To create a sustainable business environment, Novatech upholds integrity as a core operating principle. To maintain the Company's ethical values and reputation,
and to guide internal personnel behavior in adhering ethical standards, the Company has established regulations and communication mechanisms governing key internal codes of conduct. These provide guidelines for employees and implement the company's business philosophy of Service, Integrity, Professionalism, and
Shared Prosperity.
Ethics and Integrity Management ┃ Management Approach
Significance and Meaning to the Company
- Comply with all applicable laws and regulations. Company decisions and business activities must adhere to government regulations. Any illegal or dishonest behavior is strictly prohibited, and all actions must be executed according to integrity management principles.
Management Strategies
- Upholding integrity as a key operating principle, and to protect the Company's ethical values and reputation while guiding employees to follow ethical standards, the Company has established regulations and communication mechanisms for key internal codes of conduct to provide clear guidance for personnel.
Policy/Commitment
- Established internal regulations including Ethical Corporate Management Best Practice Principles, Procedures and Behavioral Guidelines for Ethical Management, and Principles of Ethical Behaviors.
- Established comprehensive internal control systems and formulated and implemented annual audit plans in accordance with the Company's Internal Control Systems.
Actual and potential, negative and positive impacts
Positive:
- Ensure that employee behaviors align with business ethics and social expectations, enhance corporate reputation,and comply with fair trade practices and anti-corruption policies and management to avoid penalties.
Negative:
- Negative incidents can harm corporate image, and in serious cases, the Company could face litigation.
Action
- Promote relevant regulations and policies through all-hands meetings and implement an online course system, incorporating related courses into employees' mandatory training list.
- Conduct insider trading prevention training and related regulatory promotion for directors and senior management at least once a year; regularly promote the prohibition of trading stocks during blackout periods before financial report releases.
- Establish assessment mechanisms and whistleblowing systems for risks of unethical behavior.
- Formulate and implement annual audit plans in accordance with the Regulations Governing Establishment of Internal Control Systems by Public Companies.
- Require directors and senior management to issue declarations of compliance with the integrity management policy, and employees to comply with the integrity management policy.
- During the project bidding process, cooperate with customer tendering methods, uphold the principles of openness, fairness, and honesty, sign integrity management commitments in bidding documents, and participate in bidding activities in accordance with laws, regulations, and tender requirements. Resist any form of bribery and unfair competition practices and insist on operating legally.
* This material topic does not involve activities or business relationships with negative impacts.
Integrity Management Policy
To foster a corporate culture of ethical management and sound development, Novatech's Board of Directors has approved the Ethical Corporate Management Best Practice Principles,Procedures and Behavioral Guidelines for Ethical Management,and Principles of Ethical Behaviors. By adopting these policies,the Company establishes the ethics and sense of responsibility expected of all employees in business operations, implements an honest and pragmatic management philosophy, and guides all employees to conduct business activities in line with high ethical standards, and ensures effective compliance with domestic and international regulations. The regulations include 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, Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies, Guidelines for the Adoption of Codes of Ethical Conduct for TWSE/GTSM Listed Companies, United Nations Universal Declaration of Human Rights, Global Compact, and International Labor Organization Fundamental Conventions.
The Company is committed to upholding shared values in business conduct, promoting corporate governance with high ethical standards, and requiring all employees and suppliers to comply with laws, integrity codes, protect intellectual property rights, and prevent the transfer of improper benefits that could
harm the interests of the Company, its customers, and suppliers.
Our integrity management is primarily reflected in the following four behavioral dimensions:
Implementation of Ethical Corporate Management
To ensure the implementation of ethical corporate management, the Company takes multiple approaches from four major aspects: organization and responsibility, internal control, education, training and evaluation, and supplier commitment:
Ethical Management Education and Training
To establish a responsible business ethics culture among all internal staff, Novatech conducts educational campaigns on insider trading prevention guidelines and related regulations at least once a year for directors, managers, and employees, while providing timely educational campaigns for newly appointed directors, managers, and employees.Relevant company policy documents are posted on the internal system where employees can browse and read in depth at any time. To further strengthen the culture of ethical management, the Company has also incorporated ethical management courses into mandatory courses to ensure active participation among employees
In 2024, the Company conducted four online educational training sessions specifically focused on topics such as internal material information handling, insider trading prevention, ethical management, and principles of ethical behavior. The accumulated number of trainees reached 592 person-times with a total training duration of 296 hours, achieving a 100% employee training rate. For new employees, ethical management-related courses were also arranged during orientation training, with 16 new employees receiving training in 2024, achieving a 100% completion rate.
Status of Ethical Management Education and Training for All Employees
