Noah considers honesty and integrity of particular importance. The Code of Business Conduct and Ethics and Noah Holdings Employee Manual were developed as the fundamental business conduct guidelines for Noah employees across the globe.
All employees of Noah Holdings including its branches and subsidiaries, regardless of position, level or location, should act in accordance with the Code. Unless articles therein come into conflict with the laws and decrees enacted by local governments in a country of operation, the Code shall prevail over any local regulations.
To ensure that all Noah employees fully understand and observe relevant policies and methods, we carried out the following measures during our routine operation. Under the control and management of effective mechanisms, there was no violation of the Code of Business Conduct and Ethics in 2022.
1. Formulation and regular updates of the Compliance Manual and Administrative Methods for Operating Risky Events. Related systems include explanations on key points about the design of relevant management systems, and principles against commercial bribery and other behaviors, as well as methods for dealing with violations.
2. The Noah Human Resources Center communicates the code of conduct to each new employee on their first day of onboarding and provides relevant training.
3. Each year, all employees undergo training via online platforms such as “Noah Home”. Typical cases of violations are communicated to all employees via email as a warning against abuse of power or any other form of misconduct such as bribery, corruption and deception.
4. The values of integrity and honesty, and anti-corruption and anti-fraud principles are repeatedly underscored during employee meetings and other company-wide communication events. Relevant contents have been reiterated as mandatory online courses at Noah Academy. Every single employee must enroll in the courses and pass the exams.
Noah actively advocates a corporate culture of integrity and conforms to high ethical standards. Noah adopts international sustainability standards, acts in accordance with laws, regulations, and supervision requirements of listed companies, and sees trust, credibility, and integrity as our most valuable assets.
Code of Conduct
Anti-Commercial Bribery Training Achievements in 2021
Category
Gender
Total number of employees
Number of employees who received training
Total hours of training
Management
Male
Female
Female
196
150
150
196
150
150
1,117.2
885
885
General employees
Male
Female
Female
1755
1055
1055
1755
1055
1055
9,968.4
5,992.4
5,992.4
Note: Average time spent in training is 5.028 h
Anti-Money Laundering and Anti-Fraud
Honesty and integrity have always been a cornerstone in the financial service industry. To ensure that all Noah employees sufficiently understand and implement these principles, we formulated the Compliance Manual, which includes anti-commercial bribery principles and methods for dealing with violations as well.
In 2012, we created an online version of the Compliance Manual, available from our intranet, and added a mandatory reading function to ensure that all employees read over the document and pass the related test every year.
In 2020, the Group founded the Discipline Supervision Committee, which provides guidance for our auditing, discipline inspection and internal control efforts in order to promote internal supervision capacity and prevent and rectify material violations.
In 2021, Noah further strengthened the accountability mechanism and anti-fraud mechanism. Ethics Compliance Committee reviewed and released the Audit and Accountability Procedures for Noah and updated the Code of Business Conduct and Ethics for Noah Employees. In addition, the Committee enhanced integrity education and publicity to help foster a positive organizational culture and create an atmosphere of integrity within the group.
In 2012, we created an online version of the Compliance Manual, available from our intranet, and added a mandatory reading function to ensure that all employees read over the document and pass the related test every year.
In 2020, the Group founded the Discipline Supervision Committee, which provides guidance for our auditing, discipline inspection and internal control efforts in order to promote internal supervision capacity and prevent and rectify material violations.
In 2021, Noah further strengthened the accountability mechanism and anti-fraud mechanism. Ethics Compliance Committee reviewed and released the Audit and Accountability Procedures for Noah and updated the Code of Business Conduct and Ethics for Noah Employees. In addition, the Committee enhanced integrity education and publicity to help foster a positive organizational culture and create an atmosphere of integrity within the group.
Anti-Money Laundering
To steadfastly support China’s anti-corruption agenda, we proactively comply with the Anti-Money Laundering Law of the People’s Republic of China, Anti-Money Laundering Regulations for Financial Institutions, Administrative Measures for the Reporting of Large Transactions and Suspicious Transactions by Financial Institutions, Administrative Measures for Financial Institutions’ Customer Identification and Preservation of Customer Identity Materials and Transaction Records as well as other related laws, rules, and regulations. To this end, we have undertaken the following measures:
1.An anti-money laundering section was set up on our website to publicize anti-money laundering rules and regulations and educate clients about anti-money laundering issues;
2.Anti-money laundering systems were created, and client identity is authenticated through the application form, interview and other forms during the client’s on-boarding and account registration process;
3.Steps are taken to ensure that funds used by a client for transactions originate from his or her own account;
4.Information on client identity and transactions is carefully kept and protected;
5.Noah actively cooperates with financial institutions and relevant organizations for investigations into any suspicious transactions detected.
Noah takes substantive steps in the supervision and management of anti-money laundering and anti-terrorism financing. We earnestly perform our anti-money laundering and anti-terrorism financing duties, so as to prevent Noah’s products and channels from being used for money laundering. In view of various new acts of corruption and money laundering in the market, we will continue to improve our anti-money laundering efforts and our ability in this regard to carry out national policies.
We relied on technological means to assess and analyze historical records and discern and identify anti-money laundering risks. For instance, sales organizations use fund accounts to make the declaration. Each fund account has its corresponding records, and when relevant information is added or modified, all anti-money laundering information of the fund account will be sent, instead of sending only the modified information.
In 2021, Noah Upright updated and released the Anti-Money Laundering and Taxation Due Diligence System for Noah Upright in accordance with the Measures for the Supervision and Administration of Distribution Institutions of Publicly Offered Securities Investment Funds and add taxation due diligence for non-resident financial accounts to ensure that Noah Upright fulfills its legal duties.
1.An anti-money laundering section was set up on our website to publicize anti-money laundering rules and regulations and educate clients about anti-money laundering issues;
2.Anti-money laundering systems were created, and client identity is authenticated through the application form, interview and other forms during the client’s on-boarding and account registration process;
3.Steps are taken to ensure that funds used by a client for transactions originate from his or her own account;
4.Information on client identity and transactions is carefully kept and protected;
5.Noah actively cooperates with financial institutions and relevant organizations for investigations into any suspicious transactions detected.
Noah takes substantive steps in the supervision and management of anti-money laundering and anti-terrorism financing. We earnestly perform our anti-money laundering and anti-terrorism financing duties, so as to prevent Noah’s products and channels from being used for money laundering. In view of various new acts of corruption and money laundering in the market, we will continue to improve our anti-money laundering efforts and our ability in this regard to carry out national policies.
We relied on technological means to assess and analyze historical records and discern and identify anti-money laundering risks. For instance, sales organizations use fund accounts to make the declaration. Each fund account has its corresponding records, and when relevant information is added or modified, all anti-money laundering information of the fund account will be sent, instead of sending only the modified information.
In 2021, Noah Upright updated and released the Anti-Money Laundering and Taxation Due Diligence System for Noah Upright in accordance with the Measures for the Supervision and Administration of Distribution Institutions of Publicly Offered Securities Investment Funds and add taxation due diligence for non-resident financial accounts to ensure that Noah Upright fulfills its legal duties.
Anti-Fraud
We actively advocate a corporate culture of integrity and honesty, strictly observe rules, regulations，and regulatory requirements of listed companies, and steadfastly perform our anti-fraud duties. The following measures have been taken in our operations.
• Operate the Ethics Compliance Committee, the highest decision-making body for group-wide discipline supervision and compliance management to focus on preventing and handling material violations within the Group.
• Strengthen organizations and systems of auditing and supervision, carry out integrity education, and lay a solid foundation for anti-corruption and anti-bribery efforts.
• Establish the Audit Department and Discipline Inspection Team that report to the Ethics Compliance Committee and Audit Committee in order to strengthen internal supervision.
• Establish Internal Control Department to promote systematic and fine management in order to prevent and mitigate risks at the institutional level. In 2020, system establishment was included in the KPI system, resulting in drastic improvement in the system management level. Thanks to a sustained effort to improve systems in 2021, we have basically established a sound management scheme.
• Formulate Code of Business Conduct and Ethics, Anti-Corruption Management Rules, complaint and reporting mechanism and other systems. In 2020, the complaint and reporting mechanism was further improved and communicated to employees, and the Discipline Inspection Team was put in complete charge of dealing with complaints and reports. In 2021, an updated version of the Code of Business Conduct and Ethics for Noah Employees was issued to further clarify business conduct advocated and prohibited by the Company.
• Thoroughly implement supervisory functions, carry out strict accountability, select exemplary cases to warn employees against violation, address problems at the earliest sign, and push employees to respect the rules.
• Focus auditing works on high-risk areas and cover the main business segments of the Group to carry out systematic risk investigation.
• Empower the Discipline Inspection Team to handle all complaints and reports and conduct investigations into various types of violations.
• Carry out risk mapping based on an orientation that emphasizes client interests, shareholder interests and corporate values.
• Respond actively to all complaints and reports without distinction and ensure whistleblower protection.
• Conduct punishment on violations based on audit results, and announce said punitive outcomes to correct and warn against future violations. In 2021, Noah handled and published improper expense reimbursement through the above mechanisms. Handling violations identified in our business process and publishing their punishment acted as an effective warning. Other matters under investigation will also be handled in strict accordance with the Company’s governance mechanisms. In 2022, Noah handled and published improper procurement and violations like expense reimbursement identified in our business process, which acted as an effective warning. Other matters under investigation will also be handled in strict accordance with the Company’s governance mechanisms.
• Operate the Ethics Compliance Committee, the highest decision-making body for group-wide discipline supervision and compliance management to focus on preventing and handling material violations within the Group.
• Strengthen organizations and systems of auditing and supervision, carry out integrity education, and lay a solid foundation for anti-corruption and anti-bribery efforts.
• Establish the Audit Department and Discipline Inspection Team that report to the Ethics Compliance Committee and Audit Committee in order to strengthen internal supervision.
• Establish Internal Control Department to promote systematic and fine management in order to prevent and mitigate risks at the institutional level. In 2020, system establishment was included in the KPI system, resulting in drastic improvement in the system management level. Thanks to a sustained effort to improve systems in 2021, we have basically established a sound management scheme.
• Formulate Code of Business Conduct and Ethics, Anti-Corruption Management Rules, complaint and reporting mechanism and other systems. In 2020, the complaint and reporting mechanism was further improved and communicated to employees, and the Discipline Inspection Team was put in complete charge of dealing with complaints and reports. In 2021, an updated version of the Code of Business Conduct and Ethics for Noah Employees was issued to further clarify business conduct advocated and prohibited by the Company.
• Thoroughly implement supervisory functions, carry out strict accountability, select exemplary cases to warn employees against violation, address problems at the earliest sign, and push employees to respect the rules.
• Focus auditing works on high-risk areas and cover the main business segments of the Group to carry out systematic risk investigation.
• Empower the Discipline Inspection Team to handle all complaints and reports and conduct investigations into various types of violations.
• Carry out risk mapping based on an orientation that emphasizes client interests, shareholder interests and corporate values.
• Respond actively to all complaints and reports without distinction and ensure whistleblower protection.
• Conduct punishment on violations based on audit results, and announce said punitive outcomes to correct and warn against future violations. In 2021, Noah handled and published improper expense reimbursement through the above mechanisms. Handling violations identified in our business process and publishing their punishment acted as an effective warning. Other matters under investigation will also be handled in strict accordance with the Company’s governance mechanisms. In 2022, Noah handled and published improper procurement and violations like expense reimbursement identified in our business process, which acted as an effective warning. Other matters under investigation will also be handled in strict accordance with the Company’s governance mechanisms.
Mystery Man Reporting Program
An effective reporting management mechanism is an important building block to promote and ensure the healthy and orderly operation and management of a company. Noah has issued a series of Noah Complaint Reporting Methods since 2015, which set out the legal right of employees to file reports, to improve the Company’s supervision level.
In 2020, Noah released the image of a mystery man, an intellectual property of the Company, to clarify the baseline that Noah tolerates no disciplinary violation for development’s sake, that accomplishments and faults shall not cancel each other out, and that anyone that touches the red line will be punished. In addition, we drew on blackboard bulletins to communicate the principle to our employees. The core values and baselines of the Company are clarified in the Reward and Punishment Management Methods and relevant external and internal cases. Employees must avoid the red line to contribute to Noah’s sustainable development. In 2022, via online compulsory courses for all employees and offline publicity targeted at key position holders and in key areas, Noah conducted another round of promotion regarding the code of business conduct, accountability system, red lines, auditing and supervisory system, and complaint and reporting mechanism, covering all employees. Noah strengthened the promotion and guidance during Auditing Promotion Month to facilitate a positive group culture.
In 2020, Noah released the image of a mystery man, an intellectual property of the Company, to clarify the baseline that Noah tolerates no disciplinary violation for development’s sake, that accomplishments and faults shall not cancel each other out, and that anyone that touches the red line will be punished. In addition, we drew on blackboard bulletins to communicate the principle to our employees. The core values and baselines of the Company are clarified in the Reward and Punishment Management Methods and relevant external and internal cases. Employees must avoid the red line to contribute to Noah’s sustainable development. In 2022, via online compulsory courses for all employees and offline publicity targeted at key position holders and in key areas, Noah conducted another round of promotion regarding the code of business conduct, accountability system, red lines, auditing and supervisory system, and complaint and reporting mechanism, covering all employees. Noah strengthened the promotion and guidance during Auditing Promotion Month to facilitate a positive group culture.
Noah Reporting Management Methods – Confidential Whistleblowing and Protection of Whistleblowers
• The name, organization, department, home address, and other information of the whistleblower and the content of his/her report must be kept strictly confidential. The report materials shall be managed as confidential documents.
• It is strictly forbidden to transfer the original report materials to the department, organization, or person involved.
• Accept a report or verify information with the whistleblower in a confidential manner without revealing the whistleblower’s identity.
• Publicize whistleblowing cases and the rewards for truthful whistleblowers within the Company. The name and department of the whistleblower shall not be disclosed without the consent of the whistleblower.
• It is strictly forbidden to hamper, suppress, or retaliate against the whistleblower on any pretext. Once verified, retaliation against the whistleblower and reported matter shall be seriously dealt with according to our rules and regulations, and retaliators shall be investigated for economic and administrative responsibilities by the Company. Cases that constitute crimes shall be transferred to judicial organs for handling.
• It is strictly forbidden to transfer the original report materials to the department, organization, or person involved.
• Accept a report or verify information with the whistleblower in a confidential manner without revealing the whistleblower’s identity.
• Publicize whistleblowing cases and the rewards for truthful whistleblowers within the Company. The name and department of the whistleblower shall not be disclosed without the consent of the whistleblower.
• It is strictly forbidden to hamper, suppress, or retaliate against the whistleblower on any pretext. Once verified, retaliation against the whistleblower and reported matter shall be seriously dealt with according to our rules and regulations, and retaliators shall be investigated for economic and administrative responsibilities by the Company. Cases that constitute crimes shall be transferred to judicial organs for handling.
Relevant Management Policies
- Noah Holdings Code of Business Conduct and Ethics
Noah actively advocates a corporate culture of integrity and conforms to high ethical standards. Noah adopts international sustainability standards, acts in accordance with laws, regulations, and supervision requirements of listed companies, and sees trust, credibility, and integrity as our most valuable assets.
Code of Conduct
Noah considers honesty and integrity of particular importance. The Code of Business Conduct and Ethics and Noah Holdings Employee Manual were developed as the fundamental business conduct guidelines for Noah employees across the globe.
All employees of Noah including its branches and subsidiaries, regardless of position, level, or location, should act in accordance with the Code. Unless articles therein come into conflict with the laws and decrees enacted by local governments in a country of operation, the Code shall prevail over any local regulations.
To ensure that all Noah employees sufficiently understand and implement these principles and methods, we implemented the following measures and incorporated them into our operations. Under the management of effective mechanisms, not a single violation happened within Noah in 2022. We take the following measures:
1.Formulation and regular updates of the Compliance Manual and Administrative Methods for Operation of Risky Events. Related systems include explanations of key points about the design of relevant management systems, and principles against commercial bribery and other behaviors, as well as methods for dealing with violations.
2.The Noah Human Resources Center communicates the code of conduct to each new employee on their first day of onboarding and provides relevant training.
3.Each year, all employees undergo training via online platforms such as "Noah Home". Typical cases of violations are communicated to all employees via email as a warning against abuse of power or any other form of misconduct such as bribery, corruption, and deception.
4.The values of integrity and honesty, and anti-corruption and anti-fraud concepts are repeatedly underscored during employee meetings and other company-wide communication events. Relevant contents have been reiterated as mandatory online courses at Noah Academy. Every single employee must enroll in the courses and pass the exams.
All employees of Noah including its branches and subsidiaries, regardless of position, level, or location, should act in accordance with the Code. Unless articles therein come into conflict with the laws and decrees enacted by local governments in a country of operation, the Code shall prevail over any local regulations.
To ensure that all Noah employees sufficiently understand and implement these principles and methods, we implemented the following measures and incorporated them into our operations. Under the management of effective mechanisms, not a single violation happened within Noah in 2022. We take the following measures:
1.Formulation and regular updates of the Compliance Manual and Administrative Methods for Operation of Risky Events. Related systems include explanations of key points about the design of relevant management systems, and principles against commercial bribery and other behaviors, as well as methods for dealing with violations.
2.The Noah Human Resources Center communicates the code of conduct to each new employee on their first day of onboarding and provides relevant training.
3.Each year, all employees undergo training via online platforms such as "Noah Home". Typical cases of violations are communicated to all employees via email as a warning against abuse of power or any other form of misconduct such as bribery, corruption, and deception.
4.The values of integrity and honesty, and anti-corruption and anti-fraud concepts are repeatedly underscored during employee meetings and other company-wide communication events. Relevant contents have been reiterated as mandatory online courses at Noah Academy. Every single employee must enroll in the courses and pass the exams.
Anti-Money Laundering and Anti-Fraud
Honesty and integrity have always been a cornerstone in the financial service industry. To ensure that all Noah employees sufficiently understand and implement these principles, we formulated the Compliance Manual, which includes anti-commercial bribery principles and methods for dealing with violations as well.
In 2012, we created an online version of the Compliance Manual, available from our intranet, and added a mandatory reading function to ensure that all employees read over the document and pass the related test every year.
In 2020, the Group founded the Discipline Supervision Committee, which provides guidance for our auditing, discipline inspection and internal control efforts in order to promote internal supervision capacity and prevent and rectify material violations.
In 2021, Noah further strengthened the accountability mechanism and anti-fraud mechanism. Ethics Compliance Committee reviewed and released the Audit and Accountability Procedures for Noah and updated the Code of Business Conduct and Ethics for Noah Employees. In addition, the Committee enhanced integrity education and publicity to help foster a positive organizational culture and create an atmosphere of integrity within the group.
In 2012, we created an online version of the Compliance Manual, available from our intranet, and added a mandatory reading function to ensure that all employees read over the document and pass the related test every year.
In 2020, the Group founded the Discipline Supervision Committee, which provides guidance for our auditing, discipline inspection and internal control efforts in order to promote internal supervision capacity and prevent and rectify material violations.
In 2021, Noah further strengthened the accountability mechanism and anti-fraud mechanism. Ethics Compliance Committee reviewed and released the Audit and Accountability Procedures for Noah and updated the Code of Business Conduct and Ethics for Noah Employees. In addition, the Committee enhanced integrity education and publicity to help foster a positive organizational culture and create an atmosphere of integrity within the group.
Anti-Money Laundering
To steadfastly support China’s anti-corruption agenda, we proactively comply with the Anti-Money Laundering Law of the People’s Republic of China, Anti-Money Laundering Regulations for Financial Institutions, Administrative Measures for the Reporting of Large Transactions and Suspicious Transactions by Financial Institutions, Administrative Measures for Financial Institutions’ Customer Identification and Preservation of Customer Identity Materials and Transaction Records as well as other related laws, rules, and regulations. To this end, we have undertaken the following measures:
1.An anti-money laundering section was set up on our website to publicize anti-money laundering rules and regulations and educate clients about anti-money laundering issues;
2.Anti-money laundering systems were created, and client identity is authenticated through the application form, interview and other forms during the client’s on-boarding and account registration process;
3.Steps are taken to ensure that funds used by a client for transactions originate from his or her own account;
4.Information on client identity and transactions is carefully kept and protected;
5.Noah actively cooperates with financial institutions and relevant organizations for investigations into any suspicious transactions detected.
Noah takes substantive steps in the supervision and management of anti-money laundering and anti-terrorism financing. We earnestly perform our anti-money laundering and anti-terrorism financing duties, so as to prevent Noah’s products and channels from being used for money laundering. In view of various new acts of corruption and money laundering in the market, we will continue to improve our anti-money laundering efforts and our ability in this regard to carry out national policies.
We relied on technological means to assess and analyze historical records and discern and identify anti-money laundering risks. For instance, sales organizations use fund accounts to make the declaration. Each fund account has its corresponding records, and when relevant information is added or modified, all anti-money laundering information of the fund account will be sent, instead of sending only the modified information.
In 2021, Noah Upright updated and released the Anti-Money Laundering and Taxation Due Diligence System for Noah Upright in accordance with the Measures for the Supervision and Administration of Distribution Institutions of Publicly Offered Securities Investment Funds and add taxation due diligence for non-resident financial accounts to ensure that Noah Upright fulfills its legal duties.
1.An anti-money laundering section was set up on our website to publicize anti-money laundering rules and regulations and educate clients about anti-money laundering issues;
2.Anti-money laundering systems were created, and client identity is authenticated through the application form, interview and other forms during the client’s on-boarding and account registration process;
3.Steps are taken to ensure that funds used by a client for transactions originate from his or her own account;
4.Information on client identity and transactions is carefully kept and protected;
5.Noah actively cooperates with financial institutions and relevant organizations for investigations into any suspicious transactions detected.
Noah takes substantive steps in the supervision and management of anti-money laundering and anti-terrorism financing. We earnestly perform our anti-money laundering and anti-terrorism financing duties, so as to prevent Noah’s products and channels from being used for money laundering. In view of various new acts of corruption and money laundering in the market, we will continue to improve our anti-money laundering efforts and our ability in this regard to carry out national policies.
We relied on technological means to assess and analyze historical records and discern and identify anti-money laundering risks. For instance, sales organizations use fund accounts to make the declaration. Each fund account has its corresponding records, and when relevant information is added or modified, all anti-money laundering information of the fund account will be sent, instead of sending only the modified information.
In 2021, Noah Upright updated and released the Anti-Money Laundering and Taxation Due Diligence System for Noah Upright in accordance with the Measures for the Supervision and Administration of Distribution Institutions of Publicly Offered Securities Investment Funds and add taxation due diligence for non-resident financial accounts to ensure that Noah Upright fulfills its legal duties.
Anti-Fraud
We actively advocate a corporate culture of integrity and honesty, strictly observe rules, regulations，and regulatory requirements of listed companies, and steadfastly perform our anti-fraud duties. The following measures have been taken in our operations.
• Operate the Ethics Compliance Committee, the highest decision-making body for group-wide discipline supervision and compliance management to focus on preventing and handling material violations within the Group.
• Strengthen organizations and systems of auditing and supervision, carry out integrity education, and lay a solid foundation for anti-corruption and anti-bribery efforts.
• Establish the Audit Department and Discipline Inspection Team that report to the Ethics Compliance Committee and Audit Committee in order to strengthen internal supervision.
• Establish Internal Control Department to promote systematic and fine management in order to prevent and mitigate risks at the institutional level. In 2020, system establishment was included in the KPI system, resulting in drastic improvement in the system management level. Thanks to a sustained effort to improve systems in 2021, we have basically established a sound management scheme.
• Formulate Code of Business Conduct and Ethics, Anti-Corruption Management Rules, complaint and reporting mechanism and other systems. In 2020, the complaint and reporting mechanism was further improved and communicated to employees, and the Discipline Inspection Team was put in complete charge of dealing with complaints and reports. In 2021, an updated version of the Code of Business Conduct and Ethics for Noah Employees was issued to further clarify business conduct advocated and prohibited by the Company.
• Thoroughly implement supervisory functions, carry out strict accountability, select exemplary cases to warn employees against violation, address problems at the earliest sign, and push employees to respect the rules.
• Focus auditing works on high-risk areas and cover the main business segments of the Group to carry out systematic risk investigation.
• Empower the Discipline Inspection Team to handle all complaints and reports and conduct investigations into various types of violations.
• Carry out risk mapping based on an orientation that emphasizes client interests, shareholder interests and corporate values.
• Respond actively to all complaints and reports without distinction and ensure whistleblower protection.
• Conduct punishment on violations based on audit results, and announce said punitive outcomes to correct and warn against future violations. In 2021, Noah handled and published improper expense reimbursement through the above mechanisms. Handling violations identified in our business process and publishing their punishment acted as an effective warning. Other matters under investigation will also be handled in strict accordance with the Company’s governance mechanisms. In 2022, Noah handled and published improper procurement and violations like expense reimbursement identified in our business process, which acted as an effective warning. Other matters under investigation will also be handled in strict accordance with the Company’s governance mechanisms.
• Operate the Ethics Compliance Committee, the highest decision-making body for group-wide discipline supervision and compliance management to focus on preventing and handling material violations within the Group.
• Strengthen organizations and systems of auditing and supervision, carry out integrity education, and lay a solid foundation for anti-corruption and anti-bribery efforts.
• Establish the Audit Department and Discipline Inspection Team that report to the Ethics Compliance Committee and Audit Committee in order to strengthen internal supervision.
• Establish Internal Control Department to promote systematic and fine management in order to prevent and mitigate risks at the institutional level. In 2020, system establishment was included in the KPI system, resulting in drastic improvement in the system management level. Thanks to a sustained effort to improve systems in 2021, we have basically established a sound management scheme.
• Formulate Code of Business Conduct and Ethics, Anti-Corruption Management Rules, complaint and reporting mechanism and other systems. In 2020, the complaint and reporting mechanism was further improved and communicated to employees, and the Discipline Inspection Team was put in complete charge of dealing with complaints and reports. In 2021, an updated version of the Code of Business Conduct and Ethics for Noah Employees was issued to further clarify business conduct advocated and prohibited by the Company.
• Thoroughly implement supervisory functions, carry out strict accountability, select exemplary cases to warn employees against violation, address problems at the earliest sign, and push employees to respect the rules.
• Focus auditing works on high-risk areas and cover the main business segments of the Group to carry out systematic risk investigation.
• Empower the Discipline Inspection Team to handle all complaints and reports and conduct investigations into various types of violations.
• Carry out risk mapping based on an orientation that emphasizes client interests, shareholder interests and corporate values.
• Respond actively to all complaints and reports without distinction and ensure whistleblower protection.
• Conduct punishment on violations based on audit results, and announce said punitive outcomes to correct and warn against future violations. In 2021, Noah handled and published improper expense reimbursement through the above mechanisms. Handling violations identified in our business process and publishing their punishment acted as an effective warning. Other matters under investigation will also be handled in strict accordance with the Company’s governance mechanisms. In 2022, Noah handled and published improper procurement and violations like expense reimbursement identified in our business process, which acted as an effective warning. Other matters under investigation will also be handled in strict accordance with the Company’s governance mechanisms.
Mystery Man Reporting Program
An effective reporting management mechanism is an important building block to promote and ensure the healthy and orderly operation and management of a company. Noah has issued a series of Noah Complaint Reporting Methods since 2015, which set out the legal right of employees to file reports, to improve the Company’s supervision level.
In 2020, Noah released the image of a mystery man, an intellectual property of the Company, to clarify the baseline that Noah tolerates no disciplinary violation for development’s sake, that accomplishments and faults shall not cancel each other out, and that anyone that touches the red line will be punished. In addition, we drew on blackboard bulletins to communicate the principle to our employees. The core values and baselines of the Company are clarified in the Reward and Punishment Management Methods and relevant external and internal cases. Employees must avoid the red line to contribute to Noah’s sustainable development. In 2022, via online compulsory courses for all employees and offline publicity targeted at key position holders and in key areas, Noah conducted another round of promotion regarding the code of business conduct, accountability system, red lines, auditing and supervisory system, and complaint and reporting mechanism, covering all employees. Noah strengthened the promotion and guidance during Auditing Promotion Month to facilitate a positive group culture.
In 2020, Noah released the image of a mystery man, an intellectual property of the Company, to clarify the baseline that Noah tolerates no disciplinary violation for development’s sake, that accomplishments and faults shall not cancel each other out, and that anyone that touches the red line will be punished. In addition, we drew on blackboard bulletins to communicate the principle to our employees. The core values and baselines of the Company are clarified in the Reward and Punishment Management Methods and relevant external and internal cases. Employees must avoid the red line to contribute to Noah’s sustainable development. In 2022, via online compulsory courses for all employees and offline publicity targeted at key position holders and in key areas, Noah conducted another round of promotion regarding the code of business conduct, accountability system, red lines, auditing and supervisory system, and complaint and reporting mechanism, covering all employees. Noah strengthened the promotion and guidance during Auditing Promotion Month to facilitate a positive group culture.
Noah Reporting Management Methods – Confidential Whistleblowing and Protection of Whistleblowers
• The name, organization, department, home address, and other information of the whistleblower and the content of his/her report must be kept strictly confidential. The report materials shall be managed as confidential documents.
• It is strictly forbidden to transfer the original report materials to the department, organization, or person involved.
• Accept a report or verify information with the whistleblower in a confidential manner without revealing the whistleblower’s identity.
• Publicize whistleblowing cases and the rewards for truthful whistleblowers within the Company. The name and department of the whistleblower shall not be disclosed without the consent of the whistleblower.
• It is strictly forbidden to hamper, suppress, or retaliate against the whistleblower on any pretext. Once verified, retaliation against the whistleblower and reported matter shall be seriously dealt with according to our rules and regulations, and retaliators shall be investigated for economic and administrative responsibilities by the Company. Cases that constitute crimes shall be transferred to judicial organs for handling.
• It is strictly forbidden to transfer the original report materials to the department, organization, or person involved.
• Accept a report or verify information with the whistleblower in a confidential manner without revealing the whistleblower’s identity.
• Publicize whistleblowing cases and the rewards for truthful whistleblowers within the Company. The name and department of the whistleblower shall not be disclosed without the consent of the whistleblower.
• It is strictly forbidden to hamper, suppress, or retaliate against the whistleblower on any pretext. Once verified, retaliation against the whistleblower and reported matter shall be seriously dealt with according to our rules and regulations, and retaliators shall be investigated for economic and administrative responsibilities by the Company. Cases that constitute crimes shall be transferred to judicial organs for handling.
Relevant Management Policies
Noah Holdings Code of Business Conduct and Ethics
