Integrity Management

Business ethics & Integrity Management

CTCI Group Codes of Ethical Conduct

CTCI takes "Most Reliable" as its brand positioning. The "Codes of Ethical Conduct", "Ethical Corporate Management Principles of CTCI" adopted by the Board of Directors and CTCI issued, as the ethical standards and codes of conduct that CTCI's directors, managers and all employees should follow when performing their duties, manage anti-corruption, fair trade, prohibition of insider trading, etc. to prevent dishonest behavior and submit CTCI Corporate Integrity Operation Policy to the board of directors at the end of each year.
　
CTCI hopes to improve and drive the sustainable development of the entire value chain through the mutual influence of upstream and downstream. Therefore, we have also formulated a "Code of conduct for vendors" for suppliers”. For detailed management instructions, please refer to Supply Chain Sustainability Management. CTCI respect and uphold all internationally recognized human rights, we follow the UN Global Compact, the Universal Declaration of Human Rights, at Work, Equal Remuneration Convention, and other norms and spirits related to human rights, labor standards, environment and anticorruption, formulating CTCI Human Right Policy.
　
　

Implement Ethical Management - Education and Training Advocacy

In order to establish a responsible business ethics culture for all internal parties, for directors and supervisors, the Company conducts education and advocacy for directors, managers and employees on the "Measures to Prevent Insider Trading" and relevant laws and regulations at least once a year, and provide timely education and advocacy for new directors, managers and employees. Every year, regular training and signing of the CTCI Codes of Ethical Conduct are held for all employees of the Group (including formal, contracted and dispatched employees) to continue to emphasize CTCI’s integrity concepts of anti-corruption, integrity, commitment and honesty.  In 2023, the training coverage rate and signing rate are both 100%; for new recruits, courses related to ethical behavior are also arranged in the new employee training. In 2023, a total of 857 new recruits in Taiwan will be trained, and the coverage rate is 100%.
　
　

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Anti-corruption and bribery

To ensure prevent bribery and corruption, CTCI requires that employees should not give discounts when conducting trading activities with stakeholders, and cannot ask for, make deals with, give, or accept gifts, entertainment, kickbacks, or bribes for himself / herself or on behalf of others when carrying out his / her job duties. CTCI clearly defines the principles and penalties of "rules for gift receiving", "prevention of conflict of interest" and "protection of trade secrets and intellectual property rights" in the "Rules for Ethical Conduct". The "Code of Integrity Business" prohibits the provision of illegal political donations and prohibits improper charitable donations or sponsorships to avoid disguised bribery.  CTCI checked the 20 lowest ranking countries in the Transparency International's Corruption Perception Index in 2023 and the Group found no construction projects in those countries.
　
In order to specifically promote the anti-corruption policy, CTCI regularly announces the "no gift acceptance policy" on three occasions every year. Overseas projects are also implemented and promoted according to the same standards, and publicity and communication are also provided to contractors, customers, etc.  Since purchasing personnel are in direct contact with external manufacturers when handling procurement operations, in order to clarify personal responsibilities, all colleagues who enter the purchasing department should sign the Purchasing Personnel Code, which specifically promises that purchasing personnel should comply with legal requirements when performing matters and must not solicit personal improper benefits or accept payments.  Any form of remuneration and other ethical standards, and a questionnaire survey will be conducted when new people join the purchasing department to establish personal information, so that department work assignments can implement the avoidance of interests in purchasing operations.   For construction site colleagues, we will continue to strengthen relevant publicity and training for construction site colleagues through online meetings, education and training, and post behavioral indicators of corporate culture at each construction site to cultivate the concept of integrity and sustainability among colleagues and contractors.  There were no confirmed corruption incidents between 2020 and 2023.
　
　

Anti-Fair Competition

CTCI Group maintains visions of legal compliance and honest business operations, and fully exercises professionalism and integrity. To ensure fair trade, fair competition and to prevent unfair competition, monopoly, joint inappropriate behavior, inappropriate market allocations and joint price manipulations, the Group always abides by a fair-trade spirit, regardless of project tenders or external contracted service / procurement projects. In order to enhance the efficiency and quality of project tendering and procurement processes, CTCI always undertakes fair and open tendering process when competing for business targets. CTCI will continue to expand the spirit of fair trading by encouraging all employees to file reports. In addition, it continues to carry out employee trainings targeted at marketing and sales, procurement representatives, legal affairs, contract personnel and other relevant department employees that may be involved in related risks and are required to regularly participate in antitrust law, fair trade law education, training and case analysis courses every year and pass the test. Colleagues in other departments can also take the courses to improve knowledge of regulations. Current statistics from 2020 to 2023, the total number of trained employees (including new and current colleagues) who have completed the relevant training courses has reached 451 and they are aggressively implementing fair trade and related laws and regulations on their positions. 
　
If CTCI’s employee is found to have violated or breach regulations pertaining to anti-trust laws, the company will conduct a comprehensive and thorough investigation of the employee's work history and suspend the employee from having any contact with the work. If a criminal offense is involved, the company will deal with it in accordance with the law. Therefore, no anti-competitive behavior related cases occurred in CTCI Group in 2023.
　

Reporting and Protection

If employees have questions about ethical business conduct or the Code of Conduct, they can seek advice from their immediate supervisor, human resources Department or compliance department. In order to prevent inappropriate behavior, CTCI has an independent internal reporting mailbox and has established a reporting platform through a third-party impartial organization. If internal colleagues or external personnel discover any illegal or improper behavior within the group or cooperative vendors, they will immediately or are in the process of reporting it. Anyone who has a negative impact on the group can take the initiative to report it through relevant channels.  Reporting cases are accepted by the human resources department. In addition to investigating the case and implementing follow-up improvements in accordance with relevant regulations, a list of reports is sent to the independent directors every quarter for reference.
　

Accusation Management Regulations

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CTCI Corporate Integrity Operation Policy for 2023

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