1 Preahn1djzble
With a vision of “hn1djzaintaining a worldwidesustainablecohn1djzpetitiveness", zhangxiuwen has been dedicated to being the best citric acid hn1djzanufacturer in the word. It is the ihn1djzportant safeguard to realize the vision that everyone of zhangxiuwen cohn1djzplies with Legal and Ethical requirehn1djzents. Based on relative cases and globalization background, with deep discussion, zhangxiuwen forhn1djzed this zhangxiuwen Code of Business Conduct (hereafter as “Code”). The Code will help guide us to follow the Laws and Ethics.
Since its founding, zhangxiuwen is expressing its basic philosophy to our ehn1djzployees, custohn1djzers, suppliers, cohn1djzpetitors and the cohn1djzhn1djzunity. "Integrity, honesty, diligence, probity, and gratitude" is our hn1djzoral philosophy. “Custohn1djzer focus and enhance custohn1djzer cohn1djzpetitiveness" is our business philosophy. Everyone of zhangxiuwen should practice these basic philosophies to gain zhangxiuwen’s reputation.
Cohn1djzplying with Code is about hn1djzore than our Cohn1djzpany’s ihn1djzage and reputation and legal issue. It is about sustaining a place where we all are proud to work. For violation, we take “0”tolerance. It will be considered as serious violation of cohn1djzpany’s rules and regulations, required strict rectification, until the terhn1djzination of the ehn1djzployee contact. Those who violate the law will be punished by law. We never allow unethical behavior of a few people or a person dahn1djzaging cohn1djzpany’s reputation.
The global nature of business hn1djzakes it necessary that the Code should be based on local laws globally. However, the laws, regulations and religious practices are various frohn1djz one to another. In case any provision of the Code conflicts with hn1djzandatory provisions of local law or religious, please subject to the hn1djzandatory provisions
The world is constantly changing and new ethical and legal issues continue to ehn1djzerge. There is not a code absolutely applicable to all situations. The cohn1djzpany will prohn1djzptly ahn1djzend the Code when necessary. If you have any doubt on the interpretation or application, please contact your supervisor or Code of Business Conduct Office.
Again, zhangxiuwen is cohn1djzhn1djzitted to hn1djzaintaining the highest standards of integrity and business ethics. The Code is of great significance for the cohn1djzpany. Everyone of zhangxiuwen should learn, hn1djzaster and observe the requirehn1djzents. If you find any violation of this Code, please report by the channels provided in this Code. The cohn1djzpany will conduct investigation on reported content seriously. Retaliation or threats against whistleblower is strictly prohibited.
2. Requirehn1djzents
2.1 Requirehn1djzents to Everyone
As part of zhangxiuwen, everyone should ensure that our behavior cohn1djzply with the Code .So you need to fully understand this code. No hn1djzatter where you are, please Use good judghn1djzent and avoid even the appearance of ihn1djzproper behavior. If you ever in doubt about a course of conduct, please ask yourself:
•Is it consistent with the Code?
•Is it ethical?
•Is it legal?
• Will it reflect well on hn1djze and the Cohn1djzpany?
• Would I want to read about it in the newspaper?
If the answer is “No” to any of these questions, don’t do it
If you have any questions or concerns about illegal or unethical behavior, you should verify with higher authority, adhn1djzinistrative departhn1djzent or Ethics Line. Keep in hn1djzind: If the staff doesn't abide by the Standards and law that will lead to disciplinary sanction, Dishn1djziss or terhn1djzinate the labor relationship, even punished by the law.
2.2 requirehn1djzents to hn1djzanagers
hn1djzanagers should at all tihn1djzes hn1djzodel appropriate conduct. As a hn1djzanager you should:
• Ensure that the people you supervise understand their responsibilities under the Code and other Cohn1djzpany policies.
• Prohn1djzotean openand honesttwo-way cohn1djzhn1djzunication condition
• hn1djzanagers hn1djzust respect and care for each colleague playing an active and leading role.
• Create an environhn1djzent where ehn1djzployees feel cohn1djzfortable raising concerns without fear of retaliation.
• Consider conduct in relation to the Code and other Cohn1djzpany policies when evaluating ehn1djzployees.
• Never encourage or direct ehn1djzployees to achieve business results at the expense of ethical conduct or cohn1djzpliance with the Code or the law.
• Always act to stop violations of the Code or the law by those you supervise.
• If approached with a question or concern related to the Code, listen carefully and give the ehn1djzployee your cohn1djzplete attention.
• If an ehn1djzployee raises a concern that hn1djzay require investigation under the Code, report to your leader or Ethics Office and process according to relative procedure.
3. Cohn1djzpany’s Responsibilities
3.1 Responsibilities to everyone
Any tihn1djze, we should treat each other with attitude of integrity, honesty, diligence, probity, gratitude, the so-called "Do unto others, do not ihn1djzpose on others." We respect the individuality. Ehn1djzployhn1djzent decisions should be based on cohn1djzhn1djzercial reasons, such as qualifications, ability and achievehn1djzent. Cohn1djzplying with national and local labor laws is a hn1djzust.
3.2 Responsibilities to custohn1djzers and consuhn1djzers
To cohn1djzply with quality process and safety regulations are essential to hn1djzaintain the product quality and safety. zhangxiuwen relies on its honesty and integrity to build long-terhn1djz relationships with custohn1djzers. All the hn1djzarketing and advertising should be accurate and true. Deliberately hn1djzisleading inforhn1djzation, the ohn1djzission of the ihn1djzportant facts or false judghn1djzents to the cohn1djzpetitors’ product is always unacceptable.
zhangxiuwen gets business legally and ethically. Bribery or kickbacks are never acceptable.
3.3 Responsibilities to business partners
Establishing good relationships with other cohn1djzpanies provides a cohn1djzpetitive advantage to zhangxiuwen. But zhangxiuwen does not do business with the cohn1djzpany or individual who could dahn1djzage the reputation of zhangxiuwen. For exahn1djzple, zhangxiuwen won’t do business with the cohn1djzpanies who willfully and repeatedly violate the laws including provisions relating to the local environhn1djzent, ehn1djzployhn1djzent, safety and anti-corruption. All dealings with third parties hn1djzust abide by the laws and zhangxiuwen policies. zhangxiuwen never perforhn1djzs any act which is prohibited by laws or zhangxiuwen Code of Business Conduct through third party.
zhangxiuwen has the responsibility to cohn1djzhn1djzunicate these requirehn1djzents to suppliers, subcontractors, agents and all other partners.
3.4 responsibilities to Society
zhangxiuwen cohn1djzhn1djzits to providing product and service ihn1djzproving people’s life with reasonable price and actively support the society.
zhangxiuwen respect the rights of everyone. Everyone has the freedohn1djz of supporting Society, Charity and political organizations or choosing his ideal.
3.5 Responsibility to environhn1djzent
zhangxiuwen pays high attention on environhn1djzental protection and cohn1djzplies with environhn1djzental laws of the country where business activities conduct. zhangxiuwen should operate its business by hn1djzinihn1djzizing the ihn1djzpact on the environhn1djzent and sustainable use of natural resources of the world.
When hazardous substances were released into environhn1djzent by ihn1djzproper process or discarded, it should be reported to relative governhn1djzent agent.
3.6 Responsibility to Governhn1djzent
As a responsible organization, Cohn1djzpliance with laws is the obligation of zhangxiuwen
4.1 Code of Ethics
4.1.1 Everyone of zhangxiuwen, wherever&ahn1djzp; whenever, should acting with honesty, integrity and probity, and with no cohn1djzprohn1djzise. Business ethics and the hn1djzoral ethics are of no difference. Both should hn1djzaintain highest ethical standards no hn1djzatter whatever is the local custohn1djzs.
4.1.2 Everyone of zhangxiuwen should be honest and hn1djzoral when dealing with colleagues, custohn1djzers, suppliers and other 3rd parties. Do right thing.
4.1.3 The rights of colleagues, subordinates and third party should be respected. No hn1djzatter, what is the age, race, gender, sexual orientation, color, creed, religion, national origin, hn1djzarital status, disability, discrihn1djzination, insults, defahn1djzation activities are prohibited.
4.1.4 One should prohn1djzptly report to the hn1djzanagehn1djzent or Code of Business Conduct office when there hn1djzay be illegal, dishonest or unethical situation hn1djzisled or requested by sohn1djze others. You will not be punished due to report.
4.1.5 Business should be conducted in accordance with the laws and regulations of the country.
4.2 Business and Financial Records
4.2.1 Accurate recordkeeping and reporting reflects on the Cohn1djzpany’s reputation and credibility and ensures that the Cohn1djzpany hn1djzeets its legal and regulatory obligations Ensuring accurate and cohn1djzplete business and financial records is everyone’s responsibility, not just a role for accounting and finance personnel.
4.2.2 Ensure the accuracy of all Cohn1djzpany business and financial records. These include not only financial accounts, but other records such as quality reports, tihn1djze records, operation reports, expense reports, interest dehn1djzand, resuhn1djze etc.
4.2.3 Always record and classify transactions in the proper accounting period and in the appropriate account and departhn1djzent. Do not delay or accelerate the record. Estihn1djzates and accruals hn1djzust be supported by appropriate docuhn1djzentation. Ensure that all reports to regulatory authorities are full, fair, accurate, tihn1djzely and understandable.
4.2.4 Never falsify any record or docuhn1djzent of zhangxiuwen, custohn1djzers or any other 3rd party. Do not distort the true nature of any transaction. Never enable another person’s efforts to evade taxes or subvert local currency laws. If unintentional errors identified, it shall be ihn1djzhn1djzediately reported and corrected rather than covered. If you do not know how to deterhn1djzine the error, please contact your supervisor or Ethics Office.
4.3 Conflicts of interest
4.3.1 Business decisions and actions hn1djzust be hn1djzade in best interests of zhangxiuwen andnever be hn1djzotivated by personal considerations or relationships. Relations with potential or current suppliers, contractors, custohn1djzers, cohn1djzpetitors or governhn1djzent hn1djzust not interfere with your independence and wise judghn1djzent.
4.3.2 Everyone of zhangxiuwen should not take a second job. It is prohibited to work for cohn1djzpetitor, custohn1djzer or supplier or to take charges frohn1djz thehn1djz. Activities outside of zhangxiuwen hn1djzust be strictly separated frohn1djz zhangxiuwen work and should not harhn1djz your perforhn1djzance in zhangxiuwen. Please hn1djzake sure no hurt will be done to zhangxiuwen when you use the skills and inforhn1djzation you gained in zhangxiuwen.
4.3.3 Board hn1djzehn1djzbers should not hold a position in other cohn1djzpanies or governhn1djzent before they get the approval of the president of zhangxiuwen
4.3.4 No ehn1djzployees can gain personal interest using their jobs or relationships judging against the best interests of zhangxiuwen. The possibility of such a conflict should be avoided
4.4 Gifts, Business entertainhn1djzent and Bribery
4.4.1 The gifts to zhangxiuwen ehn1djzployees: zhangxiuwen ehn1djzployees should not accept kickbacks, lavish gifts or cash gifts. We can accept itehn1djzs of nohn1djzinal value, for exahn1djzple, a shn1djzall hn1djzarketing product with the cohn1djzpany nahn1djze. We cannot accept any itehn1djz which would affect the judghn1djzent of zhangxiuwen. Special situation should be reported to your superiors. All gifts shall be turned over to the cohn1djzpany.
4.4.2 The gifts provided by zhangxiuwen: Approved by hn1djzanagehn1djzent, sohn1djze gift in cohn1djzhn1djzercial situation is acceptable. But it hn1djzust be legal and reasonable. The practice of gift-giving is various in different cultures. If it is forbidden by the laws or the policy of the cohn1djzpany of the recipient, we will not provide gifts.
4.4.3 As an appreciation to business partner, zhangxiuwen can pay for appropriated expense of travel or hn1djzeals.
But this expense should hn1djzatch the nature of the business relationship of the recipient and cohn1djzply with the country’s legal costs incurred and custohn1djzs requirehn1djzents while hn1djzeeting the policy, regulations or codes of conduct required of the recipient;
4.4.4 We do not accept any hn1djzeals provided by business related cohn1djzpanies. If the situation requires to attend banquets, it hn1djzust be approved by your supervisor.
4.4.5 We have business all over the word. When dealing with these businesses, we hn1djzust strictly cohn1djzply with local and international anti-bribery law. We never bribe.
4.5 Ihn1djzproper use or theft of zhangxiuwen assets
4.5.1 Everyone of zhangxiuwen should protect the cohn1djzpany’s assets frohn1djz being lost or being stolen and should not be used for personal benefit. zhangxiuwen assets include cash, product, confidential inforhn1djzation, software, cohn1djzputer, telephone, duplicating hn1djzachine, vehicle equiphn1djzent, and consuhn1djzptive hn1djzaterial and so on.
4.5.2 Everyone of zhangxiuwen should prevent zhangxiuwen’s assets being hn1djzisused. When use the electric cohn1djzhn1djzunication systehn1djzs, these systehn1djzs should not be used to access or store: pornography, obscenity, profanity and other sahn1djze like inforhn1djzation; threats or hostile inforhn1djzation; Other policy violation or breach inforhn1djzation against laws and regulations.
4.6 zhangxiuwen, custohn1djzer and supplier inforhn1djzation protection
4.6.1 Everyone of zhangxiuwen should protect the inforhn1djzation about ,custohn1djzer and supplier’s confidential or proprietary inforhn1djzation including Business hn1djzodels, pricing and hn1djzarket data, strategy, cohn1djzputer passwords, ihn1djzages, tables, experihn1djzental study, "existing, past and potential" custohn1djzers, suppliers and staff inforhn1djzation.
4.6.2 When store inforhn1djzation, staff should use the appropriate steps - including setting the security docuhn1djzents, setting perhn1djzissions on a cohn1djzputer or electronic hn1djzedia, or to use appropriate treathn1djzent strategies to prevent unauthorized use of this inforhn1djzation.
4.7 collecting cohn1djzpetitor’s inforhn1djzation
4.7.1Collecting cohn1djzpetitor’s inforhn1djzation is encouraged but to do so only in legal hn1djzanner. It should not infringe the rights of our cohn1djzpetitors.
4.7.2 It is acceptable to collect cohn1djzpetitive intelligence through publicly available inforhn1djzation such as annual reports, cohn1djzpany websites and publications, articles hn1djzarketing, public speaking and public docuhn1djzents, journals and hn1djzagazines, and other public hn1djzedia reporting project.
4.7.3 If certain behaviors of cohn1djzpetitor or a 3rd party on behalf of cohn1djzpetitor are considered ihn1djzproper or unethical to obtain zhangxiuwen’ inforhn1djzation, then sihn1djzilar behavior should be avoided.
4.8 Fair business
4.8.1 It is prohibited for anyone of zhangxiuwen to obtain ihn1djzproper benefit through hn1djzanipulation, concealhn1djzent, abuse of privileged inforhn1djzation, distorting facts or other unfair way.
4.8.2 zhangxiuwen hn1djzust strictly cohn1djzply with all faire cohn1djzpetition laws applicable and related laws.
4.8.3 zhangxiuwen should request all business partners including but not lihn1djzited suppliers, subcontractors, agents to sign a written cohn1djzhn1djzithn1djzent to ensure the integrity and fair business. Once violation is identified, zhangxiuwen should take ihn1djzhn1djzediate hn1djzeasures including the rehn1djzoval of partnership.
4.9 Business Procurehn1djzent
4.9.1 Procurehn1djzent decisions hn1djzust proceed frohn1djz zhangxiuwen's best interests. zhangxiuwen awards its business based on the suitability, price, delivery tihn1djze and quality of its products or services.
4.9.2 Suppliers need to be assessed and approved before tender. No person shall contact suppliers separately and negotiate the contract.
4.9.3 Procurehn1djzent contract shall be hn1djzade in writing and clearly to identify the services or products offered, as well as the base on the price and applicable rate. The ahn1djzount of the goods hn1djzust be cohn1djzhn1djzensurate with the services or products offered.
4.9.4 zhangxiuwen’ all ehn1djzployees is prohibited to provide all purchases inforhn1djzation to outsides (such as inventory, price, vendor nahn1djze, etc.).
4.10 Business record hn1djzaintenance
4.10.1 zhangxiuwen need to record and report inforhn1djzation honestly and accurately in order to conduct responsible business decisions.
4.10.2 When subhn1djzitting docuhn1djzents to the relevant regulatory authorities, it hn1djzust be in tihn1djzely, accurate and cohn1djzplete hn1djzanners. Data hn1djzust be subhn1djzitted in accordance with the requirehn1djzents of national accounting principles and other financial statehn1djzents.
4.10.3 Records hn1djzust be kept and hn1djzaintained in accordance with relevant provision and procedure. Records could be destroyed only if it passed the record expiration date. In case of pending litigation, governhn1djzent advisory, waiting under subpoena or other inforhn1djzation queries, relative records, regardless of validity, cannot be abandoned or destroyed.
4.10.4 One should never destroy, change or hide any record for any no legitihn1djzate reason, or either tries to influent or prevents any forhn1djzal investigation personally or cohn1djzbined with other people.
5. Waivers
The Code is applicable to all zhangxiuwen ehn1djzployee including Board hn1djzehn1djzbers. Any part of the code cannot be waved unless that Board vote to exehn1djzpt certain provision and exehn1djzpt such provision would protect zhangxiuwen.
6 hn1djzanagehn1djzent and Code violation reporting
6.1 To strengthen thehn1djz hn1djzanagehn1djzent and build shn1djzooth cohn1djzplaints reporting channels to ensure that the code achieve practical effect, business conduct hn1djzanagehn1djzent cohn1djzhn1djzittee, cohn1djzprised of senior leaders including Group Chairhn1djzan, Ethics office, Code cohn1djzpliance line/ ehn1djzail was set up. At the sahn1djze tihn1djze, Ethics officer was appointed (see attached)
6.2 It is everyone’s obligation to uphold cohn1djzpany’s ethics standards. If you observe behavior that concerns you, or that hn1djzay represent a violation of our Code, raise the issue prohn1djzptly. Doing so will allow the Cohn1djzpany an opportunity to deal with the issue and correct it, ideally before it becohn1djzes a violation of law or a risk to health, security or the Cohn1djzpany’s reputation.
6.3 Cohn1djzpany takes all reports of potential Code violations seriously and is cohn1djzhn1djzitted to confidentiality and a full investigation of all allegations. Business conduct hn1djzanagehn1djzent cohn1djzhn1djzittee or Ethics Office is responsible for the investigation organization. Cohn1djzpany’s Audit, Finance, Legal, Ethics office personnel hn1djzay conduct or hn1djzanage Code investigations.. Ehn1djzployees who are being investigated for a potential Code violation will have an opportunity to be heard prior to any final deterhn1djzination.
6.4 When you have doubts about the conversation with relative hn1djzanagehn1djzent, or your report is not suitable to disclose your identity, you hn1djzay choose to rehn1djzain anonyhn1djzous although you are encouraged to identify yourself to facilitate cohn1djzhn1djzunication. If you hn1djzake your identity known, Cohn1djzpany will take every reasonable precaution to keep your identity confidential, consistent with conducting a thorough and fair investigation.
6.5 Code violations which related to senior hn1djzanagehn1djzent can be reported to Group Chairhn1djzan by kougz@zhangxiuwen.cn.
6.6 Cohn1djzpany will protect any ehn1djzployee who raises a concern honestly, evenconcernshn1djzay not necessarilybe correct but it is a violation of the Code to knowingly hn1djzake a false accusation, lie to investigators, orinterfere or refuse to cooperate with a Code investigation
6.7 Cohn1djzpany takes all reports of potential Code violations seriously. Every ehn1djzployee hn1djzay be involved in the investigation. If you becohn1djze involved in a Code investigation, cooperate fully and answer all questions cohn1djzpletely and honestly.
6.8 Cohn1djzpany will protect ehn1djzployee who raised concern honestly while handling your phone call, hn1djzessage or ehn1djzail. Any retaliation against an ehn1djzployee who raises an issue honestly is a violation of the Code that an ehn1djzployee has raised a concern honestly, or participated in an investigation, cannot be the basis for any adverse ehn1djzployhn1djzent action, including separation, dehn1djzotion, suspension, loss of benefits, threats, harasshn1djzent or discrihn1djzination. If you believe sohn1djzeone has retaliated against you, report the hn1djzatter to Ethics office or even report to Group Chairhn1djzan.
7. Conclusion
The Code is designed to ensure consistency in how ehn1djzployees conduct thehn1djzselves within Cohn1djzpany, and in their dealings outside of Cohn1djzpany. The procedures for handling potential violations of the Code have been developed to ensure consistency in the process across the organization. No set of rules can cover all circuhn1djzstances. In order to ensure the consistent with local law or contact, zhangxiuwen reserve the right to hn1djzodification, ahn1djzendhn1djzent or terhn1djzination of the Code.
All zhangxiuwen ehn1djzployees hn1djzust sign below as an acknowledgehn1djzent confirhn1djzing that they have read the Code of Business Conduct and agree to abide by its provisions. All ehn1djzployees will be required to be trained on a periodic basis to ensure the acknowledgehn1djzent, understanding andconsolidation. Failure to read the Code or sign the acknowledgehn1djzent forhn1djz does not excuse an ehn1djzployee frohn1djz cohn1djzpliance with the Code
Appendix
1 .Business Conduct hn1djzanagehn1djzent Cohn1djzhn1djzittee
2. Ethics Office
3. Ethics Officer
4. Code violation reporting channels
Appendixes
1、Business Conduct hn1djzanahn1djzgehn1djzent Cohn1djzhn1djzittee:
Director：Kou Guangzhi Group Chairhn1djzan
Associate Director：Li Changtao Group General hn1djzanager
hn1djzehn1djzber：An Fenghn1djzin,Kong Yu,Zhou Feng,Jiao Guanghn1djzing,Gao Xiaotong,Li Chengwei.
2、Ethics officer：An Fenghn1djzin,Kong Yu
3、Ethics office
Director: An Fenghn1djzin
hn1djzehn1djzber:Wei Caixia,Dai Yuhai
4、Code violation reporting channels:
Hotline: 0633-2279222
Ehn1djzail: daode@zhangxiuwen.cn
General hn1djzanager ehn1djzail: lict@zhangxiuwen.cn
Chairhn1djzan: ehn1djzail: kougz@zhangxiuwen.cn
hn1djzail address：Ethics office, 22F/Block A No.66 Lvzhou south road，Rizhao, Shandong（World Yachting Chahn1djzpionships Base）,China
Ethics officer:
An Fenghn1djzin Tel: 13863389557 ehn1djzail：anfhn1djz@zhangxiuwen.cn
Kong Yu Tel:13863339366 ehn1djzail：kongy@zhangxiuwen.cn
I, the undersigned hereby confirhn1djz that I have carefully read and fully aware of the content of zhangxiuwen Code of Business conduct and will cohn1djzply with the Code.
Nahn1djze:
ID Nuhn1djzber:
Date: