Getac Holdings Corporation

Ethical Management

In compliance with relevant laws and regulations, Getac Holdings has established good corporate governance and risk management mechanisms, advocated the corporate culture of integrity and honesty, and requested the employees to properly implement the culture in the internal management and commercial activities, preventing any behaviors against the codes of business ethics and creating a business environment for sustainable development.

In addition to creating a sincere and honest corporate culture, Getac complies with external laws and regulations and establishes internal systems to ensure that Getac employees operate by the highest level of ethical standards. The company strictly prohibits employees from making illegal political donations in exchange for commercial gains or business advantages. As for laws and regulations, Getac complies with the Corporate Governance Best Practice Principles to be a law-abiding corporate citizen. The company formulated the Ethical Management Best Practice Principles and the Code of Ethical Conduct for Directors and Supervisors to act as the business ethics and ethical management standards, and require all directors, supervisors, and employees to abide by these standards.

Getac’s Ethical Management Best Practice Principles is applicable to directors, managers, employees, appointees, and individuals with substantial control. To uphold the company's commitment to integrity in business operations, internal employees are bound by provisions such as the "Cleanliness Clause," "Professional Conduct," and "Conflict of Interest" in their employment contracts. The Employee Code of Conduct explicitly prohibits behaviors that violate professional ethics or harm the company's interests, including corruption, embezzlement, abuse of power, bribery, and fraud. Relevant personnel are also required to sign confidentiality agreements for specific projects. If an employee is found guilty of the aforementioned misconduct, the company will follow the "Employee Rewards and Punishments Regulations." In serious cases, the company may terminate the labor contract without prior notice. If criminal liability is involved, the matter will be referred to law enforcement for prosecution, and the responsible individuals will be held accountable for any resulting damages.

In terms of external governance, in order to fulfill social responsibilities and achieve success in the market, the "Getac Supplier ESG Code of Conduct" specifies that suppliers and their agents must adhere to the highest ethical standards. Supplier must avoid all activities that cause conflicts of interest with the Getac Holding Corp., and any agreement or negotiation involving offering behavior must be prohibited.

Suppliers who exchange transactions more than NT$80,000 with Getac must sign the Most Favorable Treatment and No-Corruption Guarantee Agreement. If a supplier does not sign such an agreement, the system will automatically suspend any payment activities, in order to prevent vulnerabilities. Contracts signed with suppliers also provide information on reporting hotlines. The Audit Department of the company is responsible for handling reports concerning unethical conducts.
 

To emphasize the company's commitment to human rights and due diligence, the "Guidelines Governing the Reporting of Corruption and Malpractices" were revised in 2022, expanding the scope of accepted reports to include customers, suppliers, business partners, and individuals engaged in business transactions with the company. The regulations also specify the confidentiality measures for the investigation process and provide protection mechanisms for whistleblowers. The company treats reported matters as sensitive and handles them with caution. 

For significant reports, the company may sign a unilateral confidentiality agreement with the whistleblower to ensure the confidentiality of their information. Upon conclusion of the investigation, a human rights due diligence form is provided to the whistleblower to confirm the protection of their rights and confidential information. Whistleblower reports, transcripts, or other related documents should be kept confidential and securely stored. Unauthorized disclosure is subject to disciplinary action according to the company's disciplinary policy. The company is responsible for safeguarding the safety of whistleblowers. Any threats, intimidation, or unlawful actions against whistleblowers should be strictly punished in accordance with the law.

Getac Holdings has established a whistleblowing mailbox for individuals, both internal and external, to provide feedback or report violations of ethical and moral conduct. The system also accepts anonymous reports. The details of the whistleblowing mailbox are published on the Getac Holdings’ official website and included in procurement contracts. It is also promoted during anti-corruption and anti-money laundering training courses. Whistleblowers are eligible to receive a reward of NT$200,000 or 5% of the amount of loss as specified.

Irregular Business Conduct Reporting Contact
Head of Auditing Office
gthaudit@getac.com.tw

In 2022, the company established the "Anti-Corruption and Anti-Money Laundering Policy" and the "Anti-Corruption and Anti-Money Laundering Policy Statement" to enhance the governance procedures and integrity management of the company. The company is committed to abiding by the guiding principles of the United Nations Convention Against Corruption (UNCAC), and agrees to comply with anti-corruption laws, regulations, and other commercial practices in the jurisdictions where it operates. The company maintains a zero-tolerance approach towards corruption and provides guidance to stakeholders to assist them in preventing corrupt practices. Furthermore, to prevent money laundering, tax evasion, and violations of sanctions, the company also commits to complying with relevant anti-money laundering laws and regulations and demonstrates its determination to combat money laundering crimes.
 

To promote business ethics, Getac requires all directors, independent directors, supervisors, management personnel, and employees to undergo anti-corruption and anti-money laundering training. In 2022, anti-corruption and anti-money laundering education and training were designated as mandatory courses for all subsidiary management personnel and employees. It was specified that they must complete the training and pass a post-training assessment to ensure their understanding of anti-corruption policies. The attendance rate for the education and training was set at a minimum of 80%, and a passing score of 90 points was required for the examination. 

The anti-corruption course adopts rolling training. In addition to the new employees who are compulsory for study, all employees are targeted for retraining every year, for employees to bear in mind the importance of human rights and anti-corruption. In 2022, a total of 7,123 employees from Getac Holdings and its subsidiaries received anti-corruption and anti-money laundering education and training, achieving a completion rate of 89%. Please refer to the training details of each subsidiary. We did not find or receive any internal or external reports of unethical conducts by all operational sites in 2022.
 

Getac strictly abides by regulatory laws relating to corporate governance and integrity management, environmental protection, and labor human rights to implement civic and law-related education within the organization. The organization implements regulatory education internally. In 2022, the following major5 violations of regulations did not occur:

• Major penalties for environmental protection and related disputes
• Significant penalties or non-monetary sanction due to legal violation.
• Product or service in violation of consumer health and safety laws and principles.
• Product or service in violation of information or labeling laws and principles.
• Significant fines for violating the relevant laws and decrees related to provide or use the products or services
• Marketing activities (including advertising, promotion, and sponsorships) in violation of relevant laws and principles.
• Violation of anti-competitive behaviors, anti-trust and anti-monopoly laws and regulations.
 

Getac promises to work with suppliers to take responsibility for social and environmental protection, support and comply with the Responsible Minerals Initiative and not use conflict minerals mined through human rights abuses or armed coercion, especially gold, Tantalum, tungsten, tin, cobalt, mica and other minerals or their derivatives mined in the Democratic Republic of the Congo and its neighboring countries. The suppliers will fulfill the aforementioned statement and will notify the Company and provide evidence to assist in the investigation of sources of minerals and the production and sale supervision process.

In addition, subsidiary companies MPTK and MPTZ also include conflict minerals as part of their annual supplier audits based on the guidelines of the "Responsible Business Alliance." Suppliers who fail the initial and follow-up audits are terminated. Over the past three years, no instances of suppliers using conflict minerals have been found in all audits.