Management System for Integrity

I. Objective

   To strengthen the company's integrity, establish a corruption prevention mechanism, prevent the risk of fraud, and promote the healthy and sustainable development of the company, we hereby formulate this system.       

II. Scope

           This system applies to Kuncai Technology and its subsidiaries.     

III. Structure and responsibilities of the Integrity Committee
The company has established the Integrity Committee, which is responsible for the work related to the Company's integrity management and is composed as follows:

Organizational Chart of the Integrity Committee


Director:Chairman. Responsible for setting the direction of the company's integrity work and approving the final decision on how to deal with the results of fraud investigations.

Deputy Director:Head of the Audit Department. Responsible for promoting integrity training, receiving reports and investigating fraudulent matters, issuing investigation reports and penalties, and convening fraud review meetings.

Members:Director of the General Manager's Office, Head of the Legal Department, President of the Labour Union. Responsible for attending the evaluation meeting on fraud matters, conducting a comprehensive evaluation of the decision to impose penalties on fraudulent personnel who violate the law, and providing legal opinions on how to qualify the illegal matters touched upon by internal personnel and units involved in fraudulent incidents and behaviours, how to impose penalties, or whether to refer them to public security organs.

IV. Determination of fraud

Fraud, as referred to in this system, refers to the use of deception or other means by persons inside or outside the company to obtain improper or illegal benefits, including but not limited to the following acts:

(1) Accepting or soliciting bribes or kickbacks (including equivalents of any kind);

(2) Transferring to another person a transaction that would have been profitable to the company in the normal course of events;

(3) Illegal use of company assets, embezzlement, misappropriation and theft of company funds;

(4) Making the company pay for false transactions;

(5) Intentional concealment and misstatement of transactions;

(6) Falsification or alteration of accounting records or vouchers;

(7) Disclosure of the company's trade or technical secrets;

(8) Any other fraudulent behaviour detrimental to the economic interests of the company.

V. Prohibited Behaviors

The employees shall follow the principle of integrity and lawfulness in their work activities, comply with the company's "Integrity Convention", shall not touch the company's "Ten Management Red Line", shall not violate the following behaviours:

1、Employees shall not solicit or privately accept kickbacks, commissions, gambling, loans, transfers of money, goods or purchases from the cooperation unit in any form in connection with their work.

2、Employees may not accept gifts, securities, valuables, ornaments or jewellery from the cooperation unit.

3、Employees shall not seek reimbursement from the cooperative unit or ask the cooperative unit to pay for expenses that should be paid by the individual.

4、 Employees may not attend any form of banquet or entertainment that may interfere with the performance of their official duties; if they must attend, they must obtain the approval of the Company's General Manager; and they may not accept or request excessive hospitality.

5、Employees shall not solicit or accept from the cooperation unit any favours for their own home decoration, marriage and funeral, work arrangements and travel abroad for relatives and friends (including spouses, children, other close relatives and friends).

6、Employees shall not enter into any unauthorised private negotiations or reach any tacit agreement with employees of the cooperative unit regarding the supply of equipment, prices, methods of payment, packaging, transport methods, quality standards, acceptance criteria, warranties, etc. for the company's products and materials to the detriment of the company.

7、Employees may not accept part-time jobs or positions with suppliers; they may not hold any form of shareholding or commission in suppliers; and they may not use suppliers' resources for personal gain.

8、Employees shall not introduce their friends or relatives to the cooperative unit to engage in economic activities related to the production or supply of materials, production equipment, research and development, etc., for the company's products.

9、Employees must not use improper means to harass or oppress suppliers for personal gain, e.g. delaying payment, deliberately withholding payment, making malicious complaints, etc. They must not charge suppliers for any reason that is against the rules, e.g. loading and unloading charges, etc.

10、Employees must not submit false expense claims, issue false or overstated invoices or use the company's funds for personal purposes. It is not permitted to take money from the company by making false expense claims or borrowing from the imprest account.

11、Employees must not conceal or misrepresent business transactions or falsify or alter work-related invoices or documents.

12、Employees must not divulge company secrets, including but not limited to information relating to the company's strategy and business management, product and technology, business and human resources.

13、Employees must not use, misappropriate or steal the company's assets, property, intellectual property rights, technical drawings, software programmes or other confidential information for personal use.

14、Employees shall not engage in any other fraudulent behaviour that is detrimental to the company's interests and in violation of the company's rules and regulations.

VI. Disposal of Gifts in the Normal Business

For the company's normal business received in the value of more than 200 yuan of the case gifts, gifts, etc., must be submitted to the company's General Manager's Office of the unified registration of the accounts, storage, processing:

1、Gifts that are perishable and difficult to store are registered with the General Manager's Office and distributed to company employees;

2、Unmarked gifts and vouchers may be retained by the company and transferred as gifts to other cooperative units or treated as company awards;

3、Gifts such as cigarettes and alcohol are used for the company's public use or to entertain visitors;

4、Special gifts, gifts of a large monetary value or gifts with a special significance should be discussed with the Chairman before disposal.

VII. Incentives and Penalties

1、Penalties.For violations of the company's integrity system, the Integrity Committee will, based on the results of the investigation, make a preliminary recommendation for punishment and report to the Chairman, who will make the decision to deal with it. Employees who violate the company's integrity management policy and relevant national laws and regulations will be subject to the following sanctions, depending on the severity of the case:

1)Written criticism.Minor violations where the amount of the violation does not exceed 1,000 yuan or the number of times is less than three, and no damage is caused to the company's interests or reputation;

2)Notification of criticism.There are certain circumstances of violation, and the amount of violation exceeds 1,000 yuan but does not exceed 5,000 yuan, or the amount does not exceed 1,000 yuan and does not cause serious (more than 5,000 yuan and less than 10,000 yuan) damage to the company's interests and reputation;

3)Warning.The violation is more serious and the amount of the violation exceeds 5,000 yuan but does not exceed 10,000 yuan, or although the amount does not exceed 5,000 yuan, it causes significant (more than 10,000 yuan and less than 20,000 yuan) damage or certain damage to the company's interests and reputation;

4)Record a demerit.Violation of more serious circumstances, the amount of violation exceeds 10,000 yuan, but does not exceed 30,000 yuan, or cause ultra-significant (more than 20,000 yuan and less than 30,000 yuan) damage to the company's interests and reputation;

5)Termination of labour relations.If the violation is very serious and the damage to the company exceeds 30,000 yuan, but the person actively returns and compensates the company for the damage, the company will not refer the case to the public security organs;

6)Referral to public security organs.If the violation is very serious and causes the company losses of more than 30,000 yuan, and if the person does not actively return or compensate the company for the losses, the company will refer the case to the public security organs for handling, while terminating the employment contract.

In addition to the above penalties, the company has the right to recover the illegal gains of the violators and to claim compensation for the damages caused by the violators.

2、Incentives.After consideration by the Integrity Committee and approval by the Chairman, the following incentives will be provided for timely reporting to avoid economic loss to the company:

(1) If the amount of economic loss recovered is 10,000 yuan (not included) or less, 10% of the actual amount of economic loss recovered shall be awarded, and the amount of the award shall not be less than 500 yuan;

(2) The amount of economic loss recovered 10,000-50,000 yuan (not included) will be rewarded at 5% of the actual amount of economic loss recovered, and the amount of the reward shall not be less than 1,000 yuan;

(3) The amount of economic losses recovered 50,000 yuan (including) or more, according to the actual amount of economic losses recovered 3% of the award, and the amount of the award is not less than 2,500 yuan, not more than 100,000 yuan;

(4) (4) For non-monetary fraud cases, depending on the severity of the type of fraud, a one-time award of 500 yuan, 1,000 yuan, 3,000 yuan, 5,000 yuan, four levels for the whistleblower.