To comprehensively advance the pilot program of corporate compliance reform within Shenzhen's procuratorial organs, support and safeguard high-quality economic and social development, and promote the modernization of the national governance system and governance capacity, the Shenzhen People's Procuratorate of Guangdong Province held the "Corporate Compliance Promotion Conference and Inauguration Ceremony of the Corporate Compliance Office" on July 29. The event also invited renowned experts and scholars, including Chen Weidong, Executive Vice President of the China Association for Criminal Procedure Law Studies and Professor at Renmin University of China School of Law, as well as Chen Ruihua, Professor at Peking University School of Law, along with other industry leaders, to engage in a thematic discussion.

Last March, the Bao'an District Procuratorate and the Nanshan District Procuratorate in Shenzhen were included in the first-phase pilot program for corporate compliance reform, helping to build valuable practical experience for the initiative's success. This March, procuratorates at both the city and district levels in Shenzhen were collectively integrated into the corporate compliance reform pilot—making Shenzhen the only region in Guangdong Province where both city- and district-level procuratorates are participating in the pilot program simultaneously.

Li Xiaodong, Party Secretary and Chief Prosecutor of the Shenzhen People's Procuratorate, introduced the progress made by Shenzhen’s procuratorial organs in piloting corporate compliance reforms. Since this year, the Shenzhen People's Procuratorate has firmly seized the policy opportunities presented by the central government’s clear directive to accelerate Shenzhen’s development as a pilot demonstration zone for socialism with Chinese characteristics, as well as the Shenzhen Municipal Party Committee and Government’s initiative to promote "comprehensive compliance" and build Shenzhen into a benchmark compliance model. Building on earlier pilot efforts, the procuratorate has proposed a "five-one" work plan, striving to forge a distinctive "Shenzhen Model" for corporate compliance—providing a Shenzhen-specific example and contributing innovative solutions that could inform and enhance national legislation.

Establish a dedicated corporate compliance organization. The Municipal Prosecutor's Office has set up a Corporate Compliance Office, implementing a system of division of responsibilities and coordinated collaboration between upper and lower levels, to oversee and coordinate corporate compliance efforts across the city's procuratorial agencies.

Establish a comprehensive corporate compliance mechanism that covers the entire chain—pre-event, during-event, and post-event activities. **Pre-event:** Conduct large-scale, phased compliance awareness sessions and training programs for businesses across the city, strengthening proactive measures to prevent corporate misconduct before it occurs. **During-event:** Leverage third-party expertise to provide targeted compliance guidance to companies involved in ongoing litigation, helping them address management gaps and refine their internal control systems. **Post-event:** Use tools such as prosecutorial recommendations to encourage enterprises whose cases have been closed but still require compliance efforts to initiate or enhance their own compliance initiatives.

Establish a comprehensive corporate compliance system. The Shenzhen Municipal Procuratorate has issued the "Implementation Measures for Corporate Compliance Work of Shenzhen's Procuratorial Organs (Trial)," and, in collaboration with the Municipal Justice Bureau, the Municipal Federation of Industry and Commerce, and other organizations, introduced the "Provisional Regulations on the Management Committee of the Third-Party Supervision and Evaluation Mechanism for Corporate Compliance and the Administration of Third-Party Monitors." These two documents clearly define the procedures for corporate compliance work, establish a Shenzhen-specific management committee and a third-party monitor system for corporate compliance oversight and evaluation, and collectively form the foundational framework for corporate compliance initiatives.

Issue and release a batch of typical corporate compliance cases. As of June this year, Shenzhen's procuratorial authorities have handled more than 20 corporate compliance cases, covering offenses such as issuing false special VAT invoices, embezzlement in office, counterfeiting registered trademarks, bribery of non-state employees, illegal business operations, major liability accidents, and the sale of counterfeit drugs. Based on their practical experience in handling these cases, the procuratorates will establish a corporate compliance case database to provide reference for future investigations. Currently, the first batch of eight carefully selected typical cases has been finalized and publicly released.

Establish an enterprise compliance lecturer team. Forty-eight prosecutors have been selected as lecturers, and seven renowned experts, scholars, and senior lawyers have been invited as specially appointed instructors to deliver compliance workshops to businesses across the city that have expressed a need. Additionally, a comprehensive set of enterprise compliance training materials has been developed—specifically tailored to address common criminal risks encountered in business operations—and is already available for use by the lecturer team. Currently, three volumes have been completed, with plans underway to further expand and release additional resources categorized by industry or topic in the coming stages.

At the meeting, Li Yong, Party Secretary of the Shenzhen Federation of Industry and Commerce (FIC), briefly reviewed the collaboration between the Municipal Procuratorate and the FIC in jointly promoting corporate compliance initiatives. He emphasized that the Shenzhen FIC will establish a coordinated mechanism with the Municipal Procuratorate to further advance corporate compliance efforts, and also outlined the organization's plans for the next steps.

Shenzhen Municipal Justice Bureau Director Jiang Xilin stated that they will seize this opportunity to integrate resources from various stakeholders, taking on responsibilities such as establishing a roster of third-party supervisors and selecting these supervisors, while actively collaborating with the Municipal Procuratorate to advance corporate compliance initiatives.

Yu Xinguo, Member of the Shenzhen Municipal Party Committee and Secretary of the Political and Legal Committee, delivered a speech. He noted that, with the strong support from the Supreme People's Procuratorate and the Provincial Procuratorate, Shenzhen's procuratorial organs have consistently leveraged their functional roles to deliver significant results in safeguarding the healthy development of the private economy and fostering a world-class, rule-of-law-based business environment. He emphasized that Shenzhen's procuratorial agencies should seize this opportunity to remain steadfast in their responsibilities, act boldly, and comprehensively advance pilot programs for corporate compliance reforms—paving the way for creating an internationally competitive, rule-of-law-driven business climate, while also driving Shenzhen’s "dual-zone" development initiative to new heights and achieving even greater accomplishments.

Zhang Jian, member of the Party Leadership Group and Deputy Chief Prosecutor of the Guangdong Provincial People's Procuratorate, fully endorsed the pilot program conducted by Shenzhen's procuratorial authorities. He encouraged Shenzhen's prosecutors to advance the corporate compliance reform pilot initiative in a lawful, orderly, and standardized manner, while also making the most of the outcomes from this meeting. He emphasized the importance of continuing to uphold the "dare-to-try and dare-to-innovate" spirit of the Special Economic Zone, ensuring that the reform task entrusted by the Supreme People's Procuratorate is effectively implemented—and ultimately providing replicable and scalable best practices to support broader adoption of this innovative model in corporate compliance reforms.

Gao Jingfeng, Director of the Legal and Policy Research Office of the Supreme People's Procuratorate, provided a brief overview of how procuratorial organs are promoting compliance initiatives for enterprises, as well as outlining their next steps. He expressed his hope that Shenzhen’s procuratorial bodies would continue to thoroughly implement the major decisions and plans set forth by the Party Central Committee. Focusing on delivering high-quality, efficient legal services and judicial safeguards to the Guangdong-Hong Kong-Macao Greater Bay Area, they will steadily advance pilot programs for compliance reform among enterprises involved in cases. The goal is to develop a set of replicable and scalable "Shenzhen models" that can serve as examples and references for other pilot regions, ultimately helping Shenzhen accelerate the establishment of a new development paradigm characterized by comprehensive deepening of reforms and broader opening-up—contributing both prosecutorial expertise and strength to this vital endeavor.

Amid enthusiastic applause, the attending leaders jointly unveiled the "Shenzhen Municipal People's Procuratorate Corporate Compliance Office." Following this, Chief Prosecutor Li Xiaodong presented appointment letters to the specially appointed lecturers of the "Corporate Compliance Lecture Group."

Liu Shanquan, Director of the Second Prosecution Department of the Municipal Procuratorate, provided a detailed explanation of the key features of the systems related to the enterprise compliance reform pilot program recently released by the Municipal Procuratorate. He also presented, on behalf of the Municipal Procuratorate, several exemplary cases showcasing Shenzhen’s prosecutorial efforts in corporate compliance building. Representatives from case-handling units, business leaders, legal professionals, as well as members of the Municipal People’s Congress and Municipal Political Consultative Conference, engaged in an open exchange and discussion.

Yu Xinxí, member of the Party Leadership Group and Deputy Chief Prosecutor of the Municipal Procuratorate, chaired the meeting. Leaders from relevant departments—including the Supreme People’s Procuratorate, Guangdong Provincial People’s Procuratorate, Shenzhen Municipal Justice Bureau, Municipal Federation of Industry and Commerce, Municipal Public Security Bureau, Municipal Intermediate Court, Municipal Finance Bureau, and Municipal State-owned Assets Supervision and Administration Commission—as well as prominent experts and scholars, Shenzhen municipal deputies to the People’s Congress, members of the Chinese People’s Political Consultative Conference (CPPCC), and public supervisors, along with representatives from the legal profession, industry associations, enterprises, and media outlets, attended the gathering, totaling more than 100 participants.

Author: Shen Jianjun

Source: Shenzhen People's Procuratorate