Introduction

This External Communication Policy establishes rules and guidelines of Inspur Systems regarding all company external communications, including speaking engagements and publications, crisis communications, political statements, and public endorsements. This Policy applies to all Inspur Systems employees, consultants, and contractors to uphold appropriate communications with external parties. Capitalized terms are defined in the “Key Terms” section at the end of this document. Any violation of this Policy should be brought to the attention of Inspur Systems Marketing Department or an Authorized Spokesperson and may constitute grounds for termination of employment.

Basic Principles

Complying with international conventions, laws, and regulations, and abiding by business ethics are core concepts that Inspur System adheres to. Inspur advocates fair competition and compliant operation, guarantees trade compliance, protects intellectual property rights, opposes any form of commercial violations, and embeds compliance requirements into the company’s policies, systems, and processes.

As one of the world’s leading providers of server solutions, Inspur strictly implements the applicable control requirements related to the sales, transfer, export, re-export, and processing of hardware, software, and technologies. Inspur System strictly complies with the requirements of the Bureau of Industry and Security of the U.S. Department of Commerce (BIS) and other relevant laws and regulations such as the Export Administration Regulations (EAR).

Inspur System is committed to being honest and trustworthy in external publicity behavior, not making false statements to anyone, and not making false exaggerated statements in the process of marketing and publicity.

General Policy

Only an Authorized Spokesperson may speak on behalf of the company with External Parties. No other individual is authorized to make comments to External Parties on behalf of the company.

Any Insider who is not an Authorized Spokesperson may not share internal information about the company unless that information has previously been released publicly. This includes but is not limited to information about the company’s operational results, business transactions, partnerships, and clients. Insiders who are contacted by an External Party about internal company matters/information must refer that party to an Authorized Spokesperson so that information is not provided inappropriately or inaccurately.

Any information presented publicly must either be previously authorized or receive authorization from upper management. Any information related to corporate capital, sensitive business operations, NDA clauses is strictly prohibited from being discussed with External Parties.

If any Insider suspects that unapproved information was leaked, whether intentionally or unintentionally, that Insider should immediately present the situation to the Marketing Department to handle.

All rules and guidelines laid out in this policy apply to all forms of communication, including in-person discussions, phone conversations, chat rooms, online forums, etc.

Client Information Security

Inspur System highly values client relationships and places great importance on maintaining the privacy and security of each customer. Insiders must strictly abide by business guidelines, and protect the privacy of customers in strict accordance with the NDA (Non-disclosure agreement) signed with customers or the confidentiality clauses related to business transactions. Insiders must comply with European GDPR laws and regulations, and must not sell, share, or disclose any personal information of customers without legal permission and customer authorization.

Press statements must protect the rights and interests of customers and not mention any content under the NDA terms on any occasion. If any customer-related information needs to be mentioned in any material, that information must be confirmed with the Marketing Department before use.

Information Related to Outside Companies

No Insider may discuss financial or operational information about outside companies, including competitors and partners. If any such questions are asked, one should suggest contacting the outside company in question directly.

Press Releases and Interviews

All media interview requests and press statements must be approved by the Marketing Department in advance. No media interviews on behalf of the company are allowed without the approval of the Marketing Department. Only an Authorized Spokesperson may give an interview on behalf of the company.

All content related to public speeches, media publicity materials, and press releases must be reviewed and filed by the Marketing Department. Any information that is not previously authorized by the Marketing Department must receive authorization from upper management prior to being released.

 

Key Terms

• “Authorized Spokesperson” is an employee or representative identified by the Marketing Department or upper management to speak on behalf of Inspur Systems.
• “Insider” is any employee, consultant, or contractor of Inspur Systems. All Insiders are subject to this Policy.
• “External Party” is any individual or organization that is not bound by a duty of confidentiality to Inspur Group or Inspur Systems.
• “Marketing Department” is the marketing team at Inspur Systems.