Rongsheng Petrochemical Co., Ltd. (hereinafter referred to as “Rongsheng Petrochemical,” “the Company,” or “we/us”), as a leading enterprise in China’s petrochemical industry, fully acknowledges the value, importance, and necessity of sustainability. We have developed the Business Ethics Policy in accordance with the Company Law of the People’s Republic of China, the Securities Law of the People’s Republic of China, the Anti-Money Laundering Law of the People’s Republic of China, the Anti-Unfair Competition Law of the People’s Republic of China, the Basic Internal Control Norms for Enterprises, and other relevant laws, regulations, and norms. We are committed to achieving high standards of business ethics and corporate governance. We select suppliers and other stakeholders with similar business ethics as our business partners, establish mutually beneficial relationships with them, and run our business with integrity and fairness.
The Policy applies to all Rongsheng Petrochemical and its subsidiaries’ employees (including full-time and part-time), all directors of the Company, as well as all third parties with business relations with the Company, including customers, suppliers, contractors, and other stakeholders. Because of the Company’s extensive distribution of operating locations, the Policy outlines the business ethics management policy at the Company level, and each operating location must consider local factors when determining ethics management measures and plans. If the standards required by this policy are higher than those required by laws, regulations or industry codes, the Company shall comply with such higher standards.
三、 商业道德监督Business Ethics Supervision
The Company’s Board of Directors has overall responsibility for business ethics and anti-corruption work, and directs and supervises the implementation of related work. The Strategy and ESG Committee under the Board of Directors is responsible for formulating business ethics work guidelines and key measures, identifying compliance risks, hosting regular business ethics supervision meetings, studying and deploying key supervision tasks, promoting promptly rectification of identified problems and reporting regularly to the Board of Directors.
四、 管理政策与措施Management Policies and Measures
反贿赂与反腐败Anti-bribery and anti-corruption
"Commercial bribery" refers to the act of offering, promising, giving property or other benefits to state employees, social organizations or employees of companies for the purpose of obtaining improper benefits, including seeking improper advantages or improperly influencing a decision.
We insist on operating with integrity in accordance with the law, regulate our conduct against high standards of business ethics, and adopt a “no tolerance” approach for integrity management. Any bribery, giving and taking kickbacks and other forms of corruption are strictly prohibited.
（1）收受或提供利益Taking or giving advantages：
We require all employees to sign the Integrity Practice Commitment and take integrity as an essential basis for all employees’ appraisal, appointment, dismissal, and promotion. We prohibit employees attending banquet hosted for us or ask for or accept gifts or cards and coupons with cash value. Under no circumstances should an employee provide advantages to any person or companies, to influence that person or the Company in their business dealings. Violations of this Policy will result in punishments or dismissal for the employee. Any violation of anti-bribery and anti-kickback laws will result in criminal and civil penalties for the employee and the Company.
（2）供应商及合作伙伴Suppliers and partners：
We require suppliers to sign of the Letter of Integrity Responsibility and Commitment. In contracts with suppliers, we have added a clause on the prohibition of commercial bribery, which clearly requires both parties to the agreement to strictly abide by laws and regulations on anti-commercial bribery of the People’s Republic of China. We prohibit commercial bribery in contract discussion, negotiation, signing, and performance.
"Money laundering" refers to the act of legalizing the proceeds of drug crimes, smuggling crimes, crimes of triad organizations, crimes of terrorist activities, crimes of embezzlement and bribery, crimes against the financial management order, and crimes of financial fraud by disguising and concealing their sources and nature in various ways.
We strictly resist money laundering. We require all directors, employees and all third parties to abide by the Anti-Money Laundering Law of the People’s Republic of China and other relevant laws and regulations, and eliminate any forms of financing for terrorism or other illegal and criminal activities. For our partners, we understand and investigate their background and supervise their conduct to prevent them from money laundering and ourselves from being involved in money laundering activities.
竞争与反垄断Competition and anti-monopoly
"Unfair competition" refers to the behavior of business operators in their business activities that, by means of violating recognized business ethics, seek trading opportunities or undermine the competitive advantage of other business operators, thus disrupting social and economic order. The implementation of unfair competition will face civil damages, administrative penalties, and even criminal liability. We strictly abide by the Anti-Unfair Competition Law of the People’s Republic of China and the Anti-Monopoly Law of the People’s Republic of China. The directors, all employees and all third parties of the Company shall comply with international and domestic laws against unfair competition, and are prohibited from engaging in the following acts:
（一）操控价格、集体抵制或瓜分市场的安排Arrangements to manipulate prices, collectively boycott or carve up the market；
（二）与竞争对手交换影响竞争的敏感资料 Exchanging sensitive information with competitors that affects competition；
（三）对客户或供应商实施限制 Imposing restrictions on customers or suppliers；
（四）滥用市场主导地位等Abusing market dominance.
举报与处理Reporting and handling
To regulate the performance of duties and promote ethical practice, we have established a system for monitoring and reporting, and continuously improve our reporting process and increase reporting channels, which include hotline, WeChat, and email. We expect and encourage employees, customers, suppliers, and other stakeholders to report misconduct or illegal activities within the Company. All reported violations will be investigated promptly and thoroughly. If a report of violation is substantiated, we will take appropriate corrective actions to address it.
举报范围包含但不限于以下情形Matters that shall be reported include but are not limited to：
（一）利用职务便利收受、索取供应商或其他合作伙伴所送的财物或其他利益Taking advantage of the position to accept or solicit property or other advantages from suppliers or other partners；
（二）违反规定收受礼品、礼金或未按规定及时上交公务活动中的礼品、礼金Receiving gifts or money in violation of regulations or failing to timely hand over gifts and money in official activities in accordance with regulations；
（三）侵占、盗窃、骗取、挪用公司财物或私设、私分小金库Embezzlement, theft, defrauding, misappropriation of the Company property or privately setting up or drawing from off-book accounts；
（四）违规实施关联交易或违反利益冲突条款，利用职务便利为本人或亲友谋取利益 Conducting connected transactions in violation of regulations or violating the terms of conflict of interest and taking advantage of the position to seek personal interests or interests for relatives and friends；
（五）侵害公司知识产权Infringing the Company’s intellectual property rights；
（六）营私舞弊或从事内幕交易Committing malpractice or insider trading；
（七）严重疏于职守、滥用职权或违反公司制度并造成损失Serious neglect of duty, abuse of power or violation of the Company system and cause losses；
（八）其他腐败或不诚信的行为Other corrupt or dishonest conduct.
Business ethics reporting hotline: 0571-8352 9319
Business ethics reporting e-mail：firstname.lastname@example.org
Mailing address for business ethics report letter：Received by the person in charge of the inspection department at No. 678 Xinyi Road, Yinong Town, Xiaoshan District, Hangzhou City, Zhejiang Province. Postal code: 311247
举报人保护Protection of whistleblower
Unless required by law or regulation to disclose, for legal or auditing purposes, or when the case is referred to the relevant regulatory agency or law enforcement agency, we strictly keep the identity and information and all the information and the materials we receive confidential. This provision covers the entire process of information collection, investigation, and the assistance of whistleblowers. We handle the matters reported by whistleblowers with the greatest care, and complete the report processing with the least number of personnel to reduce the risk of information leakage. Whistleblowers must also keep confidential about reporting, the nature of the report, and the identity of the person involved so as not to hinder the investigation.
We require all departments and subsidiaries to correctly treat the conduct reported by whistleblowers in accordance with the law, and shall not to retaliate against whistleblowers under any excuse. Retaliation against whistleblowers, including condoning, shielding or bribing, or instigating others to retaliate against whistleblowers, should be held accountable. Those who are found to have violated the law by the judicial organs shall be sent to the judicial organs for handling.
审计与培训Audits and training
The Company inspection department conduct at least one business ethics audit inspection annually for the Company headquarters, all subsidiaries, and subordinate enterprises to ensure that our own operations and management are in compliance with laws and regulations, and continuously improve our operational efficiency and effectiveness. We also conduct ethics and integrity audits on suppliers, and promptly remove suppliers that do not meet the requirements.
The Company directors, all employees (including full-time and part-time employees), and all suppliers are required to receive annual business ethics education and training from the Company, convey the Company’s integrity and compliance philosophy and ensure that employees and suppliers understand and abide by the Company’s code of business ethics.
五、 政策回顾Policy Review
The Policy will be reviewed and revised regularly to ensure that it reflects changing stakeholder expectations as well as changes in relevant guidelines and standards.