|
Sirdon Business Ethics and Conduct Policy
Introduction
This code of Business Ethics and Conduct Policy covers a wide range of practices. It does not cover every issue that may arise, but it sets our basic principles to guide all employees and directors of the company. All of our employees and directors of the company must conduct themselves accordingly and seek to avoid even the appearance of improper behavior. The code should also be provided to and followed by the company's agents and representatives and, including consultants.
Those who violate the standards in this Code will be subject to disciplinary action.
1. Compliance with Laws, Rules, and Regulations
Obeying the law, both in letter or spirit, is the foundation on which Sirdon's ethic standards are built. Any employees and directors should respect and obey the laws of the cities, states, countries in which we operate.
2. Conflicts of Interest
A "conflict of interest" exists when a person's private interest interferes in any way with the company's interests. Conflicts of interest are prohibited by the company. Any employee or director should be conscious of a conflict or a potential conflict.
3. Insider Trading
Employees and directors who have access to confidential information are not permitted to use or share that information for stock trading purposes or any other purpose except the conduct of our business.
4. Corporate Opportunities
Employees and directors are prohibited from taking for themselves personally opportunities that discovered through the use of corporate property, information or position without the consent of board.
5. Competition and Fair Dealing
Sirdon seek to outperform our competition fairly and honestly. Each employee should endeavor to respect the rights of and deal fairly with the company's customers, suppliers and competitors. No employee should take unfair advantage of anyone through manipulation, concealment, or any other intentional unfair-dealing practices.
6. Discrimination and Harassment
The diversity of the company's employees and directors is a tremendous asset. Sirdon are firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. Examples include derogatory comments based on racial or ethnic characteristics and unwelcome sexual advances.
7. Health and Safety
Sirdon strives to provide each employee with a safe and healthful work environment. Violence and threatening behavior are not permitted. Employees should report to work in condition to perform their duties, free from the influence of illegal drugs or alcohol.
8. Record-keeping
Sirdon requires honest and accurate recording and keeping of information in order to make responsible business decisions. For example, only the true and actual numbers of hours worked should be reported.
9. Confidentiality
Employees and directors should maintain the confidentiality of confidential information entrusted to them by the company or its customers. Confidential information includes: non-public information that maybe of use to competitors, or harmful to the company or its customers, if disclosed. It also includes: information that suppliers and customers have entrusted to us. The obligation to preserve confidential information continues even after employment or directorship terminates.
10. Protection and Proper Use of Company Assets
All employees and directors should endeavor to protect the company's assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on the company's profitability. Any suspected incident of fraud or theft should be immediately reported for investigation. Company equipment should not be used for non-company business, though incidental personal use may be permitted.
11. Payments to Government Personnel
The Chinese Foreign Corrupt Practices Act prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates.
12. Anti-malfeasance Law
Sirdon has established relevant regulations to guide its commercial actions according the National Anti-malfeasance Law.
13. Commercial Cooperation
Sirdon strictly comply with the Chinese economic transaction law and to undertake its commercial cooperation with others.
14. Reporting any Illegal and Unethical Behavior
Employees and directors are encouraged to talk supervisors, managers, Sirdon Ethics Office or other appropriate personnel about illegal and unethical behavior. It is the Sirdon's policy not to allow retaliation for reports of misconduct by others in good faith. Employees are expected to cooperate in internal investigation of misconduct.
15. Compliance Procedures
We must all work to ensure prompt and consistent action against the violations of this code. However, in some situations it is difficult to know right from wrong. Since we cannot anticipate every situation that will arise, it is very important that we have a way to approach a new question or problem. There are steps the employees should keep in mind:
• Make sure you have all the facts.
• Ask you self: what specifically am I being asked to do? Does it seem unethical or improper?
• Classify your responsibility and role.
• Discuss the question with your supervisor.
• Seek help from company resources.
• You may report ethical violations in confidence and without fear of retaliation.
16. Provisions applicable to the Principal Executive Officer and to Senior Financial Officers
The Principal Executive Officer and to Senior Financial Officers of the company are responsible for full, accurate, timely and understandable disclosure in periodic reports required to be filed by the company. As a result, the Principal Executive Officer and to Senior Financial Officers are subject to the following procedures:
• The Principal Executive Officer and to Senior Financial Officers shall promptly bring into the attention of the internal disclosure committee.
• The Principal Executive Officer and to Senior Financial Officers shall promptly bring into the attention of the Chief Ethnic Officer.
17. Waivers
Every effort will be made to resolve potential conflicts of interest or other ethnic code situations when these are disclosed promptly to management. All such waivers must be approved in advance by the board.
18. Employ Complaint Procedures
All employees of the company may submit a good faith complaint to the management of the company without a fear of dismissal or retaliation of any kind. In order to facilitate the reporting of employee complaints, the company has established the following procedures:
Receipt of Employee Complaints:
• Employee with concerns may report their concerns to Sirdon's Ethnic Office
Scope of Matters:
• fraud or deliberate error in the preparation, evaluation, or audit of any financial statement of the company;
• misrepresentation of the financial report;
• deficiencies in or noncompliance with Sirdon's internal accounting controls;
• deviation from the company's finance reporting principle;
Treat of Complaints:
• Upon receipt of a complaint, Sirdon Ethnic Office will determine whether the complaint actually pertains to relevant regulations;
• Sirdon Ethnic Office will always maintain a log of all complaints.
|
