Gemtek Technology has established a comprehensive set of policies and procedures to promote ethical conduct and integrity, including the “Code of Ethical Conduct,” “Ethical Corporate Management Best Practice Principles,” “Corporate Sustainability Code of Conduct”(which incorporates the Responsible Business Alliance [RBA] Code of Conduct and the ISO 37001 Anti-Bribery Management System), “Business Ethics and Anti-Corruption/Anti-Bribery Management Procedure,” “Employee Feedback Handling Procedure,” and “Procedure for Refusing Participation in unethical Conduct.” These standards apply to directors, managers, employees, and suppliers, requiring them to act with self-discipline, avoid conflicts of interest whenever possible, and refrain from engaging in any form of corruption or bribery. They must not exploit their position or influence for personal or third-party gain, nor retaliate against whistleblowers.
Gemtek places great emphasis on upholding business ethics and integrity, adopting a zero-tolerance policy toward any form of unethical or dishonest conduct. This principle serves as a cornerstone of the company’s culture, ensuring that all business operations are conducted in accordance with the highest ethical standards. To further strengthen ethical governance and ensure the effective implementation of related policies, Gemtek has established a comprehensive management framework that includes risk assessment mechanisms, procedural documentation, and operational guidelines, all with the full support of the Board of Directors and senior management. These efforts have significantly enhanced the company’s risk management and compliance capabilities. In 2024, Gemtek’s Taiwan headquarters obtained ISO 37001 certification for its Anti-Bribery Management System. The company has also extended its anti-bribery policies and related practices to the Gemtek (Kunshan) facility and the Gemtek Vietnam facility, embedding integrity management into the company’s daily operations.
Business Ethics Policies
- Business Integrity: Prohibit any form of bribery, embezzlement, extortion, or corruption.
- No Improper Advantages: Prohibit offering or accepting any form of bribery or improper advantages.
- Information Disclosure: Disclose information as required by applicable regulations, covering areas such as labor participation, health and safety, environmental initiatives, business activities, organizational structure, financial performance, and operational results.
- Intellectual Property Management Policy: Respect intellectual property rights. Protect intellectual property rights when transferring technology and production knowledge to customers. Confidential or proprietary information belonging to the company, customers, or suppliers must not be disclosed to any third party.
- Fair Trade, Advertising, and Competition: Adhere to standards of fair trade, advertising, and competition. Use signed NDAs (Non-Disclosure Agreements) as a measure to protect customer information.
- Identity Protection and Anti-Retaliation (Whistleblower Protection Policy): Safeguard the confidentiality of whistleblowers' identities and prevent any form of retaliation and threats.
- Personal Data Protection: Maintain the confidentiality of personal information related to all business associates, including suppliers, customers, employees, and other stakeholders. Collect, store, process, and utilize personal data solely for lawful purposes.
Training and Education
To strengthen employees’ awareness of integrity and legal compliance, Gemtek regularly promotes its integrity-related policies and codes of conduct by publishing them on the company’s internal website and bulletin boards. New hires and current employees are required to complete “Corporate Sustainability Awareness Training,” which covers key topics such as business ethics, integrity, anti-corruption, anti-bribery, and prevention of unfair competition, reinforcing employees' understanding and adherence to ethical standards and integrity in the workplace.
In 2024, the training completion rate for both new hires and current employees reached 100%.
| Target Audience |
Communication Method | Participants | Total | Participation Rate |
|---|---|---|---|---|
| Board Members |
|
9 | 9 | 100% |
| Employees |
|
4,346 | 4,346 | 100% |
|
3,896Note２ | 3,896Note2 | 100% | |
|
82 | 82 | 100% | |
|
Suppliers/ Customers |
|
378 | 426 | 89%Note4 |
Note:
1. The reported figure represents the combined total from Gemtek (Kunshan) Facility and Gemtek Vietnam Facility.
2. New employees at the Taiwan Headquarters receive "Corporate Sustainability Awareness Training," while employees at Gemtek (Kunshan) and Gemtek Vietnam Facilities undergo "RBA Training."
3. The number of individuals receiving training includes all participants, including those who resigned before completing the program.
4. As certain suppliers are designated by customers and therefore unable to sign the Company's standard procurement agreement, the return rate of signed contracts has fallen short of expectations. To actively uphold integrity and ethical standards, the Company has implemented an alternative approach by providing a standalone "Integrity Commitment Statement" for such cases, ensuring that the principle of ethical conduct remains firmly upheld in all business partnerships.
Grievance / Reporting Handling Mechanism
Suggestion boxes are placed at each manufacturing facility to enable employees to report violations of integrity and ethical conduct. Additionally, an open feedback and whistleblowing channel (Gemtek_suggestion@gemteks.com) is available for all stakeholders to raise concerns or report corporate social responsibility issues. Whistleblower reports are initially handled by a dedicated task force before being forwarded to the relevant departments for further investigation. If a case is substantiated, an ad hoc committee is convened to review and resolve the matter. To improve company management and internal controls, these cases are integrated into preventive measures to avoid future incidents. Depending on the severity of the violation, disciplinary actions may be taken, improper gains recovered, or legal action pursued. The whistleblower’s identity and report details are kept strictly confidential, accessible only to authorized personnel, with the company ensuring protection against retaliation. Additionally, these cases are used as educational tools to help mitigate the risk of future occurrences.
In 2024, there were no major penalties imposed by regulatory authorities on the Company for violations related to ethical business conduct, anti-competitive practices/antitrust, conflicts of interest, money laundering/illicit transactions, or corruption and bribery. Additionally, there were no reported complaints, whistleblower cases, or incidents related to political contributions concerning these matters.
