Q：How does the company conduct supervision and audit on the business ethics policy and case investigations? (2)
A：In order to properly handle petitions, complaints and pointers to complaints, the disciplinary inspection and supervision body of the Company continuously reviews and improves the standard and process, optimizes the procedures, establishes clear authority limits, and enhances the quality and efficiency in accordance with the relevant regulations and work requirements of their supervising bodies. When handling petitions, complaints and pointers to complaints, the Company, in light of the information obtained from routine monitoring, studies the issue closely to determine the nature of the complaints reported, refines the standards for handling pointers to the complaints, so as to be effective in its ongoing monitoring. The Company then proposes appropriate remedial action timely. We have set up an electronic information system to achieve real-time supervision of any online information flow. For complaints and allegations relating to violation of rules and regulations, if the nature is not uncommon, give rise to negative impact, or have caused adverse effects, we track the handling process closely, and strictly review any outcome.
In terms of improving on-going monitoring, the Company strengthens the supervision of its managers at different levels and establishes a supervision mechanism in which they assume their respective responsibilities and share information. We organize and hold supervision coordination meetings on a regular basis, solicit opinions and suggestions, coordinate and solve any known issues, and promote the sharing of resources, information and achievements so as to form a joint force of supervision. We strengthen the supervision of the exercise of power, uncover potential issues in a timely manner, urge rectification, and seriously pursue liabilities. We focus on public holidays and other festivals, and issue notices stressing that it is strictly prohibited to accept dinner invitation, gifts or cash gifts from the service providers, and advocate anti-corruption during festive seasons. We build a long-term mechanism, uncover potential issues in a timely manner based on constant monitoring and review, formulate a black list, and use this as a deterrent.
In terms of anti-corruption education, the headquarters of the Company organize annual trainings for all staff through our compliance management information platform. Compliance requirements and concepts including business ethics are covered. All such training sessions are recorded. Each new employee would receive relevant compliance training before he/she starts work. Each business segment and subsidiary should, in light of actual situation, organize themed trainings on anti-commercial bribery, anti-monopoly and anti-unfair competition. The Company also regularly organizes online and offline trainings for suppliers and bidders to raise awareness and promote compliance of such requirements. Such training covers all suppliers.
Q：How does the company conduct supervision and audit on the business ethics policy and case investigations? (1)
A：We abide by the laws, regulations and international conventions such as the Supervision Law of the People's Republic of China and the United Nations Convention against Corruption, and strictly enforce various measures including the Punishment Regulations for Management's Violations and Non-compliance, the Compliance Management Measures, the Self-Discipline Convention Applicable to Bidding and Tender Activities, the Material Supplier Management Measures, etc., to regulate behavior of employees and of the Company.
In order to continuously improve our anti-corruption systems and procedures, the Company makes full use of the judicial systems and rules of law. In light of actual facts and circumstances, we formulated the Working Protocol for Disciplinary Inspection and Supervision Committee Handling Petitions and Reports, the Working Protocol for Disciplinary Inspection and Supervision Committee Handling Complaints and Procedures to Handling Evidence Relating to Complaints, and the Administrative Measures of the Disciplinary Inspection and Supervision Committee for Regulating Evidence Related to Complaints, to further standardize procedures, clarify authority limits, refine measures and enhance quality and efficiency. The Company fully demonstrates its desire and ability to uphold the Party's clean government directive and advocates anti-corruption mindset. It promotes connectivity within governance functions to joint force and collaborate. We search for potential risks and possible loopholes in the existing internal control system and work process, and accurately analyze and evaluate risk factors relating to compliance management. We issue and implement the Operation Work Manual of Policy-making System and Supervision System for Three Importance and One Greatness (trial implementation) (refer to Note 1 below). And we also highlight key areas, and rigorously investigate and deal with violations of rules and regulations, including abuse of power to transfer benefits to others, and bribery.
In terms of continuously intensifying the investigation and punishment of corruption cases, the Company undertakes the general strategy and strategic goal of promoting a system and mechanism that ensures no one dares, can, and is willing to be corrupted. In addition, we continue to strengthen the disciplinary inspection and supervision system. By focusing on key processes and critical areas, we give full respect to the specific role of supervision, cooperate with local disciplinary inspection and supervision authorities, and are determined to investigate and deal with all corruption cases.
Q：How does the company monitor the supplier's business ethics behavior?(2)
A：In terms of on-going supervision, the Company periodically monitors regulatory compliance of business partners and implements professional management and continuous supervision on them. The Company implements and carries out special measures to clamp down on benefit transmission, rent-seeking, and misappropriation of public property into private hands. The Company uses big data platforms to cross-correlate corporate information of traders, agents and suppliers in order to identify indicators to potential issues. The Company strengthens the functional application of the joint supervision information system and actively establishes supervising network to fully understand and continuously monitor and evaluate suppliers' trust-worthiness and regulatory compliance. Subsidiaries of the Company track and evaluate the performance of suppliers and undertake periodic compliance reviews as a key aspect when evaluating suppliers. The Company formulates measures for management of bidders' integrity, sets up a special area on PetroChina's electronic bidding platform and regularly updates those who are blacklisted. For those suppliers in the database that exhibit compliance, credit or integrity issues, the Company will, depending on the severity of the matter, discontinue use of these products or suppliers in one of four methods. These methods range from temporary suspension of product trading rights, temporary suspension of specific supplier's trading right, removal of the product from the Company's acceptable product catalogue and removal of the supplier from the Company's list of approved suppliers.
In terms of training and education, the Company provides induction training on business ethics, anti-corruption and Quality & HSE to all new suppliers and contractors upon registration onto the Company's system as qualified suppliers. The Company's values on operations and management will be conveyed during induction. The suppliers are required to sign letters of commitment upon admission as qualified suppliers. In addition, the Company also organizes regular online and offline trainings for suppliers to strengthen the awareness and to promote these compliance requirements.
For more information on the business ethics supervision and management of the Company, please refer to the Company's Environmental, Social and Governance Report 2020, pages 14-15.
Q：How does the company monitor the supplier's business ethics behavior?(1)
A：We strictly abide by lawful business ethics and fair trade. We adhere to the principles of honesty and trustworthiness. We respect bilateral consultation in order to achieve mutual benefit for common development. We promote transacting with the highest degree of integrity and transparency, with the objective to maintain fair and impartial competition in our business environment. We strictly comply with the Anti-monopoly Law of the People's Republic of China, the Anti-unfair Competition Law of the People's Republic of China, the Supervision Law of the People's Republic of China, the UN Guiding Principles on Business and Human Rights and other applicable laws, regulations and international practices on anti-monopoly, anti-unfair competition, anti-commercial bribery, extortion and fraud. We are against monopolistic acts. We are strongly against unfair competition in any form and we comply with all market restrictions. We do not conduct, participate in or support any forms of money laundering.
In terms of supplier selection, based on our Anti-Commercial Bribery Handbook, the Company would factor in "compliance with laws and regulations" as a prerequisite. The Company also conducts relevant due diligence procedures on the supplier in accordance with the Credibility and Compliance Handbook. The targets of such due diligence work would include agents, distributors, intermediaries, advisors, etc. The detailed procedural work would cover the relevant violations and liabilities claimed in the past, whether they have been blacklisted or not, relevant interests with the relevant government departments, compliance policies and measures, etc. Upon admission as a qualified supplier, the supplier would first sign a letter of commitment that it would abide by national laws and regulations and observe professional ethics when conducting business activities. It should not provide to any individual commission, kickbacks, gift certificates or matters of value or have any other misconduct in any form or for any reason, nor should extravagant entertainment be arranged. Once such violations have been proven, the Company will take the necessary remedial action including imposing sanctions or penalties. Meanwhile, the Company also incorporates compliance clauses into its standard contract template as an essential element, which specifies that contract counterparties should adhere to the principles of openness, fairness, impartiality and acting in good faith, strictly comply with laws, regulations and policies, and should not directly or indirectly grant any benefit to the Company or its personnel for illegitimate means.(To be continued)