Shanghai @hub (hereinafter referred to as “company”) is committed to creating a new business civilization that is public, transparent and open, and will resolutely fight against corruption.

We have establishes an anti-commercial corruption committee and promulgated relevant management regulations. We also have an e-mail (ACD@athub.com) for the special purpose of complaints and reports as well as the following commercial corruption related reports:

1. Participate in activities paid by suppliers:

(1) At any time, on any occasion and of any size:

(2) Including but not limited to catering, entertainment, travel, etc.

2. Ask for or receive gifts from a business-related unit:

(1) Any business-related units including but not limited to customers, suppliers, government public relations departments, agencies and other business cooperation unites (the same below);

(2) The gifts include but are not limited to money gifts, shopping cards, consumption cards, membership cards as well as articles, food and souvenirs;

(3) Of any amount and in any form.

3. Require or accept any paid convenience from a business-related unit:

(1) The paid convenience includes but is not limited to housing decoration, wedding and funeral, travel, reimbursement of personal expenses, etc.;

(2) To any extent (including acquisition at a price significantly lower than the market price) and in any form;

(3) Appropriate or share privately the discounts, rebates, commissions and agency fees obtained from business transactions;

(4) Of normal involvement and abnormal involvement;

(5) Of any amount and in any form.

4. Misappropriate public funds.

5. Artificial transactions:

(1) In the absence of actual business needs, apply for purchasing or purchase office supplies or facilities, devices, etc.;

(2) In the absence of actual business needs, apply for or implement leasing, borrowing, etc.;

(3) In the absence of actual business or in the case of business ambiguity, implement project certification and quantity determination;

(4) Seek support from an agency when he is able to handle by himself.

6. Malicious use of trade secrets:

(1) The trade secrets include but are not limited to the company’s documents, bidding information, drawings, intellectual property, important customer information, etc.;

(2) Obtain and spread trade secrets in violation of regulations or beyond one’s authority;

(3) The malicious use includes but is not limited to:

a. Leak base price to suppliers or third parties for any benefit;

b. Collude with suppliers to fake bids;

d. Sell confidential information to competitors, including but not limited to customer information, strategies, etc.;

e. Take the company’s resources as chips for personal transactions, including but not limited to various files, drawings, intellectual property, etc.

7. Duty-related Encroachment:

(1) Take advantage of one’s position to directly or indirectly, engage in agency services associated with business of the company;

(2) Engage in business activities related to the company’s business, and invest in or accept shares of a company/an organization associated with the company’s business;

(3) Take advantage of one’s position to misappropriate, steal, defraud or otherwise illegally encroach on the company’s property;

(4) Instruct, instigate and force employees to be engaged in issues contrary to the company’s business;

(5) Take advantage of one’s position to harm the interests of the company;

(6) The abovementioned circumstances apply to the company’s employees, their relatives and friends and other persons designated.

8. Other acts of commercial corruption. 

A commercial corruption case of the company will be verified on the basis of facts, thus we hope you report such cases in your real name, and we promise to protect you and keep the content of your report confidential. The content of your report must be objective and truthful. With regard to the investigation and conclusion of your report, we will provide feedback at the contact information you left.