Shanghai Fudan Fuhua Technology Co., Ltd. Reporting Complaints and Whistleblower Protection System
Shanghai Fudan Fuhua Technology Co., Ltd. Reporting Complaints and Whistleblower Protection System (Revised in June 2026)
Chapter 1 General Provisions
Article 1 The purpose of formulating this system is to regulate the professional behavior of the company's directors, senior managers and employees, strictly abide by relevant laws, industry norms and standards, professional ethics and relevant company rules and regulations, and prevent behaviors that damage the interests of the company and shareholders.
Article 2 Scope of application: All employees of the company.
Article 3 Complaints and reporting matters referred to in this system mainly include:
(1) Violation of the Articles of Association, internal control system, professional ethics and code of conduct, etc.
(2) Seeking illegitimate benefits, accepting or committing commercial bribes, etc.
(3) Other behaviors that endanger the company's normal operations and social reputation.
Chapter 2 Complaint Methods
Article 4 Complainants may make complaints in writing, email, telephone, etc. When making a complaint, the basic process of the matter, the name, address, specific parties involved, the complainant's name, contact information, and the complainant's specific complaint requirements should be stated. Evidence of the infringement of the complainant's interests or the company's interests should also be provided, as well as other materials related to the complaint matter. Report hotline: Company Audit Department 63872288*659
Article 5 The company encourages real-name reporting. If a real-name report is made, the Audit Department will keep it strictly confidential and feedback the results to the whistleblower in an appropriate manner.
Chapter 3 Complaint and Report Handling Procedures
Article 6 The audit department shall keep records of reports and complaints received; analyze and evaluate complaints and reported matters within 48 hours, and handle them in a graded manner according to the following principles;
Level A: Involves a report that the company's directors, senior managers or board of supervisors consider to be serious in nature. If the audit department conducts a preliminary investigation and judgment on the complaint and believes that the facts of the report are basically true, it will be handled in the following manner:
a) If a report involves a disciplinary violation by the company's directors or senior managers, and it is a disciplinary violation stipulated in the company's relevant regulations, the company's audit department will report it to the company's audit committee to decide on the investigation method and put forward handling opinions on the investigation results.
b) For reports involving management defects or other major errors at the company level, the company's audit department will report to the company's supervisors after receiving the report, and propose investigation methods according to the company's internal control management system and requirements. After the situation is found out, the department responsible for the investigation will put forward handling and correction opinions or suggestions, and report the handling situation to the company's audit committee.
c) Reports of other disciplinary violations shall be handled in accordance with the company's relevant disciplinary violation procedures.
Level B: According to the preliminary investigation, if the content of the report is factual or constitutes a disciplinary violation, but does not involve the company's directors or senior managers, or the content is not serious in nature, it will be handled in the following manner:
a) For reports or complaints involving individuals who have disciplinary violations or constitute disciplinary violations, the audit department should designate a special person to further investigate and verify the content of the report, make suggestions based on the investigation, or provide handling opinions to the department where the person being reported is located. The department where the person being reported is responsible for handling the reported cases, and the handling department should provide timely feedback on the results. The company's audit department should report to the company's management in a timely manner.
b) For reports or complaints about management deficiencies or errors of the company and relevant departments of the incident, the audit department should promptly notify the relevant departments of the company of the management deficiencies and put forward opinions or suggestions on remedial measures or corrective measures. Relevant departments should take remedial measures or correct the defects or errors, and promptly feedback the results to the company's audit department.
Level C: After preliminary investigation, the Audit Department initially determines that the complaint lacks basis, but its nature is not subjective malicious false accusation or slander. After further investigation and verification, the whistleblower should be notified of the result.
Level D: After preliminary investigation, the Audit Department preliminarily determines that a report or complaint is malicious, false accusation or defamation. After further investigation and verification, based on the seriousness of the harm caused by the whistleblower's behavior to the person being reported or the company, corresponding punishments will be imposed or the complaint will be transferred to judicial authorities for processing.
Article 7 The Audit Department may, based on investigation needs for accepted reports or complaints, require the reported departments and personnel to provide documents and materials related to the reported incident, including accounting vouchers, financial statements, etc., and may require the reported departments and personnel to provide explanations and explanations on the issues involved in the reported matter, and the relevant departments shall cooperate.
Article 8 After the investigation is completed, the company's audit department shall issue the investigation results and report them to the company's management in accordance with relevant regulations; reports or complaints judged to be Level A shall be handled in accordance with the aforementioned procedures.
Article 9 If a report or complaint is found to be true after investigation, the company will handle it according to management authority based on the investigation results.
Article 10 After the Audit Department completes the procedures for handling reports or complaints, the relevant materials will be archived for future reference.
Article 11 All financial-related violations shall be reported to the Internal Audit Department.
Chapter 4 Handling of Complaints and Reports
Article 12 When accepting reports or complaints, the Audit Department shall adhere to the principles of seeking truth from facts, confidentiality, and avoidance. Any responsible personnel who violate the above regulations will be severely dealt with in accordance with relevant regulations.
Article 13 Anyone who deliberately fabricates false facts in the name of reporting or complaining, makes false accusations and frames others, or creates troubles and interferes with normal work in the name of reporting will be severely dealt with in accordance with relevant regulations; those who constitute a crime will be transferred to judicial organs for processing.
Article 14 The provisions of this chapter shall not apply to false reports or complaints resulting from misreporting or misreporting due to incomplete understanding of the facts.
Article 15 If the reported matter is verified to be true and the company recovers losses, the whistleblower may be rewarded as appropriate.
Chapter 5 Feedback
Article 16 The company will provide effective feedback to the reporter after the investigation is completed based on the complaint method. The company will not impose any punishment or repercussions on employees who report relevant violations and are found not to be maliciously making false accusations or slander.
Chapter 6 Supplementary Provisions
Article 17 The company’s board of directors is responsible for interpreting this system.
Article 18 This system will be implemented from the date it is reviewed and approved by the board of directors.