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Business Ethics Management Policy

Sino Biopharmaceutical adheres to a high-level code of business ethics, formulates and implements strict business ethics policies, continuously strengthens compliance performance, and improves the management of business ethics.

1. Business ethics supervision: Sino Biopharmaceutical establishes Risk Compliance Committee, headed by the Chairman of the Board, to perform the Group's compliance management responsibilities and supervise the implementation of the Group's business ethics policies.

2. Business ethics training policy: Sino Biopharmaceutical regularly carries out business ethics training for all employees to strengthen their business ethics awareness.

3. Audit of business ethics standards: Sino Biopharmaceutical annually audits and revises the Group's business ethics standards to ensure the applicability and comprehensiveness of the Group's business ethics standards.

 

Anti-corruption Policies

Sino Biopharmaceutical is committed to creating an integrity and honest business environment.

The Furnace Rules are the programmatic document of anti-corruption for the Group. It aims to clarify the red line of business ethics of the Group, standardize the judgment standard of violations of discipline and the procedure of accountability.

1. Laws and regulations related to duty crimes that the employee should be aware of: including the crime of bribery of non-state staff, crime of duty encroachment, crime of bid-colluding, crime of embezzlement of funds, crime of illegal operation, crime of infringing commercial secrets, crime of forging seals, etc.

2. Eight Red Lines: including disrupting production and operation order, abuse of power, data file fraud, illegal information leaks, sexual harassment, bribery, etc.

3. Accountability for violations of rules and disciplines: including the types of accountability, conflicts of interest, bribery, embezzlement and theft, dereliction of duty and application, problem investigation and disclosure methods, management of gifts, management of complaints and reports, etc.

4. Relevant rights and responsibilities: including confidentiality requirements, rules of rights and responsibilities, etc.

At the same time, to improve the anti-corruption mechanism, we have formulated regulations such as the Anti-Commercial Bribery Regulations and Supplier Integrity Agreement.

1. Commercial bribery risk points and risk control measures: including product sales, invoices, personnel employment, external interaction and communication, etc.

2. Risk assessment and response: Conduct a comprehensive risk assessment at least once a year.

3. Anti-commercial bribery training: Anti-commercial bribery training shall be carried out during the induction training of all staff, and relevant training shall be carried out from time to time.

4. Report handling process: The Compliance Department will conduct relevant investigation after receiving the report, disciplinary measures will be taken against the violators, and the internal control loopholes of the Group will be rectified.

5. Supplier Integrity Agreement: fraud, bribery, exchange of interests and other acts of seeking improper benefits are strictly prohibited, different treatment measures for default suppliers according to the severity of the circumstances are specified, and relevant reporting channels are specified.

 

Employee Integrity Agreement

Sino Biopharmaceutical adheres to the core values of "honest life and healthy development", and builds an ethical behavior culture, to emphasize internal integrity and compliance. As a pharmaceutical enterprise, it is of great significance to adhere to honesty and integrity, operate in accordance with the law and regulations, to clean up the internal atmosphere of the enterprise, enhance the reputation of the enterprise, and enhance the brand value of the enterprise. As an employee, integrity and compliance are related to the sustainable career development of employees.

1. Ethical and honest. Follow the Group's cultural values, adhere to the "conduct based on morality", integrity, dedication, and abide by fairness and justice.

2. Abide by the law, compliance and self-discipline. Strengthen the awareness of "red line" and "bottom line", comply with laws and regulations, comply with the Group's rules and regulations.

3. Adhere to principles and eliminate fraud. Firm faith, adhere to the principle, actively identify the risk of fraud, consciously resist temptation, say no to irregularities and fraud.

 

Anti-money Laundering Policy

In order to prevent and fight of money laundering and other serious crimes through the Group's business activities, safeguard the financial order, guarantee the Group's operating safety and credibility, in accordance with the Anti-Money Laundering Law of the People's Republic of China and the actual situation of the Group, Sino Biopharmaceutical has formulated the Anti-Money Laundering Management Measures of Sino Biopharmaceutical, which is applicable to Sino Biopharmaceutical and all its member companies, as well as the executives and all other employees of the companies.

1.Anti-money laundering prevention and supervision: anti-money laundering obligations, customer identity identification, anti-money laundering prevention measures, anti-money laundering supervision and assistance and other contents.Member companies and employees have the right to report when they find that the anti-money laundering obligations have not been fulfilled.

2.Anti-money laundering report: Employees have the right to report money laundering activities to the administrative department of anti-money laundering, relevant competent departments and public security organs.

 

Compliance Management Policy

In order to strengthen and standardize the compliance management of Sino Biopharmaceutical, improve the Group's operation management level and compliance risk prevention ability, and ensure the sustainable and healthy development of the Group, the Group formulated the Compliance Management Policy of Sino Biopharmaceutical.

1. Principles and objectives of compliance management

- Compliance management principles: comprehensive coverage, strengthen responsibility, consultation and linkage, independence

- Compliance management objectives: risk control, information smooth, compliance, effective management, crisis response

2. Compliance management organization

A compliance management organizational structure of leadership, compliance department and business department is established to identify, evaluate and manage the compliance risks of enterprise operation and management activities.

- The leadership shall perform the duties related to compliance management in accordance with laws, articles of association and regulations of the company, and bear the final responsibility for the effectiveness of compliance management of the enterprise;

- Compliance department is the daily management department of compliance work, which assists business departments to effectively identify and manage the compliance risks of company, reviews, supervises and inspects the compliance of company operation and management activities, and is responsible for the effectiveness of compliance management;

- Business departments shall strengthen the supervision and management of the compliance of its employees, and bear the primary responsibility for the effectiveness of the compliance management of the department.

3. Operation mechanism of compliance management

The Group’s compliance management operation includes a series of activities such as proactive identification and assessment of compliance risks, compliance consultation and review, compliance inspection, report and feedback to prevent, remedy and deal with compliance risks.

 

Supplier management

1. Supplier screening

In supplier selection, take into account both business relevance and environmental, social and corporate governance management skills. Conduct supplier ESG risk assessment to identify and screen significant suppliers. Factors to be considered in risk assessment include but are not limited to procurement scale, commodity category, sector of demand and supplier country risk.

2. Supplier assessment and audit

Establish supplier audit mechanism, including quality audit and non-quality audit, and track the production and operation of suppliers through document audit and on-site audit. For the quality audit, the quality department staff composed of the main audit team, with GMP requirements as the core to carry out. Non-quality audit consists of an audit team composed of personnel from EHS, ESG, human resources and other departments. It mainly refers to the guidelines of PSCI standard to evaluate the compliance of suppliers with business ethics, environment and labor rights. Among them, the key material suppliers must be audited on site; After the first on-site audit, a re-audit is generally conducted every three years, and an annual review of each supplier is conducted annually. According to the review summary report, on-site audit should be conducted at any time if an exception occurs more than three times a year and it is confirmed that the supplier's materials still need to be used. For suppliers with relevant changes, risk assessment should be carried out on the supplier change project combined with the company's product situation, and on-site audit should be carried out if necessary; On-site audit of non-critical material suppliers may not be carried out, but on-site audit must be carried out when anomalies occur more than 3 times a year and it is confirmed that the supplier's materials need to continue to be used; Only qualification audits are conducted for general material suppliers.

Provide guidance to suppliers on the problems found in the audit and assist them in making rectification plans. Provide remote or on-site support and required technical support to suppliers who have developed corrective action plans, and track the implementation of corrective action. All audit processes and audit results and corrections will be documented and archived in writing.

3. Supplier participation and development

Join hands with suppliers to grow together and actively enable sustainable development of the industrial chain. Based on the Supplier Code of Conduct, organize annual training on anti-corruption, quality management, environmental protection and other topics for suppliers, covering management requirements, process improvement, long-term planning, etc., to cultivate suppliers' ESG proactive management capabilities. Timely share peers' ESG management excellent practices with suppliers, organize suppliers to carry out ESG management self-assessment, help suppliers identify management gaps, improve sustainable development performance and management capabilities. Communicate with suppliers regularly to understand their ESG development needs and provide in-depth technical support and planning to support suppliers to improve long-term ESG performance.

 

Business Compliance Guidelines 

Sino Biopharmaceutical has always been adhering to the concept of compliance management, strictly abide by national laws and regulations and industry guidelines, standardize the company's business, and is committed to building a law-based enterprise with integrity and standardized governance. Basic principles of business compliance include:

- Pay attention to distinguish the type of the object of communication and the nature of activities: When the company conducts business cooperation with a certain object of communication, pay attention to the type of the object of communication and the nature of activities in accordance with the definition and relevant laws and regulations. The more the partner can exert influence on the company's business, the more attention should be paid to the behavior of the partner in the cooperation. If a business cooperation only supports or benefits the object's own business, the business conduct may violate the rules.

- Ensure proper purpose of business activities: The purpose of interaction between the company and the object it interacts with is to benefit patients and improve the medical level. The focus of interaction should be on communicating product information, providing scientific and educational advice, and supporting medical research and education.

- Not on the premise of product recommendation: Any business behavior shall not be based on the agreement or commitment of the partner to purchase or recommend the use of the product. It is strictly forbidden to provide any valuable goods directly or indirectly to the communication object in exchange for the prescription, recommendation, purchase, supply of the product and the promise of the patient's use of the product, nor to provide or promise to provide any other benefits in any way or under any conditions that may have an undue influence on the communication object in relation to the product.

- Ensure the transparency of business activities: The interaction with the communication object must be transparent, the communication process should be accurately and completely recorded, and relevant bills or accounting books and correspondence documents should be retained to provide support for the interaction and communication activities. No form of concealment, concealment or avoidance of such interaction shall be allowed.

- Compliance with national laws and regulations: The Group shall strictly abide by the applicable national laws, regulations, rules, industry norms and other relevant normative documents in carrying out any form of business activities to ensure the legal compliance of business behaviors.

 

Whistleblower Protection Policy

In order to protect the privacy and security of whistleblowers and establish a safe and credible reporting mechanism, Sino Biopharmaceutical has formulated the Sino Biopharmaceutical Whistleblower Protection Policy, which clarifies principles and measures for confidentiality of complaint information, protection of personal privacy, and handling of reports and complaints.

1.Confidentiality of complaint information: In the process of receiving complaints and reports, attention should be paid to the confidentiality of complaints and reports;

2.Protection of personal privacy: Personal privacy and business secrets involved in the investigation must be kept strictly confidential.

3.Handling of reports and complaints: It is strictly prohibited to retaliate against whistleblowers, cover up for internal "harmony", conceal and leak relevant information, and betray or damage the Group's cultural values.

  

Responsible Marketing Policy

Sino Biopharmaceutical adheres to the marketing principle of "truth and compliance", and carries out product promotion and marketing with a responsible attitude. We are committed to creating a transparent and trustworthy business environment to provide customers with reliable products and services. We are committed to:

1. Comply with marketing laws, regulations and industry norms of the country and region where the operation is located;

2. Conduct legal, true and accurate communication and publicity based on scientific facts, refrain from any false or misleading publicity, and ensure that accurate and true drug information is conveyed to stakeholders;

3.Fully respect and protect the privacy and data of customers or consumers;

4.Conduct regular marketing and sales audits to ensure the accuracy and compliance of advertising and marketing activities, as well as legal compliance of sales and marketing practices.

5.Regularly carry out marketing training to the senior management, marketing and sales personnel in the respective operating places, and enhance employees' awareness of compliance marketing.

 

Information Security and Privacy Protection Policy

Sino Biopharmaceutical attaches great importance to the information security and privacy protection of its customers and partners, and strictly complies with the laws and regulations related to information security in the countries and regions where it operates. It is clearly required in the employee labor contract and the Code of Conduct for Employees that employees shall strictly abide by the principle of confidentiality of non-public information to customers, distributors and other third parties. The Code of Conduct for Employees clearly stipulates that employees shall keep strictly confidential the information, materials and achievements they have about the Group, and shall not disclose them to any other company or unrelated individuals.

The information operation and safety management policy should comply with the relevant provisions and requirements of the national laws and regulations, the document system of the relevant regulatory authorities, the industry norms and so on. All departments assume the responsibility of information operation and security management, including the chargers, the operators, and the users.

1. The employee shall keep the data confidential and shall not access or disseminate the data without permission.

2. The permission allocation of information system users follows the "must know" and "minimum authorization"; principles.

3. The creation, change and cancellation of a user shall be approved by the relevant person in charge, and shall be recorded and put on record.

4. The user account of the information system shall be protected by password when logging in. The users and custodians take the responsibility of keeping the password.

5. Terminals are managed according to unified specifications, such as hardware configuration, operating system, initial software, device naming convention, operating system users, network, working directory, etc.

6. All departments shall use mobile devices with caution and be responsible for various security threats and data confidentiality.

7. All computer users of the Group who access the Internet shall strictly abide by the Regulations of the People's Republic of China on the Security Protection of Information Systems, the Measures for the Security Protection and Management of Computer Information Networks in International Networking, etc.

 

Intellectual Property Protection Policy

Sino Biopharmaceutical attaches great importance to intellectual property protection and respects the intellectual property rights (IPR) of any third party. The Group continues to optimize the IPR management system, formulates and publishes the IPR Management Working Manual, protects the legitimate rights and interests of employee inventors to encourage invention and creation.

1. Intellectual property rights include inventions, utility models, appearance, technical secrets, trademark rights, domain names, trade secrets, copyrights, computer software, etc.

2. The Group shall have the right to use, profit and dispose of any invention or creation arising from the performance of his/her duties during his/her service if he/she applies for intellectual property rights.

3. The Group respects the relevant personal rights of employees as creators, developers and assists employees in exercising these rights.

4. The employee shall assist the Group in obtaining and exercising the relevant intellectual property rights after obtaining the results of his/her duties.

5. Intellectual property rights shall be enjoyed by employees if they are not considered to be within the scope of their duties.

 

Bioethical Policy

Sino Biopharmaceutical attaches great importance to the welfare and ethics of laboratory animals. We have formulated Bioethical Principles, standardized the management of animal experiments, and ensure the basic rights and welfare of laboratory animals.

1. All animal experiments are subject to bioethical review, and the declared project shall be reviewed and approved by the Laboratory Animal Ethics Committee before the experiment is conducted.

2. Formulate animal experiment management system and operation guidelines, and carry out supervision, inspection and technical guidance, to promote the standardization of animal experiments.

3. Adhere to the principles of replacement, reduction and refinement of animal use, explore the application of alternative methods of animal testing, and reduce the use of animals.

4. Organize regular training of experimental animal welfare ethics knowledge, strengthen the ethical concept of animal welfare.