Compliance Policy | Shanghai Dingwujin Chemical Co., Ltd.
Scope of Application
This Policy applies to Shanghai Dingwujin Chemical Co., Ltd., its affiliated enterprises, all employees, partners, suppliers and customers. It governs all business activities and internal management behaviors of the Company.
General Principles of Compliance and Privacy
Shanghai Dingwujin Chemical Co., Ltd. adheres to the principles of legality, integrity, transparency and sustainable development. Compliance management serves as the core foundation of corporate operation and growth. The Company strictly complies with applicable laws and regulations in China, the European Union, Germany, Poland, Ukraine and other business jurisdictions. We fully implement regulatory requirements concerning data protection, anti-corruption, anti-monopoly, foreign trade, occupational safety and environmental protection, and maintain a sound internal control and risk management system to ensure standardized compliance across all corporate departments, business units and personnel.
This Policy covers all business operations of the Company, including but not limited to chemical production, hazardous chemical distribution, international logistics, warehousing, cross-border trade, technical consulting, REACH compliance services and market entry support.
Code of Business Conduct and Professional Ethics
As the core component of the Company's compliance system, this code applies to all employees and all business scenarios:
1. Anti-Corruption and Anti-Bribery
The Company maintains a zero-tolerance stance against corruption. Any form of bribery, kickback, improper gratuity and illegal interest transfer is strictly prohibited. All business activities shall be conducted openly, fairly and impartially. No individual shall seek improper gains by taking advantage of professional positions.
2. Anti-Money Laundering and Anti-Fraud
The Company enforces rigorous capital flow review, customer due diligence and transaction record retention mechanisms to prevent money laundering, terrorist financing and commercial fraud.
3. Financial and Accounting Compliance
All accounting records shall be true, accurate and complete. The Company strictly observes fiscal and tax laws and prohibits false reimbursement, off-book accounts and irregular financial operations.
4. Anti-Monopoly and Fair Competition
The Company abides by anti-monopoly and fair competition regulations. Collusive pricing, market segmentation and abuse of market position are strictly forbidden.
5. Conflict of Interest Management
Employees shall actively disclose any interest relationship that may affect impartial job performance. Participation in businesses competing with the Company's interests without official approval is prohibited.
6. Confidentiality Obligations
The Company strictly protects customer information, trade secrets, technical data and internal business information. Unauthorized disclosure, reproduction and dissemination of confidential data are prohibited.
7. Data Protection and Information Security
The Company complies with the GDPR and global data protection regulations. We standardize the collection, storage, usage and transmission of personal data to ensure comprehensive information security.
8. Foreign Trade Compliance
The Company adheres to export control, customs supervision, trade sanction and embargo regulations. The provision of restricted goods and technologies to sanctioned jurisdictions or entities is strictly prohibited.
9. Workplace Safety and Environmental Protection
Full-process safety management is implemented for the production, warehousing and transportation of hazardous chemicals. The Company complies with environmental protection laws to prevent operational pollution and safety incidents.
10. Human Rights and Labor Standards
The Company respects the legitimate rights and interests of all employees. Forced labor and workplace discrimination are prohibited. We ensure standardized occupational health and workplace safety management.
Supplier Compliance Standards
All suppliers, logistics service providers and business partners of Shanghai Dingwujin Chemical Co., Ltd. shall comply with the following requirements:
Abide by all applicable laws, regulations and industrial standards in operating regions;
Uphold the principles of integrity operation, fair competition and clean cooperation;
Fully comply with labor rights protection, occupational health and environmental management requirements;
Cooperate with the Company's compliance due diligence, internal audits and risk inspections;
Never provide falsified qualifications, non-compliant products or irregular services.
Compliance Organizational Structure and Responsibilities
1. Senior Management Accountability
Senior management assumes overall responsibility for the Company's compliance system, conducting regular reviews of compliance policies, risk reports and corrective implementation status.
2. Compliance Officer and Professional Team
A full-time compliance team is established to coordinate policy formulation, risk investigation, compliance training, audit supervision and incident handling.
3. Regional Compliance Contacts
Dedicated compliance contacts are deployed in China, Poland, Ukraine and other operational regions to ensure local regulatory implementation and regional risk control.
4. Company-Wide Compliance Accountability
Every employee is accountable for compliance within their job scope. All personnel shall proactively identify and report potential risks, participate in regular compliance training and strictly execute standardized operational procedures.
Anti-Corruption and Integrity Compliance
The Company enforces a zero-tolerance policy against corruption. Violators will face disciplinary actions, and suspected illegal conduct will be referred to judicial authorities. Internal control mechanisms including dual review, power separation, procurement price comparison and contract auditing are implemented to mitigate integrity risks. Regular anti-corruption training, audits and risk assessments are conducted. An anonymous reporting channel is maintained with full protection for whistleblowers, and retaliatory behaviors are strictly prohibited.
Foreign Trade and Export Compliance
For cross-border chemical businesses covering China, Poland, Ukraine and Central and Eastern European regions, Shanghai Dingwujin Chemical Co., Ltd. strictly complies with national export control rules, customs classification, valuation, taxation and quarantine requirements. The Company observes sanctions, embargoes and restricted entity lists issued by the United Nations, the European Union and relevant jurisdictions. We fully adhere to safety standards for hazardous chemical packaging, labeling, transportation and warehousing, as well as chemical market access regulations including REACH, CLP and Ukraine REACH.
A dual screening mechanism (systematic + manual) for customers and suppliers is implemented to prevent transactions with restricted entities and ensure full-chain trade compliance.
Data Protection and Privacy Compliance
In accordance with the GDPR and other global data protection laws, the Company establishes standardized data protection mechanisms to safeguard the personal information rights and interests of users and business partners. We standardize the full lifecycle of data collection, storage, usage, sharing, cross-border transmission and destruction, adhering to data minimization and encrypted protection principles.
Users hold legitimate rights of access, rectification, erasure, restriction of processing, data portability and withdrawal of consent. The Company conducts regular data security inspections and employee training to prevent data leakage, tampering and loss.
Compliance Reporting and Investigation Mechanism (SpeakUp)
Shanghai Dingwujin Chemical Co., Ltd. maintains a confidential, anonymous and non-retaliatory reporting channel to receive reports on irregular conduct, corruption, fraud, safety hazards and data security incidents. All reported cases are independently reviewed and strictly kept confidential. Retaliation against bona fide whistleblowers is prohibited. All clues are registered, verified, investigated and followed up to form a closed-loop management process. The Company adheres to the presumption of innocence to ensure impartial and standardized investigation procedures.
Reporting Method: Submit reports via official corporate email. Anonymous submission is supported, and case progress can be tracked through exclusive case numbers.
Compliance Training, Auditing and Continuous Improvement
The Company operates a systematic compliance training program covering new employees, key positions, management teams and overseas staff. Regular internal compliance audits are performed to inspect business processes, policy implementation and risk status. The Compliance Policy is dynamically updated in response to legislative changes and business development. The Company optimizes operational workflows, continuously improves compliance capabilities, and rectifies abnormal incidents thoroughly to prevent recurrence.
Code of Interpretation and Policy Revision
This Compliance Policy is interpreted and maintained by the Compliance Management Department of Shanghai Dingwujin Chemical Co., Ltd. The Company reserves the right to revise this Policy in accordance with updated laws, regulations and business demands. All revised versions will be published on the official website and take effect immediately upon release. Continued business cooperation and website usage constitute acceptance of the latest policy terms.
Shanghai Dingwujin Chemical Co., Ltd.
Last Updated: 2026