Ethical management

Policy

• TCC attaches great importance to business ethics and has established regulations such as the Integrity Management Code, Code of Ethical Conduct, and Anti-Corruption and Anti-Bribery Policy.
• Zero tolerance for bribery and corruption
• Directors, managers, employees, appointed persons, and substantive controllers shall not use non-public information to engage in insider trading or money laundering activities.

Management Approach

• Established the Anti-Corruption and Anti-Bribery Promotion Team, with the President serving as the highest level of management of the management system.
• Conduct corruption and bribery risk assessments of employees and business partners annually.
• Incorporate integrity management indicators such as corruption, bribery, and legal compliance into employee performance evaluations.
• Established the Related Party Transaction Procedure Management Directions to strengthen the supervision of related party transactions.
• In 2023, TCC revised its Business Partner Corruption Risk Assessment and Due Diligence Procedures, adding response measures for suppliers, contractors, and customers fail to cooperate with assessment and due diligence procedures.
• To comply with emerging legal compliance issues, such as anti-money laundering, anti-corruption, environmental safety and health, etc., these are included in standard contracts, becoming regulations for business partners' commercial cooperation with TCC
• Integrity management related policies are permanently posted on the company's official website and internal employee platform, allowing access to full information at any time, continuously strengthening belief

Performance

ISO 37001 Anti-Bribery Management System Certification

TCC is the first company in Taiwan to obtain the ISO 37001 Anti-Bribery Management System certification

TCC's Operation Headquarters and its subordinate plants - Taipei Plant, Taichung Plant, Kaohsiung Plant, Hoping Plant, and Suao Plant - were led by the Operation Headquarters in obtaining certification in August 2021, and completed recertification in July 2023.

2023 Corruption Incidents

0 件

Employee Signature Rate for the Statement of Integrity and Ethical Conduct

100 %

Signature Rate for the Integrity Code by Medium-High Risk Personnel

100 %

Education and Training

• TCC regularly promotes integrity and ethics education training through physical/ online courses (TCC Lyceum) or educational document reading. In 2023, the accumulated training hours reached 3,904.2 hours, with a total of 17,592 participants, and a 100% completion rate at the General Management Office
• Established an ISO 37001 implementation team, with a 100% participation rate of team members in additional special educational training
• Integrity management-related educational training participants include directors, business partners, employees, new hires, and interns
• Educational training has been gradually extended to contractors, with a cumulative total of 22 people and 18.7 training hours in the first quarter of 2024
• Regarding anti-competitive and anti-monopoly practices, for sales personnel who have close contact with customers, we introduced the legal definition and constituent elements of concerted actions, achieving a 100% completion rate

New employees (including part-time and student workers)

On the first day of employment, new hires must sign the Statement of Integrity and Ethical Conduct, and within ninety days of joining, receive one-on-one education on anti-corruption and anti-bribery policies, with training records maintained. From 2021 to 2023, the signing rate among new employees was 100%

Current employees (including senior managers, part-time and student workers)

Each year, employees must participate in at least one anti-corruption and anti-bribery educational training course with records maintained, and thoroughly understand the relevant operational guidelines they should follow, as well as the potential consequences and risks of violations.
Anti-corruption educational training totaled 799 hours in 2023.
Additionally, we conducted specialized thematic training for dedicated staff members who may be involved in customer and supplier interactions, as well as departmental operational processes requiring corruption risk assessments. In 2023, the cumulative training hours reached 2744.3 hours

Directors

Directors receive anti-corruption and anti-bribery training courses at least once a year, delivered via email or in print, and are required to sign the Commitment to Compliance with Integrity Management, Anti-Corruption and Anti-Bribery. In 2021 and 2023, all directors completed educational training and signed the commitment letter.

Suppliers

We promote the spirit of integrity management with our suppliers through emails, supplier conferences, and other means, requiring them to sign the Supplier Code of Conduct, which includes integrity management-related items.

Contractors

Starting from 2021, integrity management promotion has been conducted for contractors when they enter the facility, and educational training was completed in June 2022. 
Additionally, outsourced personnel such as security guards have also completed this training in June 2022

Prohibition of Unfair Competition Practices

Upholding fair business competition is a core commitment of TCC’s integrity management. TCC strictly prohibits employees from engaging in activities that violate the Fair Trade Act, such as forming monopolies or colluding to divide markets, which would undermine the principles of free market competition.

• Dedicated Unit：The Legal Office supervises the compliance of company members with competition laws and their handling procedures.

• Handling Procedures：

  

  Reports to Regulatory Authorities Should Be Made Promptly

  If a TCC member investigated by regulatory authorities for competition law compliance, they shall immediately report the matter to the following personnel: their unit's direct and highest supervisors, as well as the Legal Office.

  

  Legal Office Handling and Risk Response

  The Legal Office should understand the specific circumstances and applicable competition law provisions. If there is a potential risk of violation, the Legal Office should report to management, seek assistance from external lawyers, and promptly implement responsive measures.

  

  Supply Chain Competition Law Violation Reporting Mechanism

  If TCC's suppliers, distributors, or business partners violate or are suspected of violating competition law provisions, all relevant units should report to the Legal Office and require the vendor to cease the illegal activities and cooperate with government authorities' investigations.

• Regulatory Framework：Employees should comply with the Code of Ethical Business Conduct and the Code of Fair Trade and Anti-trust Compliance to maintain a fair competitive market and reduce the legal risks and negative impacts that violations of the law may bring to TCC's business
• Education and Training：Senior managers, managers, and business-related employees must regularly receive fair trade education and training.
• Stay Alert：During daily business operations, avoid discussing sensitive information with competitors, such as prices, quantities, production capacity, trading partners, or market share allocation. Politely decline invitations to social events that may involve the discussion of such information, and stay alert if industry peers attempt to initiate such discussions.

Whistleblower System

1. TCC has established a Reporting Mechanism for Violation of Code of Conduct, which clearly outlines the handling procedures and reporting channels. The mechanism explicitly lists applicable scopes including: corruption, theft, embezzlement, private gain, fraud, improper provision or receipt of benefits from others and other corrupt bribery behaviors, violations of TCC's established systems, regulations, and policies, as well as violations of laws and regulatory orders.
2. Whistleblowers may report either by revealing their identity or anonymously.If reporting anonymously, complete relevant information and documents must be provided. The whistleblower's identity and the report details are kept confidential with restricted access. We promise to protect whistleblowers from improper treatment that may result from their reporting.

TCC's official website and internal employee suggestion box

Items received in response over the years