Business Ethics and Integrity Policy

 

Chapter I General Provisions and Purpose

Article 1 Shenzhen Yite Holdings (Group) Co., Ltd. (referred to as Yite Holdings) and its subsidiaries [KAI PENG MINING SARLU in the Democratic Republic of Congo (DRC), etc.] consistently hold that business ethics and integrity and self-discipline are the key to practicing integrity management, building credibility and reputation, and promoting fair competition. In order to build up the company's competitiveness and reputation in the international market, every employee of the company must observe the laws and regulations of the places where they work and conduct business in a fair, just, and transparent manner. Yite Holdings and its subsidiaries are responsible enterprises, committed to efficiently fulfilling their obligations in compliance with rules and regulations, and establishing long-term stable business relationships with suppliers and partners.

In light of this, we promise to engage with our suppliers, partners, competitors, all employees, and other interested parties with honesty, trustworthiness, probity, and morality, and resolutely eradicate any form of corruption, embezzlement, money laundering, extortion, monopoly, unfair competition, and other illegal behaviors.

We will also adhere to the principle of fairness, and prevent intentional manipulation, concealment, and abuse of privileges or undisclosed information, false presentation of material facts, or any other unfair trading practices aimed to take advantage of others or obtain illegitimate benefits.

Article 2 This policy shall apply to Shenzhen Yite Holdings (Group) Co., Ltd. and its subsidiaries.

Article 3 All employees, contractors, suppliers, and other interested parties should first recognize and abide by this policy.

 

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Chapter II Anti-corruption Mechanism

Article 4 We resolutely prohibit any form of corruption. To this end, we have established relevant management processes:

1. Compliance in operation: All departments and subsidiaries are required to conduct business in strict accordance with laws and regulations on anti-corruption in the project locations.

2. Background check and screening: Before determining the business relationship, all relevant departments should thoroughly conduct background check to screen the counterparties in transactions, collaborations, and applications to ensure that the compliance and credibility of such counterparties meet the company's requirements.

3. Risk response: For existing businesses, all relevant departments should regularly investigate relevant risks of corruption and take effective measures to respond to and avoid them.

4. Training and publicity: We will carry out internal learning and training in relation to anti-corruption on an ongoing basis, and initiate publicity to enhance the anti-corruption awareness of all employees, suppliers, partners, etc., to highlight our anti-corruption requirements.

5. Strict accountability: We will conduct detailed and thorough screening and investigation of any suspected corruption, and show no tolerance to any employees and partners in violation of regulations and rigidly hold them accountable.

6. Complaint mechanism: We have established a reporting and complaint mechanism for the public, which is implemented in strict accordance with the Measures for the Management of Grievances and Complaints.

Article 5 Each contract signed by Yite Holdings and its subsidiaries with suppliers and contractors includes an Integrity Cooperation Agreement, amid the efforts to create a transparent cooperation system. In addition, we have also signed the Letter of Commitment to Professional Norms for Employees with our employees, made anti-corruption surveys, and provided lectures on integrity, etc. to enhance anti-corruption awareness of the employees and develop their habits of integrity and self-discipline.

 

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Chapter III Anti-monopoly and Anti-Unfair Competition Mechanism

Article 6 We hold firmly that product value and service quality are the key to success. Therefore, we advocate the principle of free and fair competition and oppose monopoly and illegitimate interests in any form and for any purpose. Based on the Anti-Unfair Competition Law of the People's Republic of China and other related laws and regulations on anti-monopoly and anti-unfair competition, we have established an honest and fair competition mechanism in the Group and its subsidiaries, and set up complaint and reporting mechanisms, to avoid the occurrence of improper competition from the root.

 

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Chapter IV Anti-Money Laundering Mechanism

Article 7 We promise to strictly abide by local laws and ethics, and carry out relevant business operations in accordance with laws and regulations, in the business locations of Shenzhen Yite Holdings (Group) Co., Ltd. and its subsidiaries. Based on the above code of conduct, we focus on controlling the risks to prevent and prohibit money laundering and any conduct that facilitates money laundering, terrorism, or criminal behavior.

Article 8 In order to promote continuous and effective implementation of anti-money laundering measures, we comply with the Anti-Money Laundering Law of the People's Republic of China and relevant laws and regulations of the Democratic Republic of Congo and other business locations, and have established an anti-money laundering management mechanism to effectively prevent money laundering and maintain the normal business order of the company.

The anti-money laundering efforts referred to in this system cover all business aspects that may be used as a channel of money laundering in the company's operation and management. Anti-money laundering measures should be specifically implemented in relevant businesses, departments, and positions to ensure that there are no gaps or loopholes in the management system.

 

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Chapter V Reporting Mechanism

Article 9 We encourage employees and interested parties to report corruption in all operating activities of the company. We have specified the details of the channels, processes, and measures for reporting in the Measures for the Management of Grievances and Complaints to ensure that the demands and feedback of employees and interested parties can be effectively communicated and handled in a timely manner.

We strictly follow the company's relevant regulations and systems in handling grievances. And we have assigned dedicated personnel to accept grievances and reports, and review, verify, and feed back to such grievances and reports as soon as possible in strict accordance with the Measures for the Management of Grievances and Complaints. We promise to keep the information, especially privacy, of the complainants and whistle-blowers encrypted and strictly confidential. And we will not tolerate any form of privacy disclosure. Upon review and confirmation by the corresponding management organization, we will handle the violations in strict accordance with relevant rules and regulation. For grave circumstances, we will hand them over to be dealt with by judicial organs.

 

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Chapter VI Right to Interpretation

Article 10 The right to interpret, supervise, and implement this policy belongs to Shenzhen Yite Holdings (Group) Co., Ltd.

Article 11 This policy shall come into effect from the date of promulgation.