Sangfor Technologies Inc. (hereinafter referred to as "Sangfor “or “Company”) is committed to maintaining a fair, just, open, and transparent business environment, and we strive to prevent and eradicate any internal corruption and fraud. The Sangfor Integrity and Reporting Policy is introduced in the following eight sections: The Department Accepting Reports, Obligated Parties, Reporting Methods, Confidentiality Measures, Rewards, Reporting Template and Requirements, External Reporting Channels for Fraud/Corruption Cases, Scope of Accepted Reports.
1. The Department Accepting Reports
Sangfor Audit Department
2. Obligated Parties
All employees of Sangfor and its affiliates
3. Reporting Methods
4. Confidentiality Measures
4.1 Personal protective measures
(1) "One on one single-line contact" for confidentiality
(2) Reporting rewards are distributed through exclusive channels to ensure effective protection of whistleblowers
4.2 Additional protective measures for suppliers, distributors, partners, etc.
(1) Regardless of whether the reporter/whistleblower has directly or indirectly provided illegitimate benefits to company employees or their associates in the past, if they actively report the incident to the company's audit department, they will be exempt from punishment, and the company will continue to cooperate with them and consider more preferential cooperation opportunities.
(2) During the investigation performed by the audit department, cooperating with the investigation can mitigate liabilities for the reporting party, and if the whistleblower provides valuable information unknown to the audit department, they will be exempt from penalties, and continuous cooperation may even result in monetary incentives.
5.1 150 USD will be rewarded after verification if the report and investigative cooperation are provided without valid evidence.
5.2 700-7000 USD will be rewarded on a per-case basis if the report and investigative cooperation are provided along with direct and verifiable evidence. If the resulting financial loss is recovered by Sangfor, an additional 20% to 50% of the recovery amount will be rewarded to the cooperating party (up to 140,000 USD).
5.3 In addition, 4000 USD will be rewarded if the above conditions are met, and the police have verified the case as a crime, examples being bribery of non-state staff, infringement of trade secrets, or misappropriation of funds. Higher rewards are given for cases involving higher amounts of money.
6. Reporting Template and Requirements
6.1 The reporting template should contain the following:
Offender and whistleblower (depending on his willingness) contact information, name, department, fraud subject, details of the crime or dishonest behavior (time, place, related parties, and specific details of the violation), and supporting materials.
(1) The reporting letter should be based on facts and not fabricated or contain unsubstantiated claims.
(2) We encourage reporting using a real name, but also accept anonymous reporting, although we request valid contact information so that we can reach you if needed.
7. Scope of Accepted Reports
7.1 Requesting or accepting bribes or illegitimate sales commission from third parties, including but not limited to Sangfor suppliers, distributors, partners, and other third parties or individuals. Forms of bribery or sales commission include but are not limited to any form of benefit, including cash or gifts, with the exception of non-recurring gifts with a value of less than 30 USD.
7.2 Engaging in non-work-related financial transactions with any of the third parties mentioned above or third-party staff or individuals, including but not limited to loans, etc.
7.3 Engaging in competition with Sangfor.
7.4 Using the advantages of one’s position at Sangfor to facilitate a company (organization) which directly or indirectly holds stock (equity) or holds management positions, to engage in direct or indirect financial transactions with Sangfor, including but not limited to becoming a distributor, supplier, or partner of Sangfor.
7.5 Engaging in transactions or potential transactions for the purpose of transferring benefits to one’s self or third parties, where Sangfor would be the original beneficiary, including but not limited to selling company products or services without Sangfor’s authorization by taking advantage of one’s position in Sangfor.
7.6 Other behaviors related to obtaining personal benefit from third parties and individuals mentioned above by taking advantage of positions in Sangfor.
7.7 Theft, misappropriation, intentional damage to any property and intangible assets, funds, etc., belonging to Sangfor.
7.8 Reimbursement requests for any kind of false expenses.
7.9 Private engraving, preservation, use of fake seals, misappropriation, or fraudulent use of seals or signatures of relevant approvers, and forgery or alteration of relevant qualification certificates, official documents, and other documents.
7.10 Intentionally providing false information or other fraudulent actions, including but not limited to deliberately providing fake or falsified documents or certificates and signing labor contracts with Sangfor, cheating in collective activities to undermine the fairness, such as using technology to maliciously generate votes or make instant purchases, concealing and fabricating information to deceive Sangfor for the purpose of receiving welfare or benefits.
7.11 Disclosing confidential information including but not limited to technology, business, salary and other aspects of business information that are not publicly disclosed to others.
7.12 Malicious harassment, insult, slander, defamation, intimidation or retaliation against Sangfor customers or distributors, and falsification of facts to frame or retaliate against colleagues.
The Sangfor audit department will not accept business-related complaints. For business complaints, please consult the relevant business department.
Tel: +60 12711 7129 (7511)