CITIC Securities Company Limited (hereinafter referred to as “CITIC Securities”, or the “Company”) formulates this policy in accordance with the Company’s Employee Compliance Code. The purpose of this policy is to elucidate the Company’s policy and commitment to whistleblowing-related procedures and whistleblower protection, with an aim to further foster a culture of compliance and to optimize internal management standards.

I. Whistleblowing

Employees are obligated to report all violations or other related matters found during business operations to their department’s Compliance Officer, the Executive Officer, the Compliance Department, the Compliance Director, or Senior management.

Employees who file an internal report must provide required explanatory and supporting materials on paper.

II. Violations

Violations include, but are not limited to, the following:

·       Misconducts in financial reporting or internal controls;

·       Criminal offenses or violations of legal or regulatory requirements;

·       Commercial bribery, corruption, abuse of power for personal gain, improper transfer of benefits, or other unethical behaviors;

·       Misappropriation of company property;

·       Acts that endanger the health and safety of others;

·       and intentional concealment of any of the above acts.

III. Confidentiality Requirements

The Company shall keep the identity of the whistleblower, the matters reported, and the reporting information confidential, except in cases where disclosure is requested by authorities such as judicial authorities, disciplinary and regulatory agencies, and in accordance with relevant laws, regulations, and rules.

Departments and employees shall not disclose any reporting and investigation information to the person being reported or investigated. Whistleblowers and those who hold different opinions shall not be threatened and retaliated against. The whistleblower shall also keep his or her reported acts confidential from hindering the investigation.

IV. False Reporting

The Company strictly prohibits any employees from making false reports and abusing the internal reporting mechanism out of malice, or for illegal purposes such us personal gain. Employees who deliberately make false accusations and malicious reports, create disturbance in the name of reporting, or interfere with business development will be subject to disciplinary action, or will be dismissed in accordance with the relevant provisions of the Company's disciplinary violations.

V. Reporting Channels

The Company accepts complaints and reports from clients regarding the practices of employees. Such reports may be submitted in writing to the Company’s Compliance Department or by appointment in person.

The Company Compliance Department can be contacted via the address below:

Address: Compliance Department, CITIC Securities Tower, No. 48 Liangmaqiao Road, Chaoyang District, Beijing

Postal code: 100026