
ESG
Anti-corruption

Anti fraud management system
Our sustainable development governance framework
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Provide recommendations to the board of directors regarding the company's sustainable development goals, strategies, priorities, and objectives;
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Supervise, examine, and evaluate the actions taken by our company to implement sustainable development priorities and objectives;
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Review and report sustainable development risks and opportunities to the board of directors;
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Identify, monitor, and examine important sustainable development issues that may affect the group's business operations and performance;
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Supervise and review the sustainable development policies, practices, frameworks, and management policies of the group, and provide improvement suggestions;
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Review the annual environmental, social, and governance report of the company and any public disclosures related to the company's sustainable development performance, and provide opinions to the board of directors;
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Perform such other functions related to or incidental to the aforementioned and deemed appropriate by the committee.
For details, please refer to the terms of reference of the Sustainable Development Committee.
- Audit Committee
- Remuneration Committee
- Nominating committee
- Commission on sustainable development
- Risk Management and Internal Audit Department
- Sustainable Development Working Group
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Sustainable Development Committee
The board of directors bears ultimate responsibility for the overall direction, vision, strategy, goals, performance, and reporting of the sustainable development of the group. Under the support of the Sustainable Development Committee, oversee and manage matters related to sustainable development. -
Board of Directors
The Sustainable Development Committee is chaired by a non-executive director ("Non Executive Director"), and its members include a Rain Name Executive Director and an independent non-executive director. The Sustainable Development Committee meets at least twice a year and is responsible for providing advice to the Board on the development and implementation of sustainability goals, strategies, priorities, and objectives. -
Sustainable Development Working Group
The Sustainable Development Working Group is chaired by an Executive Director (who is also a member of the Sustainable Development Committee) and composed of senior management from different brands and internal functions of the Group. The working group shall meet at least once a year and regularly report to the Sustainable Development Committee. The working group reports to the Sustainable Development Committee on identified major sustainable development risks, opportunities, or trends, and develops management objectives, policies, and action plans to manage these risks and opportunities.
The working group is responsible for planning and implementing sustainable development initiatives, promoting and encouraging cross functional cooperation. The working group is also responsible for preparing the annual environmental, social, and governance report.
Major environmental, social, and governance activities during the year
Risk Management and Internal Control
Xtep Risk Governance
Organizational
Structure
Risk management is an essential part of our operations and decision-making. The board of directors bears ultimate responsibility for supervising the risk management methods of the group and regularly evaluating their effectiveness.
We have established a risk management framework that clarifies the roles and responsibilities of all parties involved. Policies and processes have been implemented to promote smooth and effective operations, ensure reliable financial reporting, comply with applicable legal and regulatory requirements, identify and manage potential risks, and protect the assets of the Group. In addition, the Group regularly reviews its risk management system to ensure its ability to respond to rapidly changing business environments.
Xtep Risk Management Organizational Structure
- Risk Management and Internal Confidentiality Department
- Management
The main responsibilities of each party in the risk governance structure of our group are as follows:
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board of directors
The board of directors decides on the business strategy objectives of the group and evaluates the nature and extent of the risks that the group intends to bear in order to achieve its strategic objectives. The board of directors also ensures that the group appropriately and effectively establishes and maintains a risk management system, manages the overall design, implementation, and supervision of the risk management system and internal control system. -
audit committee
The Audit Committee is responsible for supervising and guiding the risk management and internal honey core departments and management to establish and operate internal management systems, regularly monitoring the Group's risk management and internal control systems, and making recommendations to the Board of Directors. The effectiveness of risk management and internal control systems shall be reviewed at least once a year, covering all significant control related matters, including financial, operational, and compliance controls. -
risk management and internal audit department
The National Insurance Management and Internal Honey Core Department evaluates the risk management and internal control systems of the Group and reports the results to the Honey Core Committee to improve identified control weaknesses or significant system deficiencies. -
management
The management has been entrusted and authorized to:
Properly and effectively design, implement, and maintain risk management and Part C control systems;
Identify, evaluate, manage, and control potential and significant risks that may have an impact on the operational process;
Monitor risks and take appropriate measures to reduce hoarding;
Quickly respond to and follow up on the investigation results of risk management and internal control issues made by the risk management and internal security departments;
Confirm the effectiveness of risk management and internal control systems with the board of directors and the confidentiality committee.
Risk identification and management
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risk identification
Identify potential and significant risks that may have an impact on its strategy, business, operations, and finances
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risk assessment
Assess identified risks by adopting designated risk assessment criteria developed by management
Assess potential impacts and their likelihood of occurrence
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risk response
Determine the priority order of major risks by comparing the results of risk assessments
Develop risk monitoring strategies and internal monitoring procedures to avoid, prevent, or mitigate identified risks
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risk reporting and monitoring
Regularly discuss the results of risk management with the board of directors, confidentiality committee, and management
Continuously monitor the identified Risk and ensure the normal operation of internal monitoring system
Re evaluate risk monitoring strategies and internal monitoring procedures in the event of any significant changes in the business and external environment
Business ethics
Maintaining the highest level of business integrity and transparency is crucial for building stakeholder trust and maintaining our reputation. Our group has formulated policies and measures to adhere to the highest level of business ethics standards.
We have established a 'Management Compliance Investigation and Accountability System' to standardize the handling mechanism, in order to address major issues or violations related to compliance with the code of conduct that may arise in our management functions and operations. During the year, the group also provided business ethics training to all employees, strengthened anti fraud concepts, and promoted a culture of integrity. In recent years, our group has demonstrated through real internal cases how ethical dilemmas can occur and how they can be appropriately resolved, placing themes that may arise in their daily business in appropriate contexts.
internal audit
Our risk management and internal audit department is responsible for performing internal audit functions, including assessing the effectiveness of the company's risk management and internal control systems, and regularly reporting to the audit committee. The board of directors and audit committee are responsible for overseeing resource allocation, ensuring that the risk management and internal audit departments have sufficient budget and manpower to perform their internal audit functions, and providing relevant training courses to qualified employees with experience in maintaining internal audit quality. Provide relevant training to experienced and qualified employees to develop the skills and abilities required to maintain internal audit quality.
Compliance management
To ensure compliance with relevant business operation laws and regulations, the Group has implemented preventive, monitoring, and control measures. During the reporting period, except for Rule A.2.1 (Chairman and CEO) of the Code, the Company complied with all Code provisions and, where appropriate, adopted the best practices recommended in the effective Corporate Governance Code for the year.
According to Article A.2.1 of the Corporate Governance Code, the positions of Chairman and CEO must be separated and cannot be held by the same person. The Group currently does not differentiate between the positions of Chairman and CEO. Mr. Ding Shuibo is currently the Chairman and CEO of our group. He has extensive experience in the sports equipment industry and is responsible for the overall corporate strategy, planning, and business management of our group. The board of directors believes that having the same person as the chairman and CEO will benefit the business prospects and management of the group. The board of directors and senior management are composed of senior and outstanding personnel, ensuring a balanced distribution of power and authorization. The board of directors currently has three executive directors and three independent non-executive directors, and the members of the board have a high degree of independence.
Compliance management
As we rely on our employees to promote and uphold our values, we provide anti-corruption training to ensure that they fully understand the expectations and principles outlined in our policies. Regularly conduct training and share with employees online for convenient purposes.
We also recognize the importance of promoting these values throughout the entire supply chain. All suppliers are required to sign a 'Clean Cooperation Agreement' and agree to comply with our standards regarding bribery and fraud issues. For more details, please refer to our supply chain management methods in "Supplier Evaluation and Management".
In 2023, we did not find any corruption, bribery, extortion, fraud, or money laundering violations.

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Transparent expectation communication and strong policies enable us to prevent, identify, and effectively mitigate any potential, perceived, or real conflicts of interest in our operations and the entire value chain.
Our 'Anti Corruption Policy' also outlines the professional and ethical standards that employees must adhere to in all business transactions. All employees are required to regularly report any potential conflicts of interest. In addition, our Supplier Code of Conduct outlines our expectations and requirements for all suppliers to ensure that their operations comply with our ethical standards.
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To avoid potential misconduct within the group and supply chain, and to ensure that we operate in accordance with the highest ethical standards, we have established a reporting system that enables employees, suppliers (including their employees), and other relevant external stakeholders to anonymously report any actual or suspected misconduct, fraud, or policy violations through confidential channels (including dedicated email, WeChat, and monitoring departments) for investigation. The risk management and internal audit departments, as well as the audit committee, strictly maintain confidentiality regarding the identity of the whistleblower and related records. Whistleblowers need not worry about any form of retaliation, such as improper dismissal or unjustified disciplinary action. All reports have undergone appropriate thorough review and investigation.
In 2023, no reports were received through the reporting channels.
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We strive to establish meaningful connections with our customers through transparent and ethical promotion. From product advertising to community initiatives, our activities are committed to ensuring accurate depictions, sustainability considerations, and stakeholder trust.
We strictly abide by relevant advertising regulations such as the Advertising Law of the People's Republic of China, the Anti Unfair Competition Law of the People's Republic of China, and the E-commerce Law of the People's Republic of China, aiming to protect consumer rights and promote the healthy development of advertising. We ensure that all promotional activities and expressions across all channels are balanced and accurate, without exaggerating their functions and environmental, social, and governance attributes.
In 2023, we did not find any violations of advertising and labeling related to the products and services provided.
Data security and customer privacy protection
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Only collect customer data and personal information that are relevant to our business and necessary.
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We will not disclose customer data and personal information outside of our group unless we obtain customer consent or legal requirements.
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Regularly maintain appropriate security systems to prevent unauthorized access to our customers' data and personal information.
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Clear customer data and information before or upon termination of data usage authorization.
Continuous awareness training is one of our methods for protecting customer privacy. We regularly broadcast information security awareness messages in public areas to emphasize the importance of network security for the entire organization. In addition, training courses are scheduled every six months to ensure that our employees fully understand the importance of information and cybersecurity.
To prevent information technology system interruptions and network attacks, we have a 7 x 24 network and information security monitoring system equipped with automatic and manual alarm systems that can respond promptly to any security issues. At the same time, we regularly backup all business data to prevent data loss, and conduct data recovery tests twice a year to evaluate our restoration procedures. The annual risk assessment, including penetration testing and phishing simulations, enables us to proactively identify vulnerabilities and enhance our security and incident response capabilities in today's constantly evolving threat environment.
We will continuously improve our data security measures to comply with the latest regulatory requirements and reflect the expectations of stakeholders.