2025-04-11
China Resources Mixc Lifestyle Anti-Corruption and Anti-Bribery Policy d
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1.  Purpose

1.1 China Resources Mixc Lifestyle Limited ("China Resources Mixc Lifestyle," "the Company," or "We") adheres to the core value of "honesty and integrity" and is committed to establishing a clean and professional work environment while maintaining a reputable corporate image based on integrity.

1.2 The Company complies with the "Company Law of the People's Republic of China," the "Anti-Money Laundering Law of the People's Republic of China," and other applicable laws and regulations. The Company implements the "China Resources Group Business Code of Conduct," the "China Resources Land Integrity Employment Guidelines," the "Integrity Agreement with Partners," the "Sunshine Declaration," and other management provisions, committing to operate under the legal framework of fair competition, anti-bribery, and anti-corruption.

1.3 This policy applies to China Resources Mixc Lifestyle and its subsidiaries and requires all partners and suppliers to comply with this policy.

2.  Anti-Corruption

2.1 The Company adopts a zero-tolerance policy toward any form of corruption, establishing a clean management system and control mechanisms. We conduct corruption risk assessments and supervisory checks, actively preventing corrupt practices. All employees are required to adhere to anti-corruption behavior codes and the relevant anti-corruption laws and regulations in business activities, refraining from engaging in any corrupt or improper actions.

2.2 The zero-tolerance anti-corruption policy is communicated to business partners, avoiding business relations with individuals or companies known to be involved in or suspected of corruption.

3.  Anti-Commercial Bribery

3.1 We pursue cooperation and business opportunities based on an outstanding team, top-tier products and services, a strong sense of social responsibility, and a good reputation, without directly or indirectly offering or accepting any form of bribery, kickbacks, or facilitation payments.

3.2 The Company does not permit, including but not limited to, the following actions: accepting, offering, or soliciting any form of bribery, kickbacks, or facilitation payments; using third parties to offer, accept, or solicit any form of bribery, kickbacks, or facilitation payments.

4.  Anti-Money Laundering

The Company strictly adheres to domestic and international anti-money laundering laws and regulations, focusing on financial integrity and legal compliance. We promptly identify suspicious transactions or potential money laundering activities and have a zero-tolerance policy toward money laundering. The following actions, including but not limited to, are prohibited:

· Engaging in money laundering activities or assisting others in money laundering;

· Obstructing official investigations, concealing, failing to report, or providing false reports to cover up money laundering activities;

· Failing to report or falsifying reports to cover up money laundering;

· Independently investigating suspected money laundering cases and refusing to report them to higher authorities in a timely manner.

5.  Compliance Requirements for Business Partners

5.1 We carefully select suppliers, agents, and other business partners who have a strong compliance management foundation and good compliance reputations, ensuring that their methods of operation do not conflict with the Company’s values and compliance philosophy.

5.2 We require all parties doing business with us (including suppliers, contractors, service providers, etc.) to sign the "Integrity Compliance Commitment," clearly stating that they will adhere to our anti-bribery and anti-corruption policies and maintain integrity in their business activities.

5.3 The Company does not permit, including but not limited to, the following actions:

· Giving gifts, cash, gift cards, securities, equity, or other financial products to our employees, their relatives, or other specific persons;

· Lending money, housing, vehicles, or other property to our employees, their relatives, or other specific persons;

· Offering meals, travel, fitness, entertainment, or other arrangements to our employees, their relatives, or other specific persons that could influence the impartiality of their duties;

· Paying or reimbursing any expenses for our employees, their relatives, or other specific persons;

· Holding shares on behalf of our employees, their relatives, or other specific persons;

· Colluding with our employees or other units and individuals to rig bids or collude on pricing, using unfair competition methods to secure business;

· Secretly negotiating or reaching an agreement with our employees on the bid, responses from other suppliers, or clauses in contracts regarding commercial secrets;

· Engaging in illegal subcontracting or splitting of projects.

6.  Compliance Relations with Government and Regulatory Bodies

6.1 In our communication with government and regulatory bodies, we must not only comply with applicable laws and regulations but also strictly adhere to the ethical standards and requirements of these bodies.

6.2 Except for appropriate gifts and hospitality to maintain good relations, the Company does not allow any form of bribery to government or regulatory personnel, including but not limited to: cash and cash equivalents, overly extravagant gifts and hospitality, any form of "facilitation payments" or "settlement fees," providing illegal job opportunities for the family members or friends of government or regulatory personnel, or bribing government and regulatory personnel through agents or third parties.

7.  Ethical Standards Training

To enhance the ethical awareness and compliance of all employees and stakeholders, ensuring they fully understand and adhere to the Company’s code of conduct and ethical standards, the Company conducts at least one comprehensive ethics training session annually for all employees and relevant parties (including full-time or part-time employees of suppliers, contractors, service providers, and other partners). The training covers, but is not limited to:

· Emphasizing the Company’s anti-bribery and anti-corruption policies and clearly informing employees and stakeholders of unacceptable behaviors;

· Using case studies and interactive discussions to reinforce employees' understanding of the importance of professional ethics;

· Providing specific compliance behavior guidelines to help employees make the right decisions in different situations;

· Guiding employees on how to identify and manage potential conflicts of interest to ensure fairness and transparency in decision-making;

· Informing employees of their legal obligations and the Company’s policies regarding information disclosure to prevent insider trading and improper information disclosure.

8.  Ethical Standards Auditing

To ensure that our ethical standards are continuously monitored and evaluated to adapt to the evolving business environment and regulatory requirements, we conduct regular business ethics audits across all business lines. This covers key areas such as financial management, supply chain management, human resource management, marketing, and customer relationship management. Specific measures include, but are not limited to:

· Establishing a professional, independent internal audit team and, when necessary, hiring external professional audit agencies;

· Identifying potential ethical and compliance risks, assessing risk levels, and developing corresponding risk management measures;

· Conducting an ethics audit covering all key business lines every three years, and conducting ethics audits for non-key business lines as needed;

· Annually optimizing existing ethical standards and regulations based on audit results and feedback.

9.  Whistleblowing and Violation Handling

Any employee who violates this policy will be dealt with according to the severity of the violation. The Company encourages stakeholders to monitor business activities and report non-compliance behaviors. For more details on the Company's whistleblowing policy, please refer to the "China Resources Mixc Lifestyle Whistleblowing Policy."