商业行为准则

XXX公司业务行为准则Code of Business Conduct

目录

Table of Contents

总则/General Provisions (3)

合法合规/ Compliance with Laws and Regulations (4)

利益冲突/Conflict of Interest (4)

礼品与利益/Gifts and Favors (5)

外部行为和董事任职/Outside Offices and Directorships (5)

内幕信息/Insider Information (6)

保密信息/Confidential Information (7)

隐私权指引/Right to Privacy Guidelines (7)

计算机系统安全/ Computer Systems Security (8)

雇用实践/Employment Practices (9)

环境/Environment (10)

交易实践/Trade Practices (10)

保险实践/Insurance Practice (10)

及时沟通/Prompt Communications (10)

外部人员与机构关系处理/Dealings with Outside Persons and Organizations (11)

记录和报告/Records and Reporting (11)

公司资金/Company Funds (12)

遵守准则/Compliance with the Code (12)

总则/General Provisions

本准则广泛陈述了能使xxx（以下统称“XXX”）持续成为最佳诚信公司的商业行为和个人道德类型。如大家所知，公司是所有员工行为的共同载体。本准则提供了全体员工需遵守的正式行为指引。

The Code sets out, in very broad terms, the type of business conduct and personal ethics which is required of you in order for XXX (hereinafter …XXX?) to continue to be regarded as a company of the utmost integrity. As you well know, the company is a reflection of the conduct of all of us who manage its affairs. The Code is a means of providing formal guidelines on the behavior which is expected of all our staff.

XXX在业务行为方面致力于达到法律和道德标准的最高准绳，希望成为并被认可为良好的企业法人和能够公平、公正地对待客户与员工的企业。本准则的目的是帮助每一位员工了解应遵循什么样的行为方式，以及建立最低行为标准。本准则适用于全体员工以及代理人员（以下统称“员工”）。"直系亲属”包括配偶、父母、岳父岳母和子女。所有员工要认真学习准则，依据准则行事，这样，XXX才能持续地获得广大客户与公众的普遍信任和信心。

XXX is committed to the highest level of legal and ethical standards in the conduct of its business and wishes to be and be known as a good corporate citizen and a company which deals fairly and equitably with its clients and employees. This Code of Business Conduct is intended to assist each member of the organization to know what is expected, and it sets out our minimum standards of behavior. The Code applies to all employees of XXX and agents (hereafter “employee”). The words “immediate family” includes spouse, parents and children. All employees are required to study the Code carefully and to be guided by its principles so that XXX may continue to earn the trust and confidence of its clients and the public at large.

以下是本准则的基本原则：

The following is the general provisions of the Code:

1. 遵守当地法律法规和职业行为标准；

We will comply with all applicable laws, regulations and professional conduct standards in every district in which we operate.

2. 为客户提供高标准的服务，尊重他们的利益，力求通过我们的服务来满足客户需要；

We will provide high standards of service to all of our customers, respecting their interests and aiming to meet their needs with the services we provide to them.

3. 避免个人或财务的利益冲突，诚实道德地处理冲突并进行恰当披露；

We will avoid personal or financial conflicts of interest and handle actual or perceived conflicts honestly and ethically, making all appropriate disclosure.

4. 不会因为给予或接受客户、供应商及其他与我们打交道的人的任何优惠待遇而妥协；

We will not be compromised through any preferential treatment given to or accepted from customers, suppliers or other people with whom we deal.

5. 诚实、准确地与利益相关者沟通；

We will communicate honestly and accurately with all of our stakeholders.

6. 对我们所在地区的社会与经济做出贡献。

We will contribute to the social and economic wellbeing of the communities where we have operations.

7. 公平对待员工，支持他们持续学习和不断发展。

We will treat our people fairly and support their ongoing learning and development.

合法合规/ Compliance with Laws and Regulations

XXX及其员工必须遵守中国的法律法规。XXX业务需遵守非常复杂及多变的法律法规，任何员工在无法确定法律法规的适用性和解释时，应从合规与运营风险部或法务部获得帮助。

XXX and its employees must comply with all laws and regulations governing XXX's business in China in which we operate. Our operations are subject to very complex and changing laws and regulations and, if an employee is in doubt about the application or interpretation of any legal and regulatory requirement, the matter should be referred to the Compliance & Operational Risk and Legal.

利益冲突/Conflict of Interest

员工需要注意，在其职权范围内采取的行动或做出的决定不能与XXX及其客户的利益相冲突。Employees are required to see that actions taken and decisions made by them within their jurisdiction are free from the influence of any interest which might reasonably be regarded as conflicting with the interests of XXX and its clients.

相应地，必须恪守以下原则：

In this connection the following principles must be adhered to:

1. 个人或外部活动不能直接或者间接与员工在XXX的职责相冲突。因此，员工应该避免任何与

其工作职责发生或可能发生利益冲突的情形。

Personal or outside activities must not conflict, either directly or indirectly, with an employee's duties to XXX. Employees should, therefore, avoid situations in which their personal interests conflict, or are likely to conflict, with their duties to XXX.

2. 员工不得参与可能导致以下情形的XXX外部的个人、商业及投资活动：

No employee should participate in a personal, business or investment activity outside XXX which would tend

(1) 花费过多的时间和注意力从而无法以最佳状态为其在XXX的岗位服务；

To create an excessive demand upon his or her time and attention and thus deprive

XXX of his or her best efforts on the job; or

(2) 造成利益冲突- 这是指，可能妨碍其做出对XXX利益最大化的独立判断的义务，利益

或其他干扰事项。

To create a conflict of interest - that is, an obligation, interest or distraction which

would interfere with the independent exercise of his or her judgment in XXX's best

interests.

员工个人行为、商业活动或者其他外部行为与XXX的商业利益，或与其已知的XXX正在酝酿的

业务发生或具有潜在利益冲突时，必须及时地向其直接主管汇报。

An employee who has a conflicting or possibly conflicting interest between his or her personal, business or other outside activities and any business interest of XXX or any transaction which he or she knows is under consideration by XXX must make timely disclosure in that connection to his or her immediate superior.

礼品与利益/Gifts and Favors

员工及其直系亲属不得接受或赠与任何正在与XXX从事业务或进行商务谈判的人员的礼品和好处。赠与或收受礼品和好处必须符合XXX《礼品政策》。这个规则并不是禁止正常的和广泛接受的地方商业惯例，比如商务用餐和招待，包括纪念品或有象征性意义的礼物。然而，任何可能被认为是贿赂和暗中给付的行为是被禁止的。应当避免存有疑点的礼品和好处。员工尤其要防止因为产生感激之情而影响业务判断的情形发生。

Employees and the members of their immediate family must neither accept nor be a party to giving gifts and favor from or to any one with whom XXX is doing or negotiating business. The activities of gift and favor offering and receiving must comply with the Gift Policy of XXX. This rule is not intended to prohibit normal and widely accepted ethical business practices such as business meals and receptions, including mementos or gifts of nominal value. However, anything which could be considered as a payoff or secret compensation is prohibited. If in doubt, the gift or favor should be avoided. In particular, employees should guard against any situation where their business judgment might be influenced by a feeling of gratitude.

对供应商，承包人及其他任何被XXX确定为供货商或服务商的公司和或个人的选择须遵守XXX 采购政策，并且只能基于最优价格、高性能和诚信做出决定。在考虑签署此类合同或采购物品或服务的过程中，绝对不能接受礼品、好处及其他个人利益与优惠。

The selection of suppliers, contractors and any other firms or individuals retained by XXX for the purchase of goods or services is to be made in accordance with XXX's purchasing policy and solely on grounds of the best available price, superior performance and integrity. Gifts and favors and other personal benefits or advantages must not be accepted in consideration of the granting of such contracts or the purchase of goods or services.

外部行为和董事任职/Outside Offices and Directorships

员工有为XXX赢得良好公共关系的职责。员工帮助慈善及教育活动可以给XXX带来良好声誉，应该得到鼓励。

Employees of XXX have a very real responsibility for good public relations. Their readiness to help with charitable and educational activities has brought great credit to XXX and should be broadened and encouraged.

在某些情况下，员工担任企业董事与XXX利益可能是一致的。担任外部企业董事必须经过XXX 总经理事先同意。然而，任何有损员工履行其在XXX的职责能力的外部活动，或与工作职责冲

突的情况都应避免。如果对员工是否正在考虑上述外部行为抱有疑问，应立即向部门负责人汇报。In some cases, it may be consistent with XXX's interests for employees to serve on the boards of business enterprises. Prior approval to serve on the board of an outside business enterprise must be obtained from the General Manager. However, any outside activities which impair an individual's ability to attend to company duties, or which might conflict with his or her duties on behalf of XXX, should be avoided. If there is any question about any such outside activities being contemplated by an employee, the head responsible for his or her department should be promptly informed.

内幕信息/Insider Information

员工不能使用自己在雇用期间获得的尚未公开的重要信息（一般称之为“内幕信息”）为自己或他人牟利，例如亲戚朋友。将内幕信息泄漏给其他个人或公司的行为是违法行为，会给个人和公司带来严重后果。

Employees shall not use material information gained in the course of employment (commonly referred to as "insider information") and which is not generally known to the public for personal gain or the advantage of others such as friends and relatives. Passing insider information to another person or company is illegal and an employee who does so could expose himself or herself and/or company to heavy damages.

“重要信息”包括重要事实以及涉及某企业当前或未来的财务状况、产品与服务、证券市场、XXX针对该企业的投资及投资意向等有关的重要变化。未经广泛披露的，或者以一个具备正常理性的人在决定是否买卖或者持有证券时作为重要因素考虑的信息都被认定为是重要信息。"Material information" may include information about a material fact or material change regarding the financial condition, present or future, of a business enterprise, its products and services, the market for its securities or XXX's investments or investment intentions with respect to such enterprise. Information will be deemed "material" if it has not been generally disclosed and a reasonable person would consider it important in deciding whether to purchase, sell or hold any securities.

员工不允许利用重要信息为自己或其直系亲属的账户交易有价证券。

No employee may trade in securities for his or her account or the account of any member of his or her immediate family on the basis of material information.

员工知道或者有理由认为XXX正在进行或积极协商对某种证券的买卖或其它投资行为时，不得在XXX此项买卖完成前直接或间接地用自己或者直系亲属的账户买卖该证券。

An employee who knows or has reason to believe that XXX is purchasing, selling or actively negotiating with respect to a particular security or other investment in a business may not purchase or sell, directly or indirectly, the securities of that business for his or her own account or that of any member of his or her immediate family until after the completion of such purchase or sale by XXX.

任何员工或其直系亲属，不得从XXX的证券交易经纪人或任何其它与XXX有证券交易往来的机构获得任何超出普通投资人应该得到的利益。

No employee and any member of his or her immediate family can get benefit more than ordinary investors from the security brokers of XXX and any other institutions which have security transactions with XXX.

保密信息/Confidential Information

个人信息是人寿及健康险行业的基础。因此XXX必须确保遵守有关保护机密和敏感信息的规定。Personal information forms the basis of the life and health insurance industry. Consequently, XXX must ensure adherence to rules governing the protection of this confidential and sensitive information.

此外，员工在雇用期间获得的所有有关XXX的业务信息，包括计划、业务战略、产品开发计划、定价、系统、投资以及相关文件和未广泛公开的文件必须按照保密信息处理。这些信息不得被对外披露，员工不能利用其为自己及亲属朋友等牟利。传播或泄露这些信息会严重削弱XXX的竞争优势，在许多情况下可能还会导致利益冲突甚至交易失败。

In addition, all information acquired by employees during the course of their employment concerning XXX's business, including its plans, business strategies, product development plans, pricing, systems and investments as well as all documentation in that connection or that is not generally known to the public must be treated as confidential. Such information is not to be disclosed outside of XXX and employees may not use it for the personal advantage of themselves, their families, friends and associates. The circulation or leaking of some kinds of information could materially weaken XXX's competitive advantage and would, in many instances, give rise to conflicts of interest and even an aborted transaction.

隐私权指引/Right to Privacy Guidelines

XXX经营的保险业务的特点要求公司收集、运用及保管员工、公司个人客户的个人信息，并依法或经授权向第三方披露。员工的个人信息遵循与客户个人信息同样的隐私权指引。必须审慎掌握尺度以平衡对信息及个人隐私权、公正性以及干预最小化等方面的需求，并采取必要的预防措施保护这些利益。为此目标，XXX遵守以下原则：

The nature of the business of insurance as carried on by XXX requires that XXX collect, use and retain personal information about its employees and those individuals to and through whom XXX's services are provided and to disclose such information to third parties when authorized or required to do so by law. Personal information about our own employees is subject to the same privacy guidelines as personal information about our customers. XXX must balance carefully its need for such information against the individual's right to privacy, the need for fairness, and the need to minimize intrusiveness, and take necessary precautions to protect these interests. To that end, XXX will observe the following guidelines:

1. 只能通过合法途径获得个人信息。

Only lawful means will be used to collect personal information.

2. 避免蓄意拜访、虚假和误导等行为。

Pretext interviews and false and misleading practices will be avoided.

3. 收集个人信息的目的需在收集信息之时或之前说明，如该目的有任何变化需告知个人。

The purpose for which personal information is collected from an individual will be specified on or before the collection of information, and any change of purpose will be communicated to the individual.

4. 告知个人，XXX依法获得的其个人信息将被妥善保管。

Individual is to be informed that the personal information collected through lawful means will be properly secured.

5. XXX收集和保存的个人信息属于机密，XXX将提供适当的安全措施以保护其机密性。

Personal information that is collected and retained will be considered to be confidential and proper safeguards will be provided to protect that confidentiality.

6. 采取一切努力保证个人信息的收集、使用、保存及披露做到准确、及时、全面并符合XXX的

现行规范。个人可以修正或者澄清被XXX保存的其个人信息。

Every reasonable effort will be made to ensure that personal information collected, used, retained or disclosed is accurate, relevant to the effective conduct of XXX's business, timely and complete. An individual may correct or clarify personal information regarding him or her retained by XXX.

7. 对个人信息的披露和使用不得超出向个人说明的目的, 除非:

Personal information will not be disclosed or used for purposes other than those specified to the individual, except:

(1) 获得个人同意; 或

With the consent of the individual concerned; or

(2) 依据法律需要; 或

Where required by law; or

(3) 在合理地认为必要的情况下，决定是否具有保险利益，或在保险合同有关的事项中保

护XXX利益不受犯罪活动、舞弊和严重误导的损害。

Where reasonably necessary, to determine eligibility for an insurance benefit or, to

protect the interests of XXX against criminal activity, fraud, and material

misrepresentation in connection with an insurance contract

8. XXX员工、董事、经纪人、中介、代理或代表XXX的个人及组织也必须遵从上述指引。非XXX

员工的中介代理人员需与XXX签署包括上述指引内容合同。

All employees, directors, brokers, intermediaries and other persons or organizations acting for XXX or on its behalf will be required to conform to these guidelines.

Intermediaries of XXX who are not employees will be required to sign a contract which incorporates these guidelines.

计算机系统安全/ Computer Systems Security

XXX计算机系统安全对于XXX的持续成功经营至关重要。计算机资源的使用权限应受到限制而且只能依据XXX政策使用。有权使用者有义务对密码保密而且只能在业务授权范围内使用计算

机系统。包含敏感信息的计算机媒体在未使用时应总是处于锁定位置，所有保密级别的计算机数据，无论是纸质还是电子文档，必须时刻被安全保管。

The security of XXX's computer systems is crucial to the continued success of XXX. Access to our computer resources is restricted and they can only be used in accordance with company policy. Individuals who are granted access have an obligation to keep their passwords confidential and to limit their use of computer systems to authorized business purposes. Computer media containing sensitive information are to be kept in a locked location at all times when not in use; and all computer data of a confidential nature, whether in paper or electronic form, must be kept secure at all times.

员工在被雇用期间为XXX开发的程序和相关资料属于XXX财产，构成有价值的机要的商业秘密，必须妥善处理。

All computer programs and related materials developed by XXX employees within the scope of their employment on behalf of XXX are the property of XXX, constitute valuable and confidential trade secrets, and must be treated accordingly.

此外，根据许可权向XXX提供软件的外部供应商的所有权必须得到保护。全体员工都应保护这些程序的机密性，不得参与未经授权的复制或使用。在某些情况下，可以使用这些软件的员工需要根据XXX的许可协议签署正式保密协议，该协议必须严格遵守。

Additionally, the proprietary rights of outside firms which provide software to XXX on a licence basis must be protected. All employees are required to protect the confidentiality of such programs and must not participate in their unauthorized duplication or use. In some instances employees who have access to such software are required by XXX's licensing arrangements to sign formal confidentiality agreements which must be rigorously observed.

雇用实践/Employment Practices

在一个认可能力和绩效的挑战性工作环境中建立并且保持一套高效的组织机构是XXX的政策。开创并保持一种人文环境，使之能够推动和鼓励员工发展、高水平的个人和部门绩效、以及与职级相符的职权授予也是XXX的政策。

It is the policy of XXX to establish and maintain an efficient organization in a challenging working environment in which ability and performance are recognized. It is also the policy of XXX to develop and maintain a personnel environment which will promote and encourage opportunities for employee advancement, high individual and departmental performance levels and the implementation of an organizational hierarchy consistent with delegation of responsibility and accountability.

XXX所有的雇用行为，包括招聘、面试、薪酬及福利都必须依照相关法律法规进行。做出晋升决定必须基于工作绩效所证明的能力。XXX将遵循所有涉及雇用标准的相关法律，包括法定假日、最低工资，工作时数, 加班工资和产假。

All of XXX's employment practices, including recruitment, interviewing, compensation and benefits are to be conducted in accordance with Laws and Regulations. Promotions are to be made on the basis of ability demonstrated by work performance. XXX will also comply with all

applicable legislation relating to employment standards including statutory holidays, minimum wages, hours of work, holiday pay entitlement, and maternity leave.

任何关于歧视、骚扰或不公平待遇的投诉应该立刻向员工直接上级或人力资源总监报告。

Any complaints concerning discrimination, harassment or unfair employment practices should be reported immediately to the employee's immediate superior or Human Resources Director.

环境/Environment

XXX承诺遵循当地法律法规，通过减少和循环利用废物，安全处理有害垃圾等措施保护环境。XXX is committed to environmental protection through the reduction and recycling of waste and the safe handling and disposal of any materials which may be considered hazardous in accordance with applicable laws and regulations.

交易实践/Trade Practices

XXX及其员工应该避免从事任何可能被认为有失公平的交易行为，例如限定价格和其它导致减少竞争、欺诈、误导性宣传，对产品和服务的误导性和欺骗性描述及对其他保险公司的错误陈述等方面的行为。

XXX and its employees should avoid doing anything which might be considered as an unfair trade practice. Examples of unfair trade practices include price fixing and other acts which result in lessened competition, false or misleading advertising, misleading or deceptive representations concerning products and services and false statements concerning other insurance companies.

保险实践/Insurance Practice

除了遵循与交易有关的全部适用法律之外，XXX还承诺将遵循中国保监会有关公平保险行为方面的一切法令、法规和指引。监管禁止的保险行为包括但不限于：保费和佣金回扣、不当保单替换、展业中进行虚假或误导性的声明或陈述以及对保险合同进行非全面比较。XXX承诺公平理赔。

In addition to complying with all applicable legislation relating to trade practices, XXX is committed to compliance with all applicable insurance statutes and regulations and the guidelines of the CIRC with respect to fair insurance practices. Practices which are prohibited under the regulations include but not limited to: premium and/or commission rebating, improper replacement of insurance policies, making false or misleading statements or representations in the solicitation of insurance, and making incomplete comparisons of contracts of insurance. XXX is also committed to fair claims settlement practices.

及时沟通/Prompt Communications

与投保人、保单持有人、理赔求偿人、监管当局、公众和公司内部其他人员进行全面、准确、及时的沟通对于XXX的持续成功至关重要；而在业绩、效率和礼貌方面提供达标的服务是每一名

员工的责任。信息咨询和客户投诉必须及时处理。

It is essential to the continued success of XXX that communications with applicants, policyholders, claimants, governmental authorities, the public and others in the organization be conducted in a complete, accurate and timely manner; and it is the duty of each employee to furnish services that meet responsible standards of performance, efficiency and courtesy. A prompt response must be made to all requests for information and to all complaints.

与监管当局、董事会、合规人员，内部与外部审计人员的沟通必须全面、准确和及时。Communications with the governmental authorities, Board of Directors, compliance officers and internal and external auditors on all matters relevant to them must be complete, accurate and timely.

外部人员与机构关系处理/Dealings with Outside Persons and Organizations

在谈及与XXX业务无关的事项时，员工必须将其个人角色与其公司职务相区分。公司标识、办公用品、供应品及设备等不得用于个人事务。

Employees must take care when communicating on matters not involving company business to separate their personal roles from their corporate positions. Company identification, stationery, supplies and equipment must not be used for personal concerns.

员工不得以XXX名义就任何XXX业务事项发表公开言论。

When communicating publicly on matters that involve company business, employees should not presume to speak for XXX on any matter.

就新闻媒体向员工直接提出的涉及XXX的询问而提供任何信息或见解之前必须首先向公司市场部总经理报告。这样做是为了确保与公众的沟通时所代表的是公司立场而不是个人观点，同时也确保XXX机密信息不被公开。

Inquiries directed to an employee from the press or other media concerning XXX should be referred to the General Manager of Marketing before any information or opinion is given. This is essential in order to ensure that public communications regarding XXX represent the corporate position, as opposed to personal views, and to ensure that there is no public disclosure of confidential information.

记录和报告/Records and Reporting

各种形式的准确和可靠的记录对于XXX履行法律和财务义务以及管理公司事务是必须的。XXX 帐务和记录必须准确、及时地反映所有业务交易。

Accurate and reliable records of many kinds are necessary to meet XXX's legal and financial obligations and to manage the affairs of XXX. XXX's books and records must reflect all business transactions in an accurate and timely manner.

不得有未被披露或记录的资金或资产，所有收入和支出必须恰当记录。负责财务和记录保存的员

工在执行这些原则时应保持足够的警惕。

No undisclosed or unrecorded funds or assets are to be maintained and all revenues and expenses are to be properly recorded. Employees responsible for accounting and record keeping functions are expected to be vigilant in enforcing these principles.

公司资金/Company Funds

以任何形式使用公司资金的所有员工必须遵照指导手册和其他说明性材料来记录、处理和保护资金，在XXX指导手册或其它说明性材料中有此详细程序。员工因工作需要使用公司资金或发生费用以后需公司报销时，有责任从XXX利益出发做出正确判断，保证每一笔开支都有所值。公司资金只能用于公司目的而非个人利益。

All employees who have access to company funds in any form must follow the prescribed procedure for recording, handling and protecting these funds as detailed in XXX's instructional manuals and other explanatory materials. Where an employee's position requires the spending of company funds or the incurring of expenses to be later reimbursed by XXX, it is the individual's responsibility to use good judgment on XXX's behalf and to ensure that good value is received for every expenditure. Company funds must only be used for company purposes and not for personal benefit.

遵守严格的标准防范舞弊和失信是XXX的政策，当发现任何违规证据时都必须立即向公司合规与运营风险部总经理报告，以便及时展开进一步调查。

It is the policy of XXX to follow strict standards to prevent fraud and dishonesty and, where any evidence of an infraction is revealed, it should be reported immediately to the General Manager of Compliance & Operational Risk so that further investigation can be promptly initiated.

遵守准则/Compliance with the Code

本准则条款是强制性要求，在任何情况下都必须完全遵守。员工不仅应尊重准则字面意义，还应尊重准则所体现的精神。员工还要遵守监管当局、行业协会或者部门管理层制定的其他规则。The provisions of the Code are mandatory and full compliance is required under all circumstances. Employees will be expected to respect not only the letter but also the spirit of the rules set out in the Code. Employees may be subject to additional rules imposed by regulatory bodies, industry associations or departmental management.

本准则并不能详细规定我们所有业务行为方面的处理方法，而且有时很难确定采取何种行动是恰当的。在特定情况下对于本准则适用性有疑问的，应当向直接上级或者人力资源部咨询。违反本准则将导致惩戒行动，甚至包括解除雇用关系。任何人发现有违反本准则的情况发生，应及时向人力资源和合规与运营风险部报告。此类报告都将被极严格保密。

The Code does not attempt to deal specifically with all aspects of the conduct of our business, and certain situations may arise in which it is difficult to determine with certainty the appropriate course of action to follow. Anyone in doubt about the application of the Code to a

specific situation should refer the matter to his or her immediate superior or to Human Resources Department. Violation of the Code will result in disciplinary action which could include termination of employment. Anyone who is aware of a contravention of the Code should report the matter promptly to Human Resources. Any such report will be treated in the strictest confidence.

本准则的要求基于充分的法律实践和商业惯例。每位员工须每年做一次正式声明遵守该准则。相应地，员工亦需在对涉及其本人或直系亲属的其它与本准则条款明显相关的业务或行为发生时做出声明。

The Code's requirements are based on sound legal and business practice. Every employee is being asked to make a formal declaration each year regarding observance of the Code. In that connection, you will be asked to declare any business affiliations or activities in which you, or the members of your immediate family, are involved which could be of significance in relation to the provisions of the Code.

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