Integrity Management System

I. Purpose

   To strengthen the company's integrity, establish a corruption prevention mechanism, prevent the risk of fraud, and promote the healthy and sustainable development of the company, we hereby formulate this system.      

II. Scope

   This system applies to Fujian Kuncai Material Science & Technology Company Limited and its subsidiaries.

III. Structure and responsibilities of the Integrity Commission

 The Company has established the Integrity Committee, which is responsible for the work related to the Company's integrity management, and is composed of the following:         

Organizational chart of the Integrity Committee

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Head:President. Responsible for establishing the direction of the company's integrity work and approving the final decision on the handling of fraud investigation results.

Deputy director:Head of the Audit Department. Responsible for promoting integrity training, receiving reports and investigating fraud, issuing investigation reports and penalties, and convening fraud review meetings.

Members:Director of the General Manager's Office, Head of the Legal Affairs Department and Chairman of the Labor Union. Responsible for participating in the evaluation meeting on fraud matters, conducting comprehensive evaluation on the decision of applying penalties to the violation matters of the fraud personnel; providing legal opinions on how to characterize the illegal matters touched upon by the internal personnel and the units involved in the fraud incidents and behaviors, how to impose penalties, or whether to transfer them to the public security organs.

IV. Determination of fraud

Fraud, as referred to in this system, refers to the use of deception or other means by persons inside or outside the Company to obtain improper or illegal benefits, including but not limited to the following acts:

(1) Accepting or soliciting bribes or kickbacks (including equivalents of any kind);


(2) Transferring to another person a matter of transaction that would, under normal circumstances, be profitable to the Company;


(3) Unlawful use of the Company's assets, embezzlement, misappropriation or theft of the Company's funds;


(4) Causing the company to make payments for false transactions;


(5) Deliberately concealing or misstating transaction matters;


(6) Falsifying or altering accounting records or documents;


(7) Disclosing the Company's commercial or technical secrets;


(8) Other fraudulent acts that jeopardize the company's economic interests.


v. prohibited acts

The company's employees in the work activities should follow the principle of integrity, compliance with the law, comply with the company's "Integrity Pact", shall not touch the "company's top ten management red line", shall not violate the following behaviors:

1, the company's employees in the work activities, shall not in any form of cooperation units to ask for or privately accept red packets, thank you, kickbacks, commissions, or in the form of gambling, borrowing, transfer of money and goods on behalf of the purchase of the form of money and wealth.

2、Company employees shall not accept gifts, securities, valuables, jewelry and ornaments from cooperative units.


3、Company employees shall not be reimbursed in the cooperative unit or require the cooperative unit to pay any expenses that should be paid by individuals;


4, the company employees shall not participate in any form of banquets and entertainment activities that may affect the performance of official duties, such as must participate in the general manager of the company must be approved by the general manager of the company for approval before participation, not allowed to accept or request excessive hospitality.


5, the company employees shall not require or accept the cooperation unit for their own housing renovation, marriage and funeral, friends and relatives (including spouses, children, other close relatives, friends, hereinafter the same) work arrangements and go abroad to provide convenience;


6, the company's employees shall not be unauthorized and cooperative unit staff on the company's products, materials and equipment supply, pricing, payment methods, packaging, transportation methods, quality standards, acceptance criteria, warranty and other unfavorable to the company's private negotiations or to reach a tacit agreement.


7、Company employees shall not work part-time in the supplier company, serving; not allowed in any form in the supplier company shareholding, shares, access to commission; not allowed to use the supplier's resources for private gain.


8、Company employees shall not introduce friends and relatives to the cooperative unit to engage in economic activities related to the production and supply of materials, production equipment and research and development of the company's products;


9、Company employees are not allowed to use any improper means to make things difficult for or suppress suppliers in order to achieve the purpose of soliciting personal benefits, such as delayed settlement, intentional deduction of funds, malicious complaints. It is not allowed to use any reason to illegally charge suppliers, such as: loading and unloading fees.


10、Company employees are not allowed to misrepresent expenses, falsely issue more invoices, or use communiqués for personal use. It is not allowed to set up a small treasury through misrepresentation of expenses, borrowing of reserve funds and other forms of money from the company.


11. Employees are not allowed to conceal or misrepresent transaction matters, or forge or alter any work-related documents or information.


12, the company employees shall not leak company secrets, including but not limited to the company's strategy and business management strategy, products and technology information, business information and human resources information.


13, the company's employees shall not be private use, misappropriation, misappropriation, theft of company assets, property and intellectual property rights, technical drawings, software programs and other confidential information.


14, the company's employees shall not have other harm to the interests of the company and violation of the company's rules and regulations of fraudulent behavior.


VI. Disposal of normal exchange gifts

For the company's normal business dealings received in the value of more than 200 yuan of gifts, gifts, etc., must be handed over to the company's General Manager's Office of the unified registration of the accounts, storage, processing.

1. Gifts that are perishable and not easy to be preserved shall be distributed to the company's employees after being registered in the General Manager's Office;


2, can be saved without special identification of gifts, shopping coupons, etc., can be transferred by the company as gifts to other business units or used as company prizes to deal with;


3, received cigarettes, alcohol and other usable items for the company's public or reception of visitors;


4、Special gifts, the value of the amount of large or relatively special significance of the gift, please consult the chairman of the board of directors before disposal.


VII. Incentives and penalties

1、Penalties.For the violation of the company's integrity system, the Integrity Committee will be based on the results of the investigation to issue a preliminary recommendation for punishment and report to the chairman of the board of directors, the chairman of the board of directors to give the decision to deal with. Employees who violate the company's integrity management regulations and relevant national laws and regulations are subject to the following penalties depending on the severity of the case:

1)written criticism.The violation is minor, the amount of violation does not exceed $1,000, or the number of times is less than three, and it does not cause damage to the company's interests or reputation;

2)criticize。There is some violation of the circumstances, the amount of violation is more than $1,000 Dan not more than $5,000, or the amount is not more than $1,000, and does not cause serious (more than $5,000 and less than $10,000) damage to the company's interests and reputation;

3)warnings.The violation is more serious, the amount of violation is more than 5,000 yuan, but not more than 10,000 yuan, or although the amount is not more than 5,000 yuan, but to the company's interests, reputation to cause significant (10,000 yuan or more than 20,000 yuan or less) loss of certain losses;

4)give someone a demerit or demerits。The violation is more serious, the amount of violation is more than $10,000, but not more than $30,000, or cause ultra-significant (more than $20,000 and less than $30,000) damage to the company's interests or reputation and goodwill;

5)Dissolution of labor relations.If the violation is very serious and causes the company to lose more than $30,000, but the company actively refunds and compensates the company for the loss afterward, the company will not hand it over to the public security organs.

6)Transfer to the Public Security Bureau.If the violation is very serious and causes the company to lose more than $30,000 and does not actively return and compensate the company for the loss, the company will hand over to the public security organs for handling while terminating the labor contract.

For the above penalties, the company also has the right to recover the illegal proceeds and demand compensation for the damages caused to the company.

2、incentives.For timely reporting to save economic losses for the company, the following rewards will be given after investigation by the Integrity Committee and approval by the Chairman of the Board of Directors:

(1) If the amount of economic loss recovered is less than 10,000 yuan (not included), 10% of the actual amount of economic loss recovered shall be awarded, and the amount of the award shall not be less than 500 yuan;

(2) The amount of economic losses recovered 10,000-50,000 (inclusive) yuan, according to the actual amount of economic losses recovered 5% of the award, and the amount of the award is not less than 1,000 yuan;

(3) For the recovery of economic losses of $50,000 (inclusive) or more, the award shall be given at 3% of the actual amount of economic losses recovered, and the amount of the award shall not be less than $2,500 or more than 100,000 yuan.

(4) for matters not involving the amount of fraud, depending on the severity of the nature of fraud, a one-time award to the whistleblower of 500 yuan, 1,000 yuan, 3,000 yuan, 5,000 yuan four grades ranging.