CR Land Anti-corruption Policy
1 Purpose
1.1 China Resources Land Limited (CR Land or the Company) adheres to the core value of “Integrity First”. All employees take pride in integrity and stigmatize corruption in pursuit of corporate profits and personal value with transparency. CR Land has formulated and issued this policy to standardize the professional conduct of its employees. All employees and entities engaged in business conduct with CR Land are required to observe and uphold the Company’s anti-bribery and anti-corruption policies, advocate integrity and clean business conducts, and maintain the good and honest corporate image.
1.2 The Company abides by laws and regulations including the Company Law of the PRC and the Law of the PRC on Anti-money Laundering, and implements CR Code of Business Conduct, CR Land Code of Honest Practices, CR Land Integrity Cooperation Agreement with Partners, Transparency Declaration, puts in place anti-corruption and anti-bribery regulations, and makes commitment to conduct business operations within the legal framework of fair competition, anti-bribery and anti-corruption.
1.3 This Policy is applicable to CR Land and its major regions, business divisions and specialized companies. All business partners, including partners, associated companies, contractors and suppliers, are encouraged to comply with this Policy.
2 Anti-corruption
2.1 Applying a zero-tolerance policy on all forms of corruption, the Company establishes integrity management measures and restraint mechanisms, effectively carries out integrity risk assessment, supervision and inspection, and actively prevents the occurrence of corrupt practices. All employees undertake to comply with anti-corruption code of conduct and anti-corruption laws and regulations governing business activities, and refrain from any corrupt or improper practices.
2.2 Communicate the Company’s zero-tolerance policy against corruption to business partners, and avoid doing business with persons and companies with known or suspected corrupt practices.
3 Anti-bribery
3.1 Bribery mentioned in this Policy includes offering, promising, giving, accepting or soliciting bribes, and refers to the financial or other inducement or reward given to unlawful, immoral, perfidious or any improper conduct. Bribery can take the form of money, gifts, loans, expenses, entertainment, services, discounts, award of contracts, or any other convenience and advantage.
3.2 Employees are required to treat customers and other business partners fairly and comply with relevant regulations governing business reception and travel expenses. No bribe or kickback shall be paid to, or solicited or accepted from business partners. Any gift or money accepted due to special circumstances shall be declared and turned over in a timely manner.
3.3 Whether in Hong Kong, Chinese mainland or elsewhere, all directors and employees are required to strictly comply with relevant regulations and must not solicit from, accept or offer bribes to any person in promoting business operations.
4 Avoiding Conflict of Interest
The Company applies the principle of avoiding special relations, no employee shall use his/her personal authority to interfere with the personnel arrangements of his/her immediate family members. In the event any organization where relative of an employee act as head or main responsible person doing business with the Company, the employee shall make voluntary declaration and withdraw from relevant affairs.
5 Reporting and Handling Non-compliance
5.1 Any employee in breach of this policy will be dealt with by the Company according to the seriousness of the case. The Company consciously accepts the monitoring of internal audit and review systems. The Company invites employees to supervise its business activities and report non-compliance to its leaders, discipline inspection office, or supervision department. The CR Land Whistleblowing Policy provides a confidential reporting channel for director, employees and relevant third parties of the Company to report any actual or suspected corruption or bribery practice.
5.2 Every report shall be made in person or in writing either by email to lianjie@crland.com.cn (accessed by Disciplinary Inspection Department) or by post to “Chairman of the Audit Committee – China Resources Land Company Limited” at 46/F China Resources Building, 26 Harbour Road, Wanchai, Hong Kong by the Whistleblower who shall report to the Chairman of the Audit Committee. The Chairman of the Audit Committee shall then determine the course of action to pursue, with power to delegate, with respect to the report.
5.3 CR Land will carry out investigation on reported matters, keep the whistleblower strictly confidential, and never allow any person to threaten or retaliate against the whistleblower.
6 Training
6.1 As part of the Company’s efforts to address and prevent corruption and bribery, its directors and employees shall comply with the provisions of this policy and its other relevant policies, procedures and internal control requirements.
6.2 The relevant departments of the Company regularly provide anti-corruption and anti-bribery trainings for all employees and the supply chain, including warning education, integrity publicity, periodical publicity and trainings, new recruits induction trainings, rectification assessment, case notification and warning, etc., with an aim to raise the anti-corruption awareness of employees and suppliers.
7 Compliance Management Requirements for Third Parties
7.1 Third parties referred to in this Policy include partners, affiliates, contractors and suppliers. CR Land's cooperation with third parties shall be truthful and lawful, and third parties shall be required to comply with the requirements of CR Land Code of Honest Practices, CR Land Code of Conduct for Suppliers, CR Land Sustainable Procurement Policy and this Policy.
7.2 The Company carefully selects third-party partners with basic compliance management capability and a good compliance image to ensure that their practices do not conflict with CR Land's values and compliance philosophy in the process of cooperation with the Company. The following practices are not allowed: colluding with business partners to carry out activities prohibited by the Company; inducing or instigating business partners to carry out activities prohibited by the Company; shielding and conniving unethical and non-compliant practices of third parties, and failing to report the situation in a timely and accurate manner.
7.3 The Company prohibits third parties from any form of bribery and corruption, including bribing CR Land's employees in any way, such as offering gifts and hospitality inappropriate with commercial practices, when acting on behalf of or in cooperation with CR Land.
7.4 When communicating with governments and regulatory authorities, the Company shall comply not only with applicable laws and regulations, but also with the ethical standards and requirements of government and regulatory authorities.
8 Bookkeeping and Records
CR Land insists on providing appropriate documentation to support business decisions in a transparent and honest manner, and making document filing as required. For each asset disposal and financial expenditure, the authentic, complete and accurate books and financial records are kept as required for verification purpose in accordance with the document preservation policy.