I. Policy Purpose
To uphold the company’s culture of integrity, regulate employee conduct, prevent commercial corruption and job-related offenses, and ensure the healthy and sustainable development of the company,
this policy is hereby formulated. All employees, partners, and stakeholders must strictly comply.
II. Scope of Application
This policy applies to all current employees, management, suppliers, contractors, and third-party partners engaged in business with the company.
III. Code of Conduct for Integrity
Prohibited Acts
1. Soliciting or accepting bribes, kickbacks, gifts, or other improper benefits.
2. Using one’s position for personal gain, including but not limited to fraudulent expense claims or misappropriation of company assets.
3. Disclosing company confidential information or using insider information for personal benefit.
4. Engaging in activities that create a conflict of interest which may harm the company’s interests.
Compliance Requirements
1. All business activities shall be transparent and comply with applicable laws, regulations, and internal company policies.
2. Sign integrity agreements with partners to clarify mutual integrity responsibilities.
IV. Reporting Mechanism
Reporting Channels
· Reporting Email: liguoqiang@cxled.net
· Reporting Phone: 191-5510-9198 (Weekdays 9:00–18:00)
Reportable Issues
1. Illegal or non-compliant activities such as graft, bribery, embezzlement, or improper benefit transfers.
2. Any other conduct that violates company integrity rules or harms the company’s interests.
Reporting Requirements
1. Reports should provide specific facts, evidence, or leads. Anonymous reports must include verifiable information.
2. Fabrication of facts or malicious false reporting is strictly prohibited and may result in legal consequences.
V. Protection of Whistleblowers
The company strictly protects the identity of whistleblowers and the content of reports. Such information shall not be disclosed without the reporter’s consent.
Retaliation against whistleblowers is prohibited and will be dealt with seriously, including referral to judicial authorities where applicable.
VI. Investigation Process
1. Upon receiving a report, the Audit & Supervision Department will initiate an investigation within three working days.
2. After verification, appropriate actions will be taken based on the severity of the violation, including:
· Internal warning, demotion, or termination of employment.
· Recovery of economic losses; suspected criminal offenses will be referred to judicial authorities.
3. Outcomes will be communicated to the whistleblower where appropriate (except for anonymous reports).
VII. Supervision & Continuous Improvement
1. The company conducts regular integrity training to strengthen anti-corruption awareness.
2. The Audit & Supervision Department reviews policy implementation annually and submits a report to the Board of Directors.
3. This policy shall be updated in line with legal changes and company development to ensure its effectiveness.
VIII. Commitment & Responsibility
The company maintains a zero-tolerance stance toward corruption. All employees and partners share the responsibility to uphold a culture of integrity. Violators of this policy will bear corresponding legal
and financial liabilities.