Make compliance a process, not a training
Compliance cannot rely on individual consciousness. The group's approach is to write constraints into the decision-making process, approval authority and assessment standards, making it difficult for violations to occur before they are discovered.
Six requirements that apply to all member companies
The Code of Conduct is formulated by the Group and applies to all employees and directors of the nine member companies, as well as third parties acting on behalf of the Group.
安全一票否决
在航空、铁路、城市轨道与医疗四类业务中，安全指标具有一票否决权。任何一线员工均有权叫停存在隐患的作业，且不因此承担业绩后果。
反腐败与反商业贿赂
禁止以任何形式向公职人员或商业伙伴提供、承诺或索取不正当利益。礼品与款待须符合集团限额规定并如实登记。
公平竞争
禁止与竞争者就价格、产能、市场划分或投标行为达成任何形式的协议或默契。在集团具有市场支配地位的业务中，尤其审慎对待定价与交易条件。
利益冲突
员工须主动申报可能影响其判断独立性的关系与利益，包括亲属关系、外部任职与对供应商或客户的持股。
信息与数据
涉及旅客个人信息、患者健康数据与工业生产数据的访问须遵循分级授权，任何越权访问均留痕并触发审计。
内幕信息
掌握未公开重大信息的人员不得进行相关证券交易，也不得向他人建议交易或泄露该信息。
Operated by an independent third party,
Not conveyed to management
The reporting channel is operated by an independent third-party organisation, and the reporting content is submitted directly to the Group Audit Committee without being relayed by the management of the member company where the person being reported is located. The annual acceptance and disposal status is disclosed in the sustainability report.
- 可举报的内容违反行为准则、法律法规或集团政策的行为，包括安全隐患、财务不实、腐败、利益冲突、数据滥用与职场不当行为。
- 匿名举报接受匿名举报。但完整的时间、地点与可核查的细节，能显著提高调查的可行性。
- 不报复承诺集团禁止对善意举报人采取任何形式的报复。对举报人的报复行为本身即构成严重违规。
- 处理流程第三方机构受理后作初步分类，提交审计委员会决定是否立案。调查过程与结论独立于被举报人所在的业务条线。
- 反馈留下联络方式的举报人，将在调查结束后收到处理结果的概要说明。
Who is going to watch these rules?
The Group Audit Committee is responsible for supervising the integrity of financial reports and the effectiveness of internal controls, and directly receives matters submitted through reporting channels. The Safety and Operations Committee is responsible for supervising the safety performance and review of major incidents in the four categories of aviation, railway, urban rail and medical services.
At the assessment level, safety, compliance and sustainable development indicators are included in the assessment of the person in charge of each member company, with the same weight as the operating indicators, and are approved by the remuneration and nomination committee. This means that poor compliance performance cannot be compensated for by operating performance.
Requirements for third parties
Third parties acting on behalf of the Group – including suppliers, agents and partners – are also subject to the Group’s Code of Conduct. Signature of the Supplier Code of Conduct is a prerequisite for entry, with a sign-up rate of 96% as of FY2025.
For supplier access conditions, procurement procedures and cooperation requirements, please view the Suppliers and Procurement page.
Suppliers and Procurement