1.Purpose

In order to solidly promote the anti-corruption and anti-bribery work in commercial activities, strengthen the internal control mechanism of the enterprise, be honest and trustworthy, sort out the business philosophy centered on law-abiding integrity and high-quality service, combine the actual situation of the company, strengthen institutional supervision, and promote institutional anti-corruption. We strengthen the supervision and management of the important links and important positions that are prone to corruption, ensure the management of commercial bribery commitment system, strictly follow the rules of fair competition, and guide company management personnel and relevant interest groups (such as customers, suppliers, etc.) to  act in accordance with the law, be honest and trustworthy, consciously resist negative and corrupt phenomena such as venality, feathering their nest, distrust, deceit and fraud, establish a good image of the enterprise, and formulate this policy.

2.Defination 

2.1Corruption is an act of unfair competition for the purpose of obtaining relevant benefits and providing extraordinary returns as a means.

Corruption/bribery can take the form of:

Cash

Red envelope

Rebate

Excessive hospitality or gifts

Business opportunity

Employment opportunities

Other non-financial interests

2.2For all internal and external activities of the company, the following actions are prohibited:

(1) Give cash or excess gifts to relevant business units or personnel;

(2) Obtain transactions, employment opportunities, preferential conditions or other non-financial benefits by giving property in the name of donation;

(3) Receive cash, rebates and other non-financial benefits from suppliers;

(4) Provide commercial sponsorship or travel and other activities that violate the principle of fair competition;

(5) Obtain benefits from workers in the form of negotiable instruments or gift certificates, such as various membership cards, consumption cards (coupons), shopping (cards) coupons and other negotiable securities;

(6) Provide and use items such as houses and cars;

(7) Provide performance shares or dividends;

(8) Give or receive financial or other benefits indirectly through gambling or under the guise of promotional fees, publicity expenses, advertising fees, training fees, consulting fees, technical service fees, scientific research fees, etc.;

(9) Other acts that violate laws, regulations and relevant rules and regulations of the company.

3. Application

3.1 This procedure is applicable to economic activities such as material procurement, outsourcing , facility engineering, business sales, equipment procurement and maintenance, quality supervision, and personnel, financial and material management within the company.

3.2 All customers, suppliers, service providers and contractors who have business dealings with the company are also within the scope of this policy.

4.Management Procedure

4.1 Implement the commercial bribery prevention commitment system in key links and key positions, sign the Anti-Bribery/Anti-Corruption Commitment between individuals in important positions and the company. 

4.2 All customers, suppliers, service providers and contractors who have business dealings with the company must also sign a "Supplier Anti-Bribery/Anti-Corruption Commitment/Integrity Construction Agreement" with our company.

4.3 As the supervision and management department of the commitment system for the prevention of commercial bribery, the management department's main responsibilities are:

(1) Carry out the work of combating commercial bribery in accordance with relevant national policies, laws, regulations and rules;

(2) Exercise the duties of discipline inspection and supervision in accordance with the law;

(3) Strengthen the supervision and management of the integrity of personnel in important positions and important links;

(4) Implement the "Anti-Bribery/Anti-Corruption Commitment Letter", strengthen the prevention and control of corruption from the source, adhere to both the symptoms and root causes, improve the system construction, and record the integrity of personnel in important positions and important links truly;

(5) Take charge of the follow-up, supervision and inspection of the company's implementation of this policy.

4.4 The undertaker/company should abide by the following responsibilities:

(1) Strictly perform the content promised in the letter of commitment;

(2) Prohibit any form of commercial bribery;

(3) Consciously accept the management of the commercial bribery prevention supervision department (management department);

(4) If violating the commitment, obey the disposition made by the supervision and management department according to the relevant regulations.

4.5 In carrying out the work of controlling commercial bribery, the management department of the company and relevant departments should strengthen information sharing and cooperate with each other.

4.6 The main tasks of carrying out anti-bribery/anti-corruption activities:

(1)Establish a leading agency for the governance of commercial bribery, and carry out the work of combating commercial bribery;

(2)Set up a report box for the prevention of commercial bribery, and publish the report number;

(3)In the process of implementing anti-bribery/anti-corruption, the management department of the company will investigate other departments openly and secretly to keep abreast of signs of commercial bribery prevention, and research and develop countermeasures and measures to prevent commercial bribery;

(4)Carry out investigation and research, grasp the characteristics and laws of corrupt behavior and commercial bribery, propose specific countermeasures and measures in terms of effective prevention such as education, system, and supervision, and solve emerging and tendentious problems timely.

4.7 Deal with the problems found in the prevention of commercial bribery in a timely manner. When carrying out the prevention of commercial bribery, all departments should stop or deal with the existing crisis and violation problems in a timely manner and report the situation to the relevant departments. Those suspected of committing crimes should be transferred to judicial organs for handling.

4.8 All units of the company should strengthen the management of personnel in important positions, and take their implementation of the "Commitment Letter" as an important content of inspection and assessment and an important basis for appointment and removal.

4.9 The administrative department of the company should supervise and inspect the implementation of these measures in accordance with its duties and powers, and deal with or put forward suggestions for dealing with behaviors that violate the "Commitment Letter" of personnel in important positions.

4.10 Persons in important positions in the company who violate this procedure should be dealt with in accordance with relevant regulations according to the seriousness of the violation.

4.11 Resolutely cancel the qualifications of suppliers and service providers who have economic activities with the company and violate the "Supplier Anti-Bribery/Anti-Corruption Commitment Letter". If the crime of commercial bribery (offering bribery) is constituted, hand them over to judicial organs to investigate criminal responsibility.

4.12 The company encourages employees and companies with business dealings to report and expose corrupt behavior. The acceptance and investigation of reports must be strictly confidential.It is strictly forbidden to disclose the name, department, company name, etc. of the informer, and it is strictly forbidden to disclose the report to the person or department being reported.When investigating and verifying the situation, the original or photocopies of the reporting materials should not be presented, the informer should not be exposed, the handwriting of anonymous reporting letters and materials should not be authenticated, and the reporting materials should not be borrowed at will.

5. Working Procedure

5.1 The relevant content of anti-corruption/anti-corruption should be added to the regular training of all employees and new employee orientation training. At the same time, relevant personnel should be arranged to conduct a comprehensive study of relevant laws.

5.2. Regularly update relevant laws and regulations on anti-corruption/anti-corruption. Enhance the legal awareness and legal concept of all staff.

5.3. Improve the financial management system, establish a restriction mechanism, and implement supervision measures.Further implement supervision measures, implement "sunshine finance", and truly implement financial disclosure.

5.4 In the event that an external unit asks for bribes or hints to accept benefits, the relevant person in charge shall explain our anti-corruption/anti-bribery policy to them.

5.5 The company will investigate all bribery behaviors. If the circumstances are true, they will be dismissed. If the circumstances are serious, they will be sent to the public security organs for disposal.

6. Anti-corruption Publicity Channels

6.1 Yifan official website: http://www.yifanmotor.com/cn/newsinfo/60.html

6.2 Internal employees of the company: new employee orientation training, daily workshop morning meeting and workshop whiteboard bulletin board

6.3 The company's sub-supplier: sign the integrity agreement

6.4 The company's parent customer: sign "Supplier Code of Conduct" in the framework agreement between the two parties

7.Anti-corruption Reporting Channels

7.1 Internal employees of the company: Please put your comments into the report box at the entrance of the 1st floor of Building 1

7.2 External suppliers or customers of the company: please call or send an email to our anti-corruption and anti-bribery departments. Tel: 0510-83570658, Email: tania.tang@yifanmotor.com