Key Points of China Minsheng Bank’s Policies for Employee Protection and Rights and Interests Protection

I. General Provision
To respect and protect the legitimate rights and interests of employees and build harmonious and stable labor relations, China Minsheng Bank (the “Bank”) has formulated the Key Points based on applicable laws and regulations, including the Labor Law of the People’s Republic of China, the Work Safety Law of the People’s Republic of China, the Trade Union Law of the People’s Republic of China, the Law of the People’s Republic of China on the Protection of the Rights and Interests of Women, and the Law of the People’s Republic of China on the Protection of Minors, with reference to the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, and relevant International Labour Organization conventions and standards, and as well as the Bank’s actual circumstances.

The Key Points is applicable to the Head Office, the branches, the sub-branches and the subsidiaries of the Bank and all employees, including regular employees, dispatched employees and interns. It is also applicable to the Bank’s own operations and set relevant requirements for contractors, suppliers, business partners and their personnel providing services at the Bank’s premises or on behalf of the Bank.
II. Governance Structure and Responsibilities
The Board of Directors and the Senior Management of the Bank are responsible for the governance and supervision of employee rights and interests, human rights and occupational health and safety. Relevant special committees review and supervise major matters concerning employee rights and interests and occupational health and safety in accordance with their responsibilities.

Trade unions at all levels of the Bank carry out their work independently and in accordance with laws and regulations. The Bank uses the employee representatives congress as a basic form of democratic management, at which rules and regulations and major matters involving employees’ vital rights and interests are reviewed and approved. The Bank’s appeal feedback platform of “Voice of Minsheng” serves as a unified channel for employee feedback and appeals, covering employees at all levels across the Bank.
III. Labor Practices Commitments
1. Remuneration and Social Security
The Bank has established a remuneration management system that is competitive in external market, fair in internal allocation, and sustainable in incentive measures. The Bank follows the principles of determining remuneration according to job position, matching employees with job positions and getting remuneration according to performance, so as to ensure that employee remuneration is not lower than the minimum wage standards prescribed by the state and the place of operation. The Bank also assesses the reasonableness of remuneration levels with reference to the cost of living, labor market conditions and operating circumstances, in order to safeguard employees’ basic living needs. 

The Bank timely pays in full amount, in accordance with the law, the social insurance contributions for employees, including basic pension, basic medical, unemployment, work-related injury and maternity insurances, and the housing provident fund for employees. The Bank also provides supplementary protection and benefits, including corporate annuity, supplementary medical insurance and health examination, and continuously improves employees’ social security levels.
2. Working Hours, Rest, Leave and Overtime Management
The Bank implements the regulations of the state and the place of operation concerning standard working hours, comprehensive working hours, non-fixed working hours, and rest and leave. In principle, the Bank does not encourage overtime work. For required overtime work due to operational or management needs, the Bank follows consultation, approval and record-keeping procedures in accordance with the law, and arranges compensatory leave or pays overtime pay in accordance with the law. 

The Bank monitors employees’ working hours and overtime work through attendance and working-hour records to prevent long-term or excessive overtime. Flexible working arrangement, job rotation, staggered leave and mandatory leave are adopted according to job position characteristics to safeguard employees’ right to rest. Employees’ daily and weekly working hours and overtime hours must not exceed the limits prescribed by laws and regulations. 

The Bank strictly implements statutory public holidays, paid annual leave and the  applicable leaves according to laws, such as marriage leave, maternity leave, paternity leave, parental leave and nursing leave, so as to safeguard employees’ entitlement to paid leave.
3. Equal Remuneration and Fair Treatment
The Bank adheres to equal remuneration for men and women employees for work of equal value. Employee remuneration is determined based on objective factors such as job value, capability requirement and performance contribution. The Bank treats employees without discrimination of any kind based on sex, age, marital status, childbirth, ethnicity, race, religion, health status, disability or other such factors. The Bank regularly monitors remuneration equality and the gender pay gap, and improves its management mechanisms based on the assessment results.
4. Major Organizational Adjustments and Employee Communications
In case that the Bank carries out major organizational adjustments, job adjustments or economic layoffs that might involve employees’ vital interests, it strictly follows the procedures of consultation, explanation, notification and reporting prescribed by laws and regulations, listens to the opinions of trade unions or employee representatives in advance, and provides affected employees with economic compensation, internal job transfers, retraining and employment support in accordance with the law.
5. Training Support
The Bank has established a layered and classified employee training and career development system, providing employees with training and retraining aligned with duty performance, digital transformation, green finance, risk compliance and other business transformations, and supports employees in enhancing their capabilities and in responding to job changes due to industrial, technological and climate transitions.
IV. Anti-Discrimination and Anti-Harassment
The Bank prohibits any forms of discrimination, harassment and workplace bullying, including sexual harassment and other non-sexual harassment, and adopts the zero-tolerance policy for discrimination and harassment. Retaliation against whistleblowers, complainants, witnesses or participants in investigations is prohibited.

Employees may report discrimination, harassment or other infringements of employee rights and interests through real-name or anonymous channels, including their respective institution, human resources departments, trade unions at all levels, discipline inspection channels and the “Voice of Minsheng” feedback platform. The Bank has established a closed-loop process of case receipt, assessment, investigation, handling, feedback and rectification, and provides necessary support and remedy to the parties concerned.

For substantiated discrimination, harassment or retaliation, the Bank takes corrective or disciplinary measures, up to and including termination of employment contract, in accordance with its internal accountability system. Those suspected of illegal or criminal acts shall be transferred to relevant authorities in accordance with the law. 
V. Human Rights Commitments
The Bank is committed to respecting human rights throughout its operations and business relationships, follows Chinese laws and regulations as well as the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the core conventions of the International Labour Organization and other internationally recognized standards, and works to prevent, identify, mitigate and properly address human rights risks.

The Bank prohibits human trafficking, any forms of forced labor and child labor, respects employees’ rights to have freedom of association, to join trade unions and to engage in collective bargaining in accordance with the law, prohibits discrimination and harassment, and protects employees’ rights to resign, rest and take leave, receive remuneration for work, and work in a safe and healthy environment in accordance with the law.

The Bank integrates human rights requirements into its own operations, products and services, procurement and partnership management. For suppliers, contractors and business partners, the Bank requires them to comply with applicable requirements in relation to labor, human rights, occupational health and safety, and anti-discrimination through access assessments, contractual terms, process supervision, rectification and exit mechanisms.

Employees and other stakeholders may raise human rights-related representations through the Bank’s grievance, petition and whistleblowing, customer service and legal remedy channels. The Bank protects individuals who raise concerns or report matters in good faith, strictly prohibits disclosure of whistleblowers’ information or retaliation, and takes remedial and corrective measures based on investigation results.
VI. Occupational Health and Safety
The Bank complies with laws, regulations and standards relating to occupational health and safety and applicable international good practices, and continuously establishes and improves its occupational health and safety management system. Occupational health and safety management covers all employees of the Bank, including regular employees, dispatched employees, interns, as well as contractors, suppliers, partners  and their relevant personnel who provide services on behalf of the Bank working at the Bank’s premises.

The Bank’s operation safety committee coordinates occupational health and safety matters, the functional departments of the safety committee implement their respective management responsibilities, and each institution implements its local management responsibilities. Through the employee representatives congress, the trade unions and the employee communication channels, the Bank ensures the participation of employees and their representatives in the formulation of occupational health and safety systems, risk assessments and improvement recommendations.

The Bank’s occupational health and safety priorities include: improving the occupational health and work safety responsibility system; carrying out security, fire safety risk investigation and rectification at office and business premises, strengthening comprehensive management of public security of the Bank, and maintaining safe and stable operation; organizing safety education, emergency drills and reporting of accident hazards; providing occupational health, medical assistance, mental health and other health promotion services; and strengthening contractors’ work safety management.

The Bank has established the mechanisms of accident hazards reporting, assessment, rectification, feedback on and reward of accident hazards. Employees and contractors may report accident hazards or dangerous situations through work safety management channels at all levels. For emergency risks, immediate on-site response and escalation reporting measures shall be taken; for general and major hazards, classified and graded management, time-limited rectification and closed-loop supervision are implemented.

The Bank has set and regularly assesses occupational health and safety targets, which focus on hazard rectification, work-related injury insurance coverage, safety training and emergency drills, employee health service coverage, and prevention of work-related injuries and accidents, and incorporates relevant targets into management evaluations.

Through internal inspections, management reviews, root-cause analysis of accidents and incidents, corrective and preventive actions, and performance evaluations, the Bank continuously improves its occupational health and safety management system and performance.
VII. Handling of Violations
The Bank adopts the zero-tolerance policy for violations of the Key Points. In case of violations of the Key Points by employees , the Bank handles the matter in accordance with the regulations on  employee conduct and violation accountability. In case of violations of relevant laws and regulations, the requirements of the Key Points or contractual agreements by suppliers, contractors or business partners , the Bank may, depending on the severity of the circumstances, take measures including rectification, accountability, suspension of cooperation and termination of contracts. Those suspected of illegal or criminal acts shall be transferred to relevant authorities in accordance with the law.
VIII. Supervision and Audit
The Bank has incorporated employee rights and interests protection, labor employment, remuneration and benefits, human rights protection and occupational health and safety into the scope of internal control assessment, internal audit and compliance supervision, and accepts external supervision through regulatory inspection, trade union supervision, external audit or certification. For identified issues, the Bank establishes mechanisms of rectification, review and accountability.
IX. Policy Review and Update
The Key Points is interpreted and maintained by the Bank and shall be reviewed at least annually with reference to laws and regulations, regulatory requirements, international best practices, implementation status and lessons learned from relevant incidents. The Key Points shall be revised in a timely manner when major changes or major risk events occur.