Ethical Management - GTM 勤益投資控股

Home - Corporate ESG - Ethical - Ethical Management

Ethical Management

Ethical Management Unit

The Company designated the Chairman’s Office as the unit responsible for promoting ethical management. It shall handle the revision, implementation, and explanation of the Procedures for Ethical Management and Guidelines for Conduct. It will also provide consultation services and filing of reports.

The primary duties listed below shall be reported regularly (at least once a year) to the Board of Directors:
Assist in integrating integrity and ethical values into the Company’s business strategy, and establish fraud prevention measures to ensure honest management in accordance with laws and regulations.
Regularly analyze and assess the risk of unethical conduct in its business, formulate plans to prevent unethical conduct accordingly, and establish various standard operating procedures and behavioral guidelines related to operations.
Plan the internal organization, establishment, and duties, and set up a reciprocal supervision mechanism for business activities with a higher risk of unethical conduct.
Promote and coordinate ethical policy advocacy training.
Plan the whistle-blowing system and ensure the effectiveness of enforcement.
Assist the Board of Directors and management in verifying and evaluating the effective operation of the safeguards established to implement ethical management. Regularly evaluate and report on the compliance of the relevant business processes.
Prepare and maintain documented information regarding the Ethical Management Policy and its compliance statement, implementation of commitments, and enforcement status.

Title

File

Report on the Implementation of the Integrity Management Policy in 2021 (Reported to the Board of Directors on Jan. 14, 2022)

Specific measures for implementing the Ethical Management Policy

The company promotes ethical policy and provides education and training.
In 2021, the Company conducted 21 hours of education and training for the current directors and managers in April, May, September, and December, for a total of 9 times.
The courses cover corporate ethical management, ethical management policy establishment, conflict of interest prevention, risk management, fraud prevention, etc.
In 2020, the Company conducted 18 hours of education and training for the current directors and managers in September, October, November, and December, for a total of 6 times.
The courses cover corporate ethical management, integrity management policy establishment, conflict of interest prevention, risk management, fraud prevention, etc.
The Board of Directors and senior management actively implement management policies: All 16 directors and senior management (including those of subsidiaries) signed the “Declaration of Compliance with Ethical Management Policy.”

Title

File

董事遵循誠信經營政策聲明書

高階管理階層遵循誠信經營政策聲明書

高階管理階層遵循誠信經營政策聲明書(子公司)

Ethical Management Operations

I. Establishment of ethical corporate management policies and programs

The Company has established the “Ethical Corporate Management Best Practice Principles”, which was approved by the Board of Directors on March 22, 2013, for the Board of Directors, managers and employees to follow. The “Code of Ethical Conduct for Directors and Mangers” and the “Code of Ethical Conduct for Employees” have been established and are posted on the Company’s website. The Board of Directors and senior management have issued a “Statement of Compliance with the Ethical Management Policy” and committed to actively implement the management policy. The Company’s policy on integrity management and its implementation by the Board of Directors and management are also described in the annual report.
The Company has established “Procedures for Ethical Management and Guidelines for Conduct”, “Regulations for Management of Related Party Transactions”, “Regulations for Management of Personal Information Protection”, “Contract for Maintenance of Official Confidentiality”, “Regulations for Prevention and Discipline of Sexual Harassment”, “Internal Control”, “Risk Management Measures”, etc. to prevent business activities with higher risk of dishonest behavior, and requires employees to understand business-related laws and regulations and make sound business and ethical judgment. Ethics and regulatory compliance also play an important role.
The Company has established a dishonesty prevention program and standard operating procedures and behavioral guidelines related to its business operations in each program to prevent dishonesty from occurring in the Company. The “Procedures for Handling Material Inside Information”, “Procedures and Guidelines for Integrity Management”, “Procedures for Preventing Insider Trading” and “Regulations for Management of Related Party Transactions” have been established to regulate the standard operating procedures and guidelines for integrity-related conduct of all stakeholders of the Company.

II. Implementation of ethical corporate management

In accordance with the “Regulations Governing Credit to Customers”, the Company conducts credit and evaluation of its customers and suppliers, and reviews their past operations for possible risks of dishonest behavior. In addition to the rights and obligations of both parties, the contract of cooperation with our important customers or suppliers will also include the terms and conditions of integrity to be observed. If any business dealings or business partners are found to be dishonest, the business dealings with them shall be stopped immediately and they shall be listed as a rejected business partner. In addition, in order to clean up the order and environment of procurement and other transactions, suppliers are invited to sign letter of undertaking of integrity, further regulate employee behavior and set up complaint mailbox.
The Company has designated the Chairman’s Office as the dedicated unit to promote honest management, and the Audit Office assists in the revision, implementation, explanation, consultation service and filing of the report contents of the operation procedures and conduct guidelines for honest management. The Company also reports to the Board of Directors on an annual basis (once a year) on its policy of honest management and its plan to prevent dishonest acts and monitor its implementation.
The Company has established a “Code of Ethical Conduct for Directors and Managers” and a “Code of Ethical Conduct for Employees” to monitor and manage the risk of conflicts of interest that may lead to dishonest behavior. The Company’s directors, managers and other interested parties attending or participating in the Board of Directors’ meetings shall explain the important contents of their interests at the current Board of Directors’ meeting if they have an interest in the motions listed in the Board of Directors’ meeting or the legal entity they represent, and shall not join the discussion or vote if it is harmful to the Company’s interests, and shall recuse themselves from the discussion or vote, and shall not exercise their voting rights on behalf of other directors. Directors shall also exercise self-discipline and must not support one another in improper dealings. If in the course of conducting company business, any personnel of this Company discovers that a potential conflict of interest exists involving themselves or the juristic person that they represent, or that they or their spouse, parents, children, or a person with whom they have a relationship of interest is likely to obtain improper benefits, the personnel shall report the relevant matters to both his or her immediate supervisor and the responsible unit, and the immediate supervisor shall provide the personnel with proper instructions. The Company strictly requires each employee to avoid conflict of interest matters and not to engage in any business, investment or related activities that may constitute a conflict of interest between the individual and the Company. Also avoid any possible conflict of interest.
The Company has established an effective accounting system and internal control systems and shall review and monitor the design and implementation of the system at any time to ensure that the design and implementation of the system are continued. The internal auditor of the Company shall periodically examine the Company’s compliance with the foregoing systems and prepare audit reports and submit the same to the Board of Directors, and management audit results and follow-up improvement plans to implement the results. In addition, through the annual internal control self-assessment, the Company must review the effectiveness of the design and implementation of the internal control system.
The Company regularly provides internal training courses and external education training for employees to understand internal rules and regulations or the latest and relevant legal regulations, in order to reinforce the employees’ firm commitment to follow the integrity of business regulations. In 2021, employees participated in 108.5 hours of education and training courses.

III. Operation of the whistle-blowing system

The Company has a whistle-blowing system, and has established and announced an internal independent whistle-blowing mailbox and a hotline for internal and external personnel to use.
Investigation operation flow of reported matters: The dedicated person is responsible for the record and preservation of the report case acceptance, investigation process, investigation result and related documents production. There were no dishonest acts in 2021.
The identity of the whistleblower and the contents of the report are kept confidential in order to protect the whistleblower from being improperly disposed of because of the report.

IV. Enhanced disclosure of ethical corporate management information

The Company has established a “Ethical Corporate Management Best Practice Principles” and reviews the effectiveness of its implementation from time to time and discloses it on the Company’s website and annual report, which can be accessed through the Market Observation Post System and the Company’s website.