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    We abide by the laws and regulations related to business ethics in the countries and regions where we operate, such as the Anti-Unfair Competition Law of the PRC (《中华人民共和国反不正当竞争法》), the Regulations of the PRC on Administrative Penalties for Public Security (《中华人民共和国治安管理处罚条例》), the Law of the People’s Republic of China on Anti-money Laundering (《中华人民共和国反洗钱法》) and the Basic Norms on Internal Control of Enterprises (《公司内部控制基本规范》).The board of directors serves as the highest leadership body for anti-corruption work (including the management of related-party transactions),the audit committee is the supervisory body, and the audit department is the permanent institution for related work. The audit department is responsible for supervising related entities and their transactions involving the management, and reporting the fairness of related-party transaction pricing to the chairman of the board and the audit committee. The audit department conducts an audit of related-party transactions at least once a year, and the audit results are submitted to the board of directors for review.

The Group has adopted the Anti-Corruption Policy (《反贪污制度》) to prevent and control various corruption and fraud incidents such as commercial bribery, commercial benefit transmission and financial embezzlement. The Group has formulated the Administrative Measures for Rewards and Punishment of Employees (《员工奖惩管理办法》), the Measures for the Investigation and Administration of Fraud Cases (《舞弊案件调查管理办法》), the Commitment for Honesty in Key and Sensitive Positions (《关键敏感岗位廉洁从业承诺书》), the Integrity Report on Key and Sensitive Positions (《关键敏感岗位述廉报告》), the List of Negative Behaviors of Cadres (《干部负向行为清单》) and other policies. By doing so, the Group aims to give full play to the role of supervision in internal audits, regulate the investigation of corruption cases, and specify the responsibilities of different departments in investigating and handling cases and punishing undisciplined personnel. Conducting unannounced audits of high-risk subsidiaries on a quarterly basis.Anti-corruption performance has been included as a one-vote veto in the year-end assessment for the subsidiaries. The punitive clauses in the Administrative Measures for Rewards and Punishment of Employees are divided into six categories: work discipline, life discipline, security management, information security, favoritism and fraud (business ethics), and crimes against the law.Disciplinary results shall be used in performance appraisals, salary adjustments, merit awards, job and rank promotions, as well as dismissal, demotion or reduction in rank.

    In addition, we issued the Circular on Strengthening the Management over the Special Sunny Integrity Module (《关於加强“免费无码婬片AAAA片软件廉政专库”管理的通知》) to establish a mechanism for reporting to the module and improve the process for handling gifts and gratuities that cannot be returned. In 2022, the Group was the only Ningbo-based nominator for the Innovation Award at the third “Top Ten Innovation Experiences in Grass-roots Integrity Building (Zhejiang)”. During the Reporting Period, the Group was recognized as an “Outstanding Performer in Zhejiang Integrity Building”.  As of December 31, 2024, the Group has not incurred any fines, penalties, or settlement costs related to corruption.

    The Group comprehensively assesses the corruption risks of external stakeholders from aspects such as system construction, corruption investigation, and abnormal cooperation. We communicate the anti-corruption policy and continuously follow up through means such as anti-corruption publicity and education, integrity training, and sending integrity reminder emails before holidays.Concurrently, we require all suppliers to sign Integrity Operation Commitment Letter (《 誠 信 經 營 承 諾 書 》) and Social Responsibility Agreement (《社会责任协议》) as binding commitments to ethical business practices.

    During the Reporting Period, there were no concluded legal cases regarding corrupt practices brought against the Group or its employees and major non-compliance matters in the audit work.No lawsuits for discrimination or harassment, no lawsuits for breaches of private customer data.No incidents of conflicts of interest.No incidents of money laundering or insider trading.

Tax Strategy

    We believe that paying the tax honestly is a social responsibility which can promote the long-term sustainable operation of enterprises. The Group complies with the tax regulations of the countries where it operates and declares and pays all taxes and fees on time. We not  transfer value created to low tax jurisdictions;not  use tax structures without commercial substance;not  use secrecy jurisdictions or so-called "tax havens” for tax avoidance;undertake transfer pricing using the arm’s length principle.