Brogent Technologies, Inc. – Flying Theatre Manufacturer

Corporate Governance

Integrity Management and Legal Compliance

Brogent has established the Ethical Corporate Management Best Practice Principles, the Code of Ethical Conduct for Directors and Managerial Officers, the “Employee Code of Conduct”, the Operating Procedure for Prevention of Insider Trading, and the Reporting Policy of Unlawful or Unethical Actions in order to guide our directors, managers, and employees in upholding integrity, complying with the law, and fulfilling their fiduciary duties in conducting business activities, maintaining operational soundness.

Internally, at Brogent Group, we have requested all of our employees, distributed around the world, to follow the Employee Code of Conduct, which clearly defines rules for internal and external, business or non-business interactions. Through establishing these management rules and working procedures, we have created a set of rules for our employees to follow during business operations, lowering the risk of corruption. New employee training courses and regular annual educational and training courses are used to teach employees about the Company's rules on internal and external, business and non-business interactions. Through an after-training evaluation, employees would be assessed on whether or not they understand the Company's rules.

Externally, all of Brogent's suppliers are required to sign an “Integrity Pledge”, in which they declare that they will not bribe or promise to reward Brogent employees with whom they have contact as a result of business dealings, and that they will satisfy our requirements on sustainable development as Brogent's suppliers. In addition, if an employee requests or accepts improper benefits from a third party, or directly or indirectly benefits him/herself or other related parties in violation of pertinent integrity provisions, any such violation can be reported through the “official reporting window” on our Company's website, as has been set out in the Reporting Policy of Unlawful or Unethical Actions. Brogent has established a uniform and dedicated e-mail,, for external reporting on business conducts and complaints. We maintain strict confidentiality with respect to the source of the report and investigate all information, as well as take special measures to protect whistleblowers, so as to reduce such incidents as corruption and malfeasance.

It is an enterprises' basic responsibility to conduct business activities in compliance with the law. Brogent strictly complies with the laws and regulations of competent authorities in corporate governance, product R&D, production and manufacture, installation and testing, and after-sale service. The Legal Affairs and Intellectual Property Department provides new information on laws and regulations to all departments on a monthly basis. The departments diligently comply with relevant laws and regulations in carrying out business operations in accordance with the Legal Compliance Management Guidelines and conduct self-evaluation using the “Self-Evaluation Form on Legal Compliance” every year.

Brogent organizes education and training on legal compliance awareness and legal knowledge for our employees every year. The departments may consult with the legal unit for professional opinions when in doubt of applicable laws. The competent authority or external consultants may be consulted when necessary.

In addition, Brogent also requires its suppliers to satisfy the Brogent Group's requirements on sustainable development, strictly carries out confirmation of the laws and regulations of the manufacturing and importing country, and provides to suppliers information on the laws and regulations of the importing country, and laws and regulations required to be complied with by the customer in the commissioning specifications, allowing suppliers to manufacture parts in compliance with the required laws and regulations, provide products that comply with international covenants, and ensure that the delivered products did not use “conflict minerals” from the Republic of Congo and its neighboring countries, thus bringing forth positive effects.

In 2022, Brogent has not violated any laws or regulations or engaged in any corruption in our corporate governance and integrity operations, and we have not accepted or made any political donation. We have not incurred any major fines or non-monetary penalties for violating environmental protection, social, or economic laws and regulations, either.