Corporate Integrity, Fair Competition, and Zero-Tolerance Governance

1. Introduction

Bribery and corruption pose significant legal, financial, and reputational risks to modern enterprises. As global regulatory scrutiny intensifies—driven by laws such as the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, China’s Criminal Law, and anti-unfair competition regulations—companies must establish strong control mechanisms to ensure transparency and ethical conduct in all business activities.

This Anti-Bribery and Corruption (ABC) policy outlines the commitments, responsibilities, and operational standards that guide our employees, managers, contractors, suppliers, and other business partners in preventing all forms of bribery and corruption.

2. Policy Statement

Our company adopts a zero-tolerance approach to bribery and corruption.
No employee or associated person shall, directly or indirectly:

• Offer, promise, give, request, or accept bribes, kickbacks, rebates, facilitation payments, or improper benefits.

• Influence business decisions through unlawful means.

• Provide benefits to public officials, clients, suppliers, or third parties to obtain or retain business advantages.

• Conceal, misreport, or falsify financial records to hide improper transactions.

Compliance with this policy is mandatory for all employees, subsidiaries, contractors, consultants, agents, and any third-party working on behalf of the company.

3. Scope of Application

This policy applies to:

• All employees at all levels (management, administrative, technical, operational staff)

• Subsidiaries, branches, joint-venture operations

• Contractors, consultants, distributors, intermediaries, brokers

• Suppliers, outsourcing partners, and any other third parties representing the company

The responsibilities extend to all business activities, including procurement, sales, marketing, bidding, contract negotiation, project execution, government communication, and overseas operations.

4. Prohibited Conduct

4.1 Bribery

Giving or receiving anything of value—including cash, gifts, entertainment, travel, services, discounts, or favors—to improperly influence business outcomes.

4.2 Kickbacks and Illegal Commissions

Any arrangement where a portion of payment is secretly returned as compensation for awarding a contract or business advantage.

4.3 Facilitation Payments

Small, unofficial payments made to speed up routine government procedures.
These are strictly prohibited.

4.4 Improper Benefits to Public Officials

Special caution is required in dealings with:

• Government officials

• State-owned enterprise employees

• Regulators

• Public administration personnel

Providing any benefit to influence official actions is strictly forbidden.

4.5 Conflicts of Interest

Situations where personal interests may influence—or appear to influence—company decisions must be avoided and promptly disclosed.

4.6 Fraudulent or Misleading Records

• Altering invoices

• Fabricating documents

• Concealing transactions
  All forms of false reporting are prohibited.

5. Acceptable Business Courtesy (Strictly Limited)

Under regulated conditions and with prior approval, the following may be acceptable:

• Low-value, reasonable business meals

• Token promotional items with company logo

• Transparent and legitimate business hospitality

Any courtesy must be:

1. Reasonable in value

2. Transparent and documented

3. Not intended to influence decisions

4. Approved through internal procedures

6. Third-Party Due Diligence

Before engaging agents, contractors, consultants, or suppliers, the company will conduct risk-based due diligence, including:

• Verification of legal identity and reputation

• Review of ownership structures and sanctions lists

• Assessment of corruption risks in relevant jurisdictions

• Signing of anti-corruption compliance undertakings

• Ongoing monitoring during cooperation

High-risk third parties require enhanced due diligence and approval by legal/compliance departments.

7. Books, Records, and Internal Controls

The company maintains accurate and complete records to prevent concealment of improper payments.
Requirements include:

• Clear documentation of all business transactions

• Strict separation of duties in financial processes

• Mandatory retention of contracts, invoices, receipts, and approval documents

• Regular internal audits and compliance checks

Any financial irregularity must be reported immediately.

8. Reporting Mechanism and Whistleblower Protection

Employees and third parties are encouraged to report suspected bribery or corruption via:

• Internal reporting channels

• Compliance department contact points

• Anonymous whistleblower systems (if applicable)

The company protects whistleblowers from retaliation and ensures confidentiality to the maximum extent permitted by law.

9. Disciplinary Actions

Violations of the ABC policy will result in strict consequences, which may include:

• Disciplinary actions

• Termination of employment or cooperation

• Contract cancellation

• Civil compensation

• Criminal reporting to authorities

The company will pursue all legal remedies to protect corporate interests.

10. Training and Awareness

Regular training programs will be provided to:

• Employees

• Managers

• Agents and contractors

• Overseas affiliates

Topics include compliance obligations, global anti-corruption laws, identification of bribery risks, and case analysis.

Employees must complete mandatory ABC training annually.

11. Commitment to Ethical Business

The company is dedicated to building a culture of integrity, emphasizing:

• Fair competition

• Transparency

• Respect for laws and regulations

• Long-term trust with clients, suppliers, and partners

Every employee shares the responsibility to uphold these principles.

12. Conclusion

Preventing bribery and corruption safeguards the company’s operations, reputation, and global competitiveness. By adhering to the ABC policy, we ensure sustainable development, maintain compliance with international laws, and foster a high-integrity corporate environment.