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Anti-fraud and complaint reporting management system

Chapter I General Provisions

Article 1 In order to prevent fraud, strengthen corporate governance and internal control, safeguard the legitimate rights and interests of the company and shareholders, and reduce the risks of the company, this system is formulated in accordance with the basic norms of internal control of enterprises and the

provisions of other relevant laws and regulations, and in combination with the actual situation of the company.

article 2 this system mainly defines the purpose of anti-fraud work, the concept and form of fraud; Prevention and control of fraud; Permanent organization for anti-fraud work; Report, investigation and report of fraud; Protection of whistleblowers; Remedial measures and punishment for the disadvantages of dancing.

Article 3 The purpose of anti-fraud work is to standardize the professional

behaviors of the company's senior and middle managers and ordinary employees, strictly abide by relevant laws, industry norms and standards, professional ethics and company rules and regulations, establish a good atmosphere of honesty

cleanliness and diligence, and prevent behaviors that harm the interests of the company and shareholders.

article 4 this system is applicable to group companies, wholly-owned subsidiaries, holding subsidiaries and branches.

Chapter II Concepts and Forms of Fraud

Article 5 The term fraud as mentioned in this system refers to the behavior of people inside and outside the company who use various illegal and illegal means to

seek personal illegitimate interests and damage the legitimate economic interests of the company; Or seek illegitimate economic interests of the company, and at the same time may bring illegitimate interests to individuals.

article 6 fraud that damages the legitimate economic interests of the company refers to the improper behavior of people inside and outside the company who use various illegal and illegal means to harm the legitimate economic interests of the company and its shareholders in order to seek their own interests.

one of the following circumstances belongs to this kind of fraud:

(1) accepting bribes or kickbacks;

(2) transferring the transactions that can make the company profitable under normal circumstances to others;

(3) illegally using company assets, embezzling, misappropriating or stealing company assets;

(4) making the company pay for false transactions;

(5) Deliberately concealing or misreporting the transaction matters;

(6) forging or altering accounting records or vouchers;

(7) disclosing the company's commercial or technical secrets;

(8) other fraudulent acts that damage the economic interests of the company.

Extended information

Article 7 Fraud in seeking illegitimate economic benefits of the company refers to the improper behavior of the company's internal personnel to harm the interests of the state, other organizations, individuals or shareholders by cheating and other illegal and illegal means in order to obtain illegitimate economic benefits of the company and possibly obtain related benefits themselves. One of the following circumstances belongs to this type of fraud:

(1) spending for improper purposes, such as paying bribes or kickbacks;

(2) selling assets that do not exist or are untrue;

(3) Deliberately misreporting transactions, recording false transactions, including inflating income and underestimating liabilities, and

issuing wrong financial reports, thus causing readers or users of financial statements to misunderstand and make inappropriate investment decisions

;

(4) concealing or deleting important information that should be disclosed to the outside world;

(5) engaging in illegal and illegal economic activities;

(6) forging or altering accounting records or vouchers;

(7) tax evasion;

(8) other fraudulent acts that seek illegitimate economic interests of the company.

Chapter III Prevention and Control of Fraud

Article 8 A company shall establish, improve and effectively implement

anti-fraud control procedures including fraud risk assessment and fraud prevention, and conduct self-assessment; To coordinate and guide the anti-fraud work across departments of the company.

article 9 the company publicizes the company's anti-fraud policies and relevant measures in various ways, and

educates and trains employees on laws, regulations and honesty and morality, advocates a corporate culture of honesty and law-abiding, and helps employees to correctly

handle conflicts of interest and resist the temptation of illegitimate interests.

article 11 the company advocates an honest and law-abiding corporate culture, creates an anti-fraud corporate culture environment, evaluates fraud risks and establishes specific control procedures and mechanisms to reduce the chances of fraud.

Article 11 Assess fraud risks and establish specific control mechanisms to reduce the chances of fraud.

Mainly through the following means:

(1) Identify and evaluate fraud risks at the company level, the business department level and the main account level. The evaluation includes the importance and possibility of fraud risks.

(II) Establish and take

measures to confirm, prevent and reduce false financial reports or abuse of company assets, which include the following different forms: approval, authorization, verification, check, division of powers and responsibilities, performance review by employees and protection of company assets safety.

(3) In view of the high-risk areas where fraud occurs, such as false financial reports and ultra vires management, the company shall establish necessary internal control measures in the fields of

information systems and technology.

Chapter IV Permanent Anti-fraud Organization

Article 12 The Company shall establish a permanent anti-fraud organization to specifically organize and implement anti-fraud work across departments and within the scope of the Company

; Each business department undertakes the anti-fraud work of its own department.

Article 13 The Company's Commission for Discipline Inspection (hereinafter referred to as the "Commission for Discipline Inspection") is the

permanent body of the company's anti-fraud work, and is responsible for the company's annual fraud risk assessment on the anti-fraud work plan and development; Write

the company's anti-fraud work evaluation report; Carry out anti-fraud prevention publicity activities; Accepting

complaints and reports of anti-fraud within the company; Investigate the reported cases of fraud and put forward handling opinions.

Article 14 The staff of the Commission for Discipline Inspection shall consciously improve their anti-fraud awareness and anti-fraud technical ability,

maintain due professional prudence, actively request and take the initiative to receive anti-fraud laws, regulations, industry standards and knowledge

skills training, and actively understand the company's business development and plans, accounting policies, financial management systems and other relevant rules and regulations.

chapter v report, investigation and report of fraud

article 15 the company has set up a special report telephone number and e-mail address, which are channels for employees and outsiders

, suppliers, customers, etc., to reflect and report the illegal and irregular behaviors of various departments and their personnel in the company's work and business process

, and to report and expose actual or suspected fraud incidents; The receiving contents include complaints and reports of internal

control process loopholes.

Article 16 The Commission for Discipline Inspection shall adhere to the working principles of openness, fairness and impartiality in filing complaints and reports, and the principles of solving problems in a timely and on-the-spot manner and safeguarding the interests of shareholders and employees of the company.

Article 17 The Commission for Discipline Inspection can check the violations of discipline reflected in the report, and make a preliminary verification according to the examination and approval procedures and powers

:

(1) If the person complained (reported) is a senior manager appointed by the board of directors of the company, it will be approved by the directors

;

(2) Other complaints and reports except the first paragraph of this article shall be examined and approved by the Commission for Discipline Inspection in conjunction with the management of the company, and

the board of directors may also be asked to determine according to the actual situation.

Article 18 The Commission for Discipline Inspection has the following powers in the process of accepting and investigating complaints and reports:

(1) Right to investigate and collect evidence: In the process of investigating and understanding complaints and reports and related work, it has the right to access and copy relevant materials in relevant units, investigate and ask relevant personnel, and has the right to ask the investigated units and personnel involved to sign and confirm all kinds of materials for investigation and collection.

(2) Follow-up right: Have the right to follow up on matters transferred to other departments and ask them to give feedback within a certain

time.

(3) the right to suggest solutions: you can directly put forward solutions to the problems found in the investigation.

Article 19 The staff of the Commission for Discipline Inspection shall abide by the following working criteria:

(1) If they have a direct interest in the contents of the complaint or the complainant, they shall withdraw;

(2) Listen to the facts and reasons stated by the complainant, and investigate and verify the situation with relevant organizations and personnel when necessary

to avoid intensifying contradictions;

(3) Do not disclose the information of complaints and reports to the object of complaints and reports, do not disclose the internal research of this department in handling complaints and reports to the complainant, and do not discuss the contents of complaints and reports with irrelevant personnel.

(4) If it meets the acceptance conditions after examination, it shall inform the complainant in writing or other appropriate ways within 7 days from the date of acceptance; If it does not meet the acceptance conditions, it shall, within 7 days from the date of making the decision not to accept it, inform the complainant in writing or other appropriate ways, and explain the reasons; Unless the contact information

is unknown.

(5) During the investigation and handling of complaints and reports, confidentiality must be maintained.

Article 21 The Commission for Discipline Inspection shall

complete the report that has been accepted and initiated for investigation within 61 days from the date of acceptance; If the situation is complicated, the processing period may be appropriately extended, but the extension period shall not exceed 31 days.

If there are other provisions in laws and regulations, those provisions shall prevail. Reports that need to be assigned or transferred shall be assigned or transferred to the relevant departments within 15 days from the date of receipt. If the results need to be fed back, they shall be required to feed back the results within the time limit of handling

and submit the completion report.

Article 21 The Commission for Discipline Inspection will, depending on the specific circumstances, assess the allegations of ordinary employees but make a decision on whether to investigate them together with the relevant departments of the company.

Article 22 The Commission for Discipline Inspection shall

feed back the investigation results to the whistleblower whether it will initiate an investigation or not. The report materials of fraud cases after reporting and investigation shall be filed in time; The investigation results of fraud cases related to

should be reported to the relevant departments of the company according to the nature of the report.

Article 23 After verification, the complaints and reports reflect that the facts of the problem are basically clear, and there is indeed a violation of discipline.

Those who are obviously not disciplined enough can be admonished; If the problem is not specific and untraceable, it will be retained after the approval of the leader < P >; For those who seriously violate the company's discipline and system and cause economic losses to the company,

shall be given corresponding punishment according to the seriousness of the case.

Article 24 A complainant (informant) who makes malicious slander out of nothing will be severely punished after verification. If the complainant or whistleblower maliciously complains and reports slander others, openly demeaning others' personality, damaging their

reputation, and slandering and insulting others is serious enough to constitute a crime, the company will transfer it to the judicial department for legal responsibility

.

Chapter VI Protection of Informants

Article 25 Informants shall be protected when assisting in the investigation. The company prohibits any discrimination or reporting

, and any obstruction, interference or hostile measures against the personnel involved in the investigation.

article 26 the company will take corresponding punishment for those who disclose the information of complaints and informants in violation of regulations or take retaliatory actions against complaints and informants

. Violate the law, the company will be transferred to the judicial organs

according to law.

Article 27 A staff member who accepts a report or participates in a fraud investigation shall not provide any unit or individual with the relevant information and report contents of the whistleblower without authorization; If it is really necessary to consult the relevant information of the report because of work, it needs to be approved by the person in charge of the Commission for Discipline Inspection. At the same time, the Commission for Discipline Inspection should register the time, content and relevant information of the inspectors.

Chapter VII Remedies and Penalties for Fraud

Article 28 After a fraud case occurs in a company, there shall be a written report on evaluating and improving the internal control

in the remedial measures, and appropriate measures shall be taken against the violator, and the handling result shall be notified to the internal and necessary

external third parties as required.

Article 29 For employees who commit fraud, the Commission for Discipline Inspection shall recommend corresponding internal economic and administrative disciplinary punishment according to relevant regulations of the company

; Fraud that violates relevant laws shall be transferred to judicial organs

for handling according to law.

chapter viii supplementary provisions

article 31 matters not covered in this system shall be implemented in accordance with relevant laws, regulations, normative documents and the company's bylaws.

article 31 the board of directors of the company shall be responsible for the interpretation and revision of this system.

article 32 this system shall come into force as of the date of deliberation and approval by the board of directors of the company.