Ethical Corporate Management ｜ Sinyi Realty Inc. ｜ Investor Relations

Facts about the Company’s Performance in Ethical Corporate Management

The Company establishes “Corporate Ethics Office” which is responsible for the promotion of ethical corporate management.  The Corporate Ethics Officer ensures the actualization of operation principles of good faith in accordance with the work functions and scope of supervising related matters of each sector and promotes to all colleagues the operation concepts of justice ahead of profit, human oriented and positive thinking and actively constructs and develops a methodology which can absorb its operation concepts to make all colleagues easy to understand and carry them out in daily life.  In addition, the Company conducts several monthly topic discussions and actions such as change management and value-created services and by means of analyzing and sharing at each meeting at all levels to make colleagues be honest internalization and implementation in the daily operation.  In December, 2023, the Corporate Ethics Office reported the plan and performance of promoting ethical corporate management at the BOD.

Every month, the founder of the Company instructs the concept of honesty and trustworthiness in our online meeting. The concept will be proclaimed by the comic works in ordinary time to arise employers’ alertness.　A total of 12 sessions, about 5 hours.

Every month, each business unit will arrange the Ethical study group to discuss the concept proposed by the founder.

The Ethical division will periodically podcast the spirit of「Guidelines for the Adoption of Codes of Ethical Conduct for Directors and Managerial Officers」：our priority「treat our client honestly」

TEM will guide the management level during the management meeting and the branch store leader meeting monthly. The supervisors will guide the employees in daily morning meetings.

The training team will infuse the Sinyi corporate vision into our internal training courses and broadcast learning materials which include a one-hour lesson of more than 25 fresh persons at the amount of 30 courses a year.

Standard Procedures of Offense Reporting and a Related Confidentiality Mechanism

The Company has established an offense report (such as "Regulations on whistle-blowing of illegal and unethical or dishonest conduct"), for each complaint or offense report shall assign exclusive personnel to be in charge, through different procedures in response to the nature of a case. It would be assigned to the related departments for action or an evaluation committee meeting would be convened, and a response is requested to be replied to the complaint filing party or offense reporting party within a specified period. In case of a major event, it shall be submitted to Corporate Ethics Office or the Board Chairperson. During the disposition process, the information of both a complaint filing party and offense reporting party shall be kept confidential; it is limited to be accessed only by the exclusive handling personnel.

Since the information of a complaint filing party and offense reporting party for a complaint or offense report shall be strictly kept confidential, in case complaint filing party and offense reporting party is a company colleague, upon filing a complaint or report, he/she may choose to be kept confidential or open out of the free will. After it is accepted by exclusive personnel on a project basis and through related procedures and disposition, due management and follow-up shall be filed, to ensure such a party to be free from suffering any improper disposition.

Prohibition of Insiders’ gains from the internal unpublished information

• Since October 2020, the Company has set up on intranet an automatic pop-up notice of "internal material information-related publicity matters", including internal material information definitions, confidential operations, penalties for insider trading violations, and treatment methods to achieve the effectiveness of educational advocacy. In 2023, there were about 74 insiders to read and confirm item by item.
• We conduct education and publicity on "Internal Significant Information Handling Procedures" and relevant laws for directors, managers and employees at least once a year, and provide training sessions for new directors, managers and employees within 2 months after being on board.　In December 2022, the board of directors resolved the proposal to revise the procedure to improve the quality of relevant works.
• From time to time, we will inform all insiders of the "Common Cases of Insider Shareholding Changes Claiming to Violate the Securities and Exchange Law" and "Insider Equity Transaction Questions and Answers" to avoid violating relevant securities laws and regulations.

Other implemented practices

• Random checks conduction

• In cases of legal doubts regarding the newly established business services or behavior, each department shall file an application to the Legal Compliance Office for review on a case-by-case basis and provide legal compliance opinions.