Purpose
Master Kong understands that integrity and legal compliance are the key to long-term business success, and endeavors to create a workplace environment with integrity, honesty and transparency. The policy requires compliance with all applicable laws and regulations on bribery and corruption, including, but not limited to, the Anti-Unfair Competition Law of the People’s Republic of China and the Anti-Money Laundering Law of the People’s Republic of China, and other applicable national anti-bribery statutes and implementing rules and regulations.
Scope and Applicability
The Anti-corruption Policy is applicable to all individuals working at all levels and grades, including directors, senior managers, officers, other employees (whether permanent, fixed-term or temporary), consultants, interns, suppliers, distributors and other third parties (business partners) who act for or on behalf of Master Kong for the purpose of business transactions with Master Kong, etc..
Policy Statement
1. Anti-corruption
·    Master Kong prohibits directors and all employees from engaging in or profiting from any illegal or unethical economic behaviors and advocates all of our employees to abide by professional ethics and moral principles;
·    We demand our employees, suppliers, distributors and to sign the Anti-Commercial Bribery Pledge, which clearly states that they will not offer or accept bribes and maintain a good working environment.
2. Whistleblower Protection
·    The Anti-corruption policy requires all employees to abide by the Whistleblowing Operation Procedures, strictly keep whistleblowers’ information confidential. If there is any leakage of the whistleblowers’ information, it will be dealt with in accordance with the Management Measures of Staff Rewards and Punishments after verification.
3. Audit
·    The Audit Department conducts company-wide audits of major risk management and the effectiveness of the internal control system every year;
·    The personnel of the Audit Department signed a commitment letter of Code of Professional Ethics and Disciplinary Guidelines for Audit Office Personnel every year, promising to strictly follow the principle of confidentiality in the performance of their duties.
4. Communication and Training

·    All new employees of the Company are required to receive the quarterly internal control system training, including the Management Measures on Employees’ Integrity and Self-discipline Behavior;
·    Regular training and awareness sessions shall be made available in relation to the Anti-corruption Policy, the culture of integrity and the code of conduct, company procedures and measures. The details of the Company’s whistleblowing procedures will be disseminated throughout the Company on a regular basis.
5. Penalties
·    Any employee found to be in violation of this policy will be subject to disciplinary action, up to and including termination of employment, in accordance with applicable laws and company policies.
6. Reporting Breaches or Concerns
·    Any employee who witnesses a breach of this policy is obliged to promptly report through the business ethics reporting channels.
·    Any employee who is in doubt, suspects that this policy has been breached or has concerns about past or proposed actions by anyone in Master Kong, or any third party working with the Company in any capacity, is encouraged to contact Master Kong through the following channels:
Master Kong Whistleblowing Official Website: https://www.masterkong.com.cn/contactus/index.shtml
Master Kong Whistleblower Acceptance Pinciples and Reward Provisions: https://www.masterkong.com.cn/contactus/20150527/32285.shtml
Hotline: 021-31753602
Email: jianju@masterkong.com.cn
Mailing address: Building A, No.1688, Wuzhong Road, Minhang District, Shanghai, China, 201103 Whistleblowing supervisor.

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