Radiant Opto-Electronics Corporation (the “Company”) is committed to engaging in public affairs on a lawful, transparent, and responsible basis, while maintaining effective communication with government authorities, industry associations, and relevant stakeholders. To support industrial development, technological innovation, corporate sustainability, and social responsibility, the Company has established these Guidelines and manages lobbying activities and membership in industry associations to ensure that such engagement is aligned with the Company’s operating principles and sustainability commitments.

I.  Public Policy Participation Governance Framework

The Company has established a public policy participation governance framework that defines relevant responsibilities and accountability mechanisms. Appropriate executive level personnel are responsible for overseeing public affairs, lobbying activities, and participation in industry associations, and may report to senior management when necessary to ensure that the Company’s public policy participation activities are subject to proper governance and oversight.

II.  Management System for Lobbying Activities and Industry Association Membership

The Company has established a management system for lobbying activities and membership in industry associations to review the purpose, scope, membership status, and external advocacy positions of industry associations, chambers of commerce, and other relevant organizations in which the Company participates. Any policy communication, advocacy, or expression of views with government bodies or external organizations shall be handled in accordance with the Company’s internal procedures, and necessary records shall be retained to ensure transparency and traceability.

III. Position on Climate Change-Related Public Policies

With respect to climate change-related public policies, the Company supports the principles of global net-zero transition, climate risk mitigation, and sustainable development, with the goal of aligning its position with the Paris Agreement. Any public stance or advocacy by the Company regarding climate change, energy transition, carbon reduction policies, or related regulations shall reflect the Company’s commitment to climate action and remain consistent with the direction of the Paris Agreement.

IV.  Review and Oversight

The Company shall review and assess whether public policy participation and lobbying activities are aligned with the Paris Agreement and the Company’s sustainability position. The scope of review includes:

1.  Direct lobbying activities; and

2.  Participation in trade associations, chambers of commerce, and other relevant organizations, including related advocacy positions and activities.

If any relevant activity, position, or public statement is found to be inconsistent with the Company’s climate position, the matter shall be reviewed, communicated, and addressed through appropriate improvement measures.

V.  Mechanism for Addressing Inconsistencies in Industry Association Positions

When the public stance of any industry association, chamber of commerce, or related organization in which the Company participates differs from the Company’s position on climate change policy, carbon reduction advocacy, or sustainability issues, the Company shall:

1.  Proactively communicate with the organization to express the Company’s position and request a review of the discrepancy;

2.  Establish reasonable corrective measures or an improvement approach, as appropriate; and

3.  If the issue is not properly addressed, take appropriate action, including reassessing the membership relationship, reducing the level of participation, or withdrawing from the organization.

VI.  Disclosure and Reporting

The Company shall appropriately disclose direct lobbying activities related to climate issues as well as the climate policy positions and activities of trade associations. Relevant information may be presented in the sustainability report, on the corporate website, or through other appropriate channels to ensure that stakeholders understand the Company’s principles and practices regarding public policy participation, climate advocacy, and participation in industry associations.

VII. Scope of Application

This policy applies to all jurisdictions in which the Company operates. All public affairs participation, lobbying activities, and management of industry association memberships conducted by the Company across its global operating locations shall comply with these Guidelines.

VIII. In the event of any inconsistency between the English version and the Chinese version of these Guidelines, the Chinese version shall prevail.