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Corporate Governance

Business Ethics

Anti-Corruption

Anti-Monopoly and Anti-Unfair Competition

Safety Production Management

Quality Management

Supply Chain Management

Customer Service Management

Compliance Management

Risk Management

Privacy Protection and Information Security

Corporate Governance Structure

As an enterprise committed to long-term value creation, Zhaowei Electromechanical consistently regards sound governance as the core pillar of high-quality development.

Business Ethics

Our Commitments

UN Sustainable Development Goals

SDG 17 – Partnerships for the Goals

The Ten Principles of the UN Global Compact

Principle 10:Businesses should work against corruption in all its forms, including extortion and bribery.

Results & Performance

100%

Business ethics training coverage for Directors, Supervisors, and Senior Executives

100%

Business ethics training coverage for Employees

100%

Business ethics training coverage for Suppliers

Code of Conduct

Guided by the RBA framework, our Code of Conduct, Business Ethics Policy, and Whistleblower Policy set clear ethical standards for all employees and suppliers. Supporting policies on oversight, whistleblowing, anti-corruption, gift acceptance, and confidentiality reinforce our ethics management system.

Anti-Corruption

We conduct annual reviews for key areas (procurement, sales, finance) and bi-annual reviews for others, adjusting plans based on risk and regulatory updates.

We carry out audits and compliance checks across all subsidiaries in line with laws and our internal policies, and continuously improve accordingly. Our comprehensive procedures include:

Zero Tolerance

We adopt a zero-tolerance stance toward corruption. All business activities strictly comply with anti-corruption laws in the jurisdictions where we operate.

Due Diligence

We conduct rigorous screening and verification before establishing business relationships with third parties.

Risk Identification and Response

We regularly identify corruption risks across all business processes and develop differentiated response measures.

Communication and Training

Through tiered training programs, we systematically convey anti-corruption requirements to all.

Monitoring and Improvement

We regularly conduct external and internal audits on the anti-corruption procedures to continuously improve them.

Accountability and Penalties

Any personnel involved in suspected corruption will be thoroughly investigated, and violators will be held accountable.

Reporting

We regularly report anti-corruption efforts to stakeholders and provide channels for feedback.

We assess high-risk roles regularly and deliver targeted training for Directors, new hires, promoted staff, and sensitive positions.

All employees and suppliers sign Integrity Agreements and Commitment Letters to keep our supply chain transparent. We also host anti-corruption seminars with suppliers and staff to review policies and build a culture of integrity.

Integrity and Anti-Corruption Reporting

Confidential, real-name preferred, rewards for verified

QR Code for reporting

Hotline:13798338178 (also available on WeChat)

Email: zhaowei_gmo@szzhaowei.net

WeChat: Follow “ZHAOWEI” → Contact → Integrity Reporting.

Address: Office 101, No.62 Yanhu Rd, Yanchuan Community, Yanluo Subdistrict, Bao'an District, Shenzhen City, Guangdong Province, China

Sunshine Policy

Confidentiality Policy

We strictly ensure the confidentiality of whistleblower’s information. The investigated parties are prohibited from retaliation; any violation will be seriously dealt with.

Real-Name Priority Policy

Reports under real names are encouraged and will be prioritized, with timely feedback on case acceptance and outcome notifications.

Reward Policy

For verified reports, whether from employees or external parties, we provide material rewards based on the specific situation, while ensuring strict confidentiality.

Scope of Acceptance

Confidentiality Policy

We accept reports of bribery, solicitation, unfair competition, fraud, or any other violations of professional ethics by our employees. Product or service quality issues are not covered here. Please report those directly to the ZHAOWEI Supervisory Committee.

The ZHAOWEI Supervisory Committee reports directly to the Board of Directors and operates independently of any other individual or organization.

Anti-Monopoly and Anti-Unfair Competition

We champion free and fair competition, oppose monopoly and unjust enrichment, and comply with all applicable laws. Fair competition strengthens our markets and benefits our customers.

We strictly adhere to China’s Laws covering Anti-Monopoly, Anti-Unfair Competition, Advertising, and Trademark, and other relevant international standards, firmly prohibiting all unfair competitive practices.

We have a fair competition management mechanism that investigates all reported or detected leads, enabling timely prevention and cessation of misconduct.

We conduct regular compliance reviews on subsidiary projects with risk-based frequencies. During the reporting period, no business ethics violations occurred, nor were there any lawsuits arising from corrupt practices.

Safety Production Management

Guided by “Safety First, Prevention Foremost, and Comprehensive Management,” we apply risk control and hazard rectification to ensure workplace safety. The reporting period saw no accidents above the general level.

Quality Management

Customer-focused, with a full-chain quality management system covering R&D, materials, production, final goods, after-sales. Digital inspections cover all stages to ensure compliance and safety from the start.

Supply Chain Management

We maintain a fair, transparent procurement environment with robust systems (Supplier Management, Procurement Control) and optimize supplier lifecycle management. We also offer sustainability training to suppliers, ensuring compliance from the start and full alignment with sustainability goals.

Supplier Lifecycle Management

Admission

We audit potential suppliers on business qualifications, IP risks, product quality and safety, environmental compliance, and business ethics. Suppliers with strong ESG performance are given preference in sourcing decisions. Only after signing auditing and testing documents can they become approved suppliers.

Tiering

Suppliers are categorized by type and tiered into 4 levels. During the reporting period, we managed 1,000+ active suppliers with differentiated strategies to optimize resource allocation and boost supply chain synergy.

Assessment

We conduct ESG surveys and on site audits every two years, covering product/service quality, delivery, technical capability, equipment quality, environmental management, and ESG performance. Based on results, we apply rewards, coaching, corrections, or elimination for optimization.

Elimination

Suppliers with persistent quality/delivery issues or "fail" assessment results undergo corrective action. Those fail to improve or deemed unqualified by relevant departments trigger exit. Blacklist for counterfeit goods, major breaches, safety incidents, or ethics violations.

Responsible Minerals Management

We are committed to not supporting or using conflict minerals sourced from armed conflict, illegal mining, or poor working condition, including gold (Au), tantalum (Ta), tin (Sn), tungsten (W), and their derivatives. We uphold lawful, compliant, and sustainable procurement practices. We require suppliers to trace origins, ensure compliance, and sign a Conflict-Free Minerals Agreement.

Our full-process due diligence system identifies and controls high-risk minerals, ensuring compliance with laws and industry standards.

Responsible Mineral Procurement Management Process

Supplier Screening & Investigation

Based on product development needs, we select appropriate suppliers and require them to submit a Conflict-Free Metals Report and sign a Conflict-Free Metals Declaration, to investigate conflict mineral information for the materials and provide assurance.

Result Analysis

Based on the supplier’s Declaration and investigation results, check compliance with Republic of the Congo Conflict-Free requirements.

Supplier Selection & Commitment

If compliant, proceed with procurement. If not, require the suppliers to provide a written explanation and immediately cease procurement. Then find new sources, provide evidence, implement corrective actions, and sign the Declaration.

Customer Service Management

The company has established and continuously refined a full-lifecycle customer service management system, supported by the formulation and upgrading of internal policies such as "Customer Satisfaction Management" and "Customer Feedback and Complaint Handling Procedures." By integrating pre-sales, in-sales, and after-sales service stages and implementing cross-departmental collaborative service mechanisms alongside multi-channel communication systems, the company strives to respond to and address customer needs at every stage through a standardized, efficient, and professional service management framework.

Pre-sales

In-sale

After-sales Service

Leveraging a standardized customer service management system and processes, the company provides comprehensive service and support—ranging from product solution development, product selection, and technical consultation to order fulfillment tracking, on-site technical support, and the closed-loop resolution of after-sales issues—to ensure an optimal customer experience.

The company incorporates metrics such as customer satisfaction, the timeliness of responding to requests, and the resolution rate of complaints into the performance assessments of customer service personnel. Simultaneously, it strengthens professional training for the customer service team and conducts regular annual customer satisfaction surveys. Driven by clear objectives, the company continuously optimizes service quality to consistently enhance the customer experience and strengthen recognition of the partnership.

Compliance Management

Compliance Philosophy

The essence of compliance is integrity.

Integrity is the foundation of business; compliance ensures ZHAOWEI's sustainable growth. It is our red line which always prioritized over business development.

Compliance Building

As a globally operating company, ZHAOWEI is committed to complying with all applicable laws and regulations. Integrity and compliance are our shared commitment and responsibility. We adopt a zero-tolerance policy and an one-vote veto system for any violations or misconduct. Employees must adhere to internal rules, control risks from the start, and uphold the three lines of defense. A top-down compliance culture is driven by leadership accountability.

Risk Management

In the course of global operations, legal and regulatory requirements vary across jurisdictions, and compliance complexity continues to rise. Non-compliance and unethical conduct may lead to operational risks, administrative penalties, and damage brand reputation. We have established robust management mechanisms and internal control systems with related documents to identify and analyze all potential risks.

Risk Identification

Business departments spot potential risks during daily operations, project execution, contract management, and compliance reviews.

Risk Analysis & Assessment

Departments report risk items. The Company centrally evaluates probability, impact scope, and controllability, classifies and tiers risks, and assigns risk levels accordingly.

Risk Response & Treatment

Based on assessment results, risks are prioritized and tiered, with differentiated response measures developed.

Correction & Improvement

Departments strictly implement corrective actions, with internal audit following up to monitor and evaluate effectiveness. Regular trainings are conducted to foster a risk-aware culture.

Privacy Protection and Information Security

We fully respect the legitimate privacy rights and interests of all stakeholders, prohibit any privacy infringements. Through robust management measures, we comprehensively safeguard the information and data security of the company, employees, customers, and suppliers.

Our Information Security Committee, chaired by the Chairman of the Board, with the CEO serving as Executive Vice Chair, responsible for information security policies, management guidelines, and major decisions, and guiding the Company in building information security systems. An Information Security Working Group is in place to implement specific security controls and management objectives.

Our management system insures the confidentiality, integrity, and availability of information systems, hardware devices, and core data, safeguarding information privacy and security. During the reporting period, we obtained ISO 27001:2022 certification for our Information Security Management System with zero penalties for privacy/security violations during the reporting period.

Security System Development

Personal & Customer Information Security

Product & Service Security

Data Asset Security

Security Incident Response

Security Patrol and Audit

Security Education and Training

Security Management Performance

In data security management, the Company faces risks such as external cyberattacks and insider misuse or abuse of data. During transmission, storage, and processing, data is also exposed to leakage and tampering risks, which may compromise its accuracy, integrity, and reliability. To address this, we have deployed Data Loss Prevention (DLP) technology to effectively safeguard data security.

We also conduct annual campaigns and trainings on information security and privacy protection, regularly update on internal platforms to keep all employees informed. Employees who violate information security policies or fail to fulfill security responsibilities are subject to disciplinary actions in accordance with our internal procedures. In addition, information security and privacy protection are incorporated into the performance evaluation of each subsidiary, accounting for 10% of their assessment.