CBI VISION Business Compliance Management Monthly Journal 2025 MAR PDF Free Download

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CBI VISION Business Compliance Management Monthly Journal 2025 MAR PDF Free Download

CBI VISION Business Compliance Management Monthly Journal 2025 MAR PDF free Download. Think more deeply and widely.

香港

北京

上海

广州

HONG KONG

BEIJING

SHANGHAI

GUANGZHOU

西安

槟城

伦敦

XI’AN

PENANG

LONDON

CBI

VISION

Business Compliance Management

Monthly Journal

Pursuing Truth · Building Trust

2025 MAR

CONTENTS

Compliance Hotspot

Case Sharing

Compliance Information

Huawei OD Recruitment Fraud: A Warning and

Reflection on Corporate Compliance Management

Loopholes

In March 2025, an internal audit announcement from Huawei sparked

public outcry—their outsourcing positions (OD positions) recruitment

system was found to have large-scale fraudulent activities, involving over

a thousand outsourced employees and nearly a hundred regular

employees, with the amount involved exceeding 67 million yuan. This

incident, referred to as the "Huawei Recruitment Scandal," not only

exposed management loopholes in leading tech companies but also

revealed systemic risks associated with third-party recruitment

collaboration models.

In the pharmaceutical industry, compliance is the lifeline of a company,

and any violation of regulations can have profound impacts on the

business. Recently, Sichuan Haimeng Zhisen Biopharmaceutical Co., Ltd.

(hereinafter referred to as "Haimeng Zhisen") and its contracted

manufacturing company, Sichuan Taiji Pharmaceutical Co., Ltd.

(hereinafter referred to as "Sichuan Taiji Pharmaceutical"), were

disqualified from the selection of Phloroglucinol Injection due to violations

and have been placed on the non-compliance list.

New Compliance Regulations for Financial Institutions in

2025 and Addressing Challenges in Listing Compliance

The "Measures for the Compliance Management of Financial Institutions,"

which will be officially implemented on March 1, 2025, systematically

reconstructs the compliance management system of financial institutions

in China. The core objective is to promote the transition of compliance

management from "passive response to regulation" to "proactive risk

governance." These measures integrate compliance rules across sectors

such as commercial banking, insurance, and securities, and for the first

time establish a unified framework covering the entire industry.

Analysis of the Cancellation of the Selection

Qualification for Haimeng Zhisen Trimethoprim Injection

PREFACE

C B I V I S I O N | 2025 MAR

Huawei OD Recruitment Fraud: A Warning and Reflection on

Corporate Compliance Management Loopholes

In March 2025, an internal audit announcement from Huawei sparked public outcry—a large-

scale fraud was discovered in its outsourcing positions (OD positions) recruitment system,

involving over a thousand outsourced employees and nearly a hundred regular employees, with

the amount involved exceeding 67 million yuan. This incident, referred to as the "Huawei

Recruitment Scandal," not only exposed management loopholes in leading tech companies but

also revealed systemic risks associated with third-party recruitment collaboration models.

Compliance Hotspot

C B I V I S I O N | 2025 MAR

The investigation reveals that some employees

and third-party organizations have formed a

complete black market chain: from resume fraud,

technical test proxies, and interview question

leaks to "salary commissions" after employment.

Each step has a clear price tag. For example, job

seekers need to pay a 20,000 RMB "referral fee"

upfront and then have 3,000 RMB deducted from

their monthly salary for a year. Moreover, some

suppliers exploited vulnerabilities in Huawei's

system to illegally obtain 65,000 resumes and

improperly recommended nearly 3,000 people for

employment, resulting in the company paying

over 50 million RMB in additional service fees.

The root cause of the fraud incident in Huawei's recruitment this time lies in the imbalance

between management mechanisms and values under the pressure of business expansion. To

quickly fill the vacancies in OD positions, some teams, in order to meet recruitment KPIs, tacitly

allowed third-party vendors to lower background check standards, falsify candidate resumes,

and even leak exam arrangements for substitutes, resulting in "hiring with issues" becoming the

norm.

Meanwhile, companies have excessively delegated core responsibilities, such as resume

screening and organizing written tests, to third-party agencies without establishing a dynamic

monitoring system. This has resulted in long-term, unchecked violations like suppliers altering

results and selling resumes.

More seriously, a culture of corruption has seeped into grassroots management. For

example, in a department in Chengdu, the entire process from resume screening to hiring

has been infiltrated by a corruption network. Managers not only partake in the spoils but also

suppress internal whistleblowing through intimidation, revealing the systemic collapse of

organizational culture following the failure of institutional constraints.

The Huawei incident is not an isolated case; the compliance loopholes it exposed are

common in the technology industry.

Outsourcing Collaboration Model: The Uncontrolled "Transfer of Power“

The OD position serves as a core channel for "outsourcing to permanent" transitions at

Huawei and is supposed to reserve talent through a strict selection process. However, in

practice, third-party suppliers have been granted critical permissions such as initial resume

screening and organizing written tests, without effective constraints. For example, a certain

supplier has been able to send hundreds of unqualified candidates to Huawei by fabricating

project experiences and altering test scores, while the company relied solely on the "formal

background check reports" provided by the supplier, failing to cross-verify key information

such as social security records and project achievements.

C B I V I S I O N | 2025 MAR

The technological measures to prevent corruption are lagging behind.

Desp ite Huaw ei's advan ced technologi cal re searc h and deve lopmen t ca pabil it ies, it s

recr uitment sys tem s till has s ignificant flaws:

Data s i los: Wri tten te st, inter v iew, and b ackgroun d ch ec k data are d ispersed acr os s

different systems, m akin g it im possible to achie ve full process tr aceabili ty .

Lack of blo ckcha in techno logy: Te chnologie s such as timestam ps and hash values ha ve

not been used to so lidif y ope rat ion recor ds, m ak in g it diff i cu lt to ob tain evid ence of

fraudulent activi ties .

Absence of AI ri s k cont ro l: The ident ifica tion of re su me fraud re lies on ma nual rev ie w,

and no AI semant ic analy si s model has been est abl ish ed to detect in con s ist enc ie s in

resu mes .

The ass essmen t m ech anism distorts compl iance logic.

Some departm ents, in order to meet re cru itm ent KPI s, h ave de ve loped a ske wed focu s on

"qua ntit y o ver qu al ity. " An involve d emp lo yee can did ly adm itted in an i nternal l etter, "The

lead ership re qui res 20 new h ire s each m onth . Complia nce checks slow do wn the proces s,

so we have no cho i ce but to take sh ort cu ts. " This "effi c ienc y -f ir st" min ds et h as redu ce d

comp lian ce checks, which sho uld be a fundam ental safeg uard, to m ere formalities .

The fai lure of the rep orting mechanism encoura ges a min dset of ta king chances.

Desp ite having inte rna l m onit or ing ch an nel s, Huawe i emp loyees gener al ly fear retal iat ion

after repor ting i ss ues . An anony mous in ter v iewe e r eveale d, "D epartment le aders are

dire ct ly in volved in the cor rup tion ; w ho wo uld dar e to report it? Eve n if som eone speak s

up, the invest igat ion team might be tipped off in advance ." The la ck of a protectiv e

whist leblowin g system all ows fr aud ulen t act iviti es to remain hidden for a l ong tim e.

The company's corrective actions following similar incidents should not be limited to

emergency measures like "dismissal and accountability." Instead, it should build a systematic

defense from three dimensions: technology, systems, and culture.

Fro m a t echn ical per spe ct ive, compan ie s should ac ce lera te dig ita l tran sfo rm ation by

adop ting bl ockch ain te chn olog y to cre ate tamper -pr oof r ecor ds for the ent ir e recr ui tm ent

proc ess (re sume sub mi ss io n, wr itt en tests, inte rv iews, and bac kgro und ch ec ks) , the reb y

elimi nat ing the possi bi lity of alterin g scor es or fa bri catin g cred ent ia ls. Add it ion al ly, AI

tool s sho uld be uti li zed to c ros s-ver ify c andidat es' re sumes w ith publ ic l y ava il able

info rm ation, aut oma ti ca ll y identif ying in cons i sten ci es su ch as t ime di sc rep an cie s or

inf late d job title s . Fur ther more, by empl oy in g a dynamic ac ces s manage men t system, th e

oper ational scop e of th ir d-party ven dors can be restr icted in spec if ic st ag es (e.g.,

allowing access to question b anks but pro hibiting m odificat ions to resumes).

Fro m an inst itutiona l pers pecti ve, it is neces sar y to rest ru ctur e outso ur cing co ope ration

rule s. T his inc lud es estab li sh ing a "comp liance po ints " s ystem for sup pl iers,

imp lement ing a "one-strike" polic y for data tamp ering and resu me fraud, and a ddin g

offenders to an indu stry blac kl is t. Addit io nal ly , the rec ru it ment p rocess shou ld

inco rp ora te inde pendent background checks by HR, bu sines s depar tme nts, and

comp l iance team s. Fo r c on tentious cand ida tes, a three -pa rty joint re v iew shou ld be

initiated . Furth erm ore , labor c ontr act s sho uld in cl ude ret roa ctive c lauses that clear l y

stat e the c ompany 's r igh t to rec over tra ining in ves tme nts and undue gains obt aine d by

fraudsters .

Fro m a cu lt ura l s tandpoint, it is es sen ti al to deeply em bed c omp lianc e a war eness into

the fa bri c of the o rga nizat ion . Th is can be a ch iev ed by imp lemen ti ng a sy ste m of

manager ia l jo in t accoun tability, lin k ing team v io latio n rat es d ire ct ly to m ana gerial

perform anc e e valuat ions, and establi sh ing an anonymous reporting channel independent

of the busin e ss s ystem . V erified wh istl eblo wers sho uld be re warded with pro motion s and

bonu ses . Addit iona l ly, v ir tual real it y te chno lo gy can be used to si mulate cor rup tion

scen ar io s, a llowi ng emplo ye es to e xper ie nce f ir stha nd the dual impac t of m i sc onduct on

thei r per sona l careers an d the company 's r epu tati on . T his appro ach he lps to fo ster a

shar ed va lue con se nsus of "no t dari ng to corrupt, not bein g able to corr up t, and not

want ing to cor rup t."

C B I V I S I O N | 2025 MAR

The Huawei incident once again confirms a harsh reality: in the frenzy of capital expansion

and technological iteration, companies often view compliance as a "cost item" rather than a

"survival item." It is not difficult to find from the cases of multiple tech companies that similar

risks are particularly prominent in areas such as outsourced recruitment, cross-border

mergers and acquisitions, and data transactions. For example, in 2024, a major internet

company experienced a significant safety production accident due to a third-party labor

dispatch company falsifying health certificates.

Currently, leading companies are facing dual pressures: on one hand, industry competition is

forcing the normalization of flexible employment models such as on-demand (OD) work; on

the other hand, regulatory bodies are intensifying the enforcement of laws like the Anti-Unfair

Competition Law and the Personal Information Protection Law. If companies fail to establish

a "firewall" in their outsourcing collaborations, they not only risk hefty fines but also

jeopardize the sustainability of their talent strategies.

In this case, several involved suppliers possess "human resource service qualifications" but

have become accomplices in fraud. This warns companies that qualification certificates do

not equate to compliance capability. Huihua suggests that when selecting partners,

companies should focus on examining their historical compliance records, data security

systems, and internal monitoring processes, rather than making decisions based solely on

industry rankings.

Huawei has revealed through a period of intense challenge that compliance is not a shackle

that binds innovation, but rather a cornerstone for long-term success. For all enterprises, only

by deeply integrating compliance into their strategy, technology, and culture can they build a

solid defense in an era of uncertainty.

C B I V I S I O N | 2025 MAR

案例分享

Analysis of the Event of Cancellation of Selection

Qualification for Haimeng Zhisen Phloroglucinol

Injection

2 0 2 4 年10月刊

In the pharmaceutical industry, compliance is the lifeline of a company, and any violation of

regulations can have profound impacts. Recently, Sichuan Haimeng Zhisen Biopharmaceutical Co.,

Ltd. (hereinafter referred to as "Haimeng Zhisen") and its contracted manufacturing enterprise

Sichuan Taiji Pharmaceutical Co., Ltd. (hereinafter referred to as "Sichuan Taiji Pharmaceutical")

were disqualified from the selection of phloroglucinol injection due to violations and were placed on

the non-compliance list. This incident not only dealt a significant blow to the companies involved but

also sounded the alarm for compliance management in the pharmaceutical industry. This article will

provide an in-depth analysis of the incident from the perspectives of its background, reasons for the

violations, punitive measures, and insights for the industry.

C B I V I S I O N | 2025 MAR

Case Sharing

The injection of phloroglucinol is one of the selected

drugs in the tenth batch of national drug centralized

procurement (hereinafter referred to as "centralized

procurement"). The national drug centralized

procurement is a significant policy in China's

pharmaceutical sector, aiming to reduce drug prices

through bulk purchasing, alleviate the financial burden

on patients, and promote the standardized development

of the pharmaceutical industry. As the main supplier of

phloroglucinol injection, Haimeng Zhisen successfully

won the bid and obtained the supply qualification.

However, on the eve of the centralized procurement implementation, Haimeng Zhisen and its

commissioned manufacturing enterprise Sichuan Taiji Pharmaceutical were disqualified from

selection due to violations, an event that garnered widespread attention. According to the

investigation by the National Joint Office for Drug Centralized Procurement, the violations of Haimeng

Zhisen and Sichuan Taiji Pharmaceutical were mainly reflected in the following two aspects:

2 0 2 4 年10月刊

C B I V I S I O N | 2025 MAR

First, Haimeng Zhisen made relevant commitments in the application materials but failed to fulfill

them. During the centralized procurement process, companies are required to submit detailed

application materials and make commitments regarding the quality and supply capacity of their drugs.

Haimeng Zhisen promised that its products met the requirements of the national Good Manufacturing

Practice (GMP) for pharmaceuticals during the application process. However, subsequent

investigations revealed that its actual production situation did not align with its commitments, and

there were serious quality management issues.

Secondly, Sichuan Taiji Pharmaceutical, as the entrusted manufacturing enterprise of Haimeng

Zhisen, failed to strictly adhere to the relevant regulations of the "National Drug Centralized

Procurement Document (GYD-Y2024-2)." Entrusted manufacturing is a common collaboration model

in the pharmaceutical industry, but both the entrusting party and the entrusted party are responsible

for the quality and compliance of the drugs. Sichuan Taiji Pharmaceutical did not meet GMP

standards during the production process, resulting in the inability to ensure the quality of the

Metaraminol Injection.

The National Joint Office for Centralized Drug Procurement has made the following disciplinary

decisions regarding the aforementioned violations:

Cancellation of Selection Qualification: The selection qualification for Haimeng Zhisen's

phloroglucinol injection has been officially canceled, meaning that the company will not be able to

participate in the supply work for this round of centralized procurement. Additionally, since Haimeng

Zhisen is the primary supplier, its supply responsibilities will be taken over by the alternate company.

If the alternate company cannot meet the supply demands, the relevant departments will initiate

procedures to supplement the supply with additional companies.

Listed on the Violation List: Haimeng Zhisen and Sichuan Taiji Pharmaceutical have been included

in the "Violation List," which is an important tool used by the state to publicize and penalize

pharmaceutical companies for non-compliance. Companies listed on the violation list will face strict

supervision and restrictions.

Suspension of bidding qualifications: Starting from March 18, 2024, Haimeng Zhisen and Sichuan

Taiji Pharmaceutical will be suspended from participating in the national centralized drug

procurement activities for a period of two years and six months, until September 17, 2026. During this

period, both companies will be unable to participate in any national organized centralized drug

procurement activities.

Cease Production and Sales: Starting from March 21,

2024, Haimeng Zhisen will cease the production and

sales of phloroglucinol injection. This measure aims to

prevent substandard drugs from entering the market

and to ensure the safety of patients' medication.

The violations by Haimeng Zhisen and Sichuan Taiji

Pharmaceutical serve as a profound warning for

compliance management in the pharmaceutical

industry.

2 0 2 4 年10月刊

C B I V I S I O N | 2025 MAR

Most importantly, enterprises must place a high emphasis on the implementation of Good

Manufacturing Practices (GMP) for pharmaceuticals. GMP is a fundamental requirement to ensure

the quality and safety of drugs, and any violations of GMP will severely damage the reputation and

operations of the enterprise. On the other hand, when participating in the national centralized drug

procurement, enterprises must strictly adhere to relevant regulations to ensure the authenticity and

completeness of the application materials. False promises or concealing facts can not only lead to the

cancellation of selection qualifications but may also result in more severe penalties.

Not only that, but the compliance risks in the contract manufacturing model also deserve attention.

The client and the contractor should clearly define their respective responsibilities and establish a

strict quality management system to ensure that the entire drug production process complies with

national standards.

In corporate compliance management, strengthening internal compliance training and enhancing

employees' compliance awareness are key elements to ensuring the long-term and stable

development of a company. Particularly in the pharmaceutical industry, compliance is directly related

to the quality of drugs, patient safety, and the company's reputation. Therefore, companies must

eliminate violations at the source.

Firstly, enterprises should establish a systematic compliance training program that covers all levels,

from top management to frontline employees. The training content should include not only national

laws and regulations and industry standards (such as GMP, GSP, etc.) but also the company's

internal management systems and operational procedures. The training methods can be diversified,

such as online courses, offline lectures, case studies, and simulation exercises, to ensure that

employees thoroughly understand compliance requirements. Additionally, since regulations and

standards in the pharmaceutical industry are constantly being updated, companies need to adjust the

training content promptly to ensure that employees are equipped with the latest compliance

requirements.