【Our Commitment】
Apache Footwear Group firmly believes that integrity is the cornerstone of sustainable operations. We are committed to building a transparent, fair, and zero-tolerance environment toward corruption, applying the same standards both internally and externally. Our integrity policies for both employees and suppliers — namely, the Commitment to Anti-Corruption and Integrity Terms and the Supplier Code of Business Integrity — are supported by an independent reporting mechanism to ensure transparency and accountability.
【Employee Integrity Policy】
Anti-Corruption and Integrity
To ensure transparency and fairness in the workplace and to maintain a healthy work environment, Apache Footwear Group (hereinafter referred to as “the Group”) requires all employees (hereinafter referred to as “Employees”) to commit to complying with the following terms:
- Definitions
1.1 “Illicit Interests” include, but are not limited to:
- Bribes, kickbacks, profit-sharing, gifts, special offers, or any other form or value of improper benefits (such as cash, travel, products, coupons, discounts, etc.);
- Undisclosed financial support, interest-free loans, or loans offered at abnormal interest rates;
- Business opportunities, employment, contracts, or services that benefit the employee or any Related Person;
- Any sponsorship, discount, undue reward, or unreasonable compensation that may impair business integrity, distort fair decision-making, or compromise the transparency of company operations.
1.2 “Related Person” refers to any individual or organization with a close connection to the employee, including but not limited to the following:
- Family members, such as a spouse, parents, children, siblings, grandparents, grandchildren, as well as close friends or other members of the household;
- Individuals who have a close, marital, foster, or familiar relationship with the employee;
- Close friends, business partners, or any person or organization that may influence the employee’s work-related decisions or gain benefits from the employee.
- Integrity Commitment
2.1 Employees fully commit to strictly complying with the Group’s integrity policies and regulations, and shall not engage in any of the following behaviors:
- Shall not, under any circumstances, directly or indirectly, through intermediaries, offer, promise, request, or give bribes or improper benefits to any the Group employee, related party, or designated partner.
- Shall not accept gifts, commissions, cash, or other valuables without the Group approval.
- Shall not support any related party, individual, or organization in profiting from the Group policies.
- Shall not abuse their position to embezzle, steal, defraud, misappropriate, or otherwise unlawfully acquire the Group assets.
- Shall not treat discounts, commissions, rebates, gifts, goods, or services obtained through the Group operations and transactions as personal property or distribute them without authorization.
- Shall not use their position or the Group resources to seek personal gain or other improper benefits for themselves or others.
- Shall not accept gifts or improper benefits from related parties, conceal or solicit such benefits from superiors, or alter data to distort transactions or engage in conduct harmful to the Group’s interests.
- Shall not accept free services, benefits, shares, or other advantages from suppliers in exchange for improper gain.
- Shall not use the Group trade secrets or intellectual property for profit or to transfer benefits to themselves or others.
- Shall not disclose images of the Group’s products, machinery, or production equipment to any partner without prior approval.
- Shall not engage in any prohibited, high-risk, profit-seeking, or otherwise harmful conduct that damages the Group’s interests, reputation, or image.
2.2 Prohibition of Personal Financial Transactions
Employees shall not engage in any personal financial transactions with any supplier, contractor, or manufacturing facility associated with the Group. This includes, but is not limited to:
- Borrowing or lending money, guaranteeing loans, or mortgaging assets;
- Investing in any company, supplier, or contractor that has business dealings with Apache Footwear Group, without prior written approval from Group leadership;
- Purchasing or selling goods/services at abnormally favorable prices or in violation of Group policies.
2.3 Duty to Report
If employees become aware of any employee requesting, accepting, or soliciting bribes or improper benefits, they shall report the matter immediately and provide relevant evidence.。
2.4 If employees discover that any business partner of the company has violated these regulations, they shall report the matter immediately and provide relevant evidence. Employees shall also cooperate with the Group in handling the violation in accordance with the law.
2.5 Employees must provide accurate and valid supplier information and promptly report any changes.
Protection of the Group assets and information: Employees commit to protecting and properly using all company assets to which they have access, including but not limited to tangible assets, intellectual property, business data, security information, and other resources. Employees shall not appropriate, copy, transfer, or use such assets beyond the scope of their job responsibilities unless formally approved in writing by the Group leadership or authorized personnel.
2.7 Employees shall not, in any form, use their position to induce any employee to resign or engage in any behavior that may harm the Group’s interests. Employees are expected to maintain a spirit of collaboration, show respect toward colleagues, and refrain from any actions that may negatively impact the Group’s work environment.
2.8 In the event of a major incident related to the Group, the Group reserves the right to investigate the individuals involved and may require employees to provide relevant information and documents, and to fully cooperate during the investigation and verification process. Employees shall not obstruct, conceal, or interfere with such investigations in any way.
2.9 Liability for Violations
Employees agree to take full responsibility for any violations of the Group rules, policies, or commitments by themselves, their authorized representatives, or their personnel. The Group reserves the right to take appropriate actions in accordance with applicable laws and internal policies.
Employees also agree to fully cooperate in handling any violations and to bear liability for any losses incurred by the Group as a result of such violations.。
3. Liability for Violations
3.1 If an employee violates the Group’s integrity-related regulations, the terms of this commitment, or applicable laws, the employee shall be responsible for all losses and expenses incurred by the Group as a result, and shall accept disciplinary actions in accordance with the Group’s policies and applicable labor laws. The employee shall not raise any claims, complaints, or demands for compensation against the Group.
3.2 During their employment with the Group, employees voluntarily commit to abiding by laws, policies, ethical standards, and relevant regulations regarding integrity, transparency, and anti-corruption. Employees shall act honestly and in good faith in all Group business activities, take responsibility for their conduct, assume accountability for any violations, and accept the Group’s supervision.
3.3 This policy shall be governed by the applicable laws of the jurisdiction where the Group is located. Both parties agree to first seek amicable negotiation in case of disputes; if negotiation fails, both parties agree to submit the dispute to arbitration at a neutral location agreed upon by both parties. The arbitration award shall be final and binding.
【Supplier Integrity Policy】
Supplier Code of Business Integrity
To uphold integrity in business operations, Apache Footwear Group (hereinafter referred to as “the Group”) has established this Supplier Code of Business Integrity, which applies to all suppliers and partners engaged with the Group.
Since integrity in transactions is vital to both parties, the Group expects suppliers to jointly adhere to principles of honesty, fostering a transparent and fair cooperative relationship。
1. Definitions
1.1 “Illicit Interests” means any benefit, including but not limited to bribes, kickbacks, gratuities, or commissions.
1.2 “Related Person” means any the Group’s spouse, parents, children, siblings, grandparents, grandchildren, and any close family members, friends, or relatives.。
2. Commitments
2.1 The Supplier shall strictly comply with all integrity policies and regulations established by the Group. Under no circumstances shall the Supplier offer, promise, solicit, or provide any bribe or Illicit Interests, whether directly or indirectly through intermediaries, to any employee of the Group, Related Person, or any designated third party.
2.2 Employees are not allowed to engage in any personal loan or cash transactions with suppliers, contractors, or manufacturing plants.
2.3 If the Supplier discovers that any the Group has requested, accepted, or sought any bribe or Illicit Interests, whether for themselves, their Related Person, or any designated third party, the Supplier shall immediately report this to the Group and provide all relevant evidence.
2.4 If the Supplier discovers that any other counterparty of the Group has violated this Code, the Supplier shall report it immediately and provide relevant evidence.
2.5 The Supplier shall provide the Group with accurate and valid vendor information in the required format. Any updates or modifications must be promptly reported.
2.6 If the Supplier gains access to any tangible or intangible property of the Group, including intellectual property, they shall not steal, occupy, replicate, transfer, or use such property beyond the scope of business transactions.
2.7 The Supplier shall not, for its own or any third party’s benefit, solicit or induce any employee of the Group to resign or engage in activities detrimental to the Group.
2.8 If the Supplier or its representative is a Related Person of any employee of the Group, the Supplier must notify the Group immediately.
3. Liabilities
3.1 If there is any violation of laws, the Group’s integrity policies, or this Code, the Group reserves the right to terminate the transaction and claim reasonable damages incurred as a result.
3.2 This Code shall be governed by the local laws of the transaction location. Both parties agree that in case of disputes, they shall first seek amicable negotiations; if negotiations fail, both parties agree to submit the dispute to arbitration at a neutral location agreed upon by both parties. The arbitration award shall be final and binding.
【Reporting Mechanism】
Apache Footwear Group encourages all internal employees and external stakeholders to report any form of corruption, bribery, dishonesty, or other misconduct. The company is committed to maintaining strict confidentiality of the reporter’s personal information and the content of the report, and to protecting whistleblowers from any form of retaliation, threats, or adverse treatment.
To uphold integrity in business operations, the Group has established an independent reporting channel accessible to both internal and external stakeholders, ensuring transparency and fairness throughout the reporting process.
Reporting Mailbox: hr@tw.apachefootwear.com
