Business Ethics and Compliance

Sustainable Corporate Operation

The Board of Directors is the highest governance oversight body for ethical practices at Powertech Technology Inc. (PTI). PTI has established the "Sustainability Management Office" as a dedicated organization under the Board of Directors, which oversees and formulates the company's integrity management and sustainable development directions and goals, reporting to the Board annually. PTI has formulated the "Code of Business Conduct and Ethics" and the "Corporate Sustainable Development Practice Guidelines" to construct a comprehensive corporate governance framework and to implement business ethics and combat corruption and bribery.

Integrity Management and Code of Ethics Policy

PTI adheres to high standards of integrity in all business interactions, adopting a zero-tolerance approach to corruption and bribery, with clear guidelines on business ethics, anti-corruption, and anti-bribery, including the "Code of Business Conduct and Ethics", "Ethics Policy", and "Anti-Bribery Policy". All employees and business partners (customers, suppliers, contractors) must comply with these to prevent corruption and bribery.

Ethics Policy

Business Integrity
We prohibit any and all forms of bribery, corruption, extortion and embezzlement.
No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted.
Disclosure of Information
Information regarding labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with local applicable law.
Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights; and customer information is to be safeguarded.

Fair Business, Advertising, and Competition
Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available.
Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained, unless prohibited by law.
Personal Information Protection
Ensure to protect personal information of employees, customers, suppliers and any other related third party. Personal information shall be collected on the legitimate purpose, processing and use.
Confidential Information
Protect company and customer related information services, technology, financial etc., shall not be disclosed to any third party without permission.

Anti-Bribery Policy

Abide by integrity and ethics and engage in business activities based on the principles of fairness, honesty, trustworthiness and transparency.
Forbidden to directly or indirectly provide, receive, promise any improper benefits, or engage in other violations of integrity, legal requirements, or fiduciary obligations.
Comply with relevant Anti-Bribery laws, regulations, and customer requirements.

Encourage reasonable reporting and protect the whistleblower from any form of retaliation or unfair treatment.
Implement Anti-Bribery Management System and keep on striving for continuous improvement in order to achieve the goals of bribery prevention.

Regular Review of Business Ethics and Anti-Corruption Standards

PTI is committed to maintaining high standards of business ethics and anti-corruption, conducting both internal and external reviews annually to timely identify and address risks, thus improving the overall transparency and integrity of the company.

Internal Review — ISO 37001 Anti-Bribery Management System and RBA Code of Conduct Internal Audits

Conduct self-reviews of the implementation of the business ethics management system through annual internal audits, and report audit results and follow-up improvements to the ESG Committee.

External Review — ISO 37001 Anti-Bribery Management System, RBA Validated Assessment Program

■ ISO 37001 Anti-Bribery Management System

Proactively aligning with international standards, PTI introduced the "ISO 37001 Anti-Bribery Management System" in 2020 and obtained certification in 2021. Systematic implementation and execution strengthen corporate governance, with annual third-party external audits to verify the effectiveness of business ethics and anti-bribery implementation. (Click here for ISO 37001 Certificate)

■ RBA Validated Assessment Program

Each site undergoes a biennial Validated Assessment Program (VAP) by a third-party organization, a recognized and shareable social responsibility audit based on Responsible Business Alliance standards. The audit report is transparently shared with customers via the RBA-ONLINE management system and is valid for two years. (Refer to 2023 PTI ESG Report, page 76)

Business Ethics and Anti-Bribery Training and Promotion

PTI holds annual "Business Ethics and Anti-Bribery" promotions and related training to enhance the awareness of the Board, the management, and all employees (including contract workers) on business ethics, anti-corruption, and anti-bribery policies, ensuring they understand the operational standards to follow and the potential consequences of violations. Business partners (including contractors) are also informed about PTI's ethical policies and reporting mechanisms through emails, annual supplier social responsibility forum, and pre-entry contractor guidelines. Employees are required to take online courses to learn Integrity Code of Conduct training. The annual employee performance appraisal systems are integrated to the course to ensure the employees’ compliance.

Regulatory Compliance

Regulatory compliance is fundamental to corporate governance, and all employees must comply with relevant laws and regulations. PTI has established a Sustainability Development Management Dept., Legal Dept., and Intellectual Property Management Dept. responsible for regulatory compliance, trade secrets, personal information, and intellectual property management. Overseas subsidiaries are evaluated and executed by local legal professionals to ensure compliance with local regulations.

Avoiding Conflicts of Interest

PTI has established the "Code of Business Conduct and Ethics" to guide directors, managers, and all employees in performing their duties in accordance with ethical standards and avoiding conflicts of interest. Directors, committee members, managers, and other stakeholders attending or participating in Board meetings must adhere to high standards of self-discipline and avoid discussions and voting on matters where they or the entities they represent have conflicts of interest that may harm the company's interests. Directors should also exercise self-discipline and not inappropriately support each other.

Personal Information Management

Personal data protection is a means of protection and promise to stakeholders such as shareholders, customers, employees, and suppliers. PTI respects the privacy of its employees, follows regulatory requirements, and fulfills personal data protection and management. The collection and processing of personal data are restricted to necessary and required operations, such as labor and health insurance upon retirement or resignation of employees, respective types of insurance, and employee health examinations, among others. Besides periodical personal data protection educational training and communication, for units that are frequently handling excessive personal data of employees during daily operations, efforts will be made to make sure the legitimacy in the collection and use of personal data. PTI conducts business secrets and personal data protection training courses each year for new hires and existing employees so that they have deeper knowledge of business secrets of the Company and personal data protection.

Business Secrets Protection

Business secrets are the life of the Company for its sustainable management. PTI has established a sound business secrets protection policy and secured the ISO 27001 Information Security Management System certification and took part in 2018 in related projects with guidance from the Institute for Information Industry as authorized by the Ministry of Economic Affairs. With assistance from the business secret readiness inspection project, the status of business secret protection for the current stage is examined comprehensively and is reinforced according to the insufficiency in order to eradicate the risk of disclosure of respective classified information. We effectively define and declare the scope of the Company’s secrets by means of the business secret inventory check. The Company’s business secret inventory check operation was already completed in 2023. The current protective measures for trade secrets and confidential information can be divided into personnel management and information management measures:

Personnel Management

To increase employee confidentiality awareness, employees sign the legally binding Confidentiality Agreement and the Non-compete Clause. If there are any on-going special cases, each case and employee sign specialized Confidentiality Agreement. In addition, regular training is conducted to strengthen protection of trade secrets. Control measures include access records, control of camera phones on the production line, and vehicle traffic to prevent any information leaks.

Information Management

In information security policies, confidential files are required to have access control mechanisms or watermarks. The research department has implemented a document protection system to achieve a better control on documents from 2016. When an employee is leaving a position, depending on the handover process of each department, the IT Department shall assist in deleting all confidential files from the computers involved. Control measures include email monitoring, employee USB access hierarchy, and internet control to prevent the risk of information leak.

Contact Us

PTI established individual mailboxes for complaints and consultation for use by the company's internal and external individuals in named or anonymous. For those who report on any perpetration of fraud, violation of business ethics principles or human rights issues, protection shall be offered to prevent from any form of retaliations. The case reported will be actively investigated and dealt with.