Key Points of China Minsheng Bank’s Policies for Anti-Bribery, Anti-Corruption and Whistleblower Protection

I. General Provision
To further promote the culture of integrity in the financial sector, prevent bribery and corruption risks, and protect the legitimate rights and interests of whistleblowers, China Minsheng Bank (the “Bank”) has formulated the Key Points based on applicable laws and regulations, including the Criminal Law of the People’s Republic of China, the Anti-Unfair Competition Law of the People’s Republic of China and the Supervision Law of the People’s Republic of China, and other relevant laws and regulations, as well as requirements of financial regulatory authorities, and the Bank’s actual circumstances. The Bank has formulated supporting policies, including the Disciplinary Measures of China Minsheng Bank on Staff Violations and the Regulations on Clean Practices of Management Personnel of China Minsheng Bank, which, together with the Key Points, constitute the the Bank’s policy framework for anti-bribery, anti-corruption and whistleblower protection.

The Key Points is applicable for all employees of the Bank and its subsidiaries in and outside the Chinese mainland, which set corresponding integrity requirements for relevant third parties and business partners conducting business on behalf of the Bank.
II. Governance Structure and Responsibilities
The Board of Directors assumes the ultimate responsibility for the management of practitioner conduct, approves relevant policies on practitioner conduct management, and supervises the Senior Management in implementing practitioner conduct management.

The Senior Management assumes responsibility for implementing practitioner conduct management, establishing the comprehensive practitioner management system, clarifying the scope of responsibilities of relevant conduct management departments, formulating policies on practitioner conduct management and ensuring their effective implementation, and reporting the results of the annual practitioner conduct assessment to the Board of Directors.

The Bank has established the Accountability Committee of China Minsheng Bank, with the Secretary of the CPC China Minsheng Bank Committee serving as the Chairman of the Committee, and the President, the Secretary of the Discipline Inspection Committee, the Executive Vice Presidents and other Senior Management serving as the Vice Chairmen of the Committee. The accountability committees at corresponding levels have also been established  at branches, the Credit Card Center and most of the tier-2 branches. Under the leadership of the Board of Directors and the Senior Management, the accountability committees at all levels strictly handle employees’ violations of laws, regulations, rules and disciplines in accordance with their respective authorities and applicable requirements.
III. Key Requirements for Anti-Bribery and Anti-Corruption
1. Prevention of Bribery and Corruption
The Bank adopts a zero-tolerance policy for bribery and corruption. It is strictly prohibited to solicit or accept bribes or improper benefits from customers, suppliers, competitors and other stakeholders in any manner; and it is strictly prohibited to offer bribes or improper benefits to government authorities, or other interested parties. The Bank strictly prohibits to take advantage of one’s position to misappropriate, embezzle or divert the Bank’s or customers’ funds and assets, or to transfer benefits in any form.
2. Management of Gifts and Gift Money
The Bank explicitly prohibits accepting or offering gifts or gift money exceeding the scope permitted by laws and commercial practices. For those cannot be refused or returned for any reason, they should be reported and handed over within three working days from the date of receipt. The offices of the discipline inspection committees at all levels are responsible for receiving, registering, keeping and handling of such gifts and gift money.
3. Political Contributions
The Bank does not make political contributions or provide any other forms of political support to any political party, political organization, political figure or related entity. It is strictly prohibited to provide fund support for political activities in the name of the Bank or by using the Bank’s resources.
4. Charitable Donations and Sponsorship
The Bank has standardized the approval and management of charitable donations and business sponsorship. Donations and sponsorship must go through the applicable approval procedures to ensure that their purposes are genuine, compliant and transparent. It is strictly prohibited to make disguised benefit transfer or commercial bribery in the name of donations or sponsorship.
5. Anti-Bribery and Anti-Corruption Training
The Bank continues to provide all employees with education and training on clean practices, anti-bribery and anti-corruption, as well as warning and awareness education, and has incorporated integrity requirements into induction training for new employees and pre-appointment education for management personnel, thereby strengthening employees’ awareness of compliance and bottom line.
6. Procedures for Handling Violations and Disciplinary Actions
The Bank has established standardized procedures for handling violations, and promptly accepts, verifies and handles clues involving suspected bribery or corruption. Individual who violates the policy shall be held accountable in accordance with the Disciplinary Measures of China Minsheng Bank on Staff Violations. Those suspected of illegal or criminal acts shall be transferred to the judicial authorities in accordance with the law.
IV. Whistleblower Protection Mechanism
1. Dedicated Responsible Departments
The discipline inspection and supervision institutions at all levels of the Bank are the dedicated departments responsible for whistleblowing. They uniformly receive, verify and handle complaints and reports on breaches concerning violations of laws, regulations, rules and disciplines by the Bank and its practitioners, and designate dedicated personnel to manage whistleblowing-related matters.
2. Reporting Channels and Anonymous Reporting
The Bank has established and improved reporting channels, including letters, in-person visits, telephone calls and online channels, making them public to employees and the general public. Whistleblowers may submit reports either under their real names or anonymously. For real-name complaints and reports, the handling department shall complete identity verification and notify the whistleblower of acceptance within the prescribed working days. Personnel conducting the verification shall proactively identify themselves and inform the whistleblower of the relevant rights and obligations.
3. Confidentiality of Whistleblowing Information
The Bank keeps whistleblowing materials and the entire process of verification and handling strictly confidential. Whistleblowing information shall not be proactively disclosed, and detailed information contained in the reports received shall be used only to the extent necessary for handling the relevant matter. It is strictly prohibited to cause any loss or leakage of confidential information due to negligence or improper conduct.
4 Zero Tolerance for Retaliation
The Bank resolutely safeguards the legitimate rights and interests and personal safety of whistleblowers and their immediate family members, and adopts a zero-tolerance policy for retaliation. It is strictly prohibited that any organization or individual threaten, insult, assault or retaliate against witnesses, whistleblowers and their immediate family members. Those who engage in retaliatory actions shall be rigorously investigated and addressed in accordance with applicable regulations and disciplines, and those suspected of illegal or criminal acts shall be transferred to the judicial authorities in accordance with the law.
5. Training on the Use of Reporting Channels
Through integrity education, compliance training and policy briefings, the Bank provides employees with training on the use of reporting channels and whistleblower protection policies, to ensure that employees are aware of and dare to exercise their rights to supervise and report.
6. Investigation Process and Feedback on Results
The Bank implements a standardized investigation procedures of reported violations, with each stage, including acceptance and registration, preliminary verification, case filing and investigation, and review and handling, conducted in accordance with relevant regulations and disciplines. The Bank implements closed-loop management of reported matters. After a complaint or report has been closed, the handling department shall, in principle, prepare a notification draft within 15 working days, and provide feedback on the handling result to the real-name whistleblower after approval. In case that the whistleblower provides new evidence during communications, the Bank will continue to conduct an in-depth investigations. In case that the whistleblower fabricates or distorts facts or makes malicious false accusations, the Bank reserves the right to take appropriate actions and to seek recovery of any loss or damage caused by false reports.
V. Supervision and Audit
The Bank has established the continuous supervision system to conduct daily supervision over the implementation of ethical standards. Through digital means, the Bank performs off-site continuous monitoring and provides alerts on abnormal employee behavior involving violations of business ethics across its business units.

In accordance with the principle of “full-coverage in every three years”, the Bank conducts comprehensive internal control evaluation audits of all business units, with focus on internal policies for ethical standards, employee ethical risks, clean practices and accountability management. It conducts comprehensive evaluations and supervisions on all lines of businesses and all personnel to ensure the depth and breadth of inspections.
VI. Policy Review and Update
The Bank regularly reviews this policy, and revises it based on the latest laws and regulations, regulatory updates and business development, to ensure its compliance, applicability and effectiveness.