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Joincare Pharmaceutical Group Industry Co., Ltd. Complaint and Reporting Policy and Whistleblower Protection Policy

Published Time:

2024-08-27

Chapter 1 General Provisions

Article 1 Joincare Pharmaceutical Co., Ltd. (hereinafter referred to as the Company or Joincare ) attaches great importance to integrity in business operations. To strengthen the management of complaints and reports, protect complainants and reporters, standardize complaint and reporting management, uphold the Company's legitimate rights and interests, and guarantee the rights of employees (including full-time, part-time, and contract employees) or third parties such as customers and suppliers to exercise their right to complain about and report illegal and irregular conduct, this protection policy is formulated in accordance with the relevant provisions of the Company Law of the People's Republic of China, Basic Standards for Enterprise Internal Control, and other laws, regulations, and normative documents, combined with the Company's actual situation.

Article 2 This policy applies to all departments of the Company, directly or indirectly wholly-owned subsidiaries, and directly or indirectly controlled subsidiaries (hereinafter collectively referred to as: subsidiaries). Joincare actively encourages and advocates that suppliers, agents, and other partners jointly abide by these regulations.

 

Chapter 2 Scope of Complaints and Reports and Management Responsibilities

Article 3   Scope of Complaints and Reports:

1 • Acts that violate the Company's Articles of Association, internal control systems, professional ethics, and codes of conduct;

2 • Acts of seeking improper benefits, accepting or engaging in commercial bribery;

3 • Transferring transactions that could legally benefit the Company to others under normal circumstances;

4 • Intentionally concealing or misreporting transactions, resulting in false records, misleading statements, or significant omissions in information disclosure;

5 • Embezzlement, misappropriation, theft, or misappropriation of company assets;

6 • Falsifying or altering accounting records or vouchers, and providing false financial reports;

7 • Disclosing the Company's trade secrets or technical secrets;

8 • Company directors, supervisors, President and other senior executives abusing their power for personal gain;

9 • Violations of the "Joincare Pharmaceutical Group Industry Co., Ltd. Labor Employment and Code of Conduct" and other acts that infringe upon the rights and interests of laborers;

10 • Other acts that endanger the normal operation and social reputation of the Company.

Article 4   The Audit Committee of the Company's Board of Directors is responsible for supervising and reviewing the operation of this policy. Company Risk Management Department is the daily management department for the protection of complainants and reporters, with specific responsibilities:

1 • Responsible for managing complaint and reporting hotlines and email addresses, receiving complaints and reports with or without names, and publishing complaint and reporting telephone numbers, email addresses, and mailing addresses as needed;

2 • Recording the content of reports in writing and promptly reporting to management or the chairman;

3 • Investigating received complaints and reports and reporting the investigation results to the chairman;

4 • Timely filing and archiving of reports on complaints, reports, and post-investigation handling.

 

Chapter 3 Methods of Complaints and Reports

Article 5 Employees at all levels and all sectors of society that have a direct or indirect economic relationship with the Company may report information on actual or suspected cases of fraud by the Company and its personnel, as well as information involving infringement of the rights and interests of laborers, including complaints and reports of violations of professional ethics by the Company and its personnel.

Article 6 Complainants and reporters may file complaints and reports in writing, by email, or by telephone. When filing a complaint or report, the basic facts of the matter, the name of the subject of the complaint or report, the specific parties involved, the name and contact information of the complainant or reporter, and the specific complaint requirements of the complainant or reporter should be stated. Evidence of harm to the interests of the complainant or reporter or the Company's interests, as well as other materials related to the complaint or report, should also be provided.

Article 7 The Company encourages complainants and reporters to use their real names when reporting. For complaints and reports made using real names, the Risk Management Department will strictly maintain confidentiality and provide feedback on the handling results to the complainant or reporter in an appropriate manner.

 

Chapter 4 Complaint and Reporting Handling Procedures

Article 8   When filing a complaint or report, the complainant or reporter should provide accurate information, and the staff receiving the complaint or report in the Company's Risk Management Department should record the content of the complaint or report. The complaints and reports will be analyzed and evaluated, and handled according to the following principles:

(1) A Level: Reports involving the Company's directors, supervisors, senior management personnel, or reports deemed serious by the Supervisory Board, Risk Management Department A preliminary investigation will be conducted to determine whether the reported facts are substantially true, and the following handling methods will be used:

1 Reports involving violations of discipline by the Company's directors, supervisors, and senior management personnel, which are violations of the Company's relevant rules and regulations, will be handled as follows: Risk Management Department After receiving the report, the Company will decide on the investigation method and propose a handling opinion on the investigation results;

2 Reports involving management defects or other major errors at the Company level, Risk Management Department should be immediately reported to the Company's Board of Directors, and the investigation method should be proposed in accordance with the Company's internal control management system and requirements. After clarifying the situation, the department responsible for the investigation will propose handling and corrective opinions or suggestions, and report the handling situation to the Company's Board of Directors;

3 • Other reports of disciplinary violations will be handled in accordance with the Company's procedures for handling disciplinary violations.

(2) B Level: Based on preliminary investigation, the reported content has factual basis or constitutes a disciplinary violation, but does not involve company directors, supervisors, senior management personnel, or reports/complaints of less serious nature. Handle according to the following methods:

1 Reports or complaints involving individuals with disciplinary violations or constituting disciplinary offenses, Risk Management Department A designated person should further investigate and verify the reported content, propose suggestions based on the investigation, or submit processing opinions to the department where the reported person belongs. For cases handled by the department where the reported person belongs, the handling department should promptly feedback the handling results to the supervisory board;

2 Reports or complaints involving management defects or errors in the company and relevant departments, Risk Management Department should promptly notify the relevant company departments about the management defects, and propose opinions or suggestions for remedial or corrective measures. Relevant departments should take remedial measures or correct the defects or errors, and promptly feedback the handling results to the supervisory board.

(iii) C Level: After preliminary investigation, by Risk Management Department preliminary determination, the complaint lacks basis, but its nature is not subjective malicious false accusation or defamation. After further investigation and verification, the handling result should be notified to the reporter;

(iv) D Level: After preliminary investigation, by Risk Management Department preliminary determination, it is a malicious false accusation or defamation report or complaint. After further investigation and verification, according to the severity of the harm caused by the reporter's behavior to the reported person or the company, make corresponding penalties or transfer to judicial organs for handling. If the reporter fabricates facts, forges evidence, and uses reports to falsely accuse and frame others, they shall bear the corresponding responsibilities.

Article Nine   After receiving the complaint, the company Risk Management Department should inform the complainant of the investigation or handling results within the prescribed time limit. Specific regulations:

1 For matters within the scope of authority, within 30 days after receiving the report, inform the complainant of the investigation or handling results; if unable to inform within the time limit, the reason should be explained to the complainant;

2 For matters outside the scope of authority, within 5 days after receiving the complaint, inform the complainant of the reason for non-acceptance,

3 and inform the accepting authority; if it needs to be transferred or submitted to relevant departments for handling, the complainant should be informed of the transferred department and the transfer time;

If the complainant does not provide a real name and address, and cannot be informed, the above two provisions do not apply.   Article 10

 

If the complainant believes that the staff receiving and handling the complaint is a close relative or has an interest relationship with the reported person, which may affect the objective and fair handling of the reported matter, they have the right to request recusal. If the situation is true, the relevant personnel must recuse themselves.   Chapter Five

Irregular Conduct and Handling During the Complaint Process Ten   One No

department, subsidiary, or individual shall interfere with or obstruct the staff handling complaints from investigating and handling complaints. Article 12

1 Staff receiving and handling complaints should abide by the following work principles:

2 Receiving face-to-face complaints should be conducted in a confidential place, with a designated person for interviews, and irrelevant personnel are not allowed to eavesdrop or inquire;

3 The receiving, opening, registration, transfer, storage of complaint letters, and the reception, answering, recording, and recording of face-to-face or telephone complaints should strictly follow the principle of confidentiality to prevent leakage of complaint content and loss of complaint materials;

4 Complaint materials are not allowed to be privately copied or reproduced;

5 When investigating the reported person or unit, confidentiality should be maintained, and the reporter's identity should not be exposed, and complaint materials should not be shown;

6 Internal research on complaints handled by the company should not be disclosed to the complainant, and complaint content should not be discussed with irrelevant personnel;

7 Complaint materials should not be withheld, concealed, or privately destroyed;

Irregular Conduct and Handling During the Complaint Process Complainants should not be harassed or threatened.   Three

Irregular Conduct and Handling During the Complaint Process 4   Staff who violate the above regulations shall be held accountable accordingly. If suspected of violating laws and regulations, they shall be transferred to judicial organs for handling. For those who deliberately fabricate false facts, falsely accuse and frame others under the pretext of complaints or reports, or create trouble and interfere with normal work under the pretext of complaints or reports, shall be dealt with seriously in accordance with relevant regulations; those who constitute crimes shall be transferred to judicial organs for handling. For false complaints or reports due to incomplete understanding of the facts, this clause does not apply.

 

Chapter Six Protection Measures for Complainants

Article 15 The protection of complainants should follow the principles of confidentiality, rewards, and the protection of their legitimate rights and interests. The company takes necessary measures to fully protect the legitimate rights and interests of complainants, including personal rights, property rights, work rights, democratic rights, reputation rights, and other legitimate rights and interests.

Article 16 All departments and subsidiaries of the company must correctly treat the behavior of complainants reporting in accordance with the law and shall not retaliate against complainants on any pretext.

Article 17 It is strictly forbidden to disclose the name, unit, address, and other relevant information of the complainant and the content of the complaint to the reported person; if the reported person is the head of a unit, the complaint materials shall not be transferred to the department or subsidiary where the head is located. For violations of the preceding paragraph, corresponding responsibilities shall be investigated, and those found to have violated the law by judicial organs shall be transferred to judicial organs for handling.

Article 18   If a complainant is retaliated against, they have the right to report to the Risk Management Department or its superior supervisor.

Article 19 Retaliation against complainants and informants, including condoning, shielding, or bribing/instructing others to retaliate against them, will be subject to corresponding liabilities. Cases deemed to violate the law by judicial authorities will be referred to them for handling.

Article 20 If any department of the company conceals or fails to promptly report complaints and reports, fails to cooperate with investigations, obstructs investigations, or retaliates against complainants, the Risk Management Department has the right to hold the relevant personnel accountable and also hold the main leaders of that department accountable.

 

Chapter Seven Supplementary Provisions

Article 21 Matters not covered in this policy shall be handled in accordance with relevant national laws, regulations, normative documents, and the Company's Articles of Association. If this policy is inconsistent with subsequently promulgated laws, regulations, or normative documents, the relevant laws, regulations, and normative documents shall prevail, and this policy shall be revised immediately.

Article 22 This policy shall come into effect from the date of its approval by the Board of Directors' Audit Committee, which shall be responsible for its interpretation and revision.

 

 

 

 

Joincare Pharmaceutical Group Industry Co., Ltd.

August 27, 2024