein.

Article 2. Commitments

1. FPT Securities Joint Stock Company is committed to providing the highest-quality services for customers with the dedication, honesty and professionalism of all the staff.

2. We deeply understand that the sustainable development of FPTS is built on ethical conducts, professional expertise and behaviors of every staff. On that basis, we are committed to strictly conforming to the regulations of this Code of Conduct. Any staff, regardless of their position, offending the regulations hereinafter shall be strictly punished.

CHAPTER II - GENERAL REGULATIONS

Article 3. In all activities, the staff of FPT Securities Joint Stock Company shall:

1. Abide by all laws of the Socialist Republic of Vietnam, the regulations of the Ministry of Finance and the State Securities Commission, and the regulations of FPT Securities Joint Stock Company.

2. Work and serve customers with full competence, dedication, fairness and transparency.

3. Not abuse his/her position, power or advantages obtained from his/her current position at FPT Securities Joint Stock Company to seek profits for himself/herself or related persons.

4. Not invest or trade in listed securities in any form, except for the following cases:

a. Buy shares of FPT Securities Joint Stock Company in accordance with Company policies;

b. Cases approved by the General Director of FPTS and announced prior to the execution of transactions

5. Strictly protect the confidentiality of customers and partners of the Company. The staff of FPTS is only allowed to provide the above information when authorized by FPTS or requested by authorities and stipulated by the current regulations of FPTS.

6. Not discuss confidential information of FPTS and of FPTS customers and partners in public places, on forums or via other means of communication.

7. Not directly or indirectly spread incorrect information or rumors to mislead FPTS’ customers, partners or other parties.

8. All staff of FPTS is strictly prohibited from receiving any personal gifts or any personal pays from customers or partners. Courtesy gifts that cannot be refused must be delivered to the Company for settlement. The person in charge of such settlement is the Chief Accountant of the Company/Branch.

9. Not to undertake any work that has not been prescribed or is prohibited by the Company.

CHAPTER III - SPECIFIC REGULATIONS

Article 4: The staff of the Investment Advisory Department and the staff of the Investment Analysis Department shall comply with the following rules:

1. Solicit the staff delegated to receive orders from customers:

a. Make sure that customers’ orders are inputted into the system according to the “first come, first served” principle.

b. Not modify information on any transaction order or forge customer’s signature on his/her transaction order. In receiving an invalid transaction order from the customer, he/she must return it to such customer for correction or create a new order.

2. Be strictly prohibited from using money and securities on client accounts.

3. Ensure the absolute confidentiality of customer account information; only provide customer account information to the account holder or a third party with the consent of such account holder or when FPTS must provide it accordance with the law.

4. Not receive the customer’s direct authorization to conduct securities transactions. Based on the customer’s authorization contract for FPTS and Work Assignment on the receipt of authorized accounts of FPTS’ representative granted to the investment advisor, such investment advisor shall receive the request from the customer and execute such request.

5. Not make any decision on securities investment in lieu of the customer or agree with the customer on the share of profit or loss in securities investment.

6. Necessarily find information about the customer and actively use knowledge, skills, integrity and discretion for the purpose of consulting, assisting the customers to achieve investment requirements and objectives

7. Have ultimate prudence in consultancy and analysis to provide the most accurate information and reports; clearly distinguish factual event information and personally subjective information in providing consultancy.

8. Guarantee independence and objectiveness in consulting and analyzing activities.

9. Not use unsourced analytical products of other people.

10. In a company where FPTS owns shares and the analyst owns shares (if any), he/she must disclose the number of shares held by FPTS and by him/her. If the number of shares held by him/her is big enough and that may affect the objectivity of analytical reports, the Department Director/Deputy Director, FPTS General Director may consider not have such reports disclosed in the name of FPT Securities Joint Stock Company.

Article 5: The staff of the Financial Corporate Advisory Department and the Corporate Governance and Management Advisory Department shall comply with the following rules:

1. Not provide information relating to the corporate customer or consultancy materials to any investment advisor or any other party.

2. Try the best to deliver best products and services to the customer, including thorough studies on customer’s needs, and provide the customer with accurate, complete information on FPTS’ advisory products and services.

Article 6: IT specialists shall comply with the following rules:

1. Be prudent in all activities, safe, secure and sufficient backup systems, ensure smooth and uninterrupted operation of the system

2. Not copy information of FPTS units or customers without written permit of competent officials (The department head approves if the information is within the department; the General Director shall approve if the information is related to customers) even for use within the project; not access data in any form not described or regulated in the Software Correction Process.

3. Maintain the confidentiality of all information of FPT Securities Joint Stock Company and customer information in implementing information technology projects; not use products of the project (materials, solutions, products, processes, etc) in other places or for other customers.

CHAPTER IV - EXECUTING REGULATIONS

Article 7: Compliance instructions to the Code of Conduct:

1. All the staff of FPT Securities Joint Stock Company shall read carefully, completely understand and strictly implement the above regulations.

2. Any staff violating the above regulations will face punishment, from warning to dismissal, depending on the nature of offense, and will compensate for any damage or loss caused by the offense.

3. Any staff detecting any offense must report to their managers or the Human Resources Department.

4. Any staff violation discovered by organizations or individuals outside FPT Securities Joint Stock Company will be settled strictly, and the official written result of the settlement will be sent to those reporting the violation.

5. The Code of Conduct is presented in four chapters and seven articles and takes effect from the date of signing by the General Director of FPT Securities Joint Stock Company.

GENERAL DIRECTOR (Signed)