2-2 Ethics and Integrity Management
In order to create a sustainable business environment, Novatech disclosed financial and corporate governance-related information on the Company's website and Market Observation Post System, established and improved the corporate governance system, established the "Ethical Corporate
Management Best Practice Principles" and the "Procedures for Ethical Management and Guidelines for Conduct", and fulfilled the company's business philosophy of" service, integrity, professionalism and all-win" with the operating philosophy.
Integrity management policy
To establish a culture of integrity in corporate operations and ensure sound development, Novatech has formulated the "Ethical Corporate
Management Best Practice Principles", "Procedures for Ethical Management and Guidelines for Conduct", and "Ethical Conduct Principles", which have been approved by the Board of Directors. Through these policies, the company sets ethical standards and responsibilities for all employees when engaging in business activities. This is aimed at implementing a business philosophy rooted in integrity and simplicity, guiding all employees to conduct their business activities to the highest ethical and moral standards. It also ensures the company'scompliance with domestic and international regulations, including but not limited to the Company Act, Securities and Exchange Act, Business Entity Accounting Act, Political Donations Act, Anti-Corruption Act, Government Procurement Act, Act on Recusal of Public Servants Due to Conflicts of Interest, Integrity Operating Guidelines for Listed and OTC Companies, Ethical Behavior Guidelines for Listed and OTC Companies, Universal Declaration of Human Rights, United Nations Global Compact, ILO Convention, and other relevant regulations.
We are committed to upholding the common values of business conduct, adhering to the Company's Code of Business Conduct for Integrity, which
requires that we take compliance with legal standards seriously and adhere to the Company's Ethical Conduct Principles. We promote corporate
governance with high ethical standards, requiring all employees and suppliers to comply with laws and regulations, integrity codes, protecting
intellectual property rights, and preventing improper transfers of benefits that could jeopardize the interests of the company, our customers, and our
suppliers. Our integrity management is mainly reflected in the following four behavioral aspects:
Integrity Management Practice
To ensure the realization of our company's commitment to ethical operations, we employ a multi-faceted approach across four major aspects,
including organization and responsibility, internal controls, education and training, and supplier commitments:
Integrity Management Education and Training
The General Manager personally promotes the above rules at the general meeting of the Company to demonstrate the company's determination to operate with integrity. He communicates them to employees to establish awareness. Relevant documents are announced in the company's internal system, for employees to view and read immediately. The company also holds a number of education and training sessions related to integrity management, and promotes appropriate conduct and practices. Novatech integrates the online course system by adding integrity management courses into the mandatory courses for colleagues, to help achieve the goal of promoting the participation of all employees in achieving operation with integrity. In 2022, a total of four online courses on Internal Material Information Handling and Prevention of Insider Trading Management Process Procedures, Ethical Corporate Management Best Practice Principles, Procedures for Ethical Management and Guidelines for Conduct, and Ethical Conduct Principles were conducted. A total of 656 trainees were trained, and the total number of training hours was 328 hours, with a training rate of 100%.
Integrity in Business Supplier Commitment
We require all qualified suppliers of Novatech to sign Novatech's "Agreement of Subcontractor Commitment", which stipulates that qualified co-operating manufacturers of Novatech are required to strictly prohibit improper gifts, entertainment or hospitality to the Company's employees who come into contact with the Company due to business contacts, and not to give bribe rebates, commissions or other improper benefits to achieve the purpose of the transaction. If a subcontractor discovers that an employee of the Company has used his/her position to obtain an improper interest from the manufacturer, it shall immediately inform the Company, and the Company shall have the right to suspend or immediately terminate the transaction between the two parties, upon discovery of the above event. In 2022, the signing rate of the "Agreement of Subcontractor Commitment" of the top 60 suppliers in total transaction amount reached 68.3%, among which the signing rate of the top 10 suppliers reached 100%. Our goal is achieving a signing rate for the top 60 suppliers in total transaction amount of 100% in the future.
