INTEGRITY AND COMPLIANCE POLICY
Concord New Energy Group Limited ("the Group") adheres to the philosophy of integrity-based management, abides by extremely rigorous commercial ethics, makes constant efforts to regulate the professional conduct of all employees (including part-time employees, casual laborers, top management and directors of the Group and its affiliates), requires strict compliance with all applicable laws and regulations as well as the Group's code of ethical conduct and rules and regulations, establishes a working style of integrity, diligence and dedication, and earnestly safeguards the legitimate rights and interests of customers, business partners and shareholders.
This policy applies to all employees of the Group, contractors and suppliers in business relations with the Group, and any other potential business partners. All employees shall familiarize themselves with and fully comply with this policy and other policies made by the Group. This policy shall be read together with all other Group policies relevant to the topics specified herein, including the "Code of Ethics & Conduct", the "Whistleblowing Policy", and the "Supplier Code of Conduct".
III. POLICY STATEMENT
(I) The Group’s tolerance for corruption is zero. The Group adheres to the basic principle of "taking a dual approach that combines prevention and punishment with the emphasis on prevention" and "whistleblower protection and recusal of interested parties" in its anti-fraud work.
(II) The Group's Board of Directors supervises the Group's anti-fraud work and guides the establishment of a Group-wide anti-fraud culture and control system. The Board of Directors and the Audit Committee provide guidance, supervision, and necessary participation in the anti-fraud work, to ensure effective implementation of the policy.
(III) The Group strictly abides by the Anti-Unfair Competition Law of the People's Republic of China, adheres to the philosophy of honest operation and fair competition, trades with customers and suppliers in a fair, honest and professional manner, while striving for higher yields. The purchases by the Group shall be in a fair and transparent manner. The Group avoids undue preference when evaluating the contractors and suppliers to be. The Group will not trade with contractors, suppliers or other potential business partners who are known to engage in bribery or corruption.
(IV) All employees of the Group shall strictly comply with relevant applicable laws and regulations, standards, codes of conduct, as well as regulations concerning the Group. All employees shall abide by the Group’s “Code of Ethics & Conduct” and procure others to do the same. All employees shall cooperate fully in the anti-fraud investigation. Please refer to the “Code of Ethics & Conduct” for further details.
(V) Contractors, suppliers or other potential business partners shall strictly comply with relevant applicable laws and regulations, the Group’s “Integrity and Compliance Policy”, and the Group’s “Supplier Code of Conduct”. (Please refer to the “Supplier Code of Conduct” for further details.) The Group has the right to decide not to pursue further cooperation or terminate existing agreements if a breach of the Group’s “Supplier Code of Conduct” occurs.
IV. PREVENTION AND TRAINING
(I) The Group strictly observes relevant laws and regulations, industry standards and listing rules of the stock exchange where the company is listed. The Group has put in place an employee anti-corruption system. The Group has formulated a system of anti-corruption regulations, including the “Anti-Fraud System”, the “Supervision and Management Measures for Tendering and Bidding”, the “Code of Ethics & Conduct”, and the “Supplier Code of Conduct” while revising them in a timely manner to ensure their applicability and effectiveness.
(II) The Group promotes the corporate culture of "honesty and integrity" and “incorruptibility and self-discipline” and creates an anti-fraud corporate environment by, including but not limited to, the following means:
1. The directors and top management of the Group shall set an example and take the lead with their actions, abide by the rules and regulations of the Group and resolutely support the anti-fraud efforts of the whole staff within the scope of the Group; the management shall exercise supervision over fraud throughout their daily management and supervision work.
2. Take various measures regularly to strengthen publicity and education about laws and regulations and professional ethics to board members and all staff each year. Through various publicity measures such as posts on the Audit Department’s WeChat Official Account and legal lectures, to communicate the idea of integrity and honesty to all employees.
3. To actively guide employees to observe relevant regulations and laws, act in good faith, and maintain ethical conduct in the daily work and communication in the Group, and assist employees to properly handle conflict of interest and temptation of improper interest in work; inform, in an appropriate form, all stakeholders in the society that have a direct or indirect relationship with the Group of the information on the Group's promotion of compliance of disciplines and laws and observance of good faith and ethics, including external stakeholders (customers, construction companies, suppliers, regulatory authorities and shareholders).
(III) Multi-angle and full-coverage anti-corruption and anti-fraud training shall be carried out by, including but not limited to, the following means:
1. Provide annual online anti-corruption training to all employees, and ensure that the anti-corruption training covers all employees of the Group and its affiliates, including part-time employees, casual laborers, top management and directors.
2. Provide training to new employees in terms of the code of ethics & conduct, and laws and regulations, and ensure that new employees promptly understand the Group's "zero tolerance" for corruption and have a detailed knowledge of misconduct and unethical behaviors as stipulated by the Group.
3. Provide training to suppliers on the Group’s “Supplier Code of Conduct” and require suppliers to cooperate with the Group to sign the “Integrity Commitment Agreement”.
V. COMPLAINT, REPORTING, AND WHISTLEBLOWER PROTECTION
(I) The Audit Department, the standing department for anti-fraud work, shall be responsible for establishing a complaint and whistleblowing platform with reporting channels such as telephone, e-mail, mail, whistleblowing page on the official website, etc., and shall make a public announcement of such platform. For detailed whistleblowing approaches, please refer to the “Whistleblowing Policy”.
(II) In general, any employees, contractors and suppliers in business relations with the Group, and any other potential business partners can make reports to the Audit Department or the higher-level Audit Committee and the Board of Directors for any complaints or concerns. The Group encourages all its employees and business partners to file real-name reports of misconduct or unethical behaviors through the reporting channels. See the “Whistleblowing Policy” for specific reporting procedures.
(III) A whistleblower protection system is set up to guarantee confidentiality protection for whistleblowers by rules, and hold accountable those who disclose classified information and retaliate against whistleblowers according to law. For more details, please refer to the “Whistleblowing Policy”.
VI. INVESTIGATION OF WHISTLE-BLOWING
(I) The Group conducts thorough investigations of all real-name reports (not just of potential anticompetitive conduct), collects and reviews evidence, and considers whether the evidence can corroborate or exclude the matter. Anonymous reports will be confirmed after investigation.
(II) The Group's investigation of the report shall include collection of evidence, and appointing an investigation team to interview the whistleblower, to obtain more detailed information. When conducting the relevant investigation, external experts or other institutions may be appointed to assist the investigation if necessary.
(III) For an employee with confirmed fraud practice, the Group will hold accountable those who have committed fraud practice and the management personnel who have failed in executing proper supervision, and the Board of Directors will impose internal economic and administrative disciplinary actions in accordance with relevant regulations. If there is sufficient evidence to suggest that a case of possible criminal offence exists, the matter will be reported by the Group to the relevant local judiciary authorities for further handling.
(IV) The result of the investigation may be communicated to the whistleblower where deemed appropriate upon the completion of corresponding investigation.
VII. POLICY REVIEW
The Group will carry out periodic review of the effectiveness of this policy.