Foreword
Midea is a technology group operating in the fields of consumer appliances, HVAC systems, robotics and automation, and smart supply chains (logistics). The Group is committed to the principle of "Creating Value for Customers," with a continued focus on technological innovation and a mission to "Create a Better Life for Humanity."
All employees are expected to comply with applicable laws and ethical standards in the course of business activities, thereby ensuring Midea’s standing as a responsible corporate citizen. Each employee is required to thoroughly read and adhere to the provisions of this Code of Conduct. Any violations may result in disciplinary action.
This Code serves as a framework to guide employees in making appropriate decisions when representing the Company in business dealings. It is acknowledged, however, that no code can cover every eventuality. Where this Code does not provide specific guidance, employees are encouraged to consider whether their actions align with their moral conscience, comply with the law, and reflect Midea’s values.
1. Purpose and Scope
1.1 All Midea Group employees are expected to uphold applicable laws, regulatory requirements, and fundamental ethical principles in all business activities, thereby advancing Midea’s commitment to responsible corporate citizenship. Employees must familiarize themselves with, understand, and comply with this Code of Business Conduct; violations will be subject to appropriate disciplinary action in accordance with established policies and procedures. Recognizing that no code can anticipate every scenario, this Code serves as a foundational framework—not an exhaustive rulebook. When faced with complex or unaddressed situations, employees are expected to exercise sound judgment by evaluating whether their decisions reflect personal integrity and professional ethics, comply with applicable laws, and align with Midea’s stated values;
1.2 This Code applies to Midea Group and its subsidiaries and departments.
2. Compliance with Laws, Regulations and Ethical Requirements
2.1 Midea Group is a global company and our business shall be conducted in accordance with the laws and regulations of the countries or regions where we operate;
2.2 Each employee of the Company shall abide by the highest ethical standards, conduct business in good faith, respect others, and set strict demands on themselves;
2.3 The integrity and compliance of all organizations originate from senior management. Management shall set an example in respect to ethics and integrity, perform its management and supervision duties, and ensure all managed personnel understand their responsibilities pursuant to the Code and other policies of the Company.
3. Fair Competition
3.1 The sustainable development of Midea Group’s business is contingent upon strict compliance with applicable laws and regulations, as well as adherence to fair competition;
3.2 The Company expressly prohibits entering into monopoly agreements with any individual or entity, and categorically refrains from abusing its dominant market position. It also opposes any merger or acquisition that has, or is likely to have, anticompetitive effects, whether unreasonable or unlawful, including the exclusion or restriction of competition;
3.3 Employees acting on behalf of the Company must comply with applicable laws, uphold voluntariness, equality, fairness, honesty and good faith, adhere to accepted business ethics, and refrain from unfair competition, including dumping, IP or trade secret infringement, false advertising, collusive tendering, reputational harm, or other improper practices.
4. Avoiding Conflicts of Interest
4.1 A conflict of interest arises when an employee’s personal relationships, familial ties, private interests, or external business affiliations impair, or reasonably appear to impair their ability to act solely in the best interests of the company.
4.2 Conflicts of interest may arise when an employee maintains familial, financial, or other substantive relationships with the company’s competitors, suppliers, customers, or other third parties, or when such relationships exist among employees within the Company;
4.3 Employees must promptly disclose any actual or potential conflicts of interest and consistently act in the best interests of the Company.
5. Gifts, Entertainment and Hospitality
5.1 Offering gifts, entertainment and hospitality:
5.1.1 To develop external contacts and business relationships, it is proper to offer courtesy gifts, entertainment, or business hospitality that conform with business customs. Employees must proactively familiarize themselves with the applicable gift, entertainment, and hospitality policies of suppliers and clients before offering gifts, arranging entertainment, or hosting business hospitality, and strictly adhere to both external requirements and the Company’s internal standards;
5.1.2 Gifts, entertainment, and business hospitality must comply with the Company’s established standards. It is strictly prohibited to offer gifts or provide hospitality for the purpose of obtaining improper advantage.
5.2 Accepting gifts, entertainment and hospitality:
5.2.1 Employees may accept, on an exceptional basis and only where consistent with prevailing business practices and locally accepted customs, gifts of purely symbolic value or modest invitations to meals and entertainment; all other gifts, meal invitations, or entertainment offers must be respectfully declined;
5.2.2 Employees are strictly prohibited from soliciting or accepting improper benefits, whether directly or indirectly, from suppliers, customers, or other stakeholders by virtue of their official position, authority, or access arising from their employment.
6. Anti-corruption
6.1 Prohibition of commercial bribery: Product competitiveness is the foundation of Midea Group and the Company is committed to delivering high-quality products and continuously enhancing its services within a business environment grounded in fairness, integrity, and sound governance. The Company expressly prohibits securing business opportunities through unfair competitive practices, including the provision of monetary payments or other improper benefits to personnel of counterparties or to any third parties capable of exerting influence over the transaction;
6.2 Prohibition of offering bribery to government officials:
The Company strictly prohibits offering gifts, entertainment, or business hospitality to government officials or their close relatives, unless expressly authorized and approved in advance. Such conduct, whether undertaken in the Company’s name or that of an individual employee, may violate applicable anti-corruption laws, including domestic and extraterritorial statutes, and may result in significant civil or criminal liability for both individuals and the Company, as well as reputational harm.
6.3 Political donations, charitable contributions and sponsorship:
6.3.1 Midea Group makes no donation to political parties, politicians or political organizations;
6.3.2 As a responsible corporate citizen, Midea Group fulfills its social responsibilities through strategic engagement in public welfare initiatives, including education, healthcare, livelihood support, disaster relief, and charitable programs, by providing financial contributions and in-kind donations;
6.3.3 The Company may provide sponsorship only for legitimate, bona fide business purposes; it is strictly prohibited from offering sponsorship to secure an unfair competitive advantage or for any other improper, unethical, or unlawful purpose;
6.3.4 All donations and sponsorships must be transparent.
7. Anti-money Laundering
7.1 Employees are strictly prohibited from participating in any money laundering activity, including the concealment or disguise of the origin or nature of proceeds derived from predicate offenses such as drug trafficking, terrorist financing, smuggling, embezzlement, bribery, and violations of financial regulatory laws;
7.2 The Company will periodically review the implementation and effectiveness of its internal anti-money laundering program, and initiate targeted anti-money laundering investigations into large-value suspicious transactions lacking verifiable shipping or sales documentation in the system and for which no legitimate business rationale has been established;
7.3 The Company shall, in the course of establishing business relationships with clients or conducting transactions therewith, adhere strictly to the “Know Your Customer” (KYC) principle by identifying and verifying the identity of clients, and shall, where required, lawfully cooperate with financial institutions in their KYC due diligence processes.
8. Compliance with Export Control and Customs Laws
8.1 Midea Group complies with the export control and customs laws applicable in the countries where it operates. Export control generally applies to the transfer of goods, services, hardware, software or technology across certain national borders, including in the form of emails and internet access, or the provision of important information to certain individuals in such countries. Direct or indirect exports to or imports from sanctioned countries or parties may trigger export control laws. Sanctioned countries or parties may be identified by the United Nations or relevant countries based on foreign policy, public order, national security or their involvement in criminal activities. Violation of the above laws and regulations may result in severe penalties, including but not limited to termination of employment, fines, imprisonment, revocation of import and export licenses, inclusion on trade sanctions lists and prohibition of entry and exit;
8.2 Employees engaged in the import & export business of the aforesaid goods, services, hardware, software or technologies shall comply with applicable laws and regulations about economic sanctions, export control and imports, as well as related policies and procedures established by the business department they serve.
9. Prohibition of Transactions Using Inside Information
9.1 Prior to the official disclosure of Midea Group’s inside information, particularly information that is material to the Company’s securities price, no employee may, directly or indirectly trade in the information related Company’s securities or information related financial instruments; provide investment advice or recommendations based on such information; disseminate or publish the information externally; disclose it to any person lacking a legitimate need-to-know and proper authorization; or assist, induce, or facilitate any third party in engaging in market manipulation involving the Company’s shares or their derivatives. Violating this prohibition constitutes insider trading by the employee under applicable laws and may give rise to civil liability, criminal prosecution, regulatory sanctions, and disciplinary measures;
9.2 The directors, supervisors and senior management of the Company are forbidden to trade using inside information. They shall also comply with the restrictive legal regulations on the purchase & sales of the Company's shares, including restrictions on the proportion of shares sold in a special period or shares reduced, as well as the restrictions on short-swing trading and trading in the window period;
9.3 Employees with access to material non-public information are required to exercise heightened diligence and discretion in all verbal and written communications, conduct, and professional activities.
10. Protection of the Assets and Reputation of the Company
Assets and reputation are foundational to Midea Group’s sustainable development and long-term value creation. Each employee shall protect the assets of the Company within their control scope, and maintain and improve the reputation of the Company in all countries. The assets of the Company include tangible assets and intangible assets. Intangible assets include intellectual property rights, non-public data, information, and other business secrets.
10.1 Tangible assets:
10.1.1 Tangible assets of the Company include cash, property, office supplies and facilities, machines and equipment, inventory products and parts, stamps, vehicles, computer hardware systems, and other materials;
10.1.2 Employees shall protect the Company's tangible assets from being stolen, lost, damaged or misused.
10.2 Intellectual property:
Intellectual property includes patents, trademarks, copyright, know-how, technical secrets, computer source code, software programs and other intellectual achievements made in work that are owned by the Company and should be protected in reliance on the huge input of human and material resources, and are an important asset concerning core competitiveness. All employees have the responsibility to protect all intellectual property of the Company that becomes known to them.
10.3 Trade secrets:
Every employee bears a duty to safeguard the Company’s business secrets. This includes, but is not limited to, product roadmaps, pricing strategies, business plans, and other technical or commercial information accessed, learned, or generated in the course of employment. Employees must implement appropriate and proportionate confidentiality measures consistent with their role, access level, and the sensitivity of the information, exercising diligence, integrity, and professional judgment at all times. Unauthorized disclosure to external parties or to internal personnel lacking a legitimate need-to-know is strictly prohibited. Upon termination or cessation of employment for any reason, employees shall promptly return or securely destroy all tangible and electronic materials containing such information, and shall refrain from retaining, copying, disseminating, publishing, or commercializing any portion thereof.
10.4 Reputation:
The Company’s reputation is a strategic intangible asset, cultivated over time through sustained product innovation, service excellence, operational rigor, transparent engagement with consumers and clients, and steadfast commitment to corporate social responsibility. Public trust, particularly that of customers and stakeholders, is foundational to long-term viability and sustainable growth. Safeguarding this reputation is a shared obligation of every employee. Accordingly, employees must refrain from making any public statements, comments, or disclosures that could reasonably be construed as damaging to the Company’s brand, integrity, or commercial standing. To ensure consistency, accuracy, and compliance in external communications, no employee may respond to media inquiries, interview requests, or information solicitations from the public or third parties without prior written authorization from either their immediate line manager or the Group’s designated department responsible for corporate communications or investor relations, acting within its delegated authority. All such requests must be promptly escalated to the appropriate authorized function for assessment and response. Notably, inquiries from financial media, equity analysts, or other capital markets participants fall exclusively under the purview of the Group’s relevant investor relations management department, which retains sole authority to approve and manage such engagements.
11. Compliance with the Business Decentralization System of Midea
“Authorized operations” are the core value of Midea Group. Reasonable centralization, ordered decentralization, well-regulated authorization and the moderate use of authorization constitute the basic principles of the Company’s business regulations. To ensure ordered business management, the Company has established a unified process approval system. Each employee shall comply with this system.
12. Cooperation with Business Partners
Midea Group expects its business partners, including suppliers, distributors, and other third-party collaborators to affirm their commitment to this Code of Business Conduct and to Midea Group’s core values, to comply fully with all applicable laws, regulations, and to uphold principles aligned with the Company’s commitments in key areas including stakeholder engagement, environmental stewardship, anti-corruption, and fair competition.
13. Accurate and Complete Work Logs
13.1 The financial records of Midea Group, including accounting vouchers, financial books, and accounting reports, must be clear, complete, accurate and comprehensive, and must not be intentionally deleted, altered, forged or falsified;
13.2 Business records must promptly, accurately and clearly reflect the nature and specific status of each transaction. Employee records, customer information, financial vouchers and contract documents in paper or electronic form generated during the business transaction must be properly kept;
13.3 The meeting minutes in the work and the Company’s internal process applications should be as normative as possible. Employees shall pay attention to preserving important e-mails and business communication records for contingency purposes.
14. Providing a Good Working Environment
14.1 Midea Group adheres strictly to all applicable labor and occupational health and safety laws and regulations in the jurisdictions where it operates. It upholds employees’ fundamental rights and dignity, ensures equitable and competitive compensation and benefits, maintains a safe and health-promoting work environment, fosters career progression through structured development pathways, and delivers high-impact training to strengthen professional competence;
14.2 Midea Group maintains a zero-tolerance policy regarding the misuse of prohibited drugs and alcohol. Substance abuse is compromising workplace safety, operational efficiency, and team morale. The possession, use, or distribution of prohibited drugs and alcohol is strictly prohibited on company premises at all times. No employee may use prohibited drugs or alcohol, or perform work while impaired by such substances, during working hours. Limited and responsible alcohol consumption is permitted solely at company-sanctioned events, provided it complies fully with applicable local laws, including the legal minimum drinking age, and does not compromise professional conduct, safety performance, or operational readiness.
14.3 The Company prohibits discrimination based on race, color, culture, religion, political opinion, marital status, gender, or any other characteristic protected under applicable law. It maintains a zero-tolerance policy toward harassment, violence, threats, intimidation, coercion, or any other conduct that violates human dignity, personal safety, or workplace integrity.
15. Privacy Protection
15.1.1 The Company shall not disclose any employee’s personal information obtained during recruitment or employment management to a third party unless the employee has provided prior authorization, or the disclosure is necessary for legitimate purposes, and the receiving party has undergone a rigorous assessment of its information security practices. Employees are strictly prohibited from using the Company’s internal information systems, or any other means, to unlawfully access, collect, disseminate, or otherwise process employee personal information. Furthermore, employees must not disclose any personal information concerning other employees, acquired in the course of their duties, to any individual or entity lacking a legitimate business need-to-know.
15.1.2 The Company reserves the right to access, copy, and use any work-related information stored on or generated through Company-provided computers, mobile phones and other devices and systems, including but not limited to documents, emails, audiovisual files, business communications, attendance data, and business travel records. Employees are expressly prohibited from storing sensitive personal information on Company-provided devices or systems. Any such information stored in violation of this policy shall be deemed voluntarily disclosed and shall not be entitled to privacy safeguards.
15.2 All personal information and user data obtained in the course of business operations shall be treated as confidential.
16. Optimize resource utilization, uphold environmental sustainability, and deliver high-quality products and services
16.1 Midea Group complies with national and international standards on environmental protection. Environmental sustainability and intelligent innovation have emerged as defining trends shaping the evolution of home appliances. The Company makes a positive effort to promote energy-saving appliances and avoid wasting resources. The Company actively promotes the use of clean energy during production to reduce pollution and emissions. The employees are required to have a sense of conservation to avoid wasting resources during production and work.
16.2 Midea Group is committed to delivering products and services that consistently meet or even exceed customer expectations regarding quality, reliability, safety, and total value, thereby reinforcing long-term trust and partnership. The Company has established and rigorously enforces a comprehensive quality management system, ensuring that all product design and manufacturing processes fully comply with applicable national and international regulatory requirements for product quality and safety, as well as contractual obligations stipulated in customer agreements. Furthermore, the Company collaborates proactively with suppliers to co-develop and implement targeted quality improvement initiatives, strengthening quality performance and enhancing the overall reputation of its products and services.
17. Non-Compliance Consequences of This Code
17.1 Once the requirements set forth in this Code and the applicable company policies become effective, employees are deemed to have full knowledge thereof. Employees shall, at all times and under all circumstances, conduct business activities strictly in compliance with both this Code and such applicable company policies. In the event of any conflict between this Code and any company policy, the provisions of this Code shall take precedence;
17.2 Employees found to have violated this Code or any applicable company policies shall be subject to appropriate accountability measures, as stipulated herein and in the relevant policies;
17.3 All business partners engaged in commercial relationships with the company are required to comply with the requirements set forth in this Code. Non-compliance may lead to termination of the business relationship, imposition of contractual or statutory liabilities, and other appropriate consequences;
17.4 Midea Group maintains a strict zero-tolerance policy with respect to any violation of this Code. Authorized by applicable internal policies, designated departments shall conduct prompt and impartial investigations into alleged violations, take immediate corrective or disciplinary action where warranted, and implement targeted remedial measures, including enhancements to governance frameworks, compliance training programs, and monitoring mechanisms, to proactively identify, mitigate, and prevent emerging or systemic compliance risks;
17.5 All employees who become aware of, or possess reasonable grounds to suspect, a violation of this Code are required to report it promptly through the Company’s designated reporting channels. The Company expressly encourages reporting under one’s true name and guarantees strict confidentiality of both the report content and the reporter’s identity. Retaliation, whether direct, indirect, overt, or covert, against any individual who reports in good faith, is strictly prohibited. Employees who believe they have experienced retaliation following a report may escalate the matter to the management of their respective business unit or directly to the Compliance Department of the Group’s Legal;
17.6 Employees can report law or Code violations through these channels:
Immediate supervisor: Employees may report to their immediate supervisor—or, if preferred, to a higher-level manager;
Legal and Compliance Counsel: Employees may consult or report via Midea Connect, email, phone, or other channels, to the legal and compliance team of their unit or the Group’s Legal.
The employee may also take the following measures:
Call the complaints hotline: +86 757 23600034/0757 23600034
Send E-mail to: Compliance @midea.com