Dongguan Zejin Biotechnology Co., Ltd. (hereinafter referred to as “the Company” or “we”), operating the cryozin website, is committed to becoming a trusted enterprise in the field of ice packs, cold and hot compress packs and other related products. We firmly believe that adhering to high standards of business ethics and strict compliance with laws and regulations are the cornerstones of the Company’s sustainable development, the guarantee of protecting the legitimate rights and interests of customers, partners, employees and other stakeholders, and the core of maintaining the Company’s reputation and brand value.
This “Business Ethics and Compliance” policy (hereinafter referred to as “the Policy”) clarifies the ethical norms and compliance requirements that the Company and all its employees, as well as partners involved in business activities, must abide by. It covers key areas such as integrity management, legal compliance, product quality, supply chain ethics, data privacy, anti-corruption and anti-bribery. All employees, management personnel, and business partners of the Company shall take this Policy as the basic code of conduct, consciously abide by and implement it, and jointly build a fair, transparent and compliant business environment.
1. Integrity in Business Operations
Integrity is the fundamental principle of the Company’s business operations, and we adhere to honest and trustworthy practices in all business activities:
Fair Transactions: When conducting business negotiations, product sales, and business docking with customers, partners and suppliers, we shall adhere to the principles of fairness, impartiality and openness, not engage in unfair competition, not manipulate prices, not distort market information, and ensure that all transactions are based on mutual consent and equal rights and obligations.
Transparent Communication: When introducing the Company’s products (including ice packs, cold and hot compress packs), technical parameters, product specifications, quotations, and after-sales services to customers, we shall provide true, accurate and complete information, and shall not make false propaganda, exaggerated promises or misleading statements. We shall clearly inform customers of product performance, scope of application, potential limitations and other key information to ensure that customers make informed decisions.
Honest Contracts: We shall strictly abide by the terms of contracts signed with customers, partners and suppliers, fulfill contractual obligations in good faith, and shall not unilaterally breach contracts, shirk responsibilities or evade obligations without legitimate reasons. In case of unforeseen circumstances that may affect the performance of the contract, we shall take the initiative to communicate with the other party in a timely manner and seek a mutually beneficial solution through negotiation.
2. Compliance Commitment and Legal Compliance
The Company takes compliance as a core obligation and strictly abides by relevant laws, regulations, rules and industry standards at home and abroad:
Compliance with Chinese Laws and Regulations: We shall firmly abide by the “People’s Republic of China Anti-Unfair Competition Law”, “People’s Republic of China Product Quality Law”, “People’s Republic of China Consumer Rights and Interests Protection Law”, “People’s Republic of China Data Security Law”, “People’s Republic of China Personal Information Protection Law”, “Administrative Regulations on Network Data Security” and other relevant national laws and regulations, and ensure that all business activities are carried out within the scope permitted by law.
Compliance with International Norms: In the process of carrying out international business docking and cooperation, we shall abide by the international trade rules, international business ethics norms and relevant local laws and regulations of the cooperative countries/regions, respect the cultural customs and business practices of different countries/regions, and maintain the Company’s international image of compliance and integrity.
Compliance with Industry Standards: We shall strictly follow the national and industry standards for ice packs, cold and hot compress packs and other products, including product safety standards, quality inspection standards, packaging and labeling standards, etc. We shall actively participate in industry self-regulation, accept the supervision of industry associations, and continuously improve the standardization level of business operations.
3. Product Quality and Safety
Product quality and safety are related to the health and safety of users and the survival and development of the Company. We adhere to the principle of “quality first, safety first” and strictly control every link of product research and development, production and sales:
Quality Control System: We shall establish and improve a sound product quality management system, covering raw material procurement, production process control, finished product inspection, storage and transportation, etc. We shall conduct strict quality inspections on raw materials to ensure that they meet relevant standards; implement full-process monitoring of the production process to eliminate quality hazards; conduct 100% inspection of finished products, and only products that pass the inspection can leave the factory and be put on the market.
Product Safety Guarantee: We shall ensure that our ice packs, cold and hot compress packs and other products are safe and non-toxic, have no potential safety hazards, and comply with relevant safety requirements for medical and health products (if applicable). We shall conduct sufficient safety tests and risk assessments on products, and clearly mark safety warnings, usage methods and precautions on product packaging to guide users to use them correctly.
After-sales Quality Tracking: We shall establish a product after-sales service system and a quality complaint handling mechanism. For product quality problems reported by customers, we shall respond in a timely manner, conduct investigations and handle them, and take effective measures such as replacement, repair or refund to protect the legitimate rights and interests of customers. At the same time, we shall summarize the quality problems found, continuously optimize the product design and production process, and improve product quality and safety.
4. Supply Chain Ethics
We advocate ethical cooperation in the supply chain and require all suppliers to abide by relevant ethical and compliance requirements to jointly build a responsible supply chain:
Supplier Selection and Evaluation: When selecting suppliers, we shall not only consider factors such as price, quality and delivery cycle, but also conduct strict ethical and compliance evaluations, including the supplier’s compliance with labor laws, environmental protection requirements, product quality standards, anti-corruption regulations, etc. We shall include ethical and compliance clauses in supplier cooperation agreements and clarify the rights and obligations of both parties.
Fair Cooperation with Suppliers: We shall treat all suppliers fairly and impartially, not discriminate against any supplier, not use our dominant position to force suppliers to accept unfair terms, and ensure that the cooperation between the two parties is based on equality and mutual benefit. We shall settle payment to suppliers in a timely manner in accordance with the provisions of the contract to protect the legitimate rights and interests of suppliers.
Supplier Supervision and Improvement: We shall conduct regular supervision and evaluation of suppliers’ ethical and compliance performance. For suppliers that fail to meet the ethical and compliance requirements, we shall urge them to rectify within a time limit; if the rectification is ineffective, we shall terminate the cooperation relationship. We shall actively communicate and cooperate with suppliers to help them improve their ethical and compliance management level and achieve win-win development.
5. Customer and Partner Relationships
We respect every customer and partner and are committed to establishing long-term, stable and mutually beneficial cooperative relationships:
Protection of Customer Rights and Interests: We shall respect the right to know, right to choose and right to fair trade of customers, and shall not infringe on the legitimate rights and interests of customers in any form. We shall strictly protect customer personal information in accordance with the “Privacy Policy of cryozin Website”, and shall not disclose, share or use customer personal information without authorization.
Fair Competition with Competitors: We shall respect competitors, abide by the rules of fair competition, and shall not engage in unfair competition behaviors such as slandering competitors’ reputation, stealing competitors’ trade secrets, counterfeiting competitors’ products or trademarks. We shall gain market share and competitive advantages through improving product quality, optimizing services and reducing costs.
Win-win Cooperation with Partners: We shall maintain open and transparent communication with partners, fulfill commitments made to partners, and resolve disputes and differences through friendly negotiation. We shall actively share resources and information with partners on the premise of abiding by laws and regulations and protecting trade secrets, and jointly promote the development of the industry.
6. Data Privacy and Information Security
In the process of business operations, we will inevitably involve the collection, use, storage and transmission of personal information and business data. We adhere to the principles of legality, legitimacy and necessity and strictly protect data privacy and information security:
Compliance with Data Protection Laws: We shall strictly implement the provisions of the “Data Security Law of the People’s Republic of China”, “Personal Information Protection Law of the People’s Republic of China” and other relevant laws and regulations, and the “Privacy Policy of cryozin Website”. We shall only collect personal information and business data that is necessary for business operations, and shall obtain the consent of the data subject (if required by law) before collection.
Data Security Protection Measures: We shall adopt advanced technical and management measures to protect the security of data, including data encryption, access control, security monitoring, regular backups, etc., to prevent data leakage, loss, tampering or illegal access. We shall establish a data security incident emergency response plan. In case of a data security incident, we shall immediately activate the plan, take remedial measures, and report to the relevant authorities and notify the affected parties in accordance with regulations.
Reasonable Use of Data: We shall only use collected data for the purposes specified in the “Privacy Policy of cryozin Website” and this Policy, and shall not expand the scope of use without authorization. Without the explicit consent of the data subject or the provisions of relevant laws and regulations, we shall not transfer or share data with any third party.
7. Anti-Corruption and Anti-Bribery
The Company firmly opposes all forms of corruption and bribery and is committed to building a clean and honest business environment:
Prohibition of Corruption and Bribery: All employees of the Company shall not, in the name of the Company or in their personal capacity, offer, promise, give or accept bribes, kickbacks, rebates or other improper benefits to or from customers, partners, suppliers, government officials or other relevant parties in order to obtain or maintain business interests. They shall not use improper means to seek advantages in business activities.
Regulation of Gift-Giving and Reception: We shall regulate the behavior of giving gifts and receiving guests in business activities. Gifts and hospitality shall be reasonable in value, compliant with relevant regulations, and shall not affect the fairness of business transactions. We shall not give or receive cash, valuable securities, luxury goods and other improper gifts.
Third-Party Anti-Corruption Requirements: We shall require partners, suppliers and other third parties to abide by anti-corruption and anti-bribery regulations. We shall include anti-corruption clauses in relevant cooperation agreements, clarifying that third parties shall not engage in corrupt or bribery behaviors in the process of cooperating with the Company. If a third party is found to have such behaviors, we shall terminate the cooperation relationship and reserve the right to pursue legal liability.
8. Employee Code of Conduct
All employees of the Company are the practitioners and defenders of business ethics and compliance. We require employees to abide by the following codes of conduct:
Integrity and Honesty: Employees shall be honest and trustworthy in their work, not forge documents, reports or data, not conceal work errors or problems, and not use their positions to seek personal interests.
Compliance with Laws and Regulations: Employees shall abide by national laws and regulations, the Company’s rules and regulations, and this Policy, and shall not engage in any illegal or non-compliant behaviors.
Confidentiality Obligation: Employees shall strictly abide by the Company’s confidentiality system, keep the Company’s trade secrets, technical secrets, customer information, business data and other confidential information, and shall not disclose, leak or use confidential information for personal purposes without authorization.
Avoidance of Conflicts of Interest: Employees shall avoid situations where their personal interests conflict with the Company’s interests. If a potential conflict of interest arises, they shall promptly report to the Company and take appropriate measures to resolve it. They shall not engage in part-time work or business activities that conflict with the Company’s business without the Company’s approval.
9. Reporting and Supervision Mechanism
The Company establishes a sound reporting and supervision mechanism to ensure that violations of business ethics and compliance requirements can be discovered and handled in a timely manner:
Reporting Channels: Employees, customers, partners, suppliers and other relevant parties can report violations of this Policy (such as corruption and bribery, unfair competition, product quality problems, data leakage, etc.) through the following channels: Contact phone number: +86 15992718044
Whatsapp account: +86 15992718044
Email address: harry@zejinbtg.com
Contact address: No. 5, Shentan Second Street, Shijie Town, Dongguan City, Guangdong Province
Protection of Reporters: The Company shall strictly protect the identity information of reporters and shall not disclose the reporter’s identity to irrelevant parties without authorization. It shall not retaliate against or discriminate against reporters in any form.
Investigation and Handling: After receiving a report, the Company shall promptly set up an investigation team to conduct a fair and impartial investigation. It shall handle the violation in accordance with the severity of the case and the Company’s relevant regulations, and shall take measures such as warning, fine, dismissal, or pursuit of legal liability against the responsible person. The investigation and handling results shall be fed back to the reporter (if appropriate).
10. Continuous Improvement and Training
The Company will continuously improve the business ethics and compliance management system and strengthen the awareness and ability of employees and partners to comply with ethics:
Regular Review and Update: The Company will regularly review the implementation effect of this Policy and update and improve it according to changes in national laws and regulations, industry standards and the Company’s business development to ensure its applicability and effectiveness.
Compliance Training: The Company will carry out regular business ethics and compliance training for all employees, covering the content of this Policy, relevant laws and regulations, typical cases, etc., to improve employees’ awareness of compliance and ethical literacy and enhance their ability to identify and avoid compliance risks.
Promotion of Compliance Culture: The Company will vigorously promote a compliance culture within the enterprise, advocate the values of integrity, compliance and responsibility, and encourage employees to take the initiative to abide by business ethics and compliance requirements. It will take compliance performance as an important part of employee assessment and incentive to form a good atmosphere of “compliance is honored, violation is shameful”.
11. Supplementary Provisions
This Policy shall take effect on the date of publication and shall apply to all employees, management personnel, business partners and other relevant parties involved in the Company’s business activities.
The Company reserves the right to interpret this Policy. If there is any conflict between this Policy and national laws and regulations, the national laws and regulations shall prevail.
Any amendment or update to this Policy shall be published in a prominent position on the cryozin website (such as the bottom of the homepage) and shall take effect on the date of publication.
Dongguan Zejin Biotechnology Co., Ltd.