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 have developed a series of internal policies and regulations such as the Sunshine Purchasing Integrity Commitment and the Integrity Agreement. These policies provide a robust institutional framework for the Company's integrity management.

 

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 Company 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. Internally, the Company has launched the "Sunshine Marketing" campaign and conducted self-examination and self-correction activities to address commercial bribery. Furthermore, we conducted inquiries, reviews, and random inspections at all levels to combat potential instances of commercial bribery in daily operations. Through these self-examination and self-correction efforts, we have mitigated potential risks and fostered a working environment characterized by fairness, equity, integrity, and vitality.

 

In FY2023 the Company had no legal cases related to corrupt practices

 

Complaints and Reports

 

We actively encourage anonymous reporting and disclosure of actual or suspected violations of our Anti-Corruption Policy. To ensure effective supervision of the Company's business ethics and operations, and to promptly address potential corruption reports in a secure manner, we have established public reporting channels in local languages across all countries and regions where the Company operates. The contact information for these reporting channels is also available on our official website in English, Chinese, and Arabic. We provide clear explanations of the principles of acceptance and policies for protecting whistleblowers.

 

We have formulated a strict “complaint and problem response” handling process, which requires that all reports or complaints received are handled fairly, promptly, accurately, and effectively. We have also implemented measures to protect the whistleblowers. The information of the whistleblowers and report content will be kept strictly confidential, and we explicitly prohibit any form of retaliation or threat against the whistleblower.

In FY2023, we received a total of 11 internal and external reports. Upon receiving each report, our internal audit team promptly conducted preliminary interviews to gain immediate insight into their contents. Subsequently, the audit leading group deliberated on and established an audit plan and work plan, and conducted rigorous and detailed verification and audit investigation on the relevant report. The group compiled an investigation report, proposed appropriate courses of action, and provided feedback to whistleblowers accordingly. We completely and properly handled all reported matters in accordance with our established handling process. The majority of the reports were found to lack factual basis.

 

Complaint, Response, and Resolution Process

 

 

Anti-corruption Culture

 

Anton promotes a culture of integrity and emphasizes the importance of never crossing ethical boundaries. To enhance employees' awareness of this principle, the Company has developed a series of training courses, such as the Popularization and Prevention of Employee Duty-related Crimes. We have also reinforced employee discipline by studying both internal and external anti-corruption cases. During festivals and holidays, we send written proposals to employees as a reminder of integrity. In addition, the Company organizes regular events such as corporate culture campaigns, inspections, on-site investigations, and employee interviews to promote ethical values and help employees at all levels establish a sense of integrity and self-discipline.

In FY2023, Anton launched anti-corruption month activities aimed at all employees. These initiatives featured courses and events centered around the theme of "learning laws and regulations, never crossing the bottom line, fulfilling responsibilities, and striving for progress and breakthroughs." By combining integrity education with business activities through various means such as training sessions, competitions, and awareness-raising painting campaigns, employees gained a deeper understanding of the significance of anti-corruption efforts. These activities contributed to creating a clean and upright environment for teamwork within the Company.

 

 

Supplier Anti-corruption Management

 

Anton has joined hands with its partners to create a clean industrial ecosystem. We have formulated and issued the Anton Supplier/Contractor Code of Conduct, and conducted evidence-inquiry inspections with business partners and suppliers. Signing the Sunshine Purchasing Integrity Commitment, and Integrity Agreement with them is a prerequisite for our transactions. These agreements serve as crucial tools in combating corruption and bribery throughout the purchasing process.

 

Fair Competition

 

We uphold fair competition in the market. We do not engage in collusion with customers or competitors to secure projects. We refrain from exchanging price or bidding information with competitors and avoid lobbying the government for policies that provide us with an unfair advantage. We firmly believe that our success should be achieved through fair play and ethical practices.