Hymson Overseas Local Reception Policy

Hymson attaches great importance to its compliance situation and firmly opposes any form of corruption and bribery. Due to the inevitable involvement of receiving external personnel in the process of expanding overseas business and territory, in order to standardize employee reception behavior and ensure that employee behavior complies with applicable anti-corruption and anti-bribery laws and regulations, Hymson has formulated this Hymson Overseas Local Reception Policy (hereinafter referred to as the "Local Reception Policy").

This Local Reception Policy applies to all employees of Hymson Laser Technology Group Co., Ltd. and its domestic and foreign subsidiaries, affiliated companies, and various branches (hereinafter collectively referred to as "Hymson"), as well as individuals acting on behalf of the Company, including all directors, senior executives, full-time employees, part-time employees, consultants, outsourcing, interns, laborers, dispatched/dispatched personnel, agents of Hymson Group, and other personnel acting on behalf of the Company (hereinafter collectively referred to as "relevant entities"). All relevant entities shall abide by and maintain the anti-corruption and anti-bribery policies formulated by Hymson. If this Local Reception Policy is inconsistent with local laws and regulations, the more stringent requirements shall prevail.

The "reception" behavior referred to in the Local Reception Policy includes but is not limited to business banquets, gift giving, providing gift cards, phone cards, and reimbursing travel expenses. If unsure whether it constitutes reception, please consult with the superior department leader or the Legal Compliance Department in a timely manner.

Reception Behavior  

Hymson understands that appropriate reception can help establish and maintain good business cooperation relationships. However, as such behavior is prone to crossing boundaries and constituting ribery, Hymson requires relevant entities to make a preliminary assessment of the risks of such reception behavior from four dimensions: "reception purpose, reception object, reception items, and reception scenario" before receiving any external personnel. If it is not clearly defined as not requiring approval in the following text, as long as there are still doubts about the compliance of such reception behavior in any dimension after analysis, or if the amount involved exceeds the amount listed in the "Reception Items-Reference Limit" section of this Local Reception Policy, it shall be reported to the [Superior Supervisory Department and the Legal Compliance Department] for approval and relevant records shall be kept.

I.   Banquets and hospitality

Reception purpose: Banquets and hospitality shall not be provided for the purpose of influencing a decision or seeking other improper benefits. It is particularly important to note that regardless of the true purpose, if such banquets and hospitality are provided in large amounts, on a continuous basis, for luxurious banquets provided to public officials, or in high-end consumer venues, there is a possibility of being considered or reasonably suspected of being able to influence the decision of the receiving Party and being suspected of bribery. Generally, banquets and hospitality shall not be provided to a single recipient more than once a month, unless it is a situation of continuous on-site presence during business cooperation such as visits and research.

Reception object: Whether the objects of banquets and hospitality have any conflicts of interest with the Company, whether they are received by an employee of the Company's partner without the knowledge or consent of their leader, and whether they are public officials related to the Company's past business Projects (such as those that have been approved or permitted by the Company), whether they are public officials related to the Company's current business Projects (such as supervising or verifying a certain business carried out by the Company), whether they are public officials related to the business Projects that the Company is preparing to carry out (such as requiring their approval or permission to carry out business), etc.

Reception items: Whether it involves external high-end hotels or entertainment venues, etc. For specific amounts, please refer to the "Reception Items - Reference Limit" section of this Local Reception Policy.

Reception scenario: Not at any critical Project nodes such as bidding, order signing, etc. (hereinafter referred to as "sensitive nodes"), and with appropriate Company representatives present. Not violating the relevant terms of the Contract signed with the other Party's Company.

II.    Gifts

Reception purpose: Gifts shall not be provided for the purpose of influencing a decision or seeking other improper benefits. It is particularly important to note that regardless of the true purpose, if the gift is very expensive or continues to provide some ordinary item, there is a possibility of being considered or reasonably suspected of being able to influence the decision of the receiving Party and being suspected of bribery.

Reception object: Whether the intended objects of gifts have any conflicts of interest with the Company, whether they are received by an employee of the Company's partner without the knowledge or consent of their leader, and whether they are public officials related to the Company's past business Projects (such as those that have been approved or permitted by the Company), whether they are public officials related to the Company's current business Projects (such as supervising or verifying a certain business carried out by the Company), whether they are public officials related to the business Projects that the Company is preparing to carry out (such as requiring their approval or permission to carry out business), etc.

Reception items: Gifts include any small gifts, electronic devices, tobacco and alcohol, luxury goods, phone cards, meal vouchers, and any valuable thing. Reception items shall bear the Company logo and the amount involved shall be lower than the amount listed in the "Reception Items - Reference Limit" section of this Local Reception Policy. In addition, Hymson strictly prohibits providing cash or cash equivalents to public officials or any other recipients.

Reception scenario: Not at any critical Project nodes such as bidding, order signing, etc. (hereinafter referred to as "sensitive nodes"). Not violating the relevant terms of the Contract signed with the other Party's Company.

III.    Travel

Reception purpose: The purpose of such external personnel's travel shall be for reasonable commercial purposes such as attending Company business meetings, visiting equipment, learning business, promotion, conducting relevant research or due diligence, and cannot provide any form of sponsorship or reimbursement for the travel expenses of such external personnel without legitimate purposes. Generally, sponsorship of travel expenses shall not be provided to a single recipient more than once a month.

Reception object: Whether the intended objects of travel sponsorship have any conflicts of interest with the Company, whether they are received by an employee of the Company's partner without the knowledge or consent of their leader, and whether they are public officials related to the Company's past business Projects (such as those that have been approved or permitted by the Company), whether they are public officials related to the Company's current business Projects (such as supervising or verifying a certain business carried out by the Company), whether they are public officials related to the business Projects that the Company is preparing to carry out (such as requiring their approval or permission to carry out business), etc. Do not bear the travel expenses of colleagues who are not related to commercial purposes.

Reception items: The so-called valuable thing also include travel expenses, and the Company can only pay reasonable expenses that are actually incurred and directly related to the business purpose of the travel. All reimbursement of travel expenses shall be based on the provision of relevant valid receipts by external personnel, and sponsorship for their travel shall not be provided in the form of advance payment for external personnel. As for the reimbursement of travel expenses, regardless of the amount, it must be reviewed by the Company's [Finance Department].

Reception scenario: Not at any critical Project nodes such as bidding, order signing, etc. (hereinafter referred to as "sensitive nodes"). Not violating the relevant terms of the Contract signed with the other Party's Company.

Consultation and Reporting

All employees of Hymson and other Third Party related personnel shall comply with applicable anti-corruption and anti-bribery laws and regulations, as well as this Hymson anti-corruption compliance policy. Those who fail to comply with this anti-corruption compliance policy will be punished in accordance with the Company's regulations and policies, such as the Management Measures for Punishment of Employee Violations. Severe cases may include termination of employment, deduction of all bonuses, severe warnings, and termination of business relationships.

If you have any questions about this anti-corruption compliance policy, please feel free to consult the [Supervision Department] through email.

   Report mailbox:jubao@hymson.com  

   Special report telephone number:+86-0755-28197985-8118   


Report mailbox: jubao@hymson.comSpecial report telephone number:+86-0755-28197985-8118  If you find anyone who is suspected or has violated this policy, please report it through the following channels:Hymson will take it seriously and conduct necessary investigations into the relevant reports. Hymson welcomes and encourages anyone to actively report illegal and disciplinary behavior, and will strictly keep the identity of the informant confidential. No one is allowed to threaten or retaliate against those who report potential compliance issues in good faith.