XX Co., Ltd. anti-fraud and whistleblowing management system

Chapter I: General Provisions

Article 1 This system is formulated in order to strengthen the company's internal control, prevent and control fraud, reduce the company's risks, further standardize and strengthen anti-fraud work, and ensure the realization of the company's business objectives and the company's sustainable, compliant and stable development.

Article 2 This system applies to all employees of XX Co., Ltd. (hereinafter referred to as "the Company") and its branches and subsidiaries (including all affiliated companies such as first-level subsidiaries, second-level subsidiaries and subsidiaries of subsidiaries).

Chapter II: Anti-Fraud Management

Article 3 The fraud referred to in this system refers to the behavior of the company's internal personnel to seek improper personal interests or damage the legitimate interests of the company by means of concealment, fraud and other violations of laws and regulations. These include:

1. Transfer the transactions that can make the company profitable under normal circumstances to others;

2. Leaking business information of upstream and downstream customers or channels;

3. Failure to actively handle business cooperation disputes with third parties such as channel customers and entrusted customs declaration agencies;

4. Terminate the cooperation agreement with a third party such as channel customers and entrusted customs declaration agencies without permission;

5. Using, stealing, embezzling, and disposing of the company's assets in violation of laws and regulations;

6. Embezzlement, misappropriation and theft of company funds;

7. Falsely reporting transactions, so that the company pays for false transactions;

8. Receiving bribes or kickbacks from internal and external personnel of the company;

9. Illegally bribing or giving benefits to third parties outside the company in the name of an individual or a company;

10. Failure to actively fulfill the administrative declaration obligations related to import and export, or failure to actively respond to the review of customs and other relevant departments, and deliberately concealing relevant facts from the company;

11. Use the company's resources to seek personal gains;

12. Divulging the company's business or technical secrets;

13. Coercing or inducing others to carry out the acts described above;

14. Other behaviors that seek improper personal benefits or damage the legitimate interests of the company.

Article 4 The legal department is responsible for coordinating and guiding the company-wide anti-fraud work, and the executive director is responsible for supervising the company-wide anti-fraud work.

Article 5 The legal department of the company is the daily work department of the anti-fraud work, and is responsible for the implementation of the anti-fraud work of the company and its branches, including:

1. Accept and register relevant fraud reports;

2. Discover clues of fraud through daily work;

3. Organize the investigation of fraud cases;

4. Submit opinions on the handling of fraud cases and opinions on pursuing responsibility;

5. Management of fraud case investigation files;

6. Construction, maintenance, and publicity of reporting channels.

Article 6 Each functional center or department, branch and subsidiary of the Company shall improve the internal control system, conduct regular self-evaluation of the effectiveness of the internal control system, establish a fraud prevention and control mechanism, and actively cooperate with the anti-fraud investigation and evidence collection.

Article 7 All employees of the company have the obligation to report fraud and actively cooperate with the anti-fraud investigation.

Chapter III: Reporting of Fraud

Article 8: Whistleblowers should report to the legal affairs department through designated channels such as letters, telephones, e-mails, and online messages, and conduct such as disseminating information through various information channels is to be regarded as a report made in an improper manner, and will not be accepted, and will be dealt with as a violation.

Article 9 Reporting Channels:

Contact:

Hotline for reporting:

Report email:

Article 10: The content of the report includes real or suspected fraud incidents, fraudulent acts, and fraud clues.

Article 11: Informants should follow the principles of seeking truth from facts, objectivity, and fairness in making reports, encourage real-name reports, and also accept anonymous reports, and give priority to accepting real-name reports.

Whistleblowers are responsible for the authenticity of the content of the materials they provide, and must not fabricate or distort facts, and must not falsely accuse or frame others.

Article 12: Informants shall truthfully inform the legal affairs department of the name, identity, and specific circumstances (time, place, person, course of events, and so forth) of the person being reported as much as possible, and provide relevant evidence.

Article 13: After receiving a report, the legal affairs department will conduct a preliminary verification of the reported information, make a decision on whether to accept or not to accept it, and give feedback to the informant.

Chapter IV: Anti-Fraud Investigation and Handling

Article 14: After the legal department decides to accept the reported matter or discovers the fraudulent matter, it shall submit the application process for compliance case inspection (investigation) and the application form for compliance case inspection (investigation) (Annex 1), and after the approval is passed, the legal department shall conduct a comprehensive investigation of the fraud matter. The legal department shall conduct an independent investigation of the reported or discovered fraud incidents, fraudulent acts, and fraud clues in the course of daily work, and no other department or individual shall interfere with the anti-fraud investigation work.

Article 15 For those involving major impacts, spanning multiple departments, serious problems or major interests, a joint investigation team shall be formed after timely reporting to the executive director of the company and obtaining authorization.

Article 16 In the course of the investigation, the investigator and the person under investigation shall perform the obligation to keep the confidentiality of the company for the investigation content that has not formed a clear investigation and handling opinion and has not been approved to be released to the outside world, and no one shall disclose the investigation content in any way and publish any tendentious opinions or remarks.

Article 17: After conducting an objective, impartial, and adequate investigation, the legal affairs department is to form an investigation conclusion based on the actual circumstances of the investigation, and submit opinions on the handling of persons responsible for fraud on the basis of the investigation conclusions and relevant systems. If it is found to be in violation of the regulations, it will be punished with reference to the relevant system of the company, and the relevant responsible person will be given an economic penalty:

1. In the case of items 1 to 4 of Article 3, once verified, the directly responsible person will be given an economic penalty of 5,000 yuan, and at the same time, the directly responsible person's superior and indirect superior will be given an economic penalty of 2,000 yuan and 3,000 yuan respectively, and the right to pursue legal responsibility will be reserved;

2. For the acts of seeking improper personal interests or damaging the legitimate interests of the company in items 5 to 12 of Article 3, according to the losses caused, the directly responsible person and the superior of the directly responsible person shall be given an economic penalty of 10% or more of the loss amount, and reserve the right to pursue legal responsibility.

Article 18 After the legal department makes a penalty decision on the relevant responsible person in accordance with the relevant system, it shall prepare the "Confirmation Form for Punishment Opinions on Employee Violations" (see Annex 2) and submit it for approval, and after the approval is passed, the legal department will issue a "Notice of Handling of Employee Violations" (see Annex 3) to the relevant responsible person.

Article 19: After a fraud case occurs, the department responsible for the case should promptly take remedial measures, and assess and improve the internal control of that department.

Article 20: Where fraudsters violate the law, they shall be transferred to the judicial organs for handling.

Chapter V: Protection of Whistleblowers

Article 21 The company's departments, branches and subsidiaries must correctly treat the acts reported by the whistleblower in accordance with the law, and no department or individual shall retaliate against the whistleblower under any pretext or form.

"Retaliation" as used in this system refers to acts carried out by the person being reported, or instructing or bribing others to infringe upon the personal rights, economic rights, and other lawful rights of the person being reported or his relatives.

Article 22: The information of informants involved in all reported cases and the corresponding content of the report must be kept strictly confidential, and unauthorized personnel must not have access to it. It is forbidden to send or present the reporting materials to the reported center, department, reported person, or other center, department, or individual unrelated to the investigation.

If it is necessary to send or present the report materials for work, it must be approved, and the content that may expose the information of the whistleblower must be hidden.

Article 23 If the whistleblower is retaliated against or the reported information is leaked, he has the right to report the situation to the company's legal department and the company's management, and if it is verified to be true, the corresponding personnel will be held accountable, and if the law is violated, it will be transferred to the judicial authorities for processing.

Chapter VI: Rewards for Whistleblowing

Article 24: Where the reported case is verified by the Legal Affairs and Compliance Department, the whistleblower will be given a certain reward:

1. For the reports in items 1 to 4 of Article 3, once verified, a one-time reward of 5,000 yuan will be given to the whistleblower;

2. In other reported cases, where economic compensation is received from the relevant responsible persons or economic losses are recovered, the informant is to be rewarded at the rate of 3%-5% of the total amount of economic compensation or losses recovered in each case, and the maximum amount of the reward is not more than 100,000 yuan; Where the clues provided by the informant play an important role in breaking through a major case, rewards are to be given as appropriate, and the maximum amount of rewards is not to exceed 10,000 RMB.

Article 25: Where multiple people report the same case, one award is to be given for each case, and rewards are to be given as appropriate in terms of the order of time for reporting, effective contribution to the investigation and handling of the case, the exact degree of lead provided, and the degree of assistance and cooperation; For joint reports, the whistleblower will share the bonus equally.

Article 26: Informants shall be objective and truthful in the matters they report, and be responsible for the veracity of the content of the materials they provide. In any of the following circumstances, no reward will be given:

1. The informant is unable to confirm his or her true identity;

2. The content of the report is vague and lacks factual basis;

3. The leads provided by the informant are unrelated to the reported case;

4. The legal department has already discovered or is in the process of investigating and handling;

5. Other circumstances that are not rewarded according to laws, regulations and company systems.

Chapter VII: Management of Rewards and Punishments

Article 27 The money for rewards and penalties shall be managed and supervised by the Financial Management Department.

Article 28: Once a report is verified, the legal affairs department is to initiate a reward for the informant, and the financial management department is to issue it to the informant.

Article 29 Once an employee's violation is verified, the legal department shall initiate an economic penalty against the responsible person, and the financial management department shall directly punish the responsible person

If the salary cannot be fully deducted from the economic penalty, the superior of the relevant responsible person will impose the economic penalty on behalf of the relevant responsible person.

Chapter VIII: Supplementary Provisions

Article 30 The terms "above", "below" and "expiration" in this system all include this number. Article 31: The legal affairs department is responsible for the interpretation and revision of this system.

Article 32 This system shall be implemented from the date of promulgation.

Appendix 1: Application Form for Audit (Investigation) of Compliance Cases

Compliance Case Audit (Investigation) Application Form

The person being inspected (investigated).	Affiliation
Reasons for audit (investigation).	Audit (investigation) time	Year, Month, Day
Preliminary verification of the statement of the situation
Opinions of the legal department
Opinions of the discipline inspection department
Opinions of company leaders

Appendix 2: Confirmation Form of Punishment Opinions for Employee Violations

Employee Violation Penalty Opinion Confirmation Form

party	Affiliation
Type of processing	Time	Year, Month, Day
Description of the violation and the basis for the punishment
Penalty opinions	type	Type of processing
Opinions of the legal department
Opinions of the discipline inspection department
Opinions of company leaders

Appendix 3: Notice of Handling of Employee Violations

Notice of Handling of Employee Violations

party	Department (Center)
Type of processing	Time
specific violations and Basis for processing
I have already seen the above situation, which is consistent with what I said and is all the facts and facts, and I agree with the relevant punishment. Signatures of the parties: Year, Month, Day
Signature of the superior leader in charge: Year, Month, Day

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