The company has established the "Code of Ethical Conduct," "Business Integrity Policies," "Business Integrity and Anti-Corruption Management Procedures" and other guidelines to regulate workplace behavior. Gemtek requires directors, supervisors, managers, employees, and suppliers to exercise due diligence and self-discipline, actively avoiding conflicts of interest, corruption, and bribery. They must also refrain from abusing their positions of authority to gain improper advantages or retaliate against whistleblowers.
Business Integrity 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 promote workplace integrity and ensure regulatory compliance, the company shares policies and documents related to ethical business practices and professional conduct through the corporate intranet and office bulletin boards. New hires are required to complete Responsible Business Alliance (RBA) training as part of their onboarding, and refresher courses are regularly provided to current employees. The RBA training covers key topics such as business ethics, integrity, anti-corruption, anti-bribery, and prevention of unfair competition, reinforcing employees' understanding of RBA principles.
In 2023, 4,354 participants completed the training, achieving a 100% completion rate.
| Communication Target | Method of Communication | Number of Attendees | Total Number of Attendees | Effectiveness % |
|---|---|---|---|---|
| Members of the BOD | Reiterate the importance of Anti-Corruption Awareness annually | 9 | 9 | 100% |
| Employees |
Note: Due to business divestment in the second half of 2023, Gemtek Electronics (ChangShu) did not conduct any employee training and development programs. |
4,354 | 4,354 | 100% |
| Suppliers/Customers |
|
532 | 601 | 89% |
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 2023, there were no instances of penalties imposed by competent authorities for violations of business ethics, anti-competitive practices, monopolistic behavior, or anti-corruption laws and regulations.
Furthermore, no cases of corruption were reported during this period.
