Beijing Quanshi World Online Network Information Co.Ltd(002995)
Anti fraud and reporting system
April, 2002
Chapter I General Provisions
1 Purpose
In order to strengthen the internal control of Beijing Quanshi World Online Network Information Co.Ltd(002995) (hereinafter referred to as "the company"), standardize the behavior of the company's employees, reduce the company's business risks, safeguard the legitimate rights and interests of the company and shareholders, and ensure the realization of the company's business objectives and the sustainable and stable development of the company, This system is formulated in accordance with the requirements of laws, administrative regulations, departmental rules and normative documents such as the securities law of the people's Republic of China, the guidelines for self discipline supervision of listed companies of Shenzhen Stock Exchange No. 1 - standardized operation of listed companies on the main board, the basic norms of enterprise internal control, the company law, the Audit Law of the people's Republic of China and the actual situation of the company.
The purpose of anti fraud work is to standardize the professional behavior of all employees of the company, strictly abide by relevant laws and regulations, industry norms, professional ethics and the company's rules and regulations, establish a good atmosphere of honesty, diligence and dedication, and prevent acts damaging the interests of the company and shareholders.
2 scope of application
This system is applicable to Beijing Quanshi World Online Network Information Co.Ltd(002995) and all subordinate subsidiaries.
3 definition
3.1 The term "fraud" in this system refers to the behavior of internal and external personnel of the company to seek personal illegitimate interests and damage the legitimate economic interests of the company by means of deception, concealment and other illegal means; Or seek improper economic benefits of the company and may bring improper benefits to individuals.
3.2 the management referred to in this system includes: senior management.
Chapter II anti fraud organizational structure and responsibilities
4. Board of directors
4.1 the board of directors is responsible for urging the management to establish a company wide anti fraud cultural environment and establish and improve the internal control system including fraud prevention, receiving reports and investigation and handling;
4.2 the board of directors authorizes the audit committee of the board of directors to guide the anti fraud work of the company.
5 Audit Committee of the board of directors
The audit committee of the board of directors is the main body responsible for the company's anti fraud work, which is responsible for guiding the internal audit department to carry out anti fraud work and continuously supervising the anti fraud work.
6 management
6.1 the management is responsible for establishing and improving the internal control mechanism including fraud prevention;
6.2 the management is responsible for implementing control measures to reduce the chance of fraud, taking appropriate and effective remedial measures for fraud, and conducting self-assessment.
7 internal audit department
7.1 the internal audit department is the responsible department for anti fraud of the company;
7.2 the internal audit department is responsible for the formulation and modification of the company's anti fraud related systems, and assisting the company's management to establish and improve the anti fraud mechanism;
7.3 the internal audit department is responsible for managing the reporting telephone and e-mail of fraud cases, receiving the company's fraud complaints and reporting clues, and responding and following up;
7.4 the internal audit department is responsible for organizing the company's anti fraud investigation and establishing an anti fraud investigation team;
7.5 the internal audit department is responsible for tracking and handling the fraud events, behaviors, personnel and other information investigated and dealt with.
8. Principals of business groups, branches and subsidiaries
8.1 the person in charge of each business group, branch and subsidiary is the first responsible person and counterpart of the anti fraud work of each department and branch and subsidiary, and is responsible for carrying out the anti fraud work within the Department;
8.2 the principals of all business groups, branches and subsidiaries are responsible for cooperating and assisting the anti fraud investigation team in its work; 8.3 heads of business groups, branches and subsidiaries are responsible for self inspection and self correction of corruption in their own departments.
9 legal department
9.1 the legal department is responsible for reviewing the cases and evidence materials handed over by the fraud investigation team;
9.2 the legal department is responsible for transferring the fraud cases that meet the filing conditions to the judicial organ;
9.3 the legal department is responsible for bringing legal proceedings against the persons involved on behalf of the company.
10 Finance Department
10.1 The finance department is responsible for handing over the clues of fraud found in financial management activities to the internal audit department in time; 10.2 the finance department is responsible for freezing all expenses paid by the person responsible for the fraud case before the case is closed;
10.3 the finance department shall assist in recovering the economic compensation for fraud cases.
11 human resources department
11.1 the human resources department is responsible for taking disciplinary actions against all personnel involved in fraud cases;
11.2 the human resources department is responsible for handling the labor relations, salary and labor remuneration of fraudsters.
Chapter III specific contents
12 forms of fraud
12.1 fraud
12.1.1 disclosure of secrets. Employees steal or attempt to steal the company's secrets or deliberately disclose the company's business information.
12.1.2 accepting bribes. Employees and their stakeholders (including but not limited to immediate family members) accept bribes, loans and other benefits from affiliated enterprises, suppliers, subordinate channels and customers.
12.1.3 counterfeiting. Employees who take advantage of their position to seek private interests, including but not limited to misappropriating channels or customers' account period quota, forging or changing false materials, helping channels or customers obtain high account period quota or high return policy, providing false cooperation information, forging or assisting in forging false certificates and materials, etc.
12.1.4 non competition restrictions. Engage in business and management activities that compete with the company without authorization, including but not limited to self-supporting or participating in the business that competes with the company during the employment period.
12.1.5 misappropriation of property. Misappropriate, embezzle and misappropriate the company's assets without authorization or by other illegal means to seek improper interests, including but not limited to requiring customers to make money for private use and misappropriate the company's assets for private use. 12.1.6 collusion and fraud. Internal and external collusion between employees, between employees and customers, between channels and suppliers, including but not limited to abnormal renewal, new opening and abnormal return of customers.
12.1.7 deliberately concealing transactions. Including but not limited to recognizing after-sales refund as income, recognizing income in advance, false shipment, fictitious order, fictitious sales volume, fictitious market activity, fictitious increase of personnel, false declaration of employee salary, etc.
12.1.8 expenses incurred for improper purposes, such as paying bribes or kickbacks;
12.1.9 take advantage of his position to transfer the company's trading opportunities or trading items that can be expected to make profits to other individuals or companies;
12.1.10 taking advantage of his position to ask for other people's property or illegally accept other people's property;
12.1. Use of petty accounts other than official accounts;
12.1.12 other fraudulent acts that damage the economic interests of the company.
12.1.13 false records, misleading statements or major omissions in financial and accounting reports and information disclosure.
12.1.15 abuse of power by directors, supervisors, managers and other senior managers.
12.2 serious violation of relevant regulations of the company (deemed as fraud)
12.2.1 failure to report to the company and interest avoidance due to the following behaviors:
The employee's close relatives work in the company;
Employees themselves or their close relatives participate in the operation of the company's products;
I or my close relatives have economic contacts with the channel provider or the close relatives of the channel provider;
I or my close relatives become a partner of the company's channel provider or entrust others to act as the company's channel provider in the name of others (I am the actual controller or behind the scenes boss);
I or my close relatives directly or indirectly invest in or participate in the company's channel providers;
12.2.2 the employee or his close relatives have economic contacts with the company's suppliers, regional partners, channel providers or their close relatives, but fail to report or avoid interests in the company;
12.2.3 privately engrave the seals of the company and its management personnel, and forge company and department documents or reports;
12.2.4 forge or falsely report annual and semi annual performance data or annual bonus data;
12.2.5 forging, altering, destroying or hiding accounting records or vouchers;
12.2.6 make up facts or conceal the truth to make the company pay for false transactions;
12.2.7 deliberately reporting wrong transactions or recording false transactions;
12.2.8 purchase and sale of non-existent (untrue) assets;
12.2.9 failure to strictly perform the contract, resulting in economic losses to the company or significant negative impact on the company's reputation;
12.2.10 falsely issuing invoices, falsely increasing the invoice amount and fictitious reimbursement matters; Illegal reimbursement (reimbursement is not within the scope specified by the company);
12.2.11 I work part-time in other enterprises and institutions without the approval of the company;
12.2.12 other serious violations (including but not limited to illegal operations).
13 authority of anti fraud investigators
13.1 the so-called investigation personnel, internal auditors or other authorized personnel of the board of directors refer to:
13.1.1 have the right to inspect the inspected department, its annual plan, monthly plan, contract agreement, accounting vouchers, account books, accounting statements, meeting minutes, documents, invoices and other paper and electronic materials, licenses, assets and other inspected matters on site; Check cash, bills, fixed assets and other assets; Have the right to copy, take photos on site and archive relevant documents and materials;
13.1.2 have the right to take measures to investigate the responsibilities of relevant personnel and stop their acts of damaging the company in case of obstructing anti fraud investigation, refusing to provide materials, or seriously damaging the interests of the company, violating financial laws and disciplines and serious waste;
13.1.3 meritorious persons who accuse or report major corruption cases may apply for awards in accordance with relevant regulations. 14 reporting and investigation of fraud cases
14.1 the internal audit department is responsible for establishing the e-mail for reporting professional ethics issues and fraud cases, publishing the e-mail for reporting on the company's website, and filing the report materials of fraud cases after reporting, investigation and handling in a timely manner.
14.2 the company's internal employees and external related personnel can report the company's internal employees or related fraud cases through e-mail, including complaints and reporting information about the violation of professional ethics by the company and its personnel. Report Mailbox: [email protected].
14.3 the company encourages and advocates the real name system for reporting. The informant shall inform the informant's name, department and the specific circumstances and evidence of violation of discipline (such as the time, event, amount, operation mode and relevant personnel involved in violation of discipline) in order to investigate and deal with it in a timely and rapid manner. In principle, the internal audit department of the company gives priority to the real name system and reports with evidence or clear clues;
The internal audit department of the company will not accept complaints and reports of no evidence, no facts, speculation, hearsay, nonsense and malicious retaliation;
The internal audit department of the company is responsible for opening and registering the telephone, letter, e-mail and other reporting materials one by one, evaluating and accepting them in time, and providing a reply to the informant within 10 working days;
The company has formal complaint reporting channels and does not accept complaints and reports through mass email, mass wechat, QQ group, microblog, etc.
14.4 after accepting the report of fraud cases, the internal audit department of the company shall carry out work according to the position or position of the informant, the reported fraud events and the severity of the circumstances, and in accordance with the following provisions:
14.4.1 for the real name report of non senior managers, the internal audit department of the company shall handle the relevant registration and investigate the incident according to the regulations after receiving the report, establish an anti fraud investigation team, and report the investigation results to the management or the audit committee of the board of directors for incident evaluation. For anonymous reports from non senior managers, the internal audit department shall register and preliminarily evaluate them, and decide whether to report them to the company's management or the audit committee of the board of directors.
14.4.2 for the real name reports involving directors, supervisors or senior managers of the company, after receiving the reports, the internal audit department of the company shall not only handle relevant registration, but also report to the audit committee of the board of directors and the chairman of the board of directors at the first time. After the audit Committee of the board of directors decides to further investigate the incident, the internal audit department and the managers of relevant departments shall jointly form a special investigation team for joint investigation, External experts can also be hired as needed to participate in and assist in the investigation, and the investigation results shall be reported to the board of directors for event evaluation.
14.4.3 if the report involves the personnel of the internal audit department, it can be reported directly to the audit committee of the board of directors or the chairman of the company.
14.5 if the anti fraud staff has an interest in the event handled by themselves or their relatives, they shall take the initiative to withdraw.
14.6 after the investigation of fraud, the anti fraud Department of the company shall timely submit a written investigation report to the management or the board of directors and the audit committee. The investigation report of a fraud case shall include the acceptance time of the reported fraud event, the composition of investigators, the investigation and verification of the event, the conclusion on whether it is true, and the handling suggestions for relevant personnel. If there is relevant evidence, evidence or testimony, it shall be indicated in the appendix of the investigation report of fraud cases.
14.7 for real name reporting, the internal audit department of the company shall feed back the investigation results to the informant regardless of whether the investigation is initiated or not.
14.8 complainants and informants shall be protected in assisting in the investigation. The company prohibits any illegal discrimination or retaliation, or hostile measures against employees involved in the investigation. Those who disclose informants' information in violation of regulations or retaliate against informants will be dismissed and their labor contracts will be terminated. Those who violate the law shall be transferred to the judicial organ for handling according to law.
14.9 staff members who receive reports and complaints or participate in fraud investigation shall not provide relevant information and contents of the complainants to any department and individual without authorization; If it is really necessary to consult the relevant materials of complaints and reports due to work, it shall be authorized by the company's management. The consulting personnel must register the contents, time and relevant information of the Consulting Personnel in the internal audit department.
15. Reward standard for reporting
15.1 if the amount of economic loss recovered is less than 10000 yuan (excluding), 10% of the actual amount of economic loss recovered shall be rewarded, and the reward amount shall not be less than 500 yuan;
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