As a renowned international contractor, China First Highway Engineering Co., Ltd. (CFHEC) is committed to establishing a compliance program covering both domestic and international business operations, maintaining a leading position and aligning with best practice. In recent years, the Company’s compliance program has been continuously improved and enhanced. Significant achievements have been made in updating and releasing multi-language versions of the “1+7” compliance policies, piloting the overseas compliance management IT system, and strengthening compliance training and communication. These efforts have received high praise for implementing international best practices and meeting Multilateral Development Bank compliance standards.
To thoroughly implement the requirements of establishing a rule-of-law country, a rule-of-law central SOE, a rule-of-law CCCC, and to continuously strengthen the initiative of building a “law-governed CFHEC” thereby strengthening the legal foundation for the Company’s high-quality development, we hereby issue the following initiative to all employees:
I. Uphold Professional Dedication and Reinforce Compliance Responsibilities
All employees shall promote a work ethic of “loyalty, pragmatism, integrity, and responsibility” and adopt a simple, direct, and efficient approach to work. They shall remain committed to their roles and responsibilities and integrate compliance requirements into job duties and business processes, ensuring clear accountability, standardized procedures, and effective execution. All employees shall strictly comply with applicable laws and regulations as well as regulatory requirements; adhere to international treaties, commercial practices, and industry standards; and observe the Company’s articles of association and internal rules and policies. With respect to key business areas such as project bidding, business partner management, information disclosure, and external communication, all employees shall rigorously follow internal policies and approval procedures, strengthen risk identification and preventive controls, and address issues at the source and eliminate potential risks at an early stage, thereby reinforcing compliance accountability through high standards of execution.
II. Uphold Integrity and Build a Compliance-Oriented Brand
All employees shall foster a strong awareness of rules and a firm commitment to obligations, strictly comply with the laws and regulations of host countries, internationally recognized rules, and the Company’s compliance requirements, engage in market competition fairly and in accordance with applicable regulations and perform contractual obligations in accordance with applicable laws and regulations. Any form of fraud, corruption, commercial bribery, or improper transfer of benefits is strictly prohibited, and a “Zero-Tolerance” approach shall be maintained. All employees shall adhere to the Code of Conduct and compliance policies, continuously strengthen their understanding and application of applicable laws and regulations, international practices, and internal compliance requirements, and cultivate a culture of compliance that is embraced by all employees, across all areas, and throughout all processes. Through concrete actions, they shall establish and safeguard the Company’s reputation and compliance brand in the international market.
III. Strengthen Supervision and Improve Compliance Framework
The Company shall continue to enhance the coordinated operation of the “three lines of defense” in compliance management and further drive the continuous improvement of the compliance system. Supervisory functions shall be exercised from the top down, while self-assessment responsibilities shall be discharged proactively at all levels and extended across all operations, forming a closed-loop management mechanism encompassing issue identification, rectification, and follow-up evaluation. All employees shall proactively identify risks, promptly report irregularities, and make effective use of compliance consulting and reporting channels to prevent and mitigate compliance risks. Efforts shall be made to continuously optimize the compliance program in practice, shifting the focus from “establishing rules” to “ensuring effective implementation and outcomes”, thereby providing sustained and robust support for the Company’s long-term and stable operations in the global market.
Let us take action together to seize the opportunities of the 15th Five-Year Plan, guide reform and development through the rule of law, and strengthen the Company's international image through an unwavering commitment to compliance and rules-based conduct. At a higher starting point, we will advance the Company’s legal and compliance framework, integrate compliance principles into corporate governance and global operations, and promote a more proactive and precise approach to compliance and risk management. These efforts will lay a more solid legal and compliance foundation for achieving the Company’s strategic objectives of “Five New Accelerators, Four High Standards, and Three Leadership Initiatives”.
