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code of business ethics

standards and regulations

tot biopharm believes that compliance with the laws and regulations and adherence to business ethics is the obligation and responsibility of any enterprise to the public and its shareholders, and it is committed to maintaining openness, transparency, integrity and honesty during corporate operation with a rigorous business ethics system. tot biopharm strictly abides by relevant applicable laws and regulations of the country, industry and the location of operation premises, including but not limited to the criminal law of the people’s republic of china, the anti-monopoly law of the people's republic of china, the anti-unfair competition law of the people's republic of china, the anti-money laundering law of the people's republic of china, the interim provisions on prohibition of commercial bribery, and resolutely eliminates all improper acts that violate business ethics.

tot biopharm has formulated and released a compliance operation manual for its compliance management system. upon systematic evaluation, the compliance management and control is mainly focused on anti-bribery compliance and anti-fraud compliance, since incompliance in such areas would pose high risks in the pharmaceutical industry and cause frequent violations. tot biopharm improves the integrity policies and builds good relationships with government officials, health care professionals, medical institutions and upstream and downstream business partners.

besides, we have refined the code of business conduct to propose the principle of treating business partners and third parties fairly and honestly. we also regulate the business dealings of internal staff through the employee handbook of tot biopharm to strengthen the business moral standards of our staff, and actively promote the signing of the integrity commitment by our suppliers when signing a contract, so as to enhance their awareness of business ethics compliance. in the current reporting period, 100% of the suppliers of tot biopharm have signed the integrity commitment, and there were no cases of embezzlement or misappropriation that have been filed or concluded. tot biopharm has also established a comprehensive whistleblower protection policy, with a whistleblower policy formulated and issued, so as to encourage employees, customers, suppliers and other stakeholders to report any misconduct, malpractice and irregularities found in the company in a non-anonymous manner. tot biopharm will verify the report and take corrective measures in a timely manner.

promote compliance awareness

tot biopharm understands the importance of compliance to the company’s operation, therefore, in accordance with the guidelines for environmental, social and administration reporting issued by the hkex, the company specially invites professional third parties to conduct training for all employees, with the training contents covering laws and case sharing on contract practices, and legal risks and prevention in healthcare industry, in order to enhance the legal awareness and professional ethics of employees, and protect the development of the company. also, tot biopharm provides compliance training to its directors on a regular basis.