Guidelines
for Enterprise Compliance with Intellectual Property Rights
(For Trial Implementation)
Chapter I General Rules
Article 1 [Formulation Basis] The Guidelines are formulated in accordance with “The Guiding Opinions on Establishment of a Third-party Supervision and Evaluation Mechanism for the Compliance of Enterprises Involved in Criminal Cases(for Trail Implementation)”, the “Specifications for the Administration of Intellectual Property Rights of Enterprises” and the pilot working experience on enterprise compliance reforms, for the purposes of enhancing enterprises’ compliance management work for intellectual property rights, guarding against and defuse compliance risks related to intellectual property rights, and guiding enterprises to operate in compliance with relevant law and regulatory requirements as well as to develop healthily.
Article 2 [Purpose] The purposes of compliance management for intellectual property rights of enterprises are to effectively identify and manage compliance risks related to intellectual property rights, ensuring that management of enterprises and other business activities conforms to relevant laws and regulatory requirements; and to promote enterprises to comprehensively enhance their compliance management on intellectual property rights, advance their lawful business management level, and guarantee the sustainable and healthy development of enterprises.
Article 3 [Compliance Risks] The “compliance risks related to intellectual property rights” this Guidelines referred to, are legal responsibilities, criminal charges, financial or reputational losses or any other negative influences resulted from enterprises’ or its employees’ non-compliance actions. The legal risks concerning intellectual property rights include but not limited to:
(1) Risks of Patent Rights: 1. risks related to patent license abuses, the right of patent application disputes, patent being infringed, being involved in patent infringement lawsuit, and patent transfer disputes; 2. risks in failing to effectively develop and implement patent, and poor management causing invalidity of patent, etc.
(2) Risks of Trademarks: 1. risks in the application for trademarks: trademark not registered or pre-registered by others, incomplete registered categories, insufficient protection of key categories, incomplete application for marks; 2.risks in the implementation of trademarks: incomplete application for territories that registered trademarks can be used within, failure to make overall arrangements for target markets, using or licensing others to use the registered trademark beyond the licensed category of the goods or services, infringement of others’ prior rights, non-standardized use of trademarks, etc.
(3) Risks of Copyrights: 1. risks related to service works, commissioned works, and the confirmation of corporates’ copyrights thereof; 2. risks of works’ material infringements; 3. right of dissemination via information networks infringements; 4. legal risks in the licensed use and transfer of copyrights, etc.
(4) Risks of Trade Secrets: 1. risks of trade secrets being acquired by others via theft, spying or hacking; 2. risks of internal employees being bought off; 3. risks of trade secrets leakage in the course of external disseminations and collaborations; 4. risks of employees’ disclosure of trade secrets after leaving office, etc.
Article 4 [Compliance Principles] The establishment of enterprise compliance system for intellectual property rights should adhere to the principles of independence, effectiveness, comprehensiveness, dynamism and traceability:
(1) Independence: The operation of compliance management department shall be free from any undue interference and pressure; the compliance management department shall objectively evaluate and handle the acts of enterprises and its employees in strict accordance with laws and regulations as well as relevant rules of the enterprises; the personnel who undertake compliance management responsibilities shall perform its duties independently without any interference from other departments and personnel.
(2) Effectiveness: The compliance management system shall be effectively embedded in the specific processes of business operation, be integrated and connected with legal risks prevention, audit and supervision, internal control and risks management, etc. A compliance responsibility system, which specifies the compliance responsibilities of managers and employees for each position and supervises their effective implementation, shall be established for all employees to ensure a closed loop of compliance management.
(3) Comprehensiveness: The basic and key areas of enterprise compliance management for intellectual property rights include patents, trade secrets, trademarks and copyrights; the compliance work shall cover all business activities such as research and development, production, sales, cooperation, investment and marketing, biding, and procurement, etc., run through the whole process of decision-making, execution and supervision, and guarantee the inclusion of all intellectual property rights-related businesses, departments and personnel in the compliance system.
(4) Dynamism: The compliance work shall be compatible with the business scope of the enterprise, its organizational structure and business scale; timely adjustments and improvements shall be made to the compliance work according to the internal and external environment changes of the enterprise; the compliance risks exist in the business management shall be reported, corrected and improved in time.
(5) Traceability: The compliance work shall have clear procedural instructions to act upon, so as to ensure the compliance management of the enterprise can be traceable and provable.
Article 5 [Compliance Management System] The establishment of a compliance system for intellectual property rights shall include organizational system, institutional system, operating system, risks identification and handling system, etc.
Chapter II Compliance Management Organizational System
Article 6 [Compliance Responsibility] In light of its business nature and scales, enterprises may reasonably select and appoint intellectual property rights compliance management department or personnel, which can organize, coordinate and supervise enterprises’ compliance management work, take direct responsibilities for compliance management as well as simultaneously support other departments for compliance management. Enterprises may guarantee such department or personnel’s veto power for matters involving significant compliance risks. Their duties mainly include:
(1) Researching and drafting compliance management plans, making compliance management rules, organizing the development of strategic plans and annual reports of compliance management;
(2) Paying continuous attention to changes in laws, regulations and other rules, and organizing the identification and early warning of compliance risk;
(3) Participating in the enterprises’ major decisions-making, providing compliance suggestions and opinions, and taking part in compliance reviews and risk management on the enterprises’ material matters;
(4) Participating in the business sections’ due diligence and periodic evaluation for vital business partners;
(5) Instructing the implementation of compliance work in each department, providing compliance consulting, and organizing compliance certification;
(6) Organizing compliance inspection and assessment, conducting compliance evaluation over rules and procedures, and urging corrective actions and continuous improvements over non-compliance ;
(7) Promoting the integration of compliance responsibilities into job duties and employee’s performance management;
(8) Establishing compliance performance review indicators, monitoring and measuring compliance performance;
(9) Establishing compliance reporting management system, accepting reports within the scope of compliance management duties, organizing or participating in the investigation of reported incidents, and offering suggestions for handling;
(10) Organizing or assisting business departments and human resources sections to conduct compliance trainings;
(11) Other compliance management duties suitable for the compliance management department.
Article 7 [Organizational Support] The board of directors, board of supervisors and senior managers of enterprises shall perform necessary compliance management responsibilities, offer support for the formulation and implementation of the intellectual property rights’ compliance plan, and ensure the independent exercise of authority by the compliance management department (personnel), with sufficient resources guaranteed.
Article 8 [Internal Collaborations] Each department of enterprises shall collaborate within the scope of their authorities to implement the routine work of compliance management, and appoint a section compliance liaison, who will be able to collect and report information regarding compliance risks as well as to cooperate with the compliance department to investigate relevant issues and make corrections.
Chapter III Compliance Management Institutional System
Article 9 [Compliance Control] Enterprises shall establish a sound and standardized business management and decision-making process of intellectual property rights, take compliance control as a compulsory procedure for business management activities such as rules formulation, material matters’ decision-making, important contracts’ conclusion and significant projects’ operation, as well as propose changes to non-compliance content in time. Such activities shall not be implemented without compliancecontrol.
Article 10 [Compliance Monitoring] Compliance monitoring on the compliance system of intellectual property rights shall be conducted regularly by enterprises. Such monitoring shall be implemented by the compliance management department personnel, and a compliance monitoring report shall be produced. The compliance monitoring shall mainly include evaluation for the effectiveness of the compliance system of intellectual property rights and the relevant compliance performance, so as to ensure the realization of the purposes of intellectual property rights compliance.
Article 11 [Compliance Reporting] Enterprises shall encourage reporting of potential or actual violations of intellectual property rights’ compliance policies or obligations. Enterprises shall broaden the sources of feedbacks for compliance performance, establish reporting systems, help hotlines, feedback or suggestion boxes for relevant personnel, and set up a compliant handling system for third parties such as suppliers and contractors, focusing on the collection of feedbacks regarding the enterprises’ non-compliance actions, compliance queries and evaluations for compliance effectiveness and performance.
Article 12 [Performance Review] Enterprises shall set up scientific compliance performance review indicators of intellectual property rights, evaluate each department’s compliance performance and contributions to the compliance work in a scientific manner, incorporate compliance performance review into the annual comprehensive assessment of each department and the relevant persons in charge, and take compliance performance as an important basis for employee assessment, promotion, merit rating and other work.
The performance review shall mainly focus on the indicators related to compliance risk, including but not limited to, initiative and effectiveness of the implementation of each compliance rules, effective training ratio of departmental personnel, frequency of interventions by regulatory institutions, negative impacts arising from non-compliance issues such as penalties, compensations, damage to goodwill, etc., potential risks of non-compliance, and the record-keeping of compliance-related information, etc.
Article 13 [Non-compliance Investigation] Enterprises shall establish an investigation system for non-compliance, adhering to principles of just and fair, and promptly and thoroughly investigate any claims or suspicions of misconducts by enterprises, its employees or related third parties. They shall investigate enterprises’ responsive documentations, disciplinary or remedial measures, and adjust the compliance management system for intellectual property rights in light of these lessons learned; find out the roots of misconducts, loopholes in the system and reasons for responsibility deficiency, including the acts and duties of managers, top management and governance bodies; and prudently analyze the identified causes, taking into account the number and level of the personnel, as well as the degree, prevalence, severity, duration and frequency of non-compliance incidents.
Article 14 [Documented Information Management] Enterprises shall establish a system of documented information management to ensure that the important process in the formation of relevant intellectual property rights in business management are recorded, marked, stored, protected, retrieved, preserved and disposed. Effective management shall be conducted over external documents such as administrative decisions, judicial judgements and lawyer’s letters, ensuring the accuracy of the sources and timing when those documents were obtained. The documents of external origin and record files shall be complete with clear preserve methods and retention periods. The carriers of the documents management system are not limited to paper documents, but also include electronic ones.
Article 15 [Resource Allocation] In order to ensure the proper implementation of compliance management, enterprises may set up regular budget accounts for intellectual property rights, which may include: expenses for the application, registration, maintenance, retrieval, analysis, evaluation, assessment, litigation and training for intellectual property rights; expenses for operation of compliance management institution of intellectual property rights; expense for the establishment, operation, maintenance and update of the compliance management system regarding intellectual property rights; expenses for intellectual property incentives. Enterprises that meet certain conditions may also set up reserves for intellectual property risks.
Article 16 [Confidentiality Management] Enterprises shall establish a system of confidentiality management, which specifies secret-related personnel and requires confidentiality registration and access permissions. Regarding the equipment that may easily cause leakage of intellectual property secrets, enterprises shall regulate the users, purposes, usage modes and circulation of such equipment; specify the scope of confidential information, classified level and period, as well as the requirements for transmission, preservation and destruction. The confidential areas and the areas which customers and visitors have access to shall also be identified.
Article 17 [Compliance Culture] Enterprises shall establish a hierarchical compliance training system for technical personnel, intellectual property management personnel and all employees. The construction of intellectual property culture shall be carried out in terms of enhancing the awareness of intellectual property protection and intellectual property values, creating an atmosphere of active pursuit of innovation and due respect for knowledge, attaching importance to intellectual property publicity and education. Enterprises shall combine the construction of intellectual property management system with talents cultivation, establish an incentive mechanism that is conducive to mobilize employees’ enthusiasm for intellectual property work, and build up an enterprise image that respects and protects intellectual property rights.
Chapter IV Compliance Management Operating System
Article 18 [Compliance In Acquisition ] Enterprises shall make timely applications for the registration of various types of intellectual property rights, clarify the management measures and procedures for applications and registrations for patent, layout design of integrated circuits, trademarks and copyrights, trade secrets protection as well as their subsequent maintenance or abandonment.
Article 19 [Compliance In Maintenance] Enterprises shall clarify the rules regarding the disposal and implementation of intellectual property rights, specify the conditions for defining service works as well as principles to determine the ownership of intellectual property rights for commissioned work or co-authored work, and provide the management measures and procedures for the transfer, licensing, investment and pledge of intellectual property rights such as patents, trademarks and copyrights.
Article 20 [Compliance in Implementation] Enterprises shall focus on the management of intellectual property rights in the processes of production and operation, clarify the management measures and procedures for all kinds of matters concerning intellectual property rights that might arise in the procurement of raw materials and equipment (including softwares, etc.), technology and product development, technology transfer(licensing) and cooperation, commissioned processing, sales of product, advertising or sales exhibition, biding, import and export trade, joint ventures, mergers and acquisitions, and listing, etc. The measures and procedures include:
(1) Intellectual property management in procurement. Enterprises shall collect relevant information of intellectual property and request the supplier to produce proof of ownership where necessary; conduct management and confidentiality work for suppliers’ information, purchase channels, and purchase price strategies, etc.; and specify the ownership of intellectual property rights, the scope of licensing, and tort liability, etc., in the procurement agreement.
(2) Intellectual property management in production. Enterprises shall focus on finding out the innovative achievements with intellectual property values, and take corresponding protective measures in a timely manner. Regarding those operating procedures, various reports and test records, inspection and testing records, etc., which are not suitable for public disclosure during production, an appropriate confidentiality system shall be established and relevant measures of confidential nature shall be taken. Enterprises shall also pay attention to avoiding intellectual property risks in the overseas processing when being engaged in commissioned processing, processing trade with supplied materials, original equipment manufacturer and other processing business, and clarifying rights, obligations and confidentiality of both parties concerning intellectual property.
(3) Intellectual property management in research and discovery(“R&D”). Enterprises shall build an intellectual property tracking, retrieval, analysis and monitoring system for R&D activities; clarify intellectual property ownership management of R&D achievements; strengthen the management of the archives and confidentiality of R&D activities, establish a management system of R&D archives and records, which guarantees the traceability of R&D activities; and enhance the selection and quality control over R&D results that proceed to patent application.
(4) Intellectual property management in marketing. Enterprises shall investigate and analyze the existing intellectual property rights of the products of the same kinds in the market where their products are to be launched, so as to prevent from encountering claims of intellectual property rights infringements; correctly use registered trademarks or patent numbers and other proof of intellectual property rights, and remind consumers and relevant market entities where necessary; establish a mechanism to monitor the market for the sales of product and use multiple channels to monitor the market situation of the products of the same kinds. For those found to be infringing, key information should be collected, and notarization should be conducted where necessary.
Article 21 [Listing Examination] Before enterprise listing, a comprehensive evaluation and planning for the legal status, duration and legal risks of existing intangible assets shall be conducted. The ownership and legal status of the intangible assets prepared by the listed company as well as relevant content in the prospectus shall be examined, and the acquisition, loss and transfer of the intellectual property rights shall be completely disclosed.
Article 22 [Overseas Business] Enterprises shall actively carry out the layout of intellectual property rights in overseas business; investigate and analyze status of relevant intellectual property rights of the technology or products to be introduced and comprehensively evaluate the risks of infringements. When concluding contracts for technology or products import or export (including agency agreements), these issues which include the licensing mode and scope of the imported technology or products, the ownership of the subsequent improvement results, sharing and maintenance of rights, confidential responsibilities and obligations of both parties, and legal liabilities the supplier undertakes in the case of intellectual property infringement of the introduced technology or products shall be provided in the contracts.
Chapter V Compliance Risk Identification and Handling System
Article 23 [Identification and Early Warning] By improving compliance risk information collection mechanism, enterprises shall comprehensively and systematically tease out the possible compliance risks in their business activities, establish a compliance risk ledger, and systematically analyze the origin, category and forming factors of risks, possible consequences and its probability, etc. For risks that are of typical significance, widespread or capable to cause serious consequences, early warnings should be issued in a timely manner.
Article 24 [Risk Inspection] Compliance management department shall lead, organize and coordinate all kinds of compliance inspection work. An joint inspection team may be formed by personnel selected from relevant departments to conduct periodical compliance risk inspections based on the business conditions of enterprises.
As to the compliance risk found in inspection, the inspection team shall put forward corrective suggestions, and each department shall propose specific solutions. After the solutions being confirmed by the inspection team, the compliance management institution shall supervise and urge all departments to actively implement the corrective plans.
Article 25 [Risks Level] Enterprises may classify the compliance risks of intellectual property rights into three levels: Significant, Medium, and General.
(1) Significant risks include: intellectual property risks arising from significant changes in laws, regulations, guidelines and local legal environment; penalty decisions, regulatory suggestions and risk warnings issued by regulatory agencies; submissions to regulatory agencies of supporting materials, special reporting materials, implementation of regulatory suggestions and rectification, compliance materials and other relevant information; information of significant intellectual property risks that are in violations of laws, regulations and guidelines during the course of business operations; any kind of regulatory documents that fail to meet the requirements of laws, regulations and guidelines; cases in which enterprises are being sued due to intellectual property compliance issues; other matters that should be identified as significant compliance risks.
(2) Medium Risks include: newly generated intellectual property risks or changes of original risks in business activities; changes in the measures or consequences of implementing the established compliance risk solutions, which fail to fully meet the original objectives; possible impacts on business operations, but the impacts are relatively insignificant or may cause small direct losses in the future; other matters that can be defined as medium compliance risks.
(3) Apart from the above-mentioned significant and medium risks, matters that have less impact on promoting the enterprises’ compliance management for intellectual property rights, improving its compliance management level pursuant to the law, or ensuring the healthy development of the companies, shall be managed as General Compliance Risks, although these issues still need to be improved by enhancing management work or by other means.
Article 26 [Risks Solutions] Enterprises shall develop and select risks solutions for intellectual property rights, including general solutions and special solutions, according to different levels of compliance risks. As to significant risks, compliance management department and other departments shall work jointly to study and introduce specific rectification plans, clarify particular requirements for rectification subjects, specific responsible persons and rectification time nodes, etc. Compliance management department shall take month as time nodes to summarize the completion of rectification, and report to the enterprises’ decision-making body in time.
Article 27 [Accountability Mechanism] An accountability mechanism shall be established based on enterprises’ own conditions. It shall conduct periodic reviews of performance objectives, bonus and other incentive measures for intellectual property compliance so as to verify whether appropriate measures are in place to avoid non-compliance actions; take appropriate disciplinary actions against personnel who violate the enterprises’ compliance obligations, objectives, systems and requirements of intellectual property rights, and hold them accountable when necessary.
Chapter VI Third-party Evaluation and Supervision System
Article 28 [Design Evaluation] The criteria for assessing and reviewing the effectiveness of the design of compliance management system mainly include:
(1) Identification and evaluation for non-compliance risks: 1. whether the compliance management departments/personnel are regularly organized to conduct a comprehensive assessment of the possible compliance risks of intellectual property rights, with a focus on the identification of risks in all stages of production and operation such as intellectual property research and discovery, procurement, production and marketing; whether a risk control and handling capacity matching the probable intellectual property compliance risks to be faced with, is developed based on the prioritized issues in the compliance management of risks identification and evaluation; 3. whether risks evaluation systems are periodically updated, which can identify and evaluate new changes to the original risks as well as newly generated risks in a timely manner.
(2) Policy and procedure arrangements: 1. whether relevant compliance management systems for intellectual property rights are established in accordance with compliance risks, business scopes and scales of enterprise, etc., and standardized managements are conducted in all the processes; 2. whether the execution standards of relevant systems, responsible entities and contents are clarified; 3. whether a compliance management operation mechanism for key segments such as the compliance acquisition, maintenance and implementation of intellectual property rights, is established, and being protected from possible risks.
(3) Training and communication arrangements: 1. whether a compliance training system is established, organizing and conducting targeted training on intellectual property compliance regularly, ensuring the employees’ fully recognition of the importance of intellectual property compliance and acquisition of professional skills for intellectual property, and improving business capacities at all levels through training; 2. whether internal and external communication channels for intellectual property and its compliance management are established, incorporating compliance culture, objectives and business of intellectual property into the content of communication, and ensuring timely collection and feedbacks of relevant information.
(4) Reporting and investigation mechanisms: 1. whether a reporting and investigation management approach for intellectual property rights is set up, and whether a special inspection system for personnel positions involving key risks is established; 2. whether a reporting channel in an open way is settled, and whether all personnel can understand and being fluent in using the relevant reporting procedures are guaranteed; 3. whether non-compliance investigation processes are established, ensuring a timely and thoroughly investigation of the non-compliance actions and its causes.
(5) Execution and guarantee institutions: 1. whether compliance management departments and personnel for intellectual property rights are set up, organizing, coordinating and supervising management work as the leading department of enterprise compliance management; 2. whether the enterprise audit, supervision, internal control, quality, security and all business departments being required in their respective areas of competence to cooperate with the implementation of the routine work of compliance managements for intellectual property rights are clarified; 3. whether corresponding professional qualifications, good business competence and morality are required in the course of appointing the enterprises’ intellectual property compliance personnel .
(6) Third-party supervision mechanism: 1. whether periodical compliance supervisions for intellectual property compliance system are conducted and compliance supervision reports are produced, focusing on evaluating the effectiveness of the intellectual property compliance system to ensure the realization of the objectives of intellectual property compliance; 2. whether a third-party institution is appointed when necessary, evaluating the effectiveness of the enterprises’ intellectual property compliance system and compliance risks management, and issuing evaluation reports.
Article 29 [Execution Evaluation] Standards of evaluation and reviewing for effectiveness of the execution of compliance management system include:
(1) Resource allocation: 1. whether enterprises provide relevant infrastructure for intellectual property compliance management, and take abidance of enterprise compliance business, rules and requirements of intellectual property rights as a condition for employment, as well as for staffing corresponding personnel; 2. whether regular budget accounts for intellectual property rights are set, including expenses for application, registration, maintenance, analyze, evaluation, litigation and training for intellectual property, and operation, maintenance and update for management system, in order to guarantee the normal operation of the compliance management work for intellectual property rights.
(2) Responsibilities and authorities: 1. whether responsibilities of compliance management departments and personnel for intellectual property rights are provided; 2. whether necessary compliance management responsibilities that the board of directors, board of supervisors and senior managers should perform are clarified; 3. whether responsibilities and communication procedures of each department to cooperate with the routine work of implementing compliance management for intellectual property rights are clearly defined.
(3) Compliance awareness: 1. whether enterprises’ management level and responsible personnel are aware of intellectual property compliance, whether they are familiar with the laws and regulations in the field of intellectual property, and whether compliance work for intellectual property rights are included in the key work of enterprises’ management and assessment; 2. whether employees of the enterprises have basic compliance awareness for intellectual property , and whether they understand and comply with enterprises’ compliance business, rules and requirements for intellectual property rights.
(4) Compliance management capability: 1. whether relevant compliance management systems for intellectual property rights can operate effectively, and whether compliance management operation system in key aspects of intellectual property compliance can operate smoothly; 2. whether contracts management system for intellectual property is established to strictly review the terms related to intellectual property rights in the contracts, including the clarification of intellectual property rights ownerships, confidentiality obligations, and infringements risks solutions, etc.; 3. whether compliance examination and risks control of third-party cooperative enterprises are strengthened, including the examination of third party’s qualifications, the existence of intellectual property defects, and requirements of providing intellectual property non-infringement commitments.
(5) Rewards and punishments mechanism: 1. whether scientific compliance performance indicators are established and employees are evaluated by relevant indicators of compliance risks characteristics; 2. whether relevant incentive processes are established and implemented, motivating employees to carry out intellectual property innovations and compliance managements; 3. whether necessary sanctions are imposed on relevant personnel who violate enterprises’ compliance obligations, objectives, rules and requirements for intellectual property rights.
(6) Documented information management: whether all elements in the processes of compliance management for intellectual property rights are created as documented information, and effectively maintained and updated in a timely manner.
Article 30 [Quality and effectiveness evaluation] The criteria of evaluation and review for effectiveness of the compliance management system mainly include:
(1) Compliance culture:1.whether the requirements for intellectual property risks management related to all aspects of business activities are publicized and disseminated to employees through processes, rules, contracts and communication methods such as training and conference, so as to embed concepts and values of risks management and enterprise compliance for intellectual property rights into business activities, creating an compliance culture for intellectual property rights; 2. whether incentive mechanisms conducive to mobilizing employees’ motivation is built, creating an enterprises’ image of respecting and protecting intellectual property rights.
(2) Compliance objectives: 1. whether all the business activities related to intellectual property rights of the enterprises meet the compliance objectives and comply with compliance requirements; 2. whether the resource allocation for achieving enterprises’ compliance objectives is adequate, and whether there is a clear time schedule and detailed process; 3. whether the progresses of the compliance objectives are regularly monitored, inspected, recorded, evaluated and timely update and adjusted.
(3) Sustainability: 1. whether compliance management systems for intellectual property is adjusted in a timely manner according to the changes of legal norms related to intellectual property rights to ensure that it remains up-to-date and adapts to the enterprises’ compliance objectives for intellectual property rights; 2. whether periodical internal supervision of intellectual property risks is carried out, and specific solutions are proposed and rectification is actively implemented in response to the identified compliance risks.
(4) Non-compliance incident and its handling: 1. After the non-compliance incidents are found, whether measures to control and correct are taken, and the causes for the incidents are sort out; 2. whether improvements and remedies for management loopholes are made in response to non-compliance incidents, including improving business processes, retraining employees and enhancing early warning mechanisms, etc.; 3. whether internal and external parties are informed of the relevant situations of non-compliance incidents and documented information are retained.
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