COMPLIANCE AND ANTI-BRIBERY POLICY
Company Overview
China Three Gorges (Europe) S.A. (hereinafter referred to as “the Company”) concentrates on investment and development in the global clean energy sector, contributes to the promotion of green development, addresses climate change, and assists green transformation of global energy.
Compliance Management
The Company shall always adhere to the compliance management concept of “integrate business with compliance, all staff actively participate in compliance, create value through compliance”, strive to strengthen the construction of the compliance management system, specify and implement the responsibilities of the principal person in charge of the Company to assume the responsibility for the development and promotion of compliance. The Chief Compliance Officer shall lead the compliance management department to carry out the relevant work and guide the subordinate units to enhance compliance management. The Company will spare no efforts to establish the compliance performance mechanism under which the compliance management department shall take the lead. All departments of the Company and companies in different regions shall work together and manage jointly. In accordance with the principle of objective and independent compliance governance, the compliance management department will not be interfered by any other department or personnel in the performance of its compliance (including anti-bribery compliance) duties and has the right to report directly to the Board of Directors and its committee. In combination with the development strategy, compliance, and anti-bribery guidelines, the Company shall set compliance goals (including anti-bribery goals) covering all areas of business. It shall continue to invest compliance resources to upgrade the compliance management and anti-bribery management systems on a consistent basis.
Compliance and Anti-bribery Values
The Company hereby solemnly pledges that the Company and all its employees shall behave in conformity with the following compliance and anti-bribery values:
Comply with applicable laws and regulations, regulatory requirements, industry norms, business rules, ethical standards, international standards (including international compliance and anti-bribery management system standards), as well as stakeholder requirements such as the Articles of Association, relevant rules and regulations, and signed compliance commitments.
Comply with applicable anti-bribery laws and regulations, practice with integrity, and eliminate any forms of corruption and bribery.
Carry out fair competition, protect and respect the intellectual property rights, trade secrets, and other intangible property of the Company and its partners, and prevent infringement from others; use and preserve the Company’s assets properly and cautiously; oppose monopolistic conducts.
Pay taxes in accordance with laws and ensure the truthfulness, accuracy and integrity of the Company’s financial situation; regulate the payment of funds and transactions and avoid any transactions with counterparties suspected of terrorist activities or money laundering.
Strengthen the construction of cyber-security and data protection systems, respect and protect personal privacy, carry out cyber security risk assessment, and enhance employees’ awareness of cyber security and data protection.
Safeguard the legitimate rights and interests of employees, and oppose any form of discrimination, harassment or unprofessional conducts.
Establish and effectively operate a quality management and safety production management system, implement quality management and safety production responsibilities; adhere to the concept of green development, strengthen the whole process of environmental protection, and promote green and low-carbon development.
Employee Responsibilities
All directors, executives, employees, and contractors of the Company must comply with all applicable compliance management and anti-bribery laws and regulations as well as all policies and procedures promulgated by the Company to ensure compliance. Under no circumstances will activities be allowed to be made contrary to applicable compliance management and anti-bribery laws and regulations by any employee or individual and entity on behalf of the Company. The Company executives at all levels are obligated to set an example for compliance and shall rely on their exemplary behaviors and influence to internalize compliance into the team’s responsibilities, making compliance a conscious action for all employees. All executives of the Company shall, within their terms of reference, avoid irregularities. All employees of the Company are responsible for compliance at work. All employees of the Company shall know and abide by applicable laws and regulations, regulatory requirements, compliance commitments made to stakeholders, internal rules, and policies related to their job responsibilities. Employees of the Company must work and go through procedures in strict compliance with the laws and regulations, promptly identify, report, and prevent corresponding compliance risks.
Business Partner Responsibilities
All individuals and entities on behalf of the Company shall comply with all applicable laws and regulations, respond to relevant compliance requirements of the Company, and cooperate with the proper compliance due diligence process in accordance with applicable procedures set by the Company. All individuals and entities on behalf of the Company shall guarantee that all declarations, information, and business statements provided are accurate and truthful and ensure mutual confidentiality of trade secrets and sensitive information. No business partner of the Company is allowed to use non-compliant means to seek benefits for the Company.
Consequences of Violations
Violations of the compliance management and anti-bribery laws and regulations may result in serious consequences for the Company and responsible individuals, including civil liabilities, administrative fines, and even imprisonment, as well as damage to the individual’s and the Company’s reputation. Any director, executive, employee, or contractor found to be in violation of the applicable compliance management and anti-bribery laws and regulations will be subject to disciplinary actions by the Company, up to and including termination of employment, in addition to legal responsibilities; and those who are suspected of committing a crime will be transferred to the judicial authorities for legal action.
Request from the company
Compliance not only protects value, but it also creates value. The Company has been building its value for our customers, employees, and the industry, through the dedication and vigilance to compliance of each employee. We request every employee and stakeholder that has a direct or indirect economic relationship with the Company at all levels to continue to take compliance matters very seriously and report all or potential violations that you identify in a timely manner.
Compliance Reporting Channels
If you want to report any potential violations, or you suspect any irregularity is being committed, communications may be made through the following authorized means:
– External Web Form https://ctgeu.com/whistleblower-channel/
– Internal SharePoint access to the form: https://chinathreegorgeseu.sharepoint.com/
– Via Post, for the attention of the Legal & Compliance department at the following address: Calle del Principe de Vergara 112, 7th Floor, 28001 Madrid, Spain
– By telephone at +34 91 954 63 09.
– In the case of being carried out through this means, you can have a telephone conversation, or be able to leave a message through voicemail that will reach the Company’s Compliance email address
– E-mail: to the e-mail address compliance@ctgeu.com
– A face-to-face meeting within a maximum period of seven days, subject to the documentation requirements set forth in the Whistleblower Channel Action Protocol of the Company
Confidentiality and Protection of Reporters
The Company will adopt practical and effective measures to keep confidential the information on report and reporter of any potential violations. We will also protect and reward employees who report illegal and irregular activities. Any form of discrimination, strike or retaliation will be strictly prohibited.
Suggestions for Improvement
If you have suggestions to improve our compliance management and anti-bribery management system, please contact through the email address compliance@ctgeu.com.
