002332SZSE

Code of Business Ethics and Conduct

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Zhejiang Xianju Pharmaceutical Co., Ltd. has issued its Code of Business Ethics and Conduct, effective April 21, 2026. This code outlines ethical guidelines for all employees and third parties, emphasizing integrity, anti-corruption, fair competition, and information security. It details responsibilities for the board, audit committee, management, HR, and employees, with provisions for handling violations and ensuring compliance with laws and regulations.

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Zhejiang Xianju Pharmaceutical Co., Ltd. Code of Business Ethics and Conduct

Chapter 1 General Provisions

Article 1 Purpose and Basis This "Code of Business Ethics and Conduct" (hereinafter referred to as the "Code") is the common action guide for all employees of Zhejiang Xianju Pharmaceutical Co., Ltd. (hereinafter referred to as the "Company"), reflecting our basic commitment to integrity, fairness, honesty, and respect. All directors, senior management, employees, and third parties representing the Company in business operations or performing duties shall understand and strictly abide by this Code. The Company uses this Code as the basic standard for measuring whether business conduct meets ethical and compliance requirements. We believe that adhering to the highest ethical standards is not only a legal obligation but also the cornerstone for the Company's long-term prosperity and social respect.

Article 2 Scope of Application This Code applies to all employees of the Company's headquarters and its wholly-owned and controlled subsidiaries (i.e., subsidiaries in which the Company directly or indirectly holds more than 50% of the shares), third parties representing the Company in business operations, and partners who establish business relationships with the Company.

Article 3 Core Values Mission: Your health and happiness, my sincerity and responsibility Purpose: Produce first-class products, dedicate to human health

Article 4 Responsibilities The Board of Directors is responsible for approving the Company's overall policies and basic systems for business ethics, anti-corruption, and anti-commercial bribery, ensuring that policies comply with laws, regulations, and international standards. The Audit Committee, as a special supervisory body under the Board of Directors, guides the Audit Department in conducting special audits and supervises the business ethics performance of all employees and business partners of the Company and its subsidiaries. The General Manager, in accordance with the policies and guidelines determined by the Board of Directors and the Audit Committee, presides over the formulation of specific systems and implementation frameworks for business ethics management. The Human Resources Department is responsible for organizing company-wide training and publicity; the Audit Department is responsible for promoting and supervising the implementation of policies by various departments, establishing a supervision mechanism, regularly inspecting policy implementation, focusing on key areas such as procurement, sales, and finance, and establishing and standardizing the handling of reporting channels. All departments shall strictly follow business ethics policies, regulate the conduct of employees in their departments, proactively identify and prevent ethical risks such as the transfer of benefits; promptly correct and report any violations discovered; and actively cooperate with supervision and inspection, and conscientiously implement rectification requirements. Employees shall strictly abide by business ethics policies, uphold professional ethics of integrity, fairness, and honesty, resolutely resist commercial bribery, unfair competition, disclosure of trade secrets, and other acts; promptly report any violations discovered and actively cooperate with investigations; proactively learn relevant knowledge, and jointly maintain the Company's good business image.

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