Building an Integrity and Transparency Business Environment
(GTMS Corporate Integrity & Whistleblowing Policy)
1. Policy Commitment
GTMS Catering Holdings Ltd. (“GTMS” or “the Company”) upholds the core values of Integrity, Transparency, and Accountability, and is firmly committed to combating fraud, corruption, and all forms of misconduct.
We hereby make the following commitments:
• Independent Investigation: The Corporate Integrity & Compliance Department reports directly to the Board of Directors and conducts investigations independently to ensure fairness and objectivity.
• Strict Confidentiality: The identity of whistleblowers and the content of reports are kept strictly confidential. Any retaliation or intimidation against whistleblowers is strictly prohibited and will be subject to severe disciplinary action.
• Priority for Real-Name Reports: Real-name reports will be prioritized for handling and progress feedback. Anonymous reports are accepted, and providing a contact method (e.g., temporary email) is encouraged to assist verification.
• Verified Reward: Verified real-name reports will be rewarded with material or honorary recognition according to internal policy.
• Timely Response: Initial feedback will be provided within seven (7) working days of receiving a report.
2. Scope of Whistleblowing
The following behaviors (including but not limited to) fall within the scope of reportable violations:
• Conflict of Interest & Illicit Benefits:
Acceptance of kickbacks or commissions, falsified expenses, collusive dealings, or related-party fraud.
• Abuse of Power:
Unauthorized approval, manipulation of bidding or procurement, or disclosure of trade secrets.
• Misappropriation of Assets:
Embezzlement of funds, falsification of financial documents, or private division of company assets.
• Other Misconduct:
Sexual harassment, discrimination, or violations of safety, labor, or environmental regulations.
3. Reporting Channels
Reports may be submitted through the following channels:
Email: ICAC@gtmsh.com
Hotline: 400-065-9988
Mailing Address: 59M Floor, Hanking Center, 9968 Shennan Avenue, Nanshan District, Shenzhen, China
4. Reporting Requirements
To facilitate effective investigation, whistleblowing materials should include the following elements:
1.Information of the Reported Person
• Name, Position, Department
2.Description of Facts
• Chronological account of the incident, specifying time, place, amount, and nature of the misconduct.
• Example:
“In March 2025, Zhang (Procurement Department) requested Supplier A to pay a ‘project coordination fee’ of RMB 50,000 or the contract would not be signed.”
3.Evidence List
• Documentary evidence: Contracts, invoices, screenshots of messages;
• Physical evidence: Audio recordings, videos, or photos;
• Witness information: Name, contact details, and position (if available).
4.Reporter’s Request or Appeal
• Example: “Request for recovery of losses” or “Request for public disclosure of disciplinary outcome.”
Note: Reports may be submitted anonymously. However, providing an anonymous contact method (such as a temporary email) is recommended to ensure follow-up communication.
5. Protection and Follow-up
All reports received will be handled under strict confidentiality, and the Company will ensure whistleblowers’ protection throughout the process.
GTMS prohibits any form of retaliation against individuals who report misconduct in good faith.
Confirmed cases will be dealt with in accordance with internal disciplinary procedures and relevant laws, and outcomes will be communicated to the whistleblower when applicable.