ANNOUNCEMENT CONCERNING COMPLIANCE PROGRAM
As a state-owned enterprise, China Communications Construction Company (CCCC or Company) strives to provide our clients with the highest quality services while maintaining our commitment to integrity, honesty and social responsibility. CCCC endeavors to pursue this commitment to excellence in all aspects of our business dealings and aims to achieve success with a sustainable business growth.
As a reputable international contractor, CCCC is to adopt a compliance program covering all of its overseas businesses, in order to ensure that CCCC is equipped with a Compliance Program that is best-in-class and to demonstrate CCCC’s commitment to ethical business practices. This Compliance Program provides detailed policies and procedures related to ethical business practices and maintains compliance with international standards and applicable laws in the following business areas: (i) Staff Behavior, (ii) Third Parties, (iii) Procurement, (iv) Bidding, (v) Contracts, (vi) Hospitality, (vii) Donations and Sponsorships, and (viii) Payments. The policies and procedures describe expectations for all CCCC employees and set forth specific procedures to follow to allow CCCC companies to ensure compliance.
CCCC takes compliance with all laws, including anti-corruption laws, very seriously. Acting ethically in our business dealings is an obligation of every CCCC employee. As such, CCCC expects all CCCC employees to carefully review the policies and procedures that make up the Compliance Program. To aid in this effort, CCCC has developed and will be administering a regular training program for employees on topics relevant to compliance with anti-corruption laws and related misconduct that would violate Company policies. We expect that all CCCC employees will treat these trainings with the highest level of importance.
In addition to policies, procedures, and trainings, we will assign certain officers and managers with compliance implementation and supervision responsibilities. CCCC International’s Legal and Compliance Department will continue to act in close coordination with the compliance officers and departments that are established at each one of the CCCC’s subsidiaries, controlled affiliates, and branch offices. More staffs will be recruited as needed.
Please feel free to contact your compliance officer or any CCCC Compliance Department member for any questions you may have regarding the Compliance Program. Do not hesitate to seek help if you are faced with a legal, compliance, or ethical issue.
CCCC prides itself on innovation and excellence. CCCC management believes that these attributes should apply to all aspects of our business dealings and believes that the Compliance Program provides CCCC and its subsidiaries the mechanism for which to maintain a position as leading companies in the area of business ethics. We expect that all employees of CCCC and its subsidiaries, controlled affiliates, and branch offices will act accordingly and take all measures to ensure that it is fully adopted and followed.
China Communications Construction Company Limited