Ethical Violation Complaint Policy

Purpose and Scope of Application

To ensure the accountability, competitiveness, and integrity of the international business team under the supervision of the public.

Covered employees: All staff of the International Business Team (including local employees of overseas subsidiaries)

Actionable Ethical Violations

We accept complaints or reports of the following misconduct:

Actions violating the standards of integrity and self-discipline (including, but not limited to, corruption, abuse of power, questionable ethical issues of any individual or team, related party transactions, nepotism, illegal behaviors, or violation of social moral standards, etc.);

Actions violating the standards of dedication and professionalism (including, but not limited to, incapability, irresponsibility, failure to perform job duties, abuse of power, low efficiency, and ineffective work of leaders or personnel within the department or across departments).

File Complaint/Report

Requirements of Complaints/Reports

Complaints or reports should be substantiated by real and clear facts. The complainant/informer shall provide detailed facts to facilitate rapid processing. The facts provided must include the basic information of the person thought to be responsible for the alleged violation and the relevant evidence.

Real-name reporting, especially reporting with both the real name and accurate contact information of the informer, is strongly encouraged. Concerns may be reported anonymously (where permitted by local law), but doing so may limit our ability to thoroughly investigate.

Confidentiality and Protection Against Retaliation

The complaint/report receiving department is directly responsible for the highest leadership of the company. Personal information of informers will be kept strictly confidential to effectively protect the legitimate rights and interests of the real-name informers. If the receiving department divulges confidential matters or commits any other disciplinary offense, disciplinary actions, up to and including termination of employment, will be taken depending on the actual severity of the circumstance. If the case constitutes a crime, it shall be transferred to judicial organizations in accordance with the law.

The company will not allow any form of retaliation against individuals for reporting or inquiring in good faith about potential ethical violations, or cooperating in the investigation of reports or ethical violations in accordance with this policy. Anyone found to be engaging in retaliation will be subject to disciplinary action, up to and including termination.

Receiving and Processing

Designated personnel shall follow up and process complaints or reports in accordance with company procedures and reach a fair resolution.

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