Corporate Governance Back to list

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Anti-corruption and anti-corruption policies



While attaching great importance to clean management, the Company is determined to put an end to bribery, extortion, fraud and money laundering of any form. The Company strictly complies with all relevant laws and regulations relating to bribery, extortion, fraud and money laundering.

The Board of the Company (Risk Management Committee) is responsible for the approval and supervision of the formulation and execution of the anti-corruption policy.

The anti-corruption policy has been announced throughout the Group. We firmly oppose all forms of corruption and bribery and will strictly implement our policies and procedures. We emphasize that this system applies to all employees and directors, and call on external suppliers and partners to comply. .

The company's policies and results are as follows:

 

1)         Anti-Bribery Policy

The Company has formulated the “Anti-Bribery Policy” and the “Code of Conduct for Employees”, and announced the Group’s anti-corruption policy throughout the Group, emphasizing that “the Company prohibits any form of corruption and bribery, and the system applies to all directors and employees”, and setting out the principles and boundaries that are required to be followed in giving and receiving gifts, discounts and commissions, as well as the supervisory responsibilities of each rank. Specifically, the Company prohibits any form of bribery, including but not limited to cash, gifts, discounts, soft dollar and other form of illegal or improper payment.

 

2)         Prohibition of Discounts and Soft Dollar Policy

The Company specifically prohibits any bribery in disguise such as discount and soft dollar, and it is explicitly stated under the “Anti Bribery Policy” of the Company. The Company announces this policy to all staff and business partners whose contracts with the Company contain specific terms relating to prohibition of bribery in disguise such as discount and soft dollar.

 

3)         Policy relating to Political Donation and Charitable Donation

The Company has committed to transparently disclosing all political donation and charitable donation and ensuring that those donations will not be used in any form of bribery. Political or charitable donations will not be used as a mean to secure business or government contract. Besides, we undertake that the Company will not, directly or indirectly, offer any cash or gifts of high value, or make any commitment with similar reward, to any government officials, political parties or the representative thereof, candidate of any political positions or public position.

 

4)         Compliance Review and Training

The Company offers regular publicity and training of anti-corruption policies for its employees. The Company has organized training for all employees of the Group (including part-time employees and outsourced personnel), and published the “Corruption Prevention Tips”, the “Practical Guidelines for the Corruption Prevention System of Listed Companies” and the “Corruption Prevention Training Materials of SITC” on the Company’s internal website for its employees to consult and study at any time. SITC will conduct internal compliance review on a regular basis to ensure effective implementation of our anti-bribery and anti-corruption policies. We provide necessary trainings and educations to make sure that all employees and business partners could have full understanding of, and abide by our policies and regulations.

 

5)         Management of Suppliers’ Incorruptibility

The Company conducts review and management on suppliers on a regular basis to ensure their compliance with anti-bribery and anticorruption policies. Cooperation with any supplier who is in breach of the relevant regulations will be terminated. The Company will visit suppliers to publicize our anti-bribery policies and will accept suppliers’ supervision to promote a clean, fair and equal competition environment. In 2023, 76 suppliers have been visited. Suppliers agree to our anti-bribery policies and are willing to maintain long-term cooperation. No bribery issue has been occurred.

 

6)         Internal and External Reporting, Investigation and Audit

The Company has promulgated the "Anti-Fraud, Reporting and Complaint System", established a sound and transparent anti-fraud, reporting and complaint mechanism, published the hotline number and email address on the company website, and accepted real-name or anonymous reports from employees and external third parties. The company has a functional department dealing with complaints and reports, dealing with complaints and reports in accordance with the prescribed process and time, and giving feedback to the complaint whistleblower. The company has also formulated protection measures for whistleblowers, encouraging relevant personnel to report fraud and fraud, and ensuring that the personal and interests of the complainant or whistleblower are not infringed. We will investigate all reports and take appropriate corrective action, including reporting to the appropriate authorities.

 

The company conducted employee questionnaires to investigate the current situation of corruption prevention in the company. The company has formulated the Internal Audit System, regularly organizes internal and external audits and implements the job rotation system every year to effectively prevent the occurrence of fraud.

 

7)         Capital Management

The Company has strengthened capital management and control. The Fund Management System clearly stipulates that “all capital receipts and payments shall be made based on a true and legal business background”. Any form of illegal acts such as bribery, extortion, fraud, and money laundering, or fund receipts and payments that violate company policies are prohibited. Payment to any party with major risk is prohibited.