Hymson has always attached great importance to enterprise compliance and honest operation, and is committed to conducting business on the basis of fairness, impartiality, and openness. In the process of conducting business both domestically and overseas, Hymson adheres to the applicable anti-corruption and anti-bribery laws and regulations of various countries, and firmly opposes any form of corruption and bribery.
To this end, Hymson has formulated the Hymson Overseas Business Employee Compliance Code of Conduct (hereinafter referred to as the "Code of Conduct"), which provides comprehensive requirements for Hymson's overseas business employees to conduct business from six perspectives: basic guidelines, internal compliance requirements, external compliance requirements, other personal code of conduct, compliance responsibilities of management, and consultation, reporting, and violation handling. Meanwhile, out of absolute importance attached to overseas anti-corruption and anti-bribery matters, Hymson has formulated this Hymson Anti-Corruption and Anti -Bribery Policy (hereinafter referred to as "Anti-Corruption Compliance Policy") to further regulate matters not covered in this domain.
This anti-corruption compliance policy applies to all employees of Hymson Laser Technology Group Co., Ltd. and its domestic and foreign subsidiaries, affiliated companies, and various branches (hereinafter collectively referred to as "Hymson"), as well as individuals acting on behalf of the Company, including all directors, senior executives, full-time employees, part-time employees, consultants, outsourcing, interns, laborers, dispatched/dispatched personnel, agents of Hymson Group, and other personnel acting on behalf of the Company (hereinafter collectively referred to as "relevant entities"). All relevant entities shall abide by and maintain the anti-corruption and anti-bribery policies formulated by Hymson. If this anti-corruption compliance policy is inconsistent with local laws and regulations, the more stringent requirements shall prevail.
Hymson is committed to establishing its own anti-corruption and anti-bribery compliance system from five dimensions: leadership, support, process, supervision, and optimization:
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Leadership
The Senior Executive of Hymson attaches great importance to the anti-corruption and anti-bribery compliance work within the group. Hymson has established an Supervision Department responsible for anti-corruption and anti-bribery compliance within the group, and has also established a Hymson Group Audit Committee. The leadership of Hymson has made a Senior Executive Anti-Corruption Commitment, and has implemented this anti-corruption and anti-bribery compliance system and supporting policies within the group, clarifying the Company's attitude and goals towards corrupt and bribery behavior and making a Hymson Anti-corruption Compliance Commitment. We are committed to laying a solid foundation for the development of the enterprise through compliant and honest operation, and establishing an effective, supervised, and continuously optimized anti-corruption and anti-bribery management system.
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Support
In order to support the establishment and sound operation of the group's anti-corruption and anti-bribery management system, Hymson provides sufficient resource support to relevant departments within the group, conducts training and publicity on anti-corruption and anti-bribery for senior executive and employees, and is committed to enabling every member of the group to learn and master the red line in their own work process, and to do a good job in the first line of defense for anti-corruption and anti-bribery work.
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Process
In specific areas such as the signing of employment and declaration documents, hospitality and travel, and procurement transactions with suppliers and other Third Party, Hymson has set clear and specific process approval requirements and steps. We ensure the effective implementation of the system through clear rules, reduce the possibility of corruption and bribery from the top-level design, and do a good job in the second line of defense for anti-corruption and anti-bribery work.
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Supervision
Supervision Department of Hymson regularly conducts compliance audits to identify risk behaviors within the group and evaluate the implementation of group policies. Meanwhile, by setting a clear reporting path with the relevant responsible departments, Hymson encourages relevant personnel to provide relevant clues through clear reporting paths and relevant departments, making effective supervision and regular evaluation the third line of defense for anti-corruption and anti-bribery work.
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Optimization
For the problems discovered through the supervision system, Hymson adheres to the attitude of being held accountable for any problems. We will clarify relevant facts and problems through investigation and research, and take relevant measures based on the investigation results. Through continuous supervision and improvement, Hymson optimizes its shortcomings in the domain of anti-corruption and anti-bribery compliance, continuously iteratively updating and improving its compliance system.
Legal Red Line
Hymson strictly prohibits bribery in the commercial and public domains. In the public domain, this anti-corruption compliance policy prohibits relevant entities from directly or indirectly providing, promising, authorizing, or giving any valuable thing or benefit to "public officials" and their families in order to obtain or retain business or improper benefits. The above-mentioned "public officials" not only include officials serving in foreign governments and their departments, but also personnel of enterprises and public international organizations owned or controlled by foreign governments and performing government functions, and even individuals acting on behalf of these entities and other individuals engaged in public services.
In the commercial domain, Hymson also prohibits Company employees from providing, promising, authorizing or giving any valuable thing to any personnel and their families of private enterprises, in order to improperly influence the recipient to do or refrain from doing any behavior that violates their responsibilities in such private enterprises, and thus obtain undue benefits. Meanwhile, Hymson also prohibits Company employees from accepting any valuable thing provided, promised, authorized or given by any entity for the aforementioned corrupt purposes.
Similarly, Hymson strictly prohibits relevant entities from evading the supervision of the group's anti-corruption and anti-bribery compliance system through providing false materials, fabricating and concealing facts, concealing sources of funds, and causing discrepancies between accounts and reality.
Specific Details
1. Gifts, Hospitality, And Travel
Hymson employees are not allowed to directly or indirectly provide, promise, authorize, give, accept, or demand any valuable thing or other benefits, including but not limited to money, gifts, travel expenses, job opportunities, etc., to public officials or related personnel in order to influence a certain decision or seek improper benefits.
Normal business banquets, receptions, and gifts are common practices in the business field, and are not prohibited by Hymson. However, in order to avoid such reception behavior constituting illegal and disciplinary behavior, relevant personnel shall make judgments from at least four dimensions when handling reception matters: reception purpose, reception object, reception items, and reception scenario:
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Reception purpose: It is not allowed to receive for the purpose of influencing a certain decision or seeking other improper benefits, but it can be received for the purpose of building or maintaining normal business cooperation relationships when other conditions are met simultaneously;
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Reception object: Whether the objects received by the Company may have government and public institution backgrounds or conflicts of interest with the Company;
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Reception items: The substance and amount of gifts, banquets, travel expenses, and other items involved in reception shall comply with normal business practices in the relevant industry and local social standards. In addition, the reception amount shall not exceed the socially acceptable level or the limit stipulated by local laws and regulations;
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Reception scenario: Whether the time node of the reception is in a "sensitive period", that is, at a critical node in bidding, Contract signing, and other matters. These time nodes are often more likely to lead to related receptions being seen as improper corrupt and bribery behavior.
Correspondingly, Hymson also prohibits employees from receiving any gifts,hospitality, or travel that may be seen as affecting their decision-making and judgment. When feasible, employees shall seek approval from their [Superior Supervisory Department] before receiving gifts. If there are situations where prior approval cannot be obtained (such as external personnel directly sending gifts to the Company), employees must also immediately report relevant matters to the [Superior Supervisory Department].
For detailed guidance on gifts, hospitality, and travel, please refers to the Hymson Overseas Local Reception Policy.
2. Charity and Donation
Hymson prohibits the use of charity and donation to cover up corrupt purposes, and never allows improper influence or exchange of any improper interests or benefits for public officials through charity or donation. However, as part of charitable activities, donating directly to government agencies (rather than individual government officials) is not necessarily prohibited. However, prior approval from the [Supervision Department] is required before making such donation.
3. Third Party Partner Management
The term "third-Party partner" referred to in this anti-corruption compliance policy refers to the Company's suppliers, distributors, agents, contractors, consultants, and any other Third Party acting on behalf of the Company (hereinafter collectively referred to as "Third Party"). Hymson upholds the principles of fairness, impartiality, and openness in cooperating with Third Party, providing them with documents such as Hymson Anti-Corruption and Anti-Bribery Policy and Supplier Integrity Notice, requiring them to comply with Hymson Third Party Partner Management Compliance Policy, and sign Contracts with them containing anti-corruption and anti-bribery related clauses.
Hymson prohibits any Third Party from bribing influential public officials or private enterprise personnel and their families. Naturally, Hymson also prohibits its employees from using Third Party to bribe any public officials or private enterprise personnel and their families. Correspondingly, Hymson also requires Third Party not to bribe Hymson employees, such as providing gifts, hospitality, and reimbursement of travel expenses that do not comply with commercial practices.
For detailed guidance on third-Party partner management, please refer to the Hymson Third Party Partner Management Compliance Policy.
4. Books and Records
Hymson adheres to a transparent and fair approach in the process of conducting business, and records the disposal and expenditure of Company assets based on the principles of truthfulness, completeness, and accuracy. Hymson strictly prohibits evading the group's anti-corruption and anti-bribery supervision system by providing false materials, fabricating and concealing facts, and concealing source of funds.
5. Other Matters
Political donations - Hymson does not directly or indirectly participate in any political Party activities, nor does it sponsor local political Parties, candidates, their affiliates, or any affiliated organizations.
Facilitation payments - The prohibition of bribery by Hymson applies to all improper payments, regardless of their scale or purpose, including facilitation payments. Facilitation payments refer to small payments made to government officials to expedite or facilitate actions or services that such officials do not have discretionary power, such as obtaining a general license or business license, processing government documents such as visas, customs clearance, providing telephone, electricity or water services, or loading and unloading goods. Since many countries prohibit such benefits fees, Hymson does not allow related entities to pay facilitation payments to government officials of any country.
Consultation and Reporting
All employees of Hymson and other third-Party related personnel shall comply with applicable anti-corruption and anti-bribery laws and regulations, as well as this Hymson anti-corruption compliance policy. Those who fail to comply with this anti-corruption compliance policy will be punished in accordance with the Company's regulations and policies, such as the Management Measures for Punishment of Employee Violations. Severe cases may include termination of employment, deduction of all bonuses, severe warnings, and termination of business relationships. If you have any questions about this anti-corruption compliance policy, please feel free to consult the [Supervision Department] through [Email].
If you find anyone who is suspected or has violated this policy, please report it through the following channels:
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Report mailbox:jubao@hymson.com |
Special report telephone number:+86-0755-28197985-8118 |
Hymson will take it seriously and conduct necessary investigations into the relevant reports. Hymson welcomes and encourages anyone to actively report illegal and disciplinary behavior, and will strictly keep the identity of the informant confidential. No one is allowed to threaten or retaliate against those who report potential compliance issues in good faith.