In line with the Chinese laws and regulations, including the Company Law of the People's Republic of China, the Anti-Unfair Competition Law of the People's Republic of China, and the Anti-Money Laundering Law of the People's Republic of China, and laws in other countries or regions where Anton operates, we established internal policies such as the Sunshine Purchasing Integrity Commitment and the Integrity Agreement to strengthen the code of conduct and operational guidelines for business ethics, ensuring that all business activities comply with legal and regulatory requirements. In 2024, the Company had no legal cases related to corrupt practices.

 

As a member of the China Enterprise Anti-Corruption Alliance, Anton has established a comprehensive internal anti-corruption management mechanism. This includes the formulation of the Code of Conduct for Employees in Sales and Business Negotiations, as well as other internal regulations, and the implementation of the "Nine Prohibitions" to prevent bribery between internal personnel and business partners or suppliers in any form. In 2024, the Majnoon Oilfield Project Department of the Company in Iraq obtained the ISO 37001:2016 Anti-Bribery Management System Certificate.

 

In FY2024 the Company had no legal cases related to corrupt practices

 

Complaints and Reports

 

Anton encourages all employees to monitor and report on each other’s conduct, protecting and incentivizing whistle-blowing based on reasonable assumptions. To ensure the smooth operation of communication channels for timely and secure handling of corruption reports, we have established localized reporting channels in all countries and regions where we operate; these channels are accessible in the local languages, and the reporting channels, contact information, scope of reportable issues, principles of acceptance, and whistleblower protection policies are clearly detailed on our official website in Chinese, English, and Arabic. Employees, third parties with business relations, and the general public can report any job-related illegal acts concerning the Company’s operations while ensuring confidentiality.

 

The company has established a standardized “Complaints and Feedback” handling process to ensure that all complaints and leads are meticulously processed as per established procedures. We promptly initiate the handling procedures, conducting investigations and taking actions as per regulations and laws, thus ensuring that all reported issues and complaints are dealt with fairly, justly, timely, and accurately. Furthermore, we place paramount importance on safeguarding the legal rights and interests of whistleblowers, stringently requiring the confidentiality of their personal information and the content of their reports. We strictly prohibit any form of retaliation, thereby guaranteeing the safety and trust of all whistleblowers.

In 2024, Anton received a total of 8 reports and complaints through its public whistleblowing channels from both internal and external sources. Upon receipt, the Company immediately conducted interviews and preliminary reviews. The Audit Leadership Team formulated detailed audit plans and work schedules, followed by rigorous verification and investigation of each case. This process culminated in formal investigation reports with proposed resolutions, with appropriate feedback provided to the whistleblowers/complainants. All reported matters were fully and properly addressed in accordance with established procedures, with the majority of cases found to be unsubstantiated upon investigation.

 

Complaint, Response, and Resolution Process

 

 

Anti-corruption Culture

 

Anton emphasizes the cultivation and dissemination of an integrity culture. Specialized training sessions on topics such as “Sunshine Marketing,” anti-commercial bribery, and team ethos building are organized for all board members and employees. Additionally, a series of online training courses like the Popularization and Prevention of Employee Duty-related Crimes, have been developed for employees to enhance their integrity and compliance awareness through self-study. In an effort to strengthen this commitment, we issued a clean and honest holiday initiative letter and the Anton Group’s anti-corruption and integrity initiative letter to all employees. Through regular cultural and ethical communication, on-site inspections, and employee seminars, we actively disseminate the Company’s ethical code, encouraging all staff to establish and uphold the principle of integrity and self-discipline.

 

In 2024, to reinforce compliance awareness, eliminate potential irregularities in marketing and business transactions, and enhance the effectiveness and adaptability of our anti-commercial bribery mechanism, the Company launched an audit and inspection campaign focused on “Sunshine Marketing” and anti-commercial bribery practices across all units to identify and promptly address certain potential compliance risks. The Company organized an anti-commercial bribery self-inspection and self-correction campaign during the Anti-Corruption and Integrity Month. This involved inquiries, reviews, and spot checks of potential commercial bribery risks in the routine operations of all employees, as well as audits and assessments of the performance, delivery, discipline, and ethics of leading cadres and personnel in key positions. This initiative aimed to deepen employees’ understanding of the significance of anti-corruption and integrity efforts and to foster a clean and positive team atmosphere. Through extensive and in-depth educational training, employees have gained a more profound understanding of the principles of “Sunshine Marketing”

 

 

Supplier Anti-corruption Management

 

Anton has collaborated with its partners to establish a corruption-free industrial ecosystem. We have formulated and issued the Anton Supplier/Contractor Code of Conduct, and conducted evidence-inquiry inspections with business partners and suppliers. All suppliers are required to sign both the Sunshine Purchasing Integrity Commitment and the Integrity Agreement as a prerequisite for our transactions. These documents serve as crucial tools in combating corruption and bribery throughout the purchasing process.

 

Fair Competition

 

The Company consistently adheres to the principle of fair competition, striving to create a healthy and orderly market environment. To achieve this objective, we rigorously regulate the market conduct of our sales teams to prevent and eliminate the risks of unfair competition. We pledge that, in the course of our business operations, we will not engage in any form of collusion with customers or competitors to unjustly secure projects or contracts. We firmly oppose price fixing and the exchange of bidding information, ensuring that all transactions are conducted under open and transparent conditions. Moreover, we adhere to principles of honest business operations, refraining from engaging in any undue lobbying activities to seek or obtain unfair competitive advantages from government policies. We believe that only through fair competition can we achieve long-term market prosperity and sustainable development for our company.