Given that the Code of Ethical Business Conduct for all employees of APT Satellite Holdings Limited (the “Company”) with its subsidiaries and associates (if applicable) is to:

1. promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
2. romote full, fair, accurate, timely, and understandable disclosure in the periodic reports required to be filed by the Company; and
3. promote compliance with applicable governmental rules and regulations.

To achieve the foregoing standards, the Company expects all its employees (“Employees”) shall conduct businesses of the Company in a fair, ethical and proper manner, and in full compliance with all applicable laws, rules and regulations, as well as this Code and all relevant internal policies and procedures.

Employees are therefore required to comply with the following the situations:

•  Employees must not allow personal interests to conflict with the interests of the Company.
•  Employees must be prohibited from (a) taking for themselves personally opportunities that are discovered through the use of the Company's property, information or position; (b) using the company's property, information, or position for personal gain; and (c) competing with the Company.
•  Employees must maintain the confidentiality of information entrusted to them by the Company or its customers, except when disclosure is authorized or legally mandated. Confidential information includes all non-public information that might be of use to competitors, or harmful to the Company or its customers, if disclosed.
•  Employees must deal fairly with the Company's customers, suppliers and competitors. None should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice. Dealings must be done in accordance with the relevant internal policies and/or procedures of the Company.
•  Employees must use the assets of the Company, customers or suppliers properly and carefully.
•  Employees must comply with all applicable laws, rules and regulations.
•  Employees must report any illegal or unethical behavior including breach of the Code of Business Conduct to appropriate personnel or authorities. Retaliation for reports made in good faith is not allowed by the Company. Employees should be aware that the Company has a duty to protect any employee reporting his or her concerns, for details, please refer to the “Whistleblower Protection Policy”.

After all, the foregoing situations are not intended to be exhaustive. Prompt and early consultation with immediate supervisor or manager is therefore encouraged when in doubt.

The Code is the minimum standard of behavior that the Company expects of its employees, breaches will be taken into consideration when assessing performance pay, discretionary bonuses, merit raises and renewal of fixed term contracts etc. In extreme, material cases the Company shall treat such breach as a breach of employment contract and consider termination of employment.