STOCK CODE

REPORT FRAUD

FRAUD REPORT

2024.02.27

Report Policy


1. Purpose

1.1 TOPBAND adheres to the business ethics and corporate governance standards of integrity, reliability, compliance, and transparency. We welcome employees and external parties to report fraud and other violations committed by the employees of our company and its affiliated company in business activities;

1.2 This policy aims to clarify TOPBAND's policy and commitment to reporting and protecting whistleblowers, and to provide detailed instructions on how to report fraud and other violations;

1.3 This policy applies to the employees of TOPBAND and its subsidiaries (including ordinary employees, directors, supervisors, and senior executives), and to third parties (such as customers, suppliers) who have dealings with TOPBAND.


2. Reporting Matters

The whistleblower (including but not limited to employees of TOPBAND or third parties) may report any related fraud and other violations, including but not limited to the following:

2.1 Violation of TOPBAND's Code of Business Conduct, which outlines TOPBAND's principles regarding business ethics, conflicts of interest, anti unfair competition, anti bribery, trade secrets, employee equality, safety, health, and personal privacy protection, including but not limited to the following actions:

1) Using one's position and influence to obtain undue benefits;

2) Accepting kickbacks, benefits, or other improper benefits in economic transactions;

3) Accepting bribes, introducing bribes, or participating in fraudulent transactions;

4) Embezzlement, misappropriation, misappropriation, or theft of company assets;

5) Implementing related party transactions or violating conflict of interest policies;

6) There is retaliation that damages the company's reputation;

7) Encircling, colluding, or intentionally leaking the bid price during the bidding process;

8) Intentionally disclosing trade secrets;

9) Other fraudulent, illegal, or unethical behaviors.



3. Policies to Protect Whistleblowers

3.1 Confidentiality of Reporting: Except for disclosure in accordance with legal provisions or referral of fraud cases to judicial departments for processing, Tuobang will keep confidential the reported materials received; Strictly keep confidential the identity information of the whistleblower, and only the whistleblower administrator has the authority to access the whistleblower email and other reporting media;

3.2 Prevention of retaliation: Tuoban ensures that whistleblowers who truthfully report under this policy receive fair treatment, including protecting whistleblowers from unfair dismissal, persecution, or improper punishment. Seriously deal with acts of retaliation against whistleblowers and witnesses;

3.3 Real name priority: Encourage real name reporting, facilitate contacting the informant to understand the reported matter, and provide feedback on the investigation results to the informant;

3.4 Anonymous reporting: If the informant is unwilling to disclose their identity, they can report anonymously.



4. Reporting Method

4.1 Email Report

tbjb@topband.com.cn


4.2 Telephone Report

Shenzhen and other regions/countries:

Telephone: 0755-27651888-8040

Mobile: (+86) 13538296472


Huizhou area:

phone: 0752-3315188-5217

Mobile: (+86) 13570800705

4.3 Letter Report

Audit Center, Shenzhen Topband Co., Ltd,

Liyuan Industrial Zone, Tangtou Village, Shiyan Town, Bao'an District, Shenzhen (Postal Code: 518108)

4.4 Reporting Box

There are reporting boxes located diagonally opposite the company's Phase I Human Resources and next to the small stir fry shop on the first floor of the cafeteria.

4.5 Online Report

Audit WeChat official account:


4.6 If one reports the fraud problem to the employee’s direct superior or department supervisor, the superior or department supervisor must transfer the reported problem to the audit center.


5. Investigation and Handling

The audit center strictly keeps confidential the information of real name whistleblowers, and conducts objective investigations based on the clues provided by the whistleblowers. If verified, fines, dismissals, and dismissals will be imposed at the company level depending on the severity of the circumstances. If the circumstances are particularly serious or severe, the company will transfer them to judicial authorities for processing.


6. Reward Management

The company encourages real name reporting, and the clues provided by real name reporting should be based on facts, truthful, objective, and detailed. Once the audit department of the company confirms that it is an improper and fraudulent behavior, the company will reward the real name whistleblower with a maximum of 200000 RMB. Please refer to the following for details. For individuals who maliciously provide false clues or intentionally defame, the company will hold them legally responsible depending on the severity of the situation.


The specific reward amount details for reporting are as follows:

2.1 If the reporting of one of the above contents is verified by the company as a general fault (only for internal punishment such as demerit, dismissal, etc., which does not constitute a crime), or causes actual loss and recovers within 100,000 yuan, the company will give the informant a reward of 500 yuan to 10,000 yuan for the level of the reporting clues.


2.2 If the reporting of one of the situations in the above 2.1 is verified by the Company and causes certain losses, the circumstances are serious mistakes and constitute a crime, the informant is transferred to the judicial organ to meet the filing standards, or the actual losses are caused and the recovery is 100,000-200,000 yuan, the Company will give the informant a reward of 50,000 yuan each time.

2.3 If the reporting of one of the above contents is verified by the company as a general fault (only for internal punishment such as demerit, dismissal, etc., which does not constitute a crime), or causes actual loss and recovers within 100,000 yuan, the company will give the informant a reward of 500 yuan to 10,000 yuan for the level of the reporting clues.

2.4 If the reporting of one of the situations in the above 2.1 is verified by the Company and causes certain losses, the circumstances are serious mistakes and constitute a crime, the informant is transferred to the judicial organ to meet the filing standards, or the actual losses are caused and the recovery is 100,000-200,000 yuan, the Company will give the informant a reward of 50,000 yuan each time.