Integrity violation constitutes serious breaches of the Company's regulations and systems under the labour laws and regulations. It refers to the act of the Company's staff, who, during performance of their duties, make use of the convenience of their positions, work or information obtained in advance at work for the purpose of obtaining improper benefits, either for themselves or others, that causes reputational damage, loss of benefits or poses a risk of loss of benefits to the Company, including but not limited to:
1) Obtaining improper benefits for themselves or others by means of embezzlement, misappropriation, bribery, theft, fraud, concealment, etc. that cause loss of benefits or pose a risk of loss of benefits to the Company;
2) Engaging in acts that cause loss of benefits or pose a risk of loss of benefits to the Company for the purpose of obtaining improper benefits; failure of which during execution due to objective reasons is also deemed as integrity violation;
3) Staff is deemed to have committed integrity violation if such staff or their relatives and friends, without truthful declaration to the Company, obtained benefits within such staff's business administration, regardless of whether loss of benefits to the Company are caused;
4) Staff who caused their colleagues to engage in integrity violation through instigation, instruction, coercion and inducement, regardless of whether such staff has obtained benefits, are deemed to have committed integrity violation.
Staff and external personnel are encouraged to actively whistleblow and expose any integrity violations, either in real names or anonymously. The Company advocates whistleblowing in real name and will accord absolute priority to matters whistleblew in real names, whereas feedback on the investigation will be given to the whistleblower within 48 hours after receiving the report. Those units or individuals who make outstanding contribution in detecting, preventing or correcting any integrity violations in a timely manner will be rewarded by the Company.
1) The Group has set up a central mailbox (lianzheng@agile.com.cn) and hotline (020-88839935) to monitor integrity violations.
2) Integrity reporting channels are made available to customers, construction contractors, material suppliers and other cooperating business parties, to ensure each of them is aware of the Company's integrity supervision channels.
3) Privacy protection: Regardless of whether the issues reflected in the complaining report are verified, the Company deemed the personal information of the whistleblower as confidential. The information shall be protected by the Company's Confidentiality System. Under our Accountability System for Defaults, staff who leaked the information of the whistleblower, revealed the integrity investigation process and investigation data, threatened and retaliated against the whistleblower may be subject to demotion, re-designation/disciplinary records, and in severe cases, termination. Those who commit a crime will be transferred to the police.
All staff are encouraged to contribute to the integrity. Those units and individuals who make outstanding contribution in detecting, preventing or correcting any integrity violations in a timely manner will be rewarded by the Company. Specific rewards are as follows:
(1) For those who has reported and exposed an integrity violation that proved to be true, and helped the Company avoid an economic loss of less than RMB100,000, will be rewarded with RMB2000 for each case;
(2) For those whose report and exposure helped the Company avoid an economic loss of RMB100,000 or above, will be rewarded with 2% of the recovered amount for each case;
(3) If multiple reports are received in one case, the Risk Management and Audit Center will distribute the reward in proportion according to the value of the reported information provided by the whistleblower, and the distribution plan will be reported to the competent officer of the Group for approval before implementation.
1. Information disclosure on introduction of cooperating units All companies and departments under the Group (government departments, banks, power supply, communications, water supply entities and other state-owned monopoly enterprises are exempt from disclosure, save and except for the companies separately authorized by the above-mentioned entities) are required to request its first cooperating parties to make information disclosure on the supplier and bidding system. The information to be declared include the Party's business scale, operation status, shareholders, methods of introduction, historical performance, personal relationship with the Company's staff, etc.
1) For introduction of suppliers, those with insufficient information in preliminary research or substantially deviated from the introduction criteria are forbidden to introduce.
2) The relevant procurement staff or business personnel should perform their due diligence and fulfill their approval obligations on the information and data declared by the suppliers. Any failure in detecting false information provided by suppliers shall be dealt with in accordance with the Accountability System for Defaults. If internal staff collude with external suppliers to provide false information or otherwise fraudulently get selected, they will be dismissed from employment once found and pursued as a disciplinary case against integrity to the fullest extent.
3) Suppliers found to have provided false information, once verified, will be blacklisted in the supplier and bidding system and no cooperation in the future is allowed.
4) Subordinate companies, departments and staff are strictly forbidden to conduct business with suppliers prior to research and introduction procedures (except for trial cooperation with suppliers in which a formal cooperating contract is not required), otherwise those individuals or departments found responsible shall be subject to disciplinary actions according to the Accountability System for Defaults.
2. Requiring Cooperating Partners to Sign Anti-corruption Agreement
All subordinate companies and departments under the Group, while signing any business contracts with cooperating business parties, are also requested to disclose information and required to sign an Anti-corruption Agreement in the prescribed form to clarify their responsibility for integrity.
(1) In the event of failure to sign the Anti-corruption Agreement with any business cooperating party as per the Company's requirements, or any unauthorized modification to the terms of the Anti-corruption Agreement, relevant department heads, personnel who approve such contract and personnel who sign such contract will be dealt with in accordance with the Accountability System for Defaults for dereliction of duty.
(2) Suppliers who are in breach of the Anti-corruption Agreement will be held legally accountable and will be blacklisted. The cooperation will be terminated if necessary.
