(1)

to encourage compliance with all applicable laws and regulations;

(2)

to promote honest and ethical conduct, including the ethical handling of conflicts of interest;

(3)

to promote full, adequate, accurate and timely disclosure;

(4)

to deter wrongdoing in duties;

(5)

to promptly discover and report any violations against code of ethics; and

(6)

to carry out all regulations and obligations in connection with this Code.

(1)

It is the Company's basic principle to act in good faith and with integrity in handling its relations with its clients and shareholders, as well as the society and other external interest groups, and also in handling the relations between the Company and its employees and among the employees.

(2)

It is each Senior Officer's commitment to the Company to act in good faith and with integrity. He or she shall not act in deceit or against the principle of good faith and integrity.

(3)

(4)

Each Senior Officer's obligation of good faith and integrity may not cease after the termination of his or her tenure at the Company. His or her obligation of confidentiality survives the termination of his or her tenure. Other duties may continue for such period as the principle of fairness may require depending on the amount of time which has lapsed between the termination and the act concerned and the circumstances and the terms under which the relationship between the Senior Officer on the one hand and the Company on the other hand was terminated.

(1)

any action taken, or any interest owned, by a Senior Officer that may hinder him or her to perform his or her duties objectively and effectively, and

(2)

any inappropriate personal interest obtained by a Senior Officer or his or her family as a result of his or her position at the Company.

(1)

take any advantage of his or her position to accept bribes or other illegal income;

(2)

take any advantage of his or her position or power at the Company to obtain any inappropriate interest for him- or herself or family members or any others;

(3)

take any advantage of his or her position or the Company's property or information to seize or have others seize from the Company any business opportunity, unless the Company is aware of such opportunity and has expressly given it up;

(4)

take any advantage of the Company's property, including any tangible or intangible assets and trade secrets to obtain any personal interest;

(5)

operate any business, whether on his or her own or as an employee, in competition with the Company;

(6)

engage in activities prohibited by Article 15.5 and 15.6 of the Articles of Association of China Communications Services Corporation Limited

(7)

engage in other activities that may cause any harm to the Company.

(1)

comply with the Company's Articles of Association, perform his or her duties faithfully, protect the Company's interests, avoid conflicts of interest wherever possible, and act honestly in the best interests of the Company;

(2)

discuss with the Board of Directors of China Communications Services Corporation Limited or the Board of Directors of a provincial subsidiary (collectively "the Company's Board") and material transaction or business relationship that may result in any conflict of interest; and

(3)

proceed such material transaction or business relationship only after the approval of the Company's Board. If the involved Senior Officer is also a member of the Company's Board, he or she may not participate the Board's discussion and vote for the approval such transaction or relationship. Pursuant to the Company's Article of Association, however, in the event that such transaction or business relationship is related to any contracts, transactions or arrangements entered into between the involved Senior Officer with the Company, or is related to commissions received in connection with transactions of the Company, such transaction or business relationship may not proceed without the informed approval of the shareholders given at a general meeting.

(1)

he or she owns a significant amount of equity interests or any other ownership interests in any of Company's suppliers or customers;

(2)

he or she has a relationship with any of the Company's customers, suppliers or competitors as a consultant, advisor or employee;

(3)

he or she has any external business activities that may detract him or her from devoting time and attention to his or her due performance in the Company;

(4)

he or she accepts or receives any material gift from any company that has an existing or potential business relationship which the Company;

(5)

he or she holds a position of supervising, reviewing or otherwise that may affect any of his or her immediate relatives' job evaluation, compensation or benefits; and

(6)

through him or her, as described in the Listing Rules of the Stock Exchange of Hong Kong Limited, any other company that becomes one of the Company's Connected Persons has any business relationship or transaction with the Company.

(1)

he or she shall be familiar with the Company's businesses, financial operations and information disclosure requirements;

(2)

he or she shall not consciously misrepresent or omit, or cause others to misrepresent or omit, any of the Company's material information to any internal or external parties, including the Company's independent auditors, government regulators and self-regulatory authorities; and

(3)

he or she shall carefully review and determine the accuracy and completeness of the information to be disclosed. (He or she may appropriately assign such responsibility to another party.)

(1)

to have designated persons start a preliminary investigation after receiving a report;

(2)

to determine, based on the investigation report, whether a Violation has occurred;

(3)

to take any appropriate actions for discipline or prevention (including dismissal), and in the event of any crime or other server legal violations, the applicable security regulatory authorities or other law enforcement authorities shall be notified; and

(4)

to timely disclose any amendments to or waivers of this Code made in accordance with the applicable securities regulations.

1.2.1

1.2.2

(1)

to encourage compliance with the Company's regulations, rules and disciplines;

(2)

to encourage honest and moral behaviors;

(3)

to encourage complete, true, accurate and timely disclosures;

(4)

to prevent misconducts;

(5)

to promptly identify or report any conduct against the code of ethics; and

(6)

to enforce regulations and obligations on professional conducts.

2.2.1

Integrity is the fundamental principle upheld by the Company in settlement of relations with customers, shareholders and others in the society, as well as the employer-employee relationship and the employee-employee relationship.

2.2.2

The employees shall be honest to the Company, and are barred from any fraud or any unscrupulous act against integrity ethics.

2.2.3

2.2.4

The integrity obligation of the employees shall survive the termination of the employment thereof as determined by the Company in the principle of fairness and in light of actual situation.

2.3.1

Employees shall fairly treat customers, suppliers, competitors and other employees of the Company.

2.3.2

Employees are prohibited from unlawful or unethical occupational behavior, or receiving corporate or personal gains via unscrupulous means. None should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice. The "gain" hereunder refers to any direct or indirect benefits for the Company, self or any other person, including any potential benefits.

2.4.1

2.4.2

2.6.1

Employee shall always stick to the principle of hardworking and thrift, and resist any extravagance, waste and luxury entertainment. Employee shall be subject to strict budget management, and should save as much as possible in duty performance and activities.

2.6.2

Employee is obligated to abide by environment protection policies, laws, regulations and rules in performing duties and shall minimize the discharge of harmful substance and negative environment impact as legally required.

(1)

Any act or any interests of the employee that may directly or indirectly impair his or her fair and efficient performance of duties.

(2)

Employee or his or her family members receive any improper personal benefits as a result of his or her position in the Company.

(1)

bribe others or receive bribe or other unlawful income as a result of the position in the Company;

(2)

make unlawful or improper benefits for himself or herself, or family members or other person as a result of the position in the Company;

(3)

seize or cause others to seize business opportunities of the Company by taking unfair advantage of the position or resources in the Company, unless the Company has known and waived such opportunity in writing;

(4)

seek for personal benefits in any manner through the corporate assets;

(5)

engage in, independently or jointly or for any other party, any business competing with the Company;

(6)

establish or maintain any direct or indirect consulting, advisor or employment relationship with any competitor of the Company;

(7)

engage in any other act impairing the interests of the Company.

(1)

abide by the Articles of Association and rules of the Company, loyally perform duties, avoid conflict of interests, safeguard the best interests of the Company and shareholders;

(2)

promptly report to same-level corporate supervisory department if there is any actual or potential conflict of interests in performing the duties.

(1)

the employee holds majority equity capital or other investor equity in any customer, supplier or competitor of the Company;

(2)

in any consulting, advisor or employment relationship with any customer, supplier or competitor of the Company;

(3)

receive any major benefits from any company having existing or potential business relationship with the Company;

(4)

engage in important business activities that occupy and disperse the time or energy commitment to the duties in the Company, and are independent from the interests of the Company;

(5)

assume any position in charge of supervision, examination, performance evaluation, compensation and benefits of any of his or her immediate family members or in any other manner.

4.1.1

Uphold the service philosophy of "Customer Service Culture", quickly respond to customer demands, honor promises, provide outstanding services to customers, truthfully inform the customers of any information about services and products of the Company in the principle of integrity in compliance with Rule 2.4 and Sections 5 hereunder, disclose no misleading, severely incomplete or fake information to customers;

4.1.2

Fairly and honestly treat customers; under equal conditions, each employee shall fairly treat all customers, fully respect customer's freedom in purchasing of services or products, and not impose unfair obligations upon or unequal business conditions to the customers against the intention of the Company through agreements or any other means; It is prohibited to take any act violating the current laws and regulations on customer interests protection, anti fraud and bribery, anti unscrupulous competition and anti monopoly;

4.1.3

Cautiously handle the arrangement of sales-related commission, discount, credit and allowance in the marketing process within legal, reasonable and proper range; provide sponsorship, gift, entertainment and business treatment to customers in the legal interest of the Company, and control such offer within the legal, reasonable and proper range; prohibit building up customer relation via bribing, discount and other illegal means or other means negative to the Company.

4.2.1

The employees shall fairly treat the suppliers, select suppliers via fair competition or bidding, and make comprehensive, independent, objective and fair consideration of the supplier qualification, product or service quality, business credit, quotation and after-sales services via bid invitation or other fair/reasonable means in light of the current rules of the Company;

4.2.2

Employees shall follow the rules below in business relation with supplies on behalf of the Company:

(1)	Abide by the provisions in Rule 2.1 hereof; prohibited from any unscrupulous competition, any behavior violating anti monopoly/corruption/bribing regulations;
(2)	Voluntarily protect legal interests of the Company, receive no bribe, discount or any other material benefits from suppliers that may prejudice independent business judgment of employees;
(3)	Stick to the corporate culture, respect the corporate culture of the supplier, treat suppliers and business representatives in generally accepted business etiquette, and not disclose any trade secrets or other confidential information of the supplier as mutually agreed or regulated.

4.3.1

In market competition, the Company is committed to trustworthy cooperation for mutual benefits in pursuit of a fair, orderly and efficient market competition order. The Company, upholding the principle of legal management and operation, prohibits employees from any occupational behaviors violating current laws and regulations about anti unscrupulous competition and anti monopoly. Any employee, becoming aware of any violation or potential violation of current laws and regulations about anti unscrupulous competition and anti monopoly by the Company or competitors, shall immediately report to the relevant departments of the Company.

4.3.2

In marketing process, highlight the market promotion through service, product and brand, prohibited from any unscrupulous competition means through exaggeration or distortion of facts, imputation of competing product quality, service quality, financial conditions and business reputation of competitors;

4.3.3

In the market research, obtain competitor information of products, service and marketing strategies through legitimate sources, prohibited from gaining any trade secrets or other confidential information of any competitor through illegal or improper sources;

4.3.4

Be extremely cautious in negotiation with competitors; in principle, any employee shall shun from any discussion of any topic that may constitute monopoly, limitation of competition or unscrupulous competition behaviors, and immediately notify the relevant departments of the Company.

4.4.1

Submit to lawful administration of the telecom market by regulatory authorities, and maintain close communications with the government to help safeguard legitimate interests of the Company;

4.4.2

In respect of the relationship with regulatory authorities or officers, the employees shall take due consideration of the anti-corrupt rules governing the government officers and control such behaviors within legal range, and it is prohibited to offer any benefits to regulatory officers that may impair his or her fair judgment. It is prohibited to bribe, directly or indirectly, any regulatory officer in the name of the Company, or take any act violating the spirit of anti-corruption/bribe regulations, or violating civil servant policies, laws, regulations and administrative rules about part-time job in companies;

4.4.3

Provide services to the government pursuant to Rule 4.1 hereof about customer relationship, and policies, laws, regulations and administrative rules about anti-corruption/bribe, government procurement, bid invitation and bidding;

4.4.4

Ensure true, complete, accurate and prompt disclosure to the government in any form, such as reports, applications, certificates and declarations; promptly communicate with the preparation organs of the Company if there is any misleading information, material omission, material mistakes, significant misunderstanding or other error in any information furnished to the government, and disclose to the government through the disclosure department of the Company for immediate correction.

4.5.1

Employees shall respect the dignity, religious belief and personal privacy of others, and are prohibited from harassing others in any manner, and any behavior resulting in threatening or hostile working environment.

4.5.2

All employees shall be devoted to teamwork from the macro perspective, forge the conscientiousness of joint creation and advance, be open-minded in sharing knowledge, experience and the joy of success with others, and try to excel over the average team level in terms of personal competence and contribution.