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 Commission Office assigns a person in charge to handle the reports according to the level of management authority. The scope of handling includes:

Accusations and complaints against Party organizations and Party members for violating Party discipline.
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 Commission Office for violating discipline.
Grievances by employees who disagree with the handling decisions made by the Discipline Inspection Commission 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 Commission 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 Commission Office directly, they can report to their immediate supervisor or manager, who will forward the report to the Discipline Inspection Commission Office.
If employees are dissatisfied with the response from the Discipline Inspection Commission 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 Commission 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.

4.1 Receipt: The contact information for our Discipline Inspection Commission Office is posted on bulletin boards near our farms, at farm gates, in cafeterias, and other locations. Our employees, contractors, local community members, and stakeholders can all access the reporting contact information for all our farms and can submit reports to our Discipline Inspection Commission Office via phone or email. The Discipline Inspection Commission Office will provide feedback on the acceptance of reports to the real-name reporter within fifteen working days of receipt and will record the content, date, time, and location of the report. The Discipline Inspection Commission Office is responsible for receiving all reports and ensuring the confidentiality and protection of the reporter’s information and the details of the received reports.

Discipline Inspection Commission Office:

Email: jijianjubao@modernfarming.cn
Phone: 18655597719

4.2 Verification: For the handling of real-name reports, before investigation, a meeting with the reporter is required to understand the case leads in detail. When meeting with a real-name reporter, staff should first identify themselves, then verify the other party’s identity documents. When communicating with the reporter, two staff members should be present. If communication is by phone, a work phone should be used, and a record of the communication should be kept. For major sensitive matters, confidentiality requirements should be explained, and a confidentiality commitment letter should be signed with the reporter. For letters and online reports signed by multiple people, the handler may select one of them for communication and verify and inform 1-2 representatives chosen by them. Reporters can submit reports anonymously. The company understands that in some circumstances, reporters may fear exposure of their identity and choose to report anonymously. The Discipline Inspection Commission Office will do its best to investigate anonymous reports, but anonymous reports may be limited in the depth and breadth of investigation due to a lack of further information.

4.3 Handling of Problem Leads: The Discipline Inspection Commission Office shall comprehensively analyze problem leads in conjunction with the overall situation of the regions and departments involved, and handle them in four ways: conversation and inquiry, preliminary verification, temporary retention for investigation, and conclusion. The handling of leads shall not be delayed or accumulated. Handling opinions shall be put forward within 1 month from the date of receiving the problem lead, and a handling plan shall be formulated, and approval procedures shall be completed.

Conversation and Inquiry: Refers to a method of handling problem leads through conversations and letters. Leads suitable for conversation and inquiry are primarily those reflecting general issues that, if clarified, would only warrant minor disciplinary action or criticism and education, or those reflecting unsubstantiated issues that need clarification; or vague issues, mostly hearsay or subjective speculation, that are difficult to verify.
Preliminary Verification: Refers to the activity of the Discipline Inspection Commission Office conducting preliminary checks and verification of leads regarding disciplinary violations by personnel under its jurisdiction. Its task is to ascertain whether problem leads exist and to provide a basis for whether or not to file a case. For problem leads involving suspected disciplinary violations or job-related illegalities or crimes that are verifiable, preliminary verification work shall be carried out diligently, and objective evidence shall be collected to ensure truthfulness and accuracy.
Temporary Retention for Investigation: Refers to cases where the issues reflected in the leads, although having a certain verifiability, are temporarily not suitable for verification due to various reasons such as timing, existing conditions, or the temporary unavailability of the involved parties, and are therefore stored for future reference. Based on the principle that leads should not be delayed or accumulated, once conditions are ripe for leads that have been temporarily retained for investigation, verification work should be initiated immediately.
Conclusion: Refers to a method of handling leads where the issues reflected are untrue or it is impossible to carry out verification work, including situations where there are disciplinary facts but the circumstances are minor and do not require accountability.

4.4 Investigation Report: After the investigation, the Discipline Inspection Commission Office will submit a detailed investigation report to the company’s senior management and/or Board of Directors, and Party Committee, based on the investigation results. The report will include factual findings, evidence analysis, conclusions, and recommended corrective or disciplinary measures. For acts constituting a crime, the company will transfer the case to judicial authorities in accordance with the law.

4.5 Notification: The Discipline Inspection Commission Office shall notify the real-name reporter of the handling result within 15 working days from the date of completion.

4.6 Appeal: If the appellant is still dissatisfied with the handling result of our Discipline Inspection Commission Office, they can appeal to a higher-level disciplinary inspection department, and we will implement the results of the review and investigation by the higher-level disciplinary inspection department.

5. Training

When conducting various integrity trainings, the company will integrate training content on the reporting mechanism. These trainings aim to enhance the awareness and trust of all employees in the reporting mechanism, encouraging them to actively and correctly use reporting channels when discovering misconduct. The training content will cover the promotion of this whistleblower protection policy, detailed introduction of reporting channels, clear explanation of reporting procedures, and popularization of the rights and obligations of reporters.

6. Consequences

Reporters shall report truthfully and shall not fabricate facts or evidence, or falsely accuse others. Individuals who intentionally make false accusations or harm the reputation or interests of others will be subject to disciplinary action or legal liability. Individuals who obstruct, suppress, conceal, or retaliate against reporters will also be subject to disciplinary action or legal liability.