Anti-Corruption Policy
HIWIN Technologies Corporation and all its subsidiaries (hereinafter referred to as "the Company") operate in adherence to the " Ethical Corporate Management Best Practice Principles " and the "Procedures for Ethical Management and Guidelines for Conduct." The company adopts a zero-tolerance policy toward corruption and is committed to maintaining high ethical standards and conducting business with integrity and honesty. Corrupt practices include bribery, facilitation payments, kickbacks, collusion, embezzlement, fraud, theft, and any actions intended to improperly influence a third party or benefit oneself to the detriment of the Company. This policy is established to guide relevant personnel to avoid corrupt practices during business operations and to support anti-corruption initiatives of international organizations and various countries.
1.Objectives:
(1) To specify prohibited practices during business operation to avoid corruption.
(2) To prevent any form of corruption and ensure compliance with relevant anti-corruption laws.
(3) To develop the corporate culture of integrity through the implementation of this policy, thereby maintaining the Company's brand image.
2.Scope of Application:
This policy applies to all directors, employees, and third parties acting for or on behalf of the Company in the course of its business.
3.Definition of Corruption:
(1) The Company prohibits the offering or acceptance of bribes, facilitation payments, kickbacks, or any other improper benefits for the following purposes. Employees, or any individuals representing the Company in business transactions, are strictly prohibited from offering or receiving any benefits with the intent of bribery, regardless of whether the party offering or receiving the benefit is a government official, legal entity, business association, or individual.
A. To obtain or retain business
B. To influence or reward improper behavior or activities;
C. To exert improper influence on government officials or the company's actions, activities, or decisions;
D. To induce government officials to violate their legal obligations by engaging in or refraining from any action
E. To induce government officials to exert influence over other departments, agencies, entities, or members of public office groups.
(2) Any improper benefit of value offered with the intent to influence the behavior or decisions of others to gain or maintain a business, regulatory, or personal advantage is considered bribery. Bribery includes kickbacks and facilitation payments. A facilitation payment refers to a bribe paid to accelerate routine administrative process of government officials.
(3) What constitutes a benefit: This includes all tangible and intangible benefits, such as gifts (including but not limited to cash and cash equivalents), entertainment, travel, meals and accommodation, hospitality, loans, preferential treatment, equity, or the provision of future employment opportunities.
(4) When Company personnel directly or indirectly offer, receive, promise, or request any benefit, they must comply with the provisions of this policy, except in the following circumstances:
A. For business purposes, during domestic or overseas visits, hosting foreign guests, promoting business, and facilitating communication and coordination, in accordance with local etiquette, customs, or practices.
B. Participation in or invitations to normal social events organized by others for the purpose of customary social etiquette, business purposes, or promoting relationships.
C. Invitations to clients or being invited to attend specific business activities, factory visits, etc., where the cost allocation, number of participants, accommodation standards, and duration of the event are clearly specified
D. Participation in the folk festivals that are publicly organized and accessible to the general public.
E. Rewards, assistance, condolences provided by superiors.
F. Other actions permitted under Company policies.
4. Avoidance of Conflicts of Interest:
(1) What is a conflict of interest: When an individual is confronted with a conflict of interests while fulfilling their responsibilities or making decisions, such conflicts may arise from personal gain, relationships with others, or external pressures. These competing interests have the potential to affect the individual's impartiality, objectivity, and integrity in both judgment and actions. Such circumstances may lead to improper conduct, resulting in preferential treatment or benefits being granted to themselves or individuals with whom they are associated. A conflict of interest situation generally includes the following,
A. Employees or their related parties hold any position with the Company’s clients, suppliers, or competitors.
B. Employees or their related parties have financial interests in the Company's customers, suppliers, or competing companies.
C. An employee uses the Company's resources for personal affairs or to gain personal benefits without prior approval.
(2) In cases of unavoidable conflicts of interest, the Company will take appropriate actions, such as adjusting roles, responsibilities, or business relationships, to minimize the conflict.
5. Political Contributions and Charitable Donations:：
(1) Donations to political parties or organizations must comply with relevant laws and regulation, and shall approved by the Company's Chairman or an authorized executive before being processed.
(2) Charitable donations made using the Company's assets must comply with relevant legal regulations and the Company's articles of association, and shall be approved by the Company's Chairman or an authorized executive before being processed.
6. Risk Assessment and Reporting Mechanism:
(1) The company will periodically take measures to identify and mitigate corruption-related risks, evaluate the effectiveness of the existing anti-corruption policy compliance system, and assess its reasonableness and clarity. Based on this evaluation, modification proposals will be submitted for approval to address the nature of the identified risks.
(2) All updates to this policy will be announced internally and can be reviewed on the Company's website for stakeholders' awareness.
7. Record-Keeping:
All financial transactions of the Company, including the approval of gifts, accounting postings, and journal entries, must be accurately and clearly recorded in the Company’s books for inspection. They must not mislead the facts, omit information, or alter records in any way.
8. Promotion and Training:
To reinforce the importance of complying with this policy, the Company will periodically conduct educational training and promotion programs for relevant personnel on the principles and standards of anti-corruption law compliance. This aims to enhance the concepts of integrity and self-discipline. Additionally, the Company’s policies will be published on the official website to ensure that relevant stakeholders fully understand the Company’s integrity management, anti-corruption, and anti-bribery policies, as well as the consequences and risks that may arise from violating this policy.
9. Audit and Monitoring:
The Company develops the annual audit plan based on a risk assessment approach. The implementation of this policy would be part of the risk assessment process, including considerations of the policy's suitability, adequacy, and effectiveness. The company's audit team conducts regular audits of the Company’s control systems and procedures to enhance overall awareness, detect potential misconduct, and monitor compliance with this policy.
10. Reporting and Disciplinary Actions for Violations:
(1) Professional ethics is one of the core operating principles of the Company. The Company has always adhered to integrity in all business activities. When interacting or transacting with affiliated companies and suppliers, the Company upholds the values of honesty and integrity, and corruption is strictly prohibited. If individuals become aware of any behavior that may violate this policy or relevant regulations, they may report or file a complaint through the Company's designated whistleblower hotline (argon@hiwin.tw). Unless otherwise stipulated by law, the Company ensures absolute confidentiality of the whistleblower's identity and the contents of the report.
(2) Violators of this policy will face severe penalties, including appropriate disciplinary actions, with the most severe penalty being termination of the employment contract. Violators should understand that actions contrary to this policy may result in serious civil liability, administrative sanctions, or criminal penalties.
11. Effective Date and Implementation:
This policy and its amendments will take effect upon approval by the Board of Directors and the announcement of the effective date.
Chairman & CEO Eddie Chuo
November, 2024