Anti-corruption and Ethics Management 
Master Kong focuses on enhancing its compliance management, endeavoring to create a workplace environment with integrity, honesty and transparency. The Company strictly complies with 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 laws and regulations, and has formulated anti-corruption-related management systems such as the Management Measures on Employees’ Integrity and Self-discipline Behaviour, and the Management Measures on Contract Inspection and Review, and continuously improves the anti-corruption management system, avoiding any direct or indirect illegal commercial acts including corruption, bribery, extortion, fraud and money laundering, etc. We published articles and shared anti-fraud cases on the enterprise WeChat platform and online learning platform, educated all employees about the integrity culture and related norms of the Master Kong Group, opened a fraud reporting channel, and sent the Audit Fraud Investigation Report to the senior management and directors, constantly strengthening the directors’ and employees’ awareness of integrity and compliance to ensure comprehensive coverage of integrity management. 

Anti-Corruption Policy
Master Kong prohibits directors and all employees from engaging in or profiting from any illegal or unethical economic behaviours and advocates all of our employees to abide by professional ethics and moral principles. We demand our employees and suppliers to sign the Anti-Commercial Bribery Pledge, which clearly states that they will not offer or accept bribes and maintain a good working environment. We enhance our ability to deal with the relevant issues, constantly improve our employees’ awareness of anti-corruption, and continue to build and promote a culture of corporate integrity. 

Whistleblower Protection
In response to commercial bribery, fraud and other illegal acts, Master Kong has established a special reporting channel to encourage internal and external personnel to monitor each other, and participate in the construction of the Company’s business ethics and compliance culture to resist malpractices. We have published the Acceptance Principles of Whistleblowing and Reward Regulations and the whistleblower hotline and e-mail address on the Company’s official website to encourage employees, suppliers and other parties to participate in real-name whistleblowing. In response to external extortion, fraud and other incidents, the Company has formulated a special emergency plan and handling mechanism to improve its ability to deal with related problems. We set up a Corporate Security Team under the Audit Department, which is fully responsible for the analysis, investigation and handling of whistleblowing cases. We have formulated the Whistleblowing Operation Procedures to regulate the process of handling reports, the principles of reward and the relevant requirements for the protection of whistleblowers, strictly keep whistleblowers’ information confidential, and strictly prohibit any form of retaliation against whistleblowers. 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. In 2023, there is no leaking the information of whistle-blowers.

Regular Audits of Ethical Standards

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 abide by the code of professional ethics and disciplinary code, and strictly follow the principle of confidentiality when performing their duties. In 2023, there is no leaking the information of whistle-blowers. As an important component of risk management, The Audit Department conducts company-wide audits of major risk management and the effectiveness of the internal control system every year. The Audit Department makes suggestions for improvements to address the deficiencies of the existing systems, which avoid the occurrence of irregularities and illegal acts such as employees taking advantage of loopholes in the system to commit fraud.

In 2023, the Corporate Security Team completed the special investigation of 35 fraud reporting cases, and also conducted special audit operations across the Group in the segments of internal control and risk management, legal compliance management, capital, insurance and investment and financing management, tax and accounting management, seal contract and archive management, procurement management, etc., reviewing the effectiveness of the control systems for business ethics and professional ethics involved in the relevant projects, and comprehensively strengthen the Company’s anti-corruption and anti-fraud management. In 2023, no concluded cases regarding corrupt litigation brought against the Company or its employees were noted.

Employee Training on Ethical Standards

In 2023, we incorporated the Measures for the Management Measures on Employees’ Integrity and Self-discipline Behavior into the quarterly internal control system training for new employees of the Company, propagated the culture of integrity and self-discipline and the code of conduct in the form of on-site lectures, and cooperated with the internal culture-building secretariat and the audit office in releasing integrity training videos on corporate WeChat to all employees (Including part-time employees) and contractors. We also provide ESG related training on anti-corruption and business ethics issues to our directors online.

Business Ethics Reporting 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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