1. Purpose
1) China Resources Mixc Lifestyle Limited ("CR Mixc Lifestyle" or "the Company" "We") adheres to the values of "honesty and trustworthiness". Foster a good atmosphere of integrity in employment and maintain a good corporate image of integrity.
2) The Company complies with national laws and regulations such as the "Company Law of the People's Republic of China" and the "Anti-Money Laundering Law of the People's Republic of China". It implements the "CR Group Code of Business Conduct", "CR Land Integrity in Employment Guidelines", "CR Land Integrity Agreement with Partners", and the "Sunshine Declaration", and has established anti-corruption and anti-bribery regulations. It pledges to conduct business within the legal framework of fair competition, anti-bribery, and anti-corruption.
3) This policy applies to CR Mixc Lifestyle and its subsidiaries, and requires all partners and suppliers to comply with this policy.
2.Anti-monopoly and Anti-unfair Competition
“INTEGRITY” is CR Mixc Lifestyle’s value and serves as its foundation for growth. Each member of the company has to ensure that daily operations are not involved in any misconduct such as monopoly, bribery, frauds and unfair competition, and has to comply with anti-monopoly and anti-unfair competition laws and regulations.
We do not allow any situations, which includes but not limited to:
• Disclose pricing information of the company, trading records with business partners and operational arrangement, to the competitors;
• Obtain competitors’ intelligence by way of any misconduct such as theft, invasion, eavesdropping, bribing and threats;
• Make any cheap shots and untrue reports defamatory to competitors;
• Enter into and execute monopoly agreements;
• Abuse of dominant market positions to commit any misconduct;
• Unauthorized use of competitor’s trademark or patent for product design and promotion.
3.Anti-commercial Bribery
Our excellent teams, first-class products and services, and social responsibilities win various business opportunities. We must not be allowed to pay or accept in any form of bribery, kickbacks, facilitation payment directly or indirectly.
We do not allow any situations, which includes but not limited to:
• Pay, accept or request bribery, kickback, facilitation payment in any form;
• Pay, accept or request bribery, kickback, facilitation payment through third party in any form.
4. Anti-Money Laundering
We place great emphasis on financial integrity and legal compliance, promptly identifying suspicious transactions or potential money laundering activities to ensure a zero-tolerance policy towards money laundering at all levels. We do not allow any situations, which includes but not limited to:
• Engaging in money laundering activities or assisting others in money laundering;
• Impeding official investigations in any way, including underreporting, misreporting, or falsifying information to cover up money laundering activities;
• Underreporting, misreporting, or falsifying information to cover up money laundering behaviors;
• Independently investigating suspected money laundering cases and failing to report to higher authorities in a timely manner.
5.Compliance Requirements on Business Partners
We carefully select business partners such as suppliers and agents based on their foundation and reputation in terms of compliance management, so as to avoid any conflict with our value and compliance concepts in our partnership with business partners. We require all parties conducting business with us (including suppliers, contractors, service providers, etc.) to sign the "Integrity and Compliance Commitment," which clearly states that they will adhere to our anti-bribery and anti-corruption policies and maintain integrity in their business activities.
We do not allow any situations, which includes but not limited to:
• Offering gifts, cash, consumption cards (vouchers), securities, equities, other financial products, or other property to our employees, their relatives, and other specific related individuals;
• Lending money, housing, vehicles, or other property to our employees, their relatives, and other specific related individuals;
• Providing banquets or arrangements for travel, fitness, entertainment, or other activities that may affect the impartial performance of duties to our employees, their relatives, and other specific related individuals;
• Paying or reimbursing any expenses on behalf of our employees, their relatives, and other specific related individuals;
• Holding shares on behalf of our employees, their relatives, and other specific related individuals;
• Colluding with our employees or other units and individuals in bidding or pricing, or using malicious competition and other improper means to compete for business;
• Engaging in private discussions or reaching tacit understandings with our employees about bid prices, the response documents of other suppliers, and other trade secrets as well as terms in contracts;
• Illegally subcontracting or subletting projects.
6.Anti-bribery With Governments and Regulators
When communicating with governments and regulators, it needs to comply with applicable laws and regulations, and ethical standards and requirements set out by governments and regulators. Except appropriate gifts and hospitality for maintaining stable relations, otherwise we do not allow any bribes offered to governments and regulators, which includes but not limited to:
• Cash and cash equivalents;
• Gifts and hospitality that exceed normal value;
• Any form of facilitation payments;
• Offer job opportunities to the relatives or friends of the officers working for governments and regulators;
• Offer any bribes or payments to governments and regulator illegally through third party.
7.Employee Training on Ethical Standards
To enhance the ethical awareness and compliance of all employees and related parties, ensuring they fully understand and adhere to the company's code of conduct and ethical standards, the company conducts at least one comprehensive ethics training on ethical standards for all employees and related parties (including full-time and part-time employees of suppliers, contractors, service providers, and other partners) each year. The training content includes, but is not limited to:
• Emphasizing the company's anti-bribery and anti-corruption policies, clearly informing employees and related parties of behaviors that are not allowed;
• Strengthening employees' understanding of the importance of professional ethics through case analysis, role-playing, and interactive discussions;
• Providing specific guidance on compliant behavior, helping employees understand how to make the right decisions in different situations;
• Educating employees on how to identify and manage potential conflicts of interest, ensuring the fairness and transparency of decision-making;
• Guiding employees on their legal obligations and company policies regarding information disclosure, to prevent insider trading and improper information disclosure.
8.Regular Audits of Ethical Standards
To ensure that our ethical standards are continuously monitored and assessed to adapt to the changing business environment and regulatory requirements, we regularly conduct comprehensive ethical standards audits across all business lines, covering key areas such as financial management, supply chain management, human resources management, marketing, and customer relationship management. Specific measures include, but are not limited to:
• Establishing a professional, independent internal audit team, and engaging external professional audit firms when necessary;
• Identifying potential ethical and compliance risks, assessing risk levels, and developing corresponding risk management measures;
• Covering all key business lines in the audit work every three years, and completing audit work for other non-key business lines as needed;
• Annually optimizing existing ethical standards and regulations based on audit results and feedback.
