Integrity and Compliance
Undertaking of the Board/the management of the Company
CIMC has been committed to the core value of integrity, holding a firm stance in combating business bribery and strictly complying with relevant laws and regulations on anti-corruption, anti-bribery, anti-extortion and anti-fraud.
CIMC has been improving the integrity supervision and administration system, has formulated relevant rules and procedures for clean practices, integrity supervision and administration and strictly implemented such rules and procedures, to prevent, control and combat corrupt conduct.
Integrity Supervision System
CIMC Supervision System for Cadres and Sensitive Position Personnel
Measures for the Administration of Supervision, Complaint and Reporting of CIMC
CIMC Accountability Procedure for Responsibility Events
CIMC Clean Practices for Cadres and Sensitive Position Personnel
CIMC Code of Conduct for Staff
Measures for the Discipline Inspection Commission of CIMC on the Management of Gifts and Cash Received by Party Members, Cadres and Employees in Business (Public) Activities
Management Organization and Responsibilities
(i) The President of the Group leads the supervision and appraisal of cadres and sensitive position personnel, provides resources to support, guides and supervises relevant works.
(ii) The Audit and Supervision Department of the Group is responsible for coordinating and managing the supervision work within the whole organization, with specific duties including:
1. Building and maintaining the unified whistleblowing channel of the Group, collecting and managing information related to the reported matters;
2. Handling the reported matters in a timely manner, and conducting investigations directly or transferring the cases to relevant departments for further actions or urging and supervising relevant departments to handle the cases;
3. Judging the responsibilities and offering advice on further actions for the matters investigated independently, and reporting the cases to the higher leadership.
(iii) Leaders who are directly responsible for the business management of entities assume the primary responsibility for the supervision of such entities and their subsidiaries, the supervisory organ of entities shall be responsible for the supervision work of entities and their subsidiaries.
Risk Identification and Prevention
·Being a part of the risk assessment, the evaluation of corruption makes contribution to the effective risk management and internal control. The Audit and Supervision Department of the Company makes regular arrangements for subsidiaries to identify the corruption risk in key business fields, assess the possibility and impact of the risk and develop risk prevention measures.
The Group prepares integrity training materials, promotes regular trainings to cadres and sensitive position personnel, and implements the mechanism of risk management e-learning, dynamic tests and employment with certificates.
The Group makes regular arrangements for cadres and sensitive position personnel to sign the integrity declaration, undertaking to act as a role model of respecting laws and regulations and resisting corrupt conduct.
The Group holds the “zero tolerance” stance towards corrupt conduct and takes the results of supervision as an important basis for the performance review, appointment and excellence appraisal of leaders, and any serious irregularities will be the “one-vote veto” if noticed.
Externally, the Group promotes the transparent cooperation agreement with suppliers and other business partners, to combat corrupt practices that undermine fair competition in the course of business and to punish partners who win business opportunities by bribery, collusive bidding and other illegal means.
The Group requires employees at all levels to avoid any conflicts of interest or any situations that are deemed to have conflicts of interest, and to report the cases prior to actual or potential conflicts of interest.
·As a key initiator of the Enterprise Combat Corruption Alliance, the Group vigorously promotes the construction and development of combat corruption administration system of the alliance and rallies forces of the society to build a clean business environment.
Employees of the Group and its member companies should strictly comply with laws and regulations of the countries and regions where they operate businesses and relevant industry rules on clean practices, adhere to business ethics, regulate business behaviours, fulfill social responsibilities and resist any forms of corrupt conduct stated below:
1. Ask for or receive bribes, kickbacks, commissions and other illegitimate benefits;
2. Embezzle, misappropriate or steal assets of the Group/the Company, or retain or appropriate incomes of the Group/member companies, or utilise resources or assets of the Group/member companies to seek personal gains;
3. Deliver benefits to related parties (enterprises or economic entities in which he/she himself/herself has a controlling stake or a certain stake or acts as a key management member, or his/her kinsfolk (including immediate family members, in-laws and three generations of blood kin) have controlling stakes or certain stakes or act as key management members) in business activities, including but not limited to purchasing or selling products/services from or to related parties at unusual prices;
4. Directly invest in customers, associated business units or competitors of the Group/member companies in his/her name or in someone else’s name, and provide benefits to investees by taking advantage of his/her position;
5. The leader himself/herself transfers or orders subordinates to transfer funds of the Group/member companies to the private coffer via the private account, but not to the business account, or the leader himself/herself falsely reports and claims or fraudulently obtains the funds of the Group/member companies, or orders subordinates to do so;
6. Transfer business opportunities that may enable the Group/member companies to obtain legitimate profits to other parties;
7. Leak business or technological secretes of the Group/member companies to other parties;
8. Forge, alter or provide false documents, data, information and materials of the Group/member companies;
9. Intentionally conceal or misstate transactions, make information disclosure contain false records, misleading statements or material omissions;
10. Seriously violate the financial expenditure requirements of the Group/member companies, use corporate funds without authorisation, or increase the benefits, rewards, allowances, discretionary compensations without authorisation, occupy or misappropriate the funds for special purposes;
11. Other acts that undermine economic benefits of the Group/member companies or obtain economic benefits by improper means.
The Group and its member companies supervise cadres and sensitive position personnel through regular supervision, audit supervision and corruption investigations. Employees of the Group and its member companies should accept and cooperate with the supervision and the investigations for clues. To strengthen the supervision of leaders at key positions, the Group and its member companies perform economic responsibility audits to leaders at all levels on the regular basis and comprehensive inspections to the risk management of all entities, and refer the clues of corruption to the Department of Audit and Supervision in accordance with relevant policies and rules once such clues are found.
The Group encourages employees, business partners and social groups to report corruption of entities and their employees and provide the evidences.
WeChat official account: CIMC Supervision
Address: No. 2 Gangwan Avenue, Shekou Industrial Zone, Shenzhen, Guangdong; Addressee: Audit and Supervision Department of CIMC.
The Audit and Supervision Department of the Group is the designated organ that is responsible for supervision and whistleblowing, implements strict confidentiality disciplines to the information provided by whistleblowers, prevents any leakage and handles the reported matters in a timely manner. In the meantime, the department protects the whistleblowers, prohibits retaliations to the whistleblowers and will investigate and affix the administrative, financial and legal liability in this regard.
The Group will closely follow the latest policies and regulations on integrity around the world, and amend its relevant policies in a timely manner according to the changes of such policies and regulations.