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

I. Guiding Principles

China Minsheng Bank (the Bank) abides by the laws and regulations, such as the Law of the People's Republic of China on the People's Bank of China and the Law of the People’s Republic of China on Banking Regulation and Supervision, the internal Party regulations, such as the Regulations on CPC Disciplinary Action, as well as the regulatory policies, such as the Guidelines on the Management of Conduct of Practitioners in Banking Financial Institutions and the Code of Ethics and Standards of Professional Conduct for Banking Practitioners. The Bank adheres to comprehensive and strict governance, promotes the principle of “not daring to corrupt, not being able to corrupt, and not wanting to corrupt”, and adopts a “zero-tolerance” attitude towards bribery and corruption.

II. General Requirements

The Bank explicitly prohibits certain behaviors in its operations and management, and requires all employees, including those at the Head Office, branches in and outside the Chinese mainland and overseas branches, to abide by the bottom lines of compliance in their daily operation and management activities, and not to surpass or violate them, which include but not limited to:

1.It is strictly prohibited to solicit or accept bribes or improper benefits from customers, suppliers, intermediaries, competitors, affiliates, subordinates and other stakeholders in any way. It is strictly prohibited to offer bribes or improper benefits to government agencies or other interested parties.

2.It is strictly prohibited to illegally charge fees from customers. It is strictly prohibited to make verbal or written agreement with customers on benefit or loss sharing.

3.It is strictly prohibited to conduct off-account operations in any forms or set up any forms of off-budget fund.

4.It is strictly prohibited to illegally self-determine remuneration, or distribute excessive allowances, subsidies and bonuses, etc. 

5.It is strictly prohibited to embezzle or steal public funds of the Bank,  utilize funds managed for or provided by customers, or borrow funds from other institutions or individuals related to the exercise of authority to make investment.

6.It is strictly prohibited to illegally disclose insider information either explicitly or implicitly. It is strictly prohibited to use insider information for personal gain, or to provide investment or financial advice to others based on such information.

7.It is strictly prohibited to run businesses or to facilitate business for spouses, children, relatives and friends.

III. Focused Positions and Areas

(1) Management personnel

China Minsheng Bank has formulated the Regulations on Clean Practices of Management Personnel of China Minsheng Bank, which requires the management personnel at all levels to strictly abide by the codes of conduct and professional ethics of banking practitioners, perform their duties in accordance with laws, conduct clean practices, stay honest and trustworthy, and separate public from private affairs to effectively safeguard the interests of the state and the bank, and the legitimate rights and interests of all employees, including but not limited to: Management personnels shall not take advantage of their positions to violate decision-making principles and procedures when making significant decisions, important personnel appointments and removals, major project arrangements, or large-scale fund operations; Management personnel shall not use their positions to accept or solicit material benefits from the  related companies of the Bank, the enterprises having business relations with the Bank, and the management and service targets of the Bank.

(2) Appointments and removals of Personnel

China Minsheng Bank has established the management systems such as duty performance recusals, specifying the requirements for post and business recusals. Any violations of regulations in recruitment, deployment, appointment and removal, performance evaluation, compensation and benefits management shall be held accountable in accordance with relevant internal regulations. These measures fully ensure that the employees perform their duties in a fair and equitable manner, and effectively prevent conflicts of interest and potential risks.

(3) Suppliers (Procurement)

China Minsheng Bank has established and continuously improved its procurement management policies and the authorization management system. The Bank has set up centralized procurement management committees at various levels to make collective decisions on centralized procurement within their scope of authorities. The Bank has also formulated the Regulations on Clean Practices of Procurement Personnel of China Minsheng Bank to strictly prevent integrity risks in the field of procurement. The following behaviors of employees are strictly prohibited:

1.Taking advantage of their position to actively accept cash, negotiable securities, or other gifts from stakeholders. If such items were received passively, they must be returned or submitted to the Bank within two working days if returning is not feasible. 

2.Participating in banquets, tours, fitness or entertainment activities provided by stakeholders.

3.Requesting stakeholders to reimburse personal expenses or accepting items under the guise of keeping or trying samples.

4.Accepting or using for free properties such as vehicles, communication devices, computers, houses, land, etc. provided by stakeholders.

5.Purchasing goods from stakeholders at a price significantly lower than the market price or selling items to stakeholders at a price significantly higher than market price.

6.Seeking personal benefits by taking advantage of insider information provided by stakeholders or obtained during the procurement process.

7.Receiving properties or facilities from stakeholders after job rotation or resignation before or after taking advantage of their positions to seek benefits for stakeholders,.

8.Requesting or accepting work-related care or assistance from stakeholders for personal purpose or for relatives and friends.

9.Engaging in other behaviors for the purpose of seeking personal benefits that affect the principles of openness, fairness, impartiality, integrity, honesty and efficiency of procurement .

(4) Main businesses

China Minsheng Bank continues to improve its internal control and compliance system, implements the "three lines of defense" mechanism, and requires employees to strictly abide by the following requirements, including but not limited to:

1.It is strictly prohibited to use false information or acquiesce, participate in or support customers to use false information to defraud or extract funds from the Bank.

2.It is strictly prohibited to access, approve and grant credit in violation of regulatory policies and the credit policies of the Bank (except for explicitly permitted exceptions).

3.It is strictly prohibited to approve secured loans to related parties under more favorable terms than those for other customers.

4.It is strictly prohibited to borrow or embezzle customer loans.

5.It is strictly prohibited to acquiesce, participate in or support the illegal use of credit funds by customers in areas restricted or prohibited by the government or the Bank, such as stock and real estate markets, or for other unauthorized purposes.

(5) Charitable donations

China Minsheng Bank adheres to laws, regulations and relevant provisions in making external donations, which focus on supporting featured projects in rural revitalization,  assistance to the vulnerable group and those in difficulties, cultural heritage, healthcare, environmental protection and disaster relief, etc. Charitable donations follow strict approval procedures and implementation protocols. The Bank regularly inquires with the donee about the use and management of donations, and provides opinions and suggestions. The donee shall use the donations in accordance with the purpose agreed upon in the agreement and shall not change the nature or purpose of the donations without authorization. If the donee violates the usage agreed upon in the agreement and misuses the donations, the Bank has the right to request corrections, and file a complaint or report to the civil affairs departments, or file a lawsuit with the people’s court in case the correction is refused.

IV. Management Mechanisms

(1) Organizational guarantees

The Bank continues to strengthen the supervision on accountability management, gives full play to the responsibilities and roles of the accountability committees at all levels. In compliance with the Disciplinary Measures of China Minsheng Bank on Staff Violations, these committees rigorously investigate and address violations and misconduct. Those who violates the criminal law will be transferred to the public security organs for legal action in accordance with the law. 

(2) Clean culture education

The Bank attaches great importance to clean culture cultivation and the enhancement of employees’ awareness of clean practices and self-discipline, and continues to improve the mechanism for investigating and dealing with violations of regulations and disciplines, urging employees to abide by laws, regulations and disciplines.

(3) Employee behavior management

China Minsheng Bank has established a system of employee behavior management. The Board of Directors has guided the formulation of the  Code of Conduct for Employees of China Minsheng Bank (Revised), supervises the implementation, and listens to the evaluation reports on employee conduct on an annual basis. The Bank has formulated the Supervision and Management Measures for Abnormal Behavior of Employees of China Minsheng Bank, to timely keep abreast of the thoughts and behaviors of employees, provide timely relief and guidance for abnormal thoughts or actions, and provide timely corrections and controls for abnormal behaviors. The aim is to enhance moral risk prevention, enabling the detection and elimination of disciplinary violations or job-related crimes in the early stages.

(4) Whistleblower protection and complaints handling (Impeachment and accusation) 

China Minsheng Bank receives complaints and tip-offs through public channels, such as telephone and emails. The discipline inspection committees at various levels handle the cases in accordance with their respective authorities. The Bank has formulated and released the Working Measures on Supervision and Discipline Execution by Discipline Inspection and Supervision Institutions of China Minsheng Banking Corporation Limited (Trial) and the Working Measures on Verification and Notification of Real-Name Complaints and Accusations within the Discipline Inspection and Supervision System of China Minsheng Banking Corporation Limited (Trial), which defined the detailed and comprehensive provisions for the discipline inspection committees at all levels to smooth up reporting channels, standardize reporting procedures, and safeguard the rights and interests of whistleblowers.The discipline inspection committees at all levels have made public the postal addresses, addresses for visits, telephone numbers, e-mail addresses and other diversified channels for complaint and tip-off reporting, to promptly receive relevant impeachment and accusation.