Operation and Implementation of Enterprise Integrity Management Unit
Performance of Honest Business Practices
| Evaluation Project | Operation status | Differences between the Code of Conduct for Integrity Management of Listed and Over-the-Counter Companies and the Reasons Therefor | ||
|---|---|---|---|---|
| yes | no | Abstract Description | ||
| I. Formulate policies and plans for honest business operations (i) Has the company formulated a policy of honest operation approved by the board of directors, and has it clearly stated the policy and practices of honest operation in its rules and regulations and external documents, as well as the commitment of the board of directors and senior management to actively implement the operating policy? |
V | The Company has established the "Code of Conduct for Honest Business Operations", "Operating Procedures and Guidelines for Honest Business Operations" and "Code of Ethical Conduct", which have been approved by the Board of Directors. These serve as the basis for the conduct of the Company's Board of Directors and management, and the implementation of the honest business operation policy is monitored in accordance with these guidelines and internal controls. | none | |
| (ii) Has the company established a risk assessment mechanism for dishonest behavior, regularly analyzed and assessed business activities with a high risk of dishonest behavior within its business scope, and formulated a plan to prevent dishonest behavior accordingly, and at least covered the preventive measures for each of the behaviors in Article 7, Paragraph 2 of the "Code of Conduct for Listed Companies"? | V | The company has established a "Code of Conduct for Honest Business" and a "Code of Conduct for Honest Business Operations and Behavioral Guidelines" which have been approved by the board of directors. These documents are used to regulate the company's business operations, behavioral guidelines, penalties for violations, and appeals system. The company also conducts regular monitoring through an internal audit system to actively prevent dishonest behavior from occurring. | none | |
| (iii) Has the company clearly defined operating procedures, behavioral guidelines, penalties for violations, and appeal system in its plan to prevent dishonest behavior, and has it implemented and regularly reviewed and revised the aforementioned plan? | V | The company has established a "Code of Conduct for Honest Business Practices," "Operating Procedures and Guidelines for Honest Business Practices," and "Code of Ethical Conduct," which have been approved by the Board of Directors and are published on the company's intranet for employees to access at any time. These guidelines are reviewed and revised periodically in accordance with updates issued by the relevant authorities. | none | |
| II. Implementing Honest Business Practices (i) Does the company assess the integrity records of its business partners and include integrity clauses in the contracts it signs with them? |
V | Our company has established an evaluation mechanism for all our clients, suppliers, and outsourcing partners, and clearly stipulates the rights and obligations of both parties in the transaction contract. If any dishonest behavior is found in our business dealings or cooperation, we will terminate our business dealings with them in order to implement the company's policy of honest operation. | none | |
| (ii) Has the company established a dedicated unit under the board of directors to promote honest business practices, and has it regularly (at least once a year) reported to the board of directors on its honest business policies, measures to prevent dishonest behavior, and the status of their implementation? | V | The Company has designated a Sustainability Team as the responsible unit to report to the Board of Directors regularly (at least once a year) on any dishonest conduct, its handling, and subsequent review and improvement measures. The implementation status for 2024 is scheduled to be reported to the Board of Directors in June 2025. | none | |
| (iii) Has the company formulated a policy to prevent conflicts of interest, provided appropriate channels for disclosure, and implemented such a policy? | V | The Company’s Board of Directors has adopted the “Honest Business Operation Procedures and Code of Conduct” to clearly define policies for preventing conflicts of interest, provide appropriate channels for disclosure, and require relevant departments to implement them. | none | |
| (iv) Has the company established an effective accounting system and internal control system to implement honest operation, and has the internal audit unit formulated relevant audit plans based on the assessment results of the risk of dishonest behavior, and used them to check the compliance of the plan to prevent dishonest behavior, or has it commissioned an accountant to perform the audit? | V | The Company has established effective accounting and internal control systems for business activities with potentially high risks of dishonest conduct. The internal audit also conducts audits based on the annual audit plan formulated according to the risk assessment results and prepares audit reports for submission to the Board of Directors. | none | |
| (v) Does the company regularly conduct internal and external education and training on honest business practices? | V | Our company regularly promotes its business philosophy and requirements through internal education and training sessions and internal meetings to ensure that employees fully understand and comply with them. | none | |
| III. Operation of the Company's Whistleblower System (i) Has the company established a specific reporting and reward system, set up convenient reporting channels, and assigned appropriate personnel to handle reports? |
V | Our company has outlined a reporting system in the "Honest Business Operation Procedures and Code of Conduct," and a designated person is responsible for handling subsequent reports. | none | |
| (ii) Has the company established standard operating procedures for handling whistleblower reports, follow-up measures to be taken after the investigation is completed, and related confidentiality mechanisms? | V | Our company has outlined the investigation procedures for handling reports in the "Integrity Management Operating Procedures and Code of Conduct" and has adopted a confidentiality mechanism regarding the identity of the whistleblower and the content of the report. | none | |
| (iii) Has the company taken any measures to protect whistleblowers from being mistreated as a result of their whistleblowing? | V | Measures to protect whistleblowers from being mistreated because of their whistleblowing have been established and implemented in the "Honest Business Operation Procedures and Code of Conduct". | none | |
| IV. Strengthen Information Disclosure Does the company disclose the content and effectiveness of its code of conduct for honest operation on its website and public information observation platform? |
V | The Company has explained its business philosophy on its website and disclosed the relevant content of its established code of conduct for honest operation on the public information observation platform; relevant information on honest operation and its implementation have been disclosed in the annual report. | none | |
| 5. If the company has its own code of conduct for honest business operations in accordance with the "Code of Conduct for Listed Companies", please describe the differences between its operation and the established code: Our company has taken into account the "Code of Conduct for Integrity Management of Listed Companies" and formulated the "Code of Conduct for Integrity Management" and the "Operating Procedures and Guidelines for Integrity Management". We have also implemented integrity management in accordance with relevant laws and regulations to regulate the matters that our personnel should pay attention to when performing business. |
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| VI. Other important information that helps in understanding the company's integrity in its operations: 1. Our company complies with the Company Act, the Securities and Exchange Act, and other laws and regulations concerning business conduct, in order to implement the principle of honest operation and create a sustainable business environment. 2. The Company’s “Rules of Procedure for Board Meetings” stipulates a system for directors to abstain from voting on matters that are of interest to them or to any legal entity they represent. Directors who have a conflict of interest with the Company shall explain the important details of their conflict of interest at the meeting. If such matters are potentially detrimental to the Company’s interests, they shall not participate in the discussion or voting, and shall abstain from voting. They shall also not act as proxies for other directors to exercise their voting rights. 3. In order to establish a sound internal mechanism for handling and disclosing material information, avoid improper disclosure of information, and ensure the consistency and accuracy of information released by the Company to the outside world, the Company has established the "Internal Material Information Handling Management Measures" and the "Insider Trading Prevention Management Measures" to stipulate that the Company's directors, managers, employees and other persons who have access to the Company's internal material information due to their identity, profession or control relationship shall comply with the relevant provisions of the operating procedures. |
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