In order to standardize the conduct of employees in China Communications Construction
Company Ltd.(hereinafter referred to as CCCC) who involved in overseas business
and guarantee that the overseas business activities are carried out legally,
this Code of Conduct is formulated in line with the compliance management
requirements of CCCC.
I. Code of Conduct
CCCC Code of Conduct for the Employees in Overseas Business (hereinafter referred to as the “Code of Conduct”) is the basic
principle and ethical standard that CCCC has to observe in legally conducting
business activities, and is also the important foundation for sustained success
of the Company.
The Code of Conduct is applicable
for all employees of CCCC International Operations and the divisions involved
in overseas business, overseas offices, as well as any Third Party who is
engaged in operation of overseas businesses (hereinafter referred to as
“Employees”). All those entities and employees who are involved in or engaged
in overseas business shall observe the value criterion of “Advocatingmorality and learning, and seeking progress”, and comply with the
compliance requirements of “Insist on honesty and compliance, Maintain fair
competition, Guard against commercial bribery and corruption, avoid conflicts
of interest and keep commercial secrets confidential. Respect for employees’
rights, and Health, safety and environmental protection”.
A. Insist on Honesty and
shall put the Company’s interests on top priority, identify the Company’s
culture and objectives, earnestly perform their own duties, and make efforts to
maintain the Company’s social image and good reputation.
shall be fully aware that they will be subject to civil or criminal liability
for any violation of laws, regulations, or compliance requirements, and any
such violations would cause damage to the Company’s reputation.
shall not conduct any unethical behavior that is prohibited and may lead to the
Company’s involvement in any unlawful or proscribed unethical practices.
shall treat all colleagues and visitors with respect and humility. Respect
religious beliefs and cultures and customs of the country where the business
shall communicate with their colleagues and supervisors in the manner of trust
and collaboration, and work together with them to complete the tasks.
shall be honest and fair to all clients, and ensure that the information
communicated with or introduced to clients is true and accurate. Employees are
prohibited from gaining business by misleading the existing or potential
7. Employees shall make financial
records honestly, objectively and fairly. Financial records and statements
shall faithfully reflect economic status of the Company's business activities.
Comply with Generally Accepted Accounting Principles, standards and accounting
and financial reporting laws and regulations.
8. Employees shall strictly comply
with all Company’s policies and applicable laws and regulations related to
documentation and record keeping.
are prohibited from stealing or abusing the Company’s property or any rights
authorized by the Company.
shall not forge or alter work records, bidding documents, or other materials.
11.Employees shall not conduct any action that may impair, harm, or
threaten to impair or harm anyone or their property or improperly influence any
colleague, client, competitor, or any other party.
shall comply with all applicable Competition Law, Anti-Monopoly Law, and other
applicable laws and regulations on maintaining fair competition in the market.
shall not collude with competitors or jointly participate in any action with an
improper intent or effect, such as bid rigging, formation of price alliance,
violating bidding processes, dividing markets, or limiting production.
shall not exchange sensitive information with competitors against Competition
or Anti-monopoly Laws.
4. Employees shall not violate
laws and regulations related to anti-money laundering and anti-terrorism
financing, and forbidden to carry out business with customers with illegal
sources of funds.
5. Employees shall comply with all
stipulations and customs regulations related to export control, economic
sanction in term of cross-border transfers of cargos and technologies.
6. Employees shall comply with
international policies and regulations against countries supporting terrorism
and other countries subject to economic sanctions.
against Commercial Bribery and Corruption
shall fully understand that the Company’s success in business must be based on
market competitiveness, performance, quality of products, services, and
technologies. No in any circumstances shall the employees seek success in any
operation activity through any form of bribery or corruption or other improper
activities of the same nature.
shall not offer, promise, authorize, give, or receive any type of bribes,
commercial or property interests, cash payments or gifts in order to influence
any commercial behavior or business decision, obtain any improper benefits, or
interfere independent judgment. Employees are also prohibited from conducting
the above acts indirectly through relatives or other trustees.
shall not offer, promise, or give money, services, gifts, or other valuable
items (including hospitality) in order to obtain or retain business opportunity
or other benefits. Employees are also prohibited from conducting the above acts
indirectly through relatives or other trustees.
shall not receive money, services, gifts, or other valuable items (including
hospitality) from subcontractors or suppliers because they have given any
business opportunity to an individual or organization. Employees are also
prohibited from conducting the above acts indirectly through relatives or other
5. Where any business is involved
with government or any affiliated organization, especially seeking approval,
permit, or relative review & approval from government, employees shall
observe the moral standards compliance policies and requirements of the
social customs and cultures, employees could exchange symbolic gifts, non-cash
courtesy souvenirs, or provide hospitality. If the ultimate goal is to
improperly influence business decisions, however, employees shall not give,
offer, promise, or accept any such gifts or hospitality (including money,
loans, invitations, and expense payments or reimbursements) or any other form
of special treatment. Employees are also prohibited from conducting the above
acts indirectly through relatives or other trustees.
D. Avoid Conflict of Interests
of interests may distort employees’ business judgment. Employees must avoid
undertaking any activities that may cause, or create the perception of, a
conflict of interests between (a) themselves or any related or associated third
party (including suppliers and subcontractors) and (b) the Company.
business decisions and actions shall be based on the best interests of the
Company. Independent judgment and reasonable decision -making shall not be
influenced by any relationships with prospective or existing suppliers,
subcontractors, representatives, contract employees, customers, competitors, or
conflict of interests, the Company may hire a former or the current
governmental employee only if all the conditions comply with the Company’s
compliance policies, procedures and requirements.
E. Keep Commercial Secrets
shall adhere to CCCC’s Commercial Secrets Protection Policy.
internal communication or prior approval from the supervisor, employees shall
not publish, discuss in public, disclose to unauthorized persons or
organizations, or use without proper authorization, any commercial confidential
information and proprietary information belonging to the Company or the related
information includes, but not limited to, results, forecasts, and other
financial data; human resources and personal data; and information with respect
to acquisitions, divestitures, new products, and orders. Proprietary
information includes, but not limited to, business strategies, technical
information, product improvements, invention, information systems, trade
secrets, proprietary technology developed or achieved by the Company, as well
as matters covered by Confidentiality Agreement.
who are responsible for the management, use, and delivery of confidential
information and proprietary information (including client and supplier related
information) shall not improperly disclose or abuse such information internally
or improperly disclose or abuse it to an external third party.
5. Employees shall strengthen the protection of intellectual
property rights, investigate and affix the responsibility for persons who use
the Company's intellectual property rights without authorization; and respect
effective intellectual property rights and avoid unauthorized use of
intellectual property rights belonging to others or organizations.
6. Employees shall enhance data protection and data
to ensure the security of Company's information, network and
shall not benefit themselves or others by taking advantage of any Company
business opportunity, property, information, or other resource.
F. Respect for Employees’ Rights
1. The Company complies with all
laws and regulations in term of prohibiting forced labor, unpaid work and
employing child labor, human trafficking and employment discrimination.
2. The Company shall protect basic
rights of employees, including employees’ working safety, health and personal
3. The Company shall comply with
all applicable laws and regulations related to treating all employees fairly
and respect mutually, and provide fair employment opportunities to all
employees. When making employment decision, the Company shall eliminate any
discrimination in employment and industry: including the race, color, religion,
nationality or ethnic origin, gender (including pregnancy or not), sexual
orientation, gender identity or performance, age, disability, military service
of individuals or other characteristics protected by law. Employees must
respect for fundamental rights of others when they work and carry out business
4. The Company shall create a work
environment that prohibits harassment and bullying, and sexual harassment and
personal insults to employees and colleagues shall be prohibited.
G. Health, safety and
1. The Company shall strictly
comply with all laws and regulations related to the health, safety and
environment applicable to the production and operation.
2. The Company shall pay attention
to environmental protection and ecological construction in the workplace, to
strive to protect the cleanliness and conservation of soil, water and air, and
the biodiversity and inheritance of culture. Encourage the development and
promotion of environmentally sound technologies.
3. The Company shall develop and
follow safe work processes, to ensure workplace safety and prevent the injury.
II. Compliance responsibilities of the Management and Employees
The Company’s management at each level and employee shall take the following responsibilities when complying with this
Code of Conduct
personnel at each level have duty to comply with the Code
of Conduct is higher than ordinary employees. Management personnel at each level must actively promote the implementation of the Code of Conduct and
demonstrate its commitment to this Code of Conduct through actions.
personnel are obligated to directly demonstrate that all Employees shall abide
by the ethical standards and compliance requirements as their top consideration
in carrying out any production and business activities.
personnel at each level must be vigilant at all time in order to prevent,
detect, and respond to any violation of this Code of Conduct, and protect from
the Employees who report the violations.
addition to abiding by the applicable law and CCCC compliance policies and procedures
that apply to their position and job activities, the Employees are obligated to
be fully aware of and implement this Code of Conduct in daily production and
5. Employees are
obligated to report any known or potential violations against the Code of
Conduct. During reporting of the above violations, employees are required to
submit the evidence proving the actual or any potential acts against the Code
of Conduct to the Compliance Department or report such act according to the Company’s
compliance policies and procedures.Upon receiving compliance report, each level
compliance personnel shall defer the matter to compliance department.
III. Consulting, Reporting and
Treating of Violation
should consult with the CCCC International Compliance Department, or other
relevant persons in charge as prescribed in the Company’s compliance policies
and procedures, any issues that arise or questions they may have with regard to
this Code of Conduct, the Company’s Core Values and compliance policies and
procedures, and applicable law, including issues or questions regarding:
concerns involving ethical or compliance problems;
hesitation, in certain specific situations, on how to proceed in accordance
with the Company’s Core Values and compliance requirements;
request from business partners, clients, or colleagues that might violate the
Company’s Core Values, compliance requirements, or applicable law;
4 Any perceived or suspected
activities of business partners, clients, or colleagues that might violate the
Company’s Core Values, compliance requirements, or applicable law; or
5. Any other
questions or circumstances involving compliance issues.
B. At any time, employees or
business partners may report in term of following situations, including but not
1. Perceive or suspect that
business partners, customers or colleagues require doing something that may
violate ethical standards or violate Company’s compliance policies or even
2. Business partners, customers or
colleagues require or do something that may violate ethical standards or violate
Company’s compliance policies or even illegal activities;
3. Any other problems or
circumstances related to the compliance.
Employees may report by means of
1. Reporting hotline;
2. Report directly to the
3. Report directly to superior
business executive, and then the superior business executive reports to the
CCCC's overseas compliance
management department shall promptly accept the consultation and report, to
carry out relevant investigations timely, and work out investigation and
processing results as soon as possible; and accepting and investigating
employee reports must be kept secret strictly to effectively protect employees
who report violations.
Employees who make good-faith
reports of actual or potential violations of this Code of Conduct are protected
from retaliation. If the reporting person is also involved in the reported
compliance violation activity, he/she may still be subject to discipline, but
the fact of his or her appropriately reporting of the misconduct will be taken
into consideration in determining the discipline imposed.
C. Any employee whofailsto comply withtheCodeofConduct shall be
subject to disciplinarymeasures,
which include but are not limited to termination of employment, dismissal,
(I)The Code of Conduct is interpretedby Strategies Development
(II)The Code of Conduct takes effectas of the date of printing.