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Whistleblowing Policy & Anti-Corruption Policy

Corporate Integrity Standards

Ever Sunshine Services adheres to the business ethics and corporate governance standards of honesty, legality, compliance, transparency, and transparency, continuously providing high-quality services, actively fulfilling social responsibilities, and safeguarding customer rights. The company has strict discipline, strictly prohibits employee fraudulent behavior, encourages internal and external reporting, and takes serious action after verifying violations. Suspected criminals are transferred to the judiciary.

Reporting Policy

Purpose 1.1 This policy aims to clarify ES-SERVICE's policies and commitments regarding reporting and protecting whistleblowers, and to provide detailed instructions on how to report fraud and other violations. 1.2 This policy applies to employees of ES-SERVICE and its subsidiaries (including ordinary employees, directors, supervisors, and senior management personnel), as well as to third parties (such as customers and suppliers) who have dealings with ES-SERVICE. As for the joint venture company, ES-SERVICE will encourage the board of directors of the joint venture company to adopt and comply with similar policies. 2. Reporting matters Whistleblowers (including but not limited to employees or third parties) may report any fraudulent or other violations related to ES-SERVICE, including but not limited to the following: 2.1 Violation of ES-SERVICE's Code of Business Conduct, which outlines ES-SERVICE's principles of business ethics, conflict of interest, anti unfair competition, anti bribery, political donations, equal opportunities for employees, trade secrets, and privacy protection; 2.2 Violations in financial reporting or internal monitoring; 2.3 Criminal offenses, violations of other laws or regulatory provisions; 2.4 Soliciting or accepting bribes from customers or cooperative units by eating, taking, card taking, or demanding; 2.5 Embezzlement of company funds or misappropriation of company funds; 2.6 Fraudulent behavior towards clients seeking personal gain; 2.7 The act of leaking or selling company trade secrets; 2.8 Other fraudulent, illegal, or unethical behaviors. 3. Policy for protecting whistleblowers 3.1 Confidentiality of Reports: Except for disclosure in accordance with legal provisions or transfer of fraud cases to judicial departments for processing, ES-SERVICE will keep confidential all reported materials received; Strictly keep the identity information of the informant confidential, and only the informant administrator has the authority to access the reporting email and other channels for receiving reports. 3.2 Prevention of retaliation: ES-SERVICE ensures that whistleblowers who truthfully report under this policy are treated fairly, including protecting whistleblowers from unfair dismissal, persecution, or improper punishment. Serious measures will be taken against acts of retaliation against whistleblowers and witnesses. 4. Reporting methods 4.1 Report by letter Address: 5th Floor, Building 39, Hengji Xuhui Center (South District), Lane 1088, Shenhong Road, Minhang District, Shanghai Postal Code: 201106 Recipient: Received by Ever Sunshine Services Audit and Supervision Department 4.2 Telephone report: 4000807878 to key 3 4.3 Email Reporting Email :jubao@ysservice.com.cn 4.4 If relevant personnel report fraud issues to the employee's immediate supervisor or department head, their supervisor or department head must transfer the reported issues to the Audit and Supervision Department. (Reminder: For issues other than reported matters that require contact with ES-SERVICE, please feel free to inquire with ES-SERVICE's national service and supervision hotline: 4000807878, press button 1) 5. Investigation and Handling 5.1 The reported information will be carefully handled and recorded, including the source, time, content, investigation, and accountability of the report. 5.2 After receiving reports of violations and fraud, the Audit and Supervision Department conducts a preliminary review based on the information provided in the reports. 5.3 If the report is confirmed to be true through preliminary examination, the Audit and Supervision Department will carry out a systematic investigation. The investigation work includes but is not limited to checking relevant documents and interviewing relevant employees and suppliers. After the investigation is completed, an investigation report will be issued and reviewed by the head of the audit and supervision department. 5.4 For those suspected of violating the company's business code of conduct and other regulations after investigation, approval shall be obtained from the group president, and responsibility shall be pursued in accordance with the company's system, including dismissal, demotion and salary reduction, demerit, warning, and criticism. If the company violates national laws, is suspected of corruption, bribery or other criminal offenses after investigation, it shall report to the public security organs in accordance with the law. 6. False reporting: 6.1 Whistleblowers must report truthfully. If the informant makes a false report, ES-SERVICE reserves the right to pursue legal responsibility in accordance with the law. Employees who make false reports have the right to be dismissed by the company. 6.2 Suggestions for reporting materials: provide the time, location, participants, main process of illegal and fraudulent behavior, and legal basis for the reported matter.

Anti corruption policies

1. Purpose ES-SERVICE adheres to the business ethics of honesty, law-abiding, compliance and transparency, and has zero tolerance for bribery and corruption. We practice professional integrity, fairness and justice in all business activities, advocate a culture of integrity and self-discipline, and establish effective anti-corruption policies. We hope that all partners who do business with us will comply with the same policy. 2. Content 2.1 Anti bribery 2.1.1 Communication with government and regulatory agencies When communicating with government and regulatory agencies, it is not only necessary to comply with laws and regulations, but also to adhere to the professional ethics standards and requirements of the government and regulatory agencies. Bribery of government and regulatory personnel, including but not limited to property and other improper benefits, is not allowed. 2.1.2 Charitable Donations and Sponsorship The use of ES-SERVICE's resources for donations or fundraising to charitable organizations or other organizations must be carried out in accordance with laws and regulations to ensure that no illegal benefits are generated. 2.1.3 Compliance requirements for business partners (1) When establishing business relationships with business partners, inform them of ES-SERVICE's compliance philosophy and anti bribery principles, and encourage them to apply these principles to their business practices. (2) At the same time as signing the cooperation agreement with the partner, it is required that the partner sign an integrity commitment, promising not to bribe ES-SERVICE's employees, otherwise the partner will bear the liability for breach of contract. (3) All employees are prohibited from colluding with business partners, engaging in activities prohibited by the ES-SERVICE Business Code of Conduct, and inducing or inciting business partners to engage in activities prohibited by the ES-SERVICE Business Code of Conduct. (4) When discovering bribery of company employees by business partners, promptly negotiate with them and dispose of them in accordance with ES-SERVICE's "Employee Reward and Punishment Management Measures", "Eight Military Regulations Management Norms" and other systems. 2.2 Antitrust and Unfair Competition ES-SERVICE complies with all applicable competition and antitrust laws. Employees should understand and comply with the competition laws applicable to the business. It is not allowed to engage in behaviors that may violate competition laws, such as participating in price manipulation, restricting production and supply, colluding in bidding, dividing the market, and other behaviors that may weaken market efficiency and fairness; Exchange sensitive information that affects competition with competitors; Implement restrictions on customers or suppliers. 2.3 Anti money laundering Strictly comply with relevant anti money laundering laws and regulations at home and abroad, and promptly report any abnormal transactions or suspected money laundering activities discovered. Not allowed to participate in money laundering activities or assist others in money laundering: not allowed to obstruct official investigations in any way; Concealing, omitting, or falsely reporting money laundering activities is not allowed. 2.4 Conflict of Interest When there is a conflict between the company's interests represented by employees performing their duties and their own personal interests, that is, a conflict of interest. ES-SERVICE employees are not allowed to engage in activities that conflict with the company's interests. They should actively identify and resolve potential conflicts of interest during the performance of their duties. Employees must proactively declare their relatives' employment with suppliers/customers/competitors; Prohibit part-time jobs, investments, and collaborations that conflict with the interests of the company in private. 2.5 Management Measures for Gifts and Gold Gifts Clarify and standardize the management of gifts and cash in business transactions, prevent violations and commercial bribery, and promote employee integrity in their work. All employees are not allowed to accept gifts or cash without authorization in business dealings. 3. Anti corruption system ES-SERVICE has established a "343 Integrity Ecological Three Dimensional Governance System", creating a clean and upright corporate environment through the construction of fraud prevention and control systems, promotion of integrity culture, and integrated governance of illegal and fraudulent activities. 4. Supervision ES-SERVICE will regularly review and evaluate the compliance of this policy to ensure that it is appropriate, effective, and suitable for our business operations and the jurisdiction in which our business activities are conducted. If any personnel raise doubts about suspected violations of the terms of this policy, or report them through the company's reporting channels, we will conduct effective investigations and take appropriate actions. Penalties will be imposed on violations and employees in accordance with company policies. Employees who fail to comply with the terms of this policy may constitute illegal behavior and may face civil or criminal litigation as a result.

Other Reporting Channels

Report by letter

Address:
5th Floor, No. 39, Lane 1088, Shenhong Road, Minhang District, Shanghai
Postal code:
two hundred and one thousand one hundred and seven
Recipient:
Audit and Supervision Center