Greenpro Capital Corp. and the subsidiaries (referred to herein, collectively, as “the Company”) are committed to high standards of ethical, honest and legal business conduct.

The Company is committed to maintaining good corporate governance, emphasizing accountability and a high degree of transparency which enable our stakeholders to have trust and faith in the Company to take care of their needs and to fulfill its social responsibility.

This policy aims to provide reporting channels and guidance on reporting possible improprieties in matters of financial reporting or other matters, and reassurance to persons reporting his or her concerns under this policy (“Whistleblowers”) of the protection that the Company will extend to them against unfair disciplinary action or victimization for any genuine reports made.





“Whistleblowing” refers to a situation in which an employee or other Stakeholder decides to report serious concerns about any suspected misconduct, malpractice or irregularity within the Company. See Section 3 of this policy for examples of misconducts, malpractices or irregularities. This policy is intended to encourage and assist the Whistleblowers to disclose information relevant to suspected misconduct, malpractice or irregularity through a confidential reporting channel (to the extent possible). The Group will handle the reports with care and will treat the Whistle-blowers’ concerns fairly and properly.


“举报”是指员工或其他利益相关者决定对公司内任何涉嫌的不当行为、渎职或违规行为报告严重关切的情况。有关不当行为、不当行为或违规行为的示例,请参阅本政策第4 3节。本政策旨在鼓励和协助举报人通过保密报告渠道(尽可能)披露与涉嫌不当行为、渎职或违规行为有关的信息。本公司将谨慎处理这些报告,并公正、适当地处理检举人的关切。

Inappropriate Conduct of the Company’s attention. Inappropriate Conduct may include, but is not limited to, the following: -

• irregular accounting methods, financial reporting practices or auditing conduct;
• unusual or dubious payments or arrangements;
• violations of state or federal securities laws, including the Foreign Corrupt Practices Act, the Sarbanes-Oxley Act of 2002 (“SOX”) and the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“DFA”);
• any other activity that may violate federal, state or local laws or regulations or is otherwise unlawful;
• violations of the rules and regulations of the principal market or transaction reporting system on which the Company’s securities are traded or quoted (at the time of the adoption of the Policy, the NASDAQ Capital Market);
• substantial and specific danger to the health and safety of directors, officers or employees of the Company or the general public; and
• other activities not in line with the Company’s Code of Ethics and Professional Conduct or any of the Company’s other policies.


• 不规范的会计方法、财务报告準則或审计行为;
• 异常或可疑的付款或安排;
• 违反州或联邦证券法,包括《反海外腐败法》、《2002年萨班斯-奥克斯利法案》(“SOX”)和《2010年多德-弗兰克华尔街改革和消费者保护法》(“DFA”);
• 可能违反联邦、州或地方法律或法规或其他非法行为的任何其他活动;
• 违反公司证券交易或报价的主要市场或交易报告系统的规章制度(在采用该政策时,即纳斯达克资本市场);
• 对公司或公众的董事、高级职员或雇员的健康和安全造成重大和具体的危害;
• 以及不符合公司道德和职业行为准则或公司其他政策的其他活动。


Whistleblowers making genuine and appropriate reports are assured of fair treatment. In addition, employees of the Company are also assured of protection against unfair dismissal, victimization or unwarranted disciplinary action.

The Company reserves the right to take appropriate actions against anyone (employees or Other Stakeholders) who initiates or threatens to initiate retaliation against the Whistleblowers. In particular, employees who initiate or threaten retaliation will be subject to disciplinary actions, which may include summary dismissal.





The Company will make every effort to keep the Whistle blower’s identity confidential. In order not to jeopardize the investigation, the Whistleblower is also required to keep confidential the fact that he or she has filed a report, the nature of concerns and the identities of those involved.

There may be circumstances in which, because of the nature of the investigation, it will be necessary to disclose the Whistle blower’s identity. If such circumstances exist, the Company will endeavor to inform the Whistleblower that his or her identity is likely to be disclosed.

Should an investigation lead to criminal prosecution, it may become necessary for the Whistleblower to provide evidence or be interviewed by relevant authorities.






The Whistleblowers should make their reports via the following email address:

1. For matter relation to non-managerial employees: whilstleblower@greenprocapital.com to Managing Director.
2. For matter relation to managerial employees and executive directors: audit.chairman@greenprocapital.com to Chairman of Audit Committee.




2. 关於管理人员和执行董事有关的事项:audit.chairman@greenprocapital.com至审计委员会主席。


As the Company takes reporting of misconducts, malpractices, and irregularities seriously and wants to conduct warranted investigations of both potential and actual violations, anonymous reports, in general, will not be acted upon. Therefore, it is strongly recommended that the report should not be made anonymously.




Any Complaints received by a Recipient will be promptly forwarded to the Chairman of the Audit Committee.

The Chairman of the Audit Committee will direct the Internal Audit to conduct or oversee an initial inquiry into the complaint and to submit an initial report of findings to the Chairman of the Audit Committee.

All Directors, Officers, and Employees of the Company have a duty to promptly cooperate and provide accurate information in connection with any investigation of a complaint

Upon completion of the investigation, a report, including its impact and action plan, as applicable, will be prepared without revealing the identity of the Whistleblower. For confirmed violations of principles of ethics, the normal process is for the responsible line management (with the assistance of e.g. Human Resources representatives) to determine what disciplinary and other appropriate actions are needed. A recommendation will be made to the relevant Executive Committee for a final decision on the actions required.

The Whistleblower will be informed of the final results of the investigation, wherever reasonably practicable.