We firmly believe that integrity and transparency are the cornerstones of our company's development.

Introduction and Commitment
Welcome to the use of our company's Whistleblower Channel. We fully understand that reporting may involve sensitive information and highly respect and value your privacy and security. We solemnly commit to handling all personal information, report content, and any information potentially involved in subsequent investigations that you provide in strict accordance with relevant national laws and regulations (including but not limited to the "Personal Information Protection Law of the People's Republic of China") and the provisions of this policy, maintaining strict confidentiality and using it solely for the purposes stated herein.

1. How We Collect Information

Information You Voluntarily Provide: When you submit a report through the designated channels (e.g., dedicated email, phone, mailing address), we collect the information you provide, which may include:

Your personal identity information such as name, contact details (e.g., phone number, email address), workplace, etc. (if you choose to report using your real name).
The specific content of the incident you are reporting, relevant evidence materials (e.g., images, documents, recordings), and information concerning the individuals and units involved.

Information Potentially Collected During Investigation: To verify the report content and conduct necessary investigations, we may, based on your authorization and legal requirements, collect additional information related to the reported incident during subsequent processes.

2. How We Use Information
The information we collect will be used solely for the following purposes:

To accept and process your integrity report or complaint.
To verify, investigate, and handle the matters you report.
To share information within a necessary scope with specific internal departments or personnel responsible for investigation (e.g., Audit & Supervision Department, Compliance Department) to advance the investigation process.
To provide relevant information to competent authorities (e.g., disciplinary inspection and supervision organs, judicial departments) when required by laws and regulations or necessary for safeguarding public interest.
To contact you and provide feedback on the progress or outcome of the investigation (if you have provided contact information).
To ensure the secure and stable operation of the reporting system and related business processes.

3. How We Protect Information
We have implemented administrative, technical, and physical security measures commensurate with industry standards to protect your information against unauthorized access, disclosure, alteration, or destruction.

Strict Confidentiality System: All report materials are handled under a system of designated personnel for acceptance and responsibility, managed as confidential documents. The leakage of report materials and your personal information to any personnel, reported units, or reported individuals unrelated to the investigation is strictly prohibited.
Access Control: Access to report information is restricted solely to specifically authorized staff who are bound by confidentiality obligations.
Security Measures: We employ security measures such as encryption technology and anonymization processing (where applicable) to protect information during transmission and storage.
Employee Training: We provide strict confidentiality awareness and security training to employees handling report information and require them to sign confidentiality agreements.

4. How We Share, Transfer, and Publicly Disclose Information

Sharing: We will not share your report information with any unrelated third parties, except in the following circumstances:

With your explicit authorization.
As required by laws and regulations or compulsory demands from governmental authorities.
Sharing with our engaged professional advisors (e.g., legal counsel), who are bound by strict confidentiality obligations.

Transfer: We will not transfer your report information to any company, organization, or individual, except in cases involving company mergers, acquisitions, or asset transfers. In such events, we will require the new holder of your information to continue being bound by this policy.
Public Disclosure: We, as a principle, will not publicly disclose your personal information and report content. If disclosure becomes necessary (e.g., to commend reporters who have contributed significantly), we must obtain your explicit consent beforehand and will take effective measures to redact content that could identify you.

5. Your Rights
According to laws and regulations, you have the following rights regarding your personal information. Please note that the exercise of some rights may be limited due to the specific nature of reporting work and the needs of confidentiality and investigation:

Right to Inquire and Correct: You have the right to inquire about the information related to your personal information that we are processing and request corrections if the information is inaccurate or incomplete.
Right to Withdraw Consent: You have the right to withdraw the consent you have previously given for the processing of your personal information through the channels we provide. However, the withdrawal of consent does not affect the lawfulness of processing activities based on consent before its withdrawal.
Right to Deletion: Under specific circumstances, you may request the deletion of your personal information.
Right to Report and Complain: If you believe our processing of your personal information has infringed upon your legitimate rights and interests, you have the right to lodge a complaint with the relevant regulatory authorities.

Please note: To ensure the impartiality and confidentiality of the investigation, exercising certain rights may require us to verify your identity first, and it might not be possible to fulfill all requests immediately (e.g., deleting information during an ongoing investigation might affect the process).

6. Information Retention Period
We retain your information only for the period necessary to achieve the purposes outlined in this policy and for the minimum period required by applicable laws and regulations. Once the retention period expires, we will delete or anonymize the relevant information.

7. How We Protect Minors
Our reporting service is not directed at minors. We do not knowingly collect personal information from minors. If you are a minor, please do not submit any personal information through this channel.

8. Updates to the Privacy Policy
We may update this policy from time to time. The updated policy will be posted on this page and will become effective from the date of publication. We will notify you of significant changes through prominent means.

9. How to Contact Us
If you have any questions, comments, suggestions regarding this Privacy Policy, wish to exercise your relevant rights, or suspect a potential information leak, please contact us via:

Department Responsible for Report Acceptance: Audit Dept
Email: mfg-c2@sinhomcn.com
Phone: +86 13514119393

We will promptly review the matter and respond within 15 working days.