Supervision and Whistleblowing

1. Objectives

1.1   TGOOD is committed to building a platform for employees’ value growth and career development, establishing mechanisms to “enable good people to excel while preventing misconduct.” To foster a culture of integrity, enhance self-discipline, ensure healthy employee development, uphold the company’s honest reputation, and protect its legitimate rights, we encourage employees and external parties to report fraud, violations, or unethical practices in business activities involving TGOOD Group and its subsidiaries.

1.2   This policy clarifies TGOOD Group’s commitment to whistleblowing protection and outlines procedures for reporting violations.

1.3   This policy applies to all employees of Qingdao TGOOD Electric Co., Ltd. and its subsidiaries (including staff, directors, supervisors, and executives); External parties (e.g., clients, suppliers) engaged with TGOOD; Joint ventures (TGOOD will advocate for their adoption of similar policies).


2. Whistleblowing Matters

Whistleblowers (including but not limited to employees or third parties) may report any fraudulent or non-compliant activities related to TGOOD Group, including but not restricted to the following:

2.1    Misappropriation of company assets through positional authority, including establishing or utilizing business entities (under one’s own or others’ names) to conduct transactions with the company for improper gains; Colluding with affiliated parties to commit fraud in project bidding, material procurement, or sales pricing schemes to obtain illicit benefits.

2.2   Solicitation or acceptance of commercial bribery through positional authority, including accepting kickbacks from stakeholders in any form (e.g., rebates, commissions, bonuses, consulting fees, or service fees); Receiving gifts, cash, securities, payment instruments, or other undue benefits from interested parties.

2.3   Violation of company financial policies and misappropriation of funds.

2.4   Violation of trade secrets and infringement of company interests, including leaking sensitive company data related to bidding quotes, cost calculations, equipment selection, procurement, tendering, or engineering projects, including details from technical negotiations, commercial discussions, or decision-making meetings, thereby disrupting operations and causing financial losses; Unauthorized sharing of proprietary trade secrets, patented technologies, software copyrights, or other critical business/technical information with external parties for personal gain.

2.5   Engaging in related business activities outside the company, including personally establishing or using others’ identities to set up business entities that engage in activities competing with the company’s core operations.

2.6   Abuse of authority harming company interests, including making material decisions that violate established decision-making principles and procedures, unauthorized approval of key project arrangements, and improper handling of capital operations or fund allocations.

2.7   Other fraudulent or unethical conduct. Additional violations of laws or regulations.


3. Whistleblower Protection Policy

2.1   Confidentiality of Reporting: Except where required by law or for judicial proceedings, TGOOD Group maintains strict confidentiality of all reported information. The identity of whistleblowers is protected, and access to reporting channels (e.g., dedicated email) is restricted to authorized case administrators only.

2.2   Anti-Retaliation Safeguards: TGOOD guarantees fair treatment for whistleblowers who report in good faith, including protection against unfair dismissal, harassment, or punitive actions. Retaliation against whistleblowers or witnesses will result in severe disciplinary measures.

2.3   Priority for Named Reports: Real-name reporting is encouraged to facilitate communication for case details and enable feedback on investigation outcomes.

2.4   Anonymous Reporting: Whistleblowers may submit reports anonymously if unwilling to disclose their identity.


4. Whistleblowing Channels

4.1   Mail Reporting: Audit Office 701, Qingdao TGOOD Electric Co., Ltd., No. 336 Songling Road, Laoshan District, Qingdao

4.2   Telephone Reporting: 0532-89087382

4.3   Email Reporting: shenji@tgood.cn

4.4   Online Reporting: Click to enter reporting    Report progress view

4.5   QR Code Reporting:

4.6   If any individual reports misconduct to an employee’s direct supervisor or department head, the supervisor/department head must immediately escalate the matter to the Group Audit Office.


5. Investigation and Disciplinary Process

5.1   Upon receiving a report or becoming aware of potential misconduct through other channels, the Audit Office shall immediately notify the President and Chairman of the Board and conduct preliminary verification of the allegations.

5.2   For matters confirmed as requiring further investigation through preliminary review, the Audit Office will establish an investigation team comprising Audit Department, Risk Control Department, Human Resources Department and other relevant business units. The team will conduct comprehensive internal/external investigations while maintaining whistleblower confidentiality.

5.3   A formal investigation report will be prepared upon investigation completion. The team will propose disciplinary actions per company policies and recommendations require approval by the President and Chairman. HR Department will execute approved sanctions and maintain records. For suspected criminal offenses (e.g., embezzlement, bribery), the case will be referred to judicial authorities and legal proceedings will be initiated in accordance with applicable laws.


6. False Whistleblowing

Whistleblowers must report truthfully. TGOOD Group reserves the right to pursue legal action against individuals who submit false reports. Employees found to have made false accusations may face termination of employment.


7. Reward Policy

Monetary rewards will be granted for verified reports:

Standard Cases: 500CNY to 5000CNY

Major Impact Cases: 5000CNY to 100000CNY