CHAPTER I. GENERAL PROVISIONS

I. Purpose of the Code

1. The Code of Ethics (“Code”) represents VTG Securities Joint Stock Company’s (“Company”, or “VTG”) commitment to conduct business activities in compliance with laws and ethical standards, with the purpose of guiding the identification and handling of situations involving ethical issues.

2. Understanding and complying with this Code is a prerequisite to build VTG’s reputation with the market and customers, professional reputation with society, and worthy of customers’ trust.

II. Applicable subjects

All officers and employees of VTG Securities Joint Stock Company are responsible for complying with this Code of Conduct.

III. Definition of terms

The terms in this Code of Conduct are understood as follows:

Professional ethics : Are standards of conduct that demonstrate honesty, prudence, professionalism and responsibility in work, implemented to protect and enhance the role and reputation of the profession and practitioners towards society and customers.

VTG’s officers and employees include members of the Board of Directors, managers and all other officers and employees who have signed labor contracts with VTSS in any form: official, probationary, collaborator or any other form.

Inside information : Information related to a public company or public fund that has not been permitted to be disclosed and, when disclosed, may have a major impact on the stock price of that public company or public fund.

CHAPTER II. CONTENT OF THE CODE

In all activities, VTG officers and employees are responsible for complying with the following basic principles of professional ethics:

1. Comply with the laws, procedures, rules and regulations of the Company:

Must comply with the laws and regulations on securities and the securities market and the regulations, processes and operations applied at the Company.

2. Ensure honesty, objectivity, fairness and transparency in practice

– Must be fair, respect the truth and not be prejudiced or biased in all your actions;

– VTG officers and employees are not allowed to receive gifts or any personal remuneration from customers or partners, in any form;

– VTG officers and employees are not allowed to use inside information to buy and sell securities for the Company or individuals and are not allowed to use inside information to guide investment for customers;

– Information provided to customers must be fair to all customers;

– It is not allowed to guarantee the benefits that customers will gain from investing other than providing factual information related to the investment;

– Do not perform any operations that the company does not have regulations or does not allow;

Preventing conflicts of interest: Must clearly disclose information related to conflicts of interest between the Company and customers or between individuals and customers when advising or instructing customers where the conflict may affect the customer’s investment results.

3. Ensure professional competence and prudence:

– The Company is responsible for building a unified system, regulations, rules, and procedures, ensuring compliance with current laws; recruiting and arranging a team of appropriately qualified personnel so that employees can work with the utmost care and responsibility for their positions;

– Officers and employees of VTG Securities Joint Stock Company must continuously update changes related to the securities business profession, including the application of modern technology and compliance with relevant legal regulations; act properly and carefully in accordance with professional procedures when providing services to customers.

4. Compliance with security principles:

VTG officers and employees must keep confidential all information obtained during the course of their work. They must not disclose any information without the permission of a competent authority, unless they are required to disclose it by law or within their professional authority.

5. Ensuring professional qualifications:

VTG officers and employees have the duty to maintain, update and improve knowledge in practical activities, in the legal environment and technical advances to meet job requirements; must cultivate and protect professional reputation, must not cause acts that reduce professional reputation.

6. Relationship with management organizations

VTG officers and employees, especially the Company’s Board of Directors, must provide and cooperate closely with the competent authorities and must provide all information and data requested by the competent authorities in accordance with current regulations of the competent authority.

7. Advertising

In marketing and promoting their business and work, officers and employees of VTG Securities Company are not allowed to:

– Using means that may affect professional image and reputation;

– Exaggerate the work and services that VTG can do or provide;

8. Some additional regulations applicable to officers and employees performing brokerage services

– Comply with the principles of entering transaction orders: in the correct order of order receipt time;

– Do not arbitrarily use money or securities in customer accounts;

– Do not use the customer’s trading account to buy and sell securities for yourself or for others;

– In consulting activities: not allowed to make decisions on behalf of clients about securities transactions;

– Do not entice or invite customers to continuously buy or sell securities to create fake supply or demand or for other purposes;

– Do not directly or indirectly collude with others to manipulate stock prices;

– Do not edit information or forge customer signatures on transaction forms. In case of receiving invalid purchase or sale orders from customers, the orders must be returned to the customers for editing or re-issuing;

– Do not collude with outside organizations or individuals to conduct buying and selling transactions for profit;

– Do not use internal information to guide customers;

9. Some additional regulations applicable to officers and employees performing securities investment consulting and analysis services

– Not to make any statements or guarantees to customers about the income or profit achieved on their investments or to guarantee that customers will not suffer losses, except in the case of investments in fixed income securities;

– Research reports must be specific and careful, results must be clearly published, not leading to misunderstanding;

– In reports, it is necessary to clearly distinguish between factual, objective information and subjective assessments or predictions;

– It is strictly forbidden to profit from inside information, either for yourself or for others;

– Ensure independent and objective analysis and consulting activities;

– Do not copy or use other people’s analytical products without clearly citing the source;

– Absolute confidentiality of customer information in consulting and analysis activities.

CHAPTER III - IMPLEMENTATION PROVISIONS

– VTG officers and employees are obliged to read and understand the regulations stated in this Code of Conduct and strictly comply with them.

– Officers and employees who discover violations are obliged to report to their direct supervisor or the Internal Control Board or the Company’s Human Resources Officer.

– Officers and employees who violate the above regulations will be subject to disciplinary action ranging from warning to dismissal depending on the severity of the violation and will be responsible for compensating for damages caused by such violation.

– This Code of Professional Ethics consists of 03 chapters and takes effect from the date of signing and promulgation by the General Director of VTG Securities Joint Stock Company.

CEO

(Signed)

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