Anti-fraud and complaint reporting management system
Chapter I General Provisions
Article 1 In order to prevent fraud, strengthen corporate governance and internal control, and safeguard the legitimate rights and interests of the company and shareholders.
Rights and interests, reduce the risk of the company, according to the basic norms of internal control of enterprises and other relevant laws and regulations.
Regulations, combined with the actual situation of the company, to develop this system.
Article 2 This system mainly defines the purpose of anti-fraud work, the concept and form of fraud; Expectation of fraud
Prevention and control; Permanent organization for anti-fraud work; Reporting, investigating and reporting fraud; Protecting whistleblowers; dance
Remedial measures and penalties for adverse conditions.
Article 3 The purpose of anti-fraud work is to standardize the occupations of senior and middle managers and ordinary employees of the company.
Behavior, strictly abide by the relevant laws, industry norms and guidelines, professional ethics and company rules and regulations, and establish a clean and honest.
Be honest, diligent and dedicated, and prevent acts that harm the interests of the company and shareholders.
Article 4 This system is applicable to group companies, wholly-owned subsidiaries, holding subsidiaries and branches.
Chapter II Concepts and Forms of Fraud
Article 5 The term "fraud" as mentioned in this system refers to all kinds of illegal means adopted by internal and external personnel of the company.
Seek personal illegitimate interests and damage the legitimate economic interests of the company; Or seek improper corporate economy.
Interests, at the same time may bring illegitimate interests to individuals.
Article 6 Fraud that damages the legitimate economic interests of the company refers to the fact that people inside and outside the company seek benefits for themselves.
Profit, improper behavior that damages the legitimate economic interests of the company and shareholders by various illegal means.
One of the following circumstances belongs to this kind of fraud:
(1) Accepting bribes or kickbacks;
(2) Transferring transactions that can make the company profitable under normal circumstances to others;
(3) Illegal use of company assets, embezzlement, misappropriation or theft of company assets;
(4) Making the company pay for the false transaction;
(5) Deliberately concealing or falsely reporting the transaction matters.
(6) Forging or altering accounting records or accounting vouchers;
(7) divulging the business secrets or technical secrets of the company;
(8) Other fraudulent acts that harm the economic interests of the company.
Extended data
Article 7 Fraudulent acts to seek illegitimate economic interests of the company refer to fraudulent acts carried out by internal personnel of the company to obtain economic interests of the company.
Obtain illegitimate economic benefits, but may also obtain relevant benefits, and adopt illegal and illegal means such as deception,
Improper behavior that harms the interests of the state, other organizations, individuals or shareholders. One of the following situations falls into this category
Class fraud:
(1) Expenditure for improper purposes, such as paying bribes or kickbacks;
(two) the sale of non-existent or untrue assets;
(3) Deliberately misstated transactions and recorded false transactions, including inflated income and underestimated liabilities.
Issuing the wrong financial report will make readers or users of financial statements misunderstand and make inappropriate investments.
Capital decision;
(4) Concealing or deleting important information that should be disclosed to the public;
(five) engaged in illegal economic activities;
(6) Forging or altering accounting records or accounting vouchers;
(7) tax evasion;
(eight) other fraudulent acts to seek illegitimate economic benefits for the company.
Chapter III Prevention and Control of Fraud
Article 8 A company shall establish, improve and effectively implement fraud risk assessment and fraud prevention.
Anti-fraud control procedures and self-assessment; Undertake the overall coordination of anti-fraud work of all departments of the company.
And guide the work.
Article 9 The Company publicizes its anti-fraud policies and related measures through various means.
Carry out education and training on laws and regulations and honesty and morality, advocate a corporate culture of honesty and law-abiding, and help employees to be correct.
Handle conflicts of interest in work and resist the temptation of illegitimate interests.
Article 10 The company advocates a corporate culture of honesty and law-abiding, creates an anti-fraud corporate culture environment, and conducts assessment and evaluation.
Fraud risk, and establish specific control procedures and mechanisms to reduce the chance of fraud.
Eleventh assess the risk of fraud, establish a special control mechanism to reduce the chance of fraud.
Mainly through the following channels:
(1) Identify and evaluate fraud risks at the company level, business unit level and major customer level.
Assess the importance and possibility of fraud risk.
(2) Formulate and take relevant measures to confirm, prevent and reduce false financial reports or abuse of company assets.
Measures, which include the following different forms: approval, authorization, verification, inspection, division of responsibilities, and work.
Conduct performance appraisal to protect company assets.
(three) in view of the high-risk areas where fraudulent acts such as false financial reports and ultra vires management occur, it is necessary to
And information systems and technologies, the company shall establish necessary internal control measures.
Chapter IV Permanent Institutions for Anti-fraud Work
Article 12 A company shall establish a permanent organization for anti-fraud work, and organize and implement it across departments and companies.
Anti-fraud work within the scope; Each business department undertakes the anti-fraud work of its own department.
Article 13 The Company's Commission for Discipline Inspection (hereinafter referred to as "the Commission for Discipline Inspection") is responsible for the company's anti-fraud work.
Permanent organization, responsible for the company's annual anti-fraud work plan and fraud risk assessment in development; write
Write an evaluation report on the company's anti-fraud work; Carry out anti-fraud prevention publicity activities; Accept anti-fraud within the company
Complaints and reports; Investigate the reported fraud cases and put forward handling opinions.
Fourteenth members of the Disciplinary Committee should consciously improve their anti-fraud awareness and anti-fraud technical ability.
Maintain due professional caution, actively request and actively accept anti-fraud laws and regulations, industry standards and knowledge.
Skills training, take the initiative to understand the company's business development and plans, accounting policies, financial management system and its
He cares about rules and regulations.
Chapter V Reporting, Investigating and Reporting Fraud
Article 15 The Company shall set up a special reporting telephone number and email address, and the reporting telephone number and email address shall be employees of the Company and external personnel respectively.
Members, suppliers, customers, etc. , reflect and report the work and business processes of various departments and their personnel within the company.
Violation of laws and regulations, reporting and exposing actual or suspected fraud channels; Includes the received content.
Information on complaints and reports about loopholes in the control procedures of the Ministry.
Article 16 The Commission for Discipline Inspection shall adhere to openness, fairness and impartiality in reporting letters and visits and in investigation and handling.
Working principle, adhere to the principle of solving problems in time and on the spot and safeguarding the interests of shareholders and employees of the company.
Seventeenth Commission for Discipline Inspection has the ability to check the illegal issues reflected in the report, according to the examination and approval procedures and authority.
Only preliminary verification:
(1) If the person complained (reported) is a senior manager appointed by the board of directors of the company, the directors shall jointly review the complaint.
Batch;
(2) Other complaints and reports other than those in the first paragraph of this article shall be examined and approved by the Commission for Discipline Inspection in conjunction with the management of the company.
Can also consult the board of directors to determine according to the actual situation.
Eighteenth Commission for Discipline Inspection shall have the following powers in the process of accepting and investigating complaints and reports:
(a) the right to investigate and collect evidence: in the investigation and understanding of complaints and related work, the right to have.
The relevant units shall read and copy the relevant materials, make investigations and inquiries to the relevant personnel, and have the right to request the units under investigation.
And all kinds of materials for investigation and evidence collection shall be signed and confirmed by the participants.
(2) Right of follow-up: Have the right of follow-up on matters transferred to other departments, which requires a certain degree.
Give timely feedback.
(3) The right to propose solutions: you can directly propose solutions to the problems found in the investigation.
Article 19 The staff of the Commission for Discipline Inspection shall abide by the following working standards:
(a) have a direct interest in the content of the complaint or the complainant, should be avoided;
(two) to listen to the facts and reasons stated by the complainant, and to investigate the relevant organizations and personnel when necessary.
Verify the situation and avoid intensifying contradictions;
(three) shall not disclose the complaint information to the object of complaint, and the department shall not handle the complaint.
Reporting internal research is open to the complainant, and the contents of the complaint report shall not be discussed with irrelevant personnel.
(four) if it meets the acceptance conditions after examination, it shall, within 7 days from the date of acceptance, make a written form or its
He informed the complainant in an appropriate manner; Do not meet the conditions for acceptance, it shall make a decision not to accept.
Inform the complainant in writing or other appropriate ways within 7 days, and explain the reasons; contact information
Except for the unknown.
(five) in the investigation and handling of complaints and reports, must be kept confidential.
Twentieth Commission for Discipline Inspection shall, within 60 days from the date of accepting the report, investigate the report that has been accepted.
Has been completed; If the situation is complicated, the processing period may be appropriately extended, but the extension period shall not exceed 30 days.
Where laws and regulations provide otherwise, such provisions shall prevail. Reports that need to be assigned or transferred shall be implemented as of the date of receipt.
/kloc-assigned or transferred to the relevant departments for handling within 0/5 days. If the processing results need to be fed back, it is required to be handled.
Feedback the results within a time limit and submit the completion report.
Article 21 The Commission for Discipline Inspection will consider the details of unsubstantiated reports concerning allegations made by ordinary employees.
The situation can be evaluated in conjunction with the relevant departments of the company and a decision can be made on whether to investigate.
Article 22 The Commission for Discipline Inspection shall report the case under its real name, and whether or not it will initiate an investigation, it is necessary to retaliate against the whistleblower.
Feedback the survey results. The materials for reporting fraud cases after investigation shall be filed in time; have
The investigation results of fraud cases should be reported to the relevant departments of the company according to the nature of the report.
Twenty-third complaints and reports, after verification, reflect the facts of the problem is basically clear, there is indeed a violation of discipline,
And the punishment is obviously not enough, you can have a admonishing conversation; If the problem is not specific and can't be found, it will be approved by the leaders.
Retain after approval; Those who seriously violate the company's discipline and system and cause economic losses to the company will be punished according to the seriousness of the case.
Give corresponding punishment.
Twenty-fourth complaints or informants who have malicious slander out of nothing will be severely punished once verified.
Clean it up If the complainant or whistleblower maliciously complains or reports slander others, openly belittle others' personality and destroy them.
If a person's reputation slanders or insults others, and the circumstances are serious enough to constitute a crime, the company will hand it over to the judicial department for legal responsibility.
Ren.
Chapter VI Protection of Informants
Article 25 Informants shall be protected when assisting in the investigation. The company prohibits any discrimination or reporting.
It is forbidden to take any obstruction, interference or hostile measures against the personnel involved in the investigation.
Twenty-sixth illegal disclosure of complaints and informants information or take revenge on complaints and informants.
The company will take corresponding punishment for those who act. Violate the law, the company will be transferred to judicial organs according to law.
Handle.
Twenty-seventh staff members who accept reports or participate in fraud investigations shall not report to any unit or individual at will.
Individuals provide relevant information and report contents of informants; If it is really necessary to consult and report relevant information because of work needs, it shall
Approved by the person in charge of the Commission for Discipline Inspection; At the same time, the Commission for Discipline Inspection should register the time, content and personnel inspected by inspectors.
Relevant information.
Chapter VII Remedial Measures and Punishment of Fraud
Article 28 After a fraud case occurs, the company shall evaluate and improve its internal control in remedial measures.
Report in writing, take appropriate measures against violators, and inform the internal of the necessary treatment results as needed.
External third party notification.
Article 29 The Commission for Discipline Inspection suggested that employees who practise fraud should be punished according to the relevant regulations of the company.
Internal economic and administrative disciplinary action; Fraud in violation of relevant laws shall be transferred to judicial organs according to law.
Handle.
Chapter VIII Supplementary Provisions
Article 30 Matters not covered in this system shall be implemented in accordance with relevant laws, regulations, normative documents and company seals.
Provisions on the implementation process.
Article 31 the board of directors of the company shall be responsible for the interpretation and revision of this system.
Article 32 This system shall come into effect as of the date of deliberation and approval by the board of directors of the company.