Code of Ethical Conduct & the procedure for responding to allegations


Ethical Management:

The Board has adopted the “Procedures for Ethical Management and Guidelines for Conduct” in 2017. The Procedures clearly state the regulations for the prevention of conflicts of interests for directors, managerial officers, employees, contractors, and any person with substantial control, and serve as a behavioral code of practice to prohibit illegal political donations, giving or receiving inappropriate profits, charity donations, or sponsorship. Besides requiring the senior management to carry out ethical management in practice, we also implement this philosophy on employees through internal promotions, the communication platform, and regular educational training.


Employees’ Code of Ethical Conduct:

Nan Pao has established a set of Code of Ethical Conduct for all managerial officers and employees to follow. We aim to enhance the behavioral conduct and business integrity throughout the Company. We hope all employees can comply with the Code of Ethical Conduct during day-to-day operation and carrying out Company tasks so that we could be trusted by the public, as well as ensure the Company’s sustainable growth and development. We also aspire to mutually fulfill corporate social responsibility and promote balanced and sustainable economic, social, and environmental development through promoting the Code of Ethical Conduct. “Employee Opinion Mailbox” and “Employee Grievance Handling System” have been established at Nan Pao. When questions regarding ethics and legal conduct emerge or when encountered with unfair treatment at work, employees can receive appropriate suggestions through consulting with the HR Department or through seeking assistance via the mailbox. Subsequently, whistle-blowing can be filed to find or prevent significant illegal conduct and breach of governmental regulations. No breach of the Code of Ethical Conduct had occurred in 2018. In the future, we will continue to strengthen educational training for employees to facilitate for more understanding of ethical conduct, preventing conflicts of interests and seeking self-interests, the responsibility to confidentiality, fair trade, protection and the appropriate use of Company property, and compliance with legal regulations.


The procedure for responding to allegations


For implementing a Code of Ethics and Procedures for Ethical Management and Guidelines for Conduct and preventing corruptions ,the Company passed the regulation of “Regulations Governing Whistle-blowing from Internal and External Parties” and setup an email box([email protected]) for reporting, the incoming cases will be investigated and followed-up by the auditing manager.

The procedures of reporting and investigating as followed:


The auditing office controls the fraud risks in the auditing processes, the auditing office will list the abnormal cases during operational processes andthe potential frauds into the follow-up procedure. All the subsidiaries of the group will take actions of “Regulations Governing Whistle-blowing from Internal and External Parties “in the future. Besides the internal regulations and policies, the Company will announce the believes, policies and regulations to our suppliers, customers and other partners for their understanding. The human resource department educates the new coming employees with the regulations and the expectations, the employees can report the illegal cases through the report