Self-disciplinary Convention for Member of Wuxi Bulk Stock Trading Association

(Accepted in the fourth session held by the first board of directors of the Association)

Chapter 1 General Provisions

Article 1 Wuxi Bulk Stock Trading Association (hereinafter referred to as “the Association”) and its members negotiate to develop the Convention and make a promise to abide by the Convention together, in order to strengthen the industrial self-discipline about bulk stock, normalize the professional conducts of members, improve the commercial morality of members, maintain a well-organized and fair industrial environment under the guidance of codes of practice about bulk stock, and promote the unity, self-discipline, and sustainable development of Wuxi bulk stock industry.

Article 2 The bulk stock stated in the Convention refers to the material commodities meeting the following requirements: they can enter the circulation domain other than retail link; they have the commodity attribute; they are used for industrial and agricultural production and consumption; in addition, they are bought or sold on a large scale. The trading market of bulk stock refers to the transaction place involving spot goods, serving the real economy, and developing the e-commerce circulation of bulk stock or wholesale of spot goods.

Article 3 The Convention applies to all members of Wuxi Bulk Stock Trading Association and trading units to which these members belong. These trading units make a promise to mutually supervise each other, abide by the Convention, unite and conduct self-discipline, consciously implement all agreements in the Convention, and consciously maintain the overall image of Wuxi bulk stock trading industry.

Chapter 2 Detailed Rules for Self-discipline

Article 4 The member unit and trading unit to which the member belongs shall both strictly abide by the national laws, the administrative laws and regulations, the departmental rules, and the relevant policies. They shall also strictly follow the articles of association, self-disciplinary regulations, and other relevant provisions. Furthermore, they shall scrupulously abide by the professional ethics and the professional integrity. According to the relevant laws and regulations, policies, and self-disciplinary regulations, they shall timely, accurately and completely announce all information about relevant business, and accept the supervision of the public.

Article 5 The member units shall establish and complete the legal-person governance structure and the internal control mechanism. They shall stick to the principle of “openness, impartiality, fairness, and good faith”. They shall run in accordance to relevant laws and regulations. They shall be diligent and conscientious. They shall perform fair competitions and devote themselves to continuously improving commercial morality and service level. They shall protect clients’ legal interests and maintain normal trading order of the industry.

Article 6 The member units shall strengthen the education management for their employees. The transaction place and its subordinate trading units shall not employ any personnel having defects in the professional ethics. They shall establish a well-organized career management system and an education & training system, so as to improve the education on the employee’s professional ethics and code of conduct, strengthen the business training, and increase the employee’s credit consciousness, business level, professional ethics level and comprehensive quality.

Article 7 The member units shall fairly and justly deal with all clients, strive to provide high-quality services, and protect clients’ legal interests. They shall fully reveal all relevant risks of the bulk stock trade to clients. They shall not perform any injurious act, such as credit-violation and fraudulent conduct, for clients’ interests. They shall not make up or spread false information to mislead clients, or induce clients to perform any unnecessary or irrational trading. They shall not develop any false, exaggerated, misleading or ambiguous publicity when soliciting business. They shall not only tell clients about the benefits but also the risks. They shall not ask clients to undertake loss together. They shall not develop clients not suitable for bulk stock trade or open accounts instead of such unqualified clients.

Article 8 During the brokerage, the member units and their subordinate trading units shall not accept or allow their staff to accept clients’ carte blanche to carry out any business exceeding the business scope, such as bulk stock trade. They shall avoid conflict of interest with clients. They shall timely disclose the probability of risk occurrence and relevant information to clients, to ensure clients’ benefits will be treated fairly. They shall keep clients’ trade secret and personal privacy. They shall not reveal any client data (unless otherwise specified by relevant laws and regulations, or except for the cooperation with organizations having right to investigate).

Article 9 The member units shall stick to the principle of fair competition, abide by the commercial morality, and maintain the normal industrial order. They shall not disturb the normal trading order. They shall not solicit business by

using any publicity means that are prejudicial to the benefits and image of other member units, or defaming the trade reputation of other units in the industry, or revealing trade secret of other units.

Article 10 The member units shall establish and complete a business rule system, normalize the delivery mode and procedures of goods, increase the protective consciousness of market risks, and improve the risk management capability.

Article 11 The member units shall take full responsibilities for the education management of their subordinate trading units. The member units shall regularly visit their subordinate trading units, and hold trainings for their subordinate trading units and trading staff, to improve the comprehensive quality of their subordinate trading units.

Article 12 The member units shall complete the supervision and service mechanism for bulk stock trade, strengthen the establishment of information system, and guarantee that trading will be legally carried out in order. It is forbidden to carry out any trading activities that will damage or influence the safe operation of market or the market order, such as insider trading and market manipulation.

Article 13 The member units shall implement the system of unified registration and settlement, to achieve the interaction with Jiangsu Exchange Depository and Clearing Co., Ltd. And guarantee the safety of transactional capital.

Article 14 The member units shall pay high attention to timely disposal of various complaints, and develop their own complaint handling method. General complaints shall be replied within 10d, and special or complex complaints shall be replied within 15d. The member units shall handle complaints based on facts, relevant rules, and the principles of “good faith and fairness”. The member units shall receive complainants in a polite, warm, and sincere manner. The member units shall patiently and meticulously reply and interpret to the complainants. The member units shall not shuffle or skimp the complainants to avoid intensification of the contradiction.

Article 15 The Association accepts authorization from Wuxi Financial Affairs Office and various complaints. In addition, the Association will develop basic investigation. The member units shall actively cooperate with the Association, without any evasiveness. Within 7 working days, the member units shall complete an investigation report and submit corresponding evidences to the Association. Moreover, the member units shall be responsible for the authenticity of investigation report and evidences. If there are any unambiguous evidences proving that a member or its subordinate trading units break(s) the rules, the member or its subordinate trading units shall be treated in accordance with relevant systems and rules, and the member or its subordinate trading units shall compensate complainants for their economic loss.

Article 16 The member units shall establish an information disclosure system. They shall issue announcement via the member units’ websites and the Association’s website, to timely, accurately, truly and fully disclose the market operation conditions, risks of abnormal trading, and major changes in transaction system and business rules. They shall protect the legal interests of clients and traders. They shall not make up or spread any false information about commodity transaction.

Article 17 The member units shall mutually respect and help each other, to pursue a mutual development. They shall be subject to the operation philosophy of modern financial enterprise, and actively undertake industrial responsibilities. They shall not damage the industrial reputation or common benefits of members.

Article 18 The member units shall actively undertake the social responsibility of enterprise. They shall actively organize and take part in public interest activities in various forms. They shall shape a good image for bulk stock trade in Wuxi City.

Chapter 3 Supervision

Article 19 The Association will organize to implement the Convention, and supervise and check the implementation of the Convention carried out by the member units.

Article 20 To facilitate the implementation of the Convention, the Association will regularly check and assess the implementation of the Convention. The Association will commend enterprises with good behaviors and reputation and recommend such enterprises to relevant government departments for further evaluation.

Article 21 The Association will accept complaints about the member units. The member units and their subordinate trading units shall cooperate with the complaint handling carried out by the Association. If occurrence of defaults is verified, the member units or their subordinate trading units shall pay the complaint acceptance fee to the Association by RMB 2,000-3,000 per case. If the quantity of complaints in each quarter exceeds 5 cases and such complaints are verified, the complaints will be submitted to the relevant department for rectification under supervision. In addition, the clients’ transaction deposit ratio in the next quarter will be increased by 2%. If the rectification effects are obvious, the Association will conduct a reassessment to decide whether the regular payment ratio will be used again or not.

Article 22 The Association has right to appropriately punish the member units for their negligent act, wrongful act and even illegal behavior and unlawful act in terms of self-disciplinary image, involving compliance operation, cooperation with supervision and management, and public trust. The member units shall accept written expostulation, circulated criticism inside the Association, public censure via media, suggestions about administrative penalty by relevant supervision departments, and cancellation of membership and announcement of the cancellation.

Article 23 The Association shall carefully listen to the party involved for its explanations before making the punishment decision. The punishment decision will not be implemented unless it is accepted by the board of directors.

Chapter 4 Supplementary Articles

Article 24 The Convention goes into effect upon the deliberations made in the fourth session held by the first board of directors.

Article 25 The Convention is interpreted and revised by Wuxi Bulk Stock Trading Association.

Article 26 If the Convention conflicts with the laws and regulations in China and rules of supervision organizations, the laws, regulations and rules shall prevail.

August 31, 2015