Modern Dairy Whistleblower Protection Policy

1. Introduction

Modern Dairy (hereinafter referred to as “the Company”) is committed to complying with the law and ethical conduct in all its activities, and requires its directors, senior management, and employees to act in accordance with applicable laws, regulations and policies, and to adhere to high standards of business and personal ethics in the performance of their duties and responsibilities. The Company encourages employees to report any actual or suspected violations of the law, regulations, policies or ethical standards by the Company, its Party organizations, Party members or employees. The Company also welcomes constructive criticism and suggestions for its anti-corruption and integrity-building work.

2. Reporting

The sources of reporting mainly include letters, phone calls, visits, online reporting, etc. The Discipline Inspection Office assigns a person in charge to handle the reports according to the level of management authority. The scope of handling includes:

Allegations of violations of Party discipline by Party organizations, Party members or employees.
Reports of employees failing to perform their duties in accordance with the law, violating rules of integrity and self-discipline and professional ethics, such as information technology network security fraud, code violations, non-compliance with appropriate codes of conduct, or suspected of crimes such as corruption, abuse of power, dereliction of duty, embezzlement, interest transfer, favoritism, etc.
Grievances by Party members or employees who disagree with the disciplinary sanctions or decisions made by the Discipline Inspection Office for violating discipline.
Grievances by employees who disagree with the handling decisions made by the Discipline Inspection Offices at various levels.
Criticism and suggestions for the anti-corruption and integrity-building work.

Employees who wish to report improper conduct should follow these steps:

Contact the Discipline Inspection Office directly through any of the above methods. Provide as much detail as possible about the nature, time, place, and personnel involved in the improper conduct. If any, attach any relevant evidence or documents.
If employees are reluctant to contact the Discipline Inspection Office directly, they can report to their immediate supervisor or manager, who will forward the report to the Discipline Inspection Office.
If employees are dissatisfied with the response from the Discipline Inspection Office or their supervisor or manager, they can report the matter to higher-level leaders within the Company or external agencies, such as law enforcement or regulatory authorities.

3. No Retaliation

The Company protects the confidentiality and anonymity of whistleblowers and prohibits any retaliation or discrimination against them. The Company promptly and thoroughly investigates all reports and takes appropriate measures to address any issues or concerns. The Company ensures that whistleblowers will not be treated differently or harmed after reporting. The Company also provides emotional support and legal consultation to help protect whistleblowers from retaliation.

The Company defines any adverse actions taken against whistleblowers because of reporting as retaliation, such as:

Dismissal, demotion, suspension, transfer, or reassignment.
Harassment, intimidation, threats, or coercion.
Reduction or denial of benefits, wages, or bonuses.
Negative performance evaluation or disciplinary action.
Isolation or exclusion from work-related activities or opportunities.
Any actions that affect the employment status or working conditions of whistleblowers.

The Company does not tolerate any retaliation against whistleblowers and will take disciplinary action against anyone who engages in such behavior. The Company will also take measures to restore the status and reputation of whistleblowers if they have suffered any retaliation.

4. Investigation

The Discipline Inspection Office is responsible for investigating and handling reports. The investigation process involves collecting evidence and information about the personnel, events, or situations to answer questions or resolve issues. The investigation may include interviews, documents, and other techniques for collecting evidence. The investigation results are usually presented in the form of a report or other document.

Fairness: The investigation will be conducted fairly, objectively, without bias or prejudice. Whistleblowers and accused will have equal opportunities to present their views and evidence.
Confidentiality: The investigation will be conducted discreetly, confidentially, respecting the privacy of all parties involved. The identities of whistleblowers and accused will be protected as much as possible unless disclosure is required by law or necessary for the investigation.
Timeliness: The investigation will be conducted as soon as possible, without compromising its quality or integrity. Whistleblowers and accused will be informed of the progress and results of the investigation in a timely manner.
Accountability: The investigation will be conducted professionally, responsibly, following established procedures and standards. The investigators will record all the steps and decisions taken during the investigation. The investigators will also report any findings or recommendations to the appropriate authorities for further action.

5. Consequences

Whistleblowers should report truthfully, and not fabricate facts or evidence, or falsely accuse others. Those who intentionally make false allegations or damage the reputation or interests of others will be subject to disciplinary action or legal liability. Those who obstruct, suppress, conceal, or retaliate against whistleblowers will also be subject to disciplinary action or legal liability.

The Company will take appropriate actions against those who are found to have violated the law, regulations, policies, or ethical standards, depending on the severity and nature of the misconduct. These actions may include:

Warning, admonition or condemnation.
Suspension, demotion, or dismissal.
Recovery of losses or compensation.
Referral to law enforcement or regulatory authorities for criminal or civil prosecution.

The Company will also take measures to prevent similar misconduct from happening again, such as:

Reviewing and revising policies and procedures.
Providing training and education on laws, regulations, and ethics.
Strengthening internal controls and oversight mechanisms.
Improving communication and feedback channels.