一、 目的 Objective
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 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.
二、 范围 Applicability
The Policy applies to all Rongsheng Petrochemical and its subsidiaries’ employees (including full-time and part-time), 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.
三、 管治 Governance
The Company’s Board of Directors has established a Strategy and ESG Committee to review and oversee ESG-related matters including business ethics policy development and implementation management, report investigation, and accountability. The Committee reports 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
We insist on operating with integrity in accordance with the law, regulate our conduct against high standards of business ethics, and adopt a “zero-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.
反洗钱 Anti-money laundering
We strictly resist money laundering. We require all employees and partners 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
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. We forbid our employees from getting involved in the following activities:
(1) Arrangements to manipulate prices, collectively boycott or carve up the market;
(2) Exchanging sensitive information with competitors that affects competition;
(3) Imposing restrictions on customers or suppliers;
(4) 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.
Matters that shall be reported include but are not limited to:
(1) Taking advantage of the position to accept or solicit property or other advantages from suppliers or other partners;
(2) Receiving gifts or money in violation of regulations or failing to timely hand over gifts and money in official activities in accordance with regulations;
(3) Embezzlement, theft, defrauding, misappropriation of company property or privately setting up or drawing from off-book accounts;
(4) 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;
(5) Infringing the Company’s intellectual property rights;
(6) Committing malpractice or insider trading;
(7) Serious neglect of duty, abuse of power or violation of company system and cause losses;
(8) Other corrupt or dishonest conduct.
举报人?；?nbsp;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
We regularly conduct compliance audits on internal business ethics and other aspects of our operations 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.
We reiterate anti-corruption and anti-bribery requirements to all employees and suppliers or host relevant trainings every year to 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.