Getac Holdings Corporation

Ethical Management

An enterprise culture of integrity and honesty forms the foundation for sustainable business operations. Getac adheres to relevant laws and regulations, establishing robust corporate governance and risk control mechanisms while promoting a culture of integrity. Employees are required to implement these principles in internal management and business activities, eliminating unethical behaviors and creating an environment conducive to 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 principles of integrity, Getac includes clauses on integrity, professional conduct, and conflict of interest in employment contracts. The employee code of conduct explicitly prohibits corruption, theft, abuse of power, bribery, and other unethical behaviors that harm the company's interests. Employees involved in specific projects are required to sign confidentiality agreements. Any violations, once verified, are addressed in accordance with the "Employee Reward and Disciplinary Measures." For severe violations, the company may terminate the employment contract without prior notice and pursue legal action for any criminal liabilities, as well as compensation for related losses.
 

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.

In 2023, Getac Holdings and its eight subsidiaries conducted a risk assessment in accordance with the spirit of the OECD Due Diligence Guidance for Responsible Business Conduct. This assessment focused on eleven anti-corruption topics, including dishonest behavior, conflicts of interest, payment processes, sales and collections, procurement and payments, as well as engineering tenders and acceptance. The evaluation considered both the likelihood of these risks occurring and their potential impact on the company's finances, operations, or reputation.

Out of the 11 anti-corruption topics evaluated, two were identified as medium risk, while the remaining were categorized as low risk. The detailed results of the 2023 anti-corruption risk assessment can be found in the table below.
 

2023 Anti-Corruption Risk Assessment Results

To reinforce our company's commitment to human rights and due diligence, we revised the "Guidelines Governing the Reporting of Corruption and Malpractices" in 2022, as depicted in the process diagram on the right. This revision expands the scope of whistleblower acceptance to include clients, suppliers, partners, and other stakeholders engaged in business dealings. The regulations specifically outline confidentiality measures during the investigation process and mechanisms for protecting whistleblowers. The company treats whistleblower reports with sensitivity and caution. For each case, we enter into a Unilateral Confidentiality Agreement with the whistleblower to protect their information. Upon conclusion of the case, we provide a questionnaire for whistleblowers to ensure their rights and confidential information are safeguarded. All reports, transcripts, or related materials are handled confidentially and securely stored. Unauthorized disclosure is subject to disciplinary action under company policies. Additionally, the company ensures the safety of whistleblowers and takes legal action against anyone threatening, intimidating, or engaging in unlawful acts against them.

Getac Holdings has established a whistleblower system for internal and external stakeholders to provide feedback or report violations anonymously regarding breaches of professional ethics. Details of the whistleblower system are available on Getac Holdings official website, procurement contracts, and the "Guidelines Governing the Reporting of Corruption and Malpractices". Promotion of the whistleblower system is also included in anti-corruption and anti-money laundering training courses. According to regulations, each reported case is categorized as significant or general based on the anticipated loss amount, with internal personnel receiving a bonus of NT$200,000 for significant cases and 5% of the loss amount for general cases upon successful investigation.

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 implement integrity education, all directors, management, and employees of Getac Holdings must undergo anti-corruption related training. Since 2022, anti-corruption and anti-money laundering education training has been designated as a mandatory course. It is stipulated that all management and employees of the company and its subsidiaries must complete the training once and take a post-training test to ensure their understanding of the anti-corruption policies. 

In 2023, the training completion rate target was raised to 80%. Completion is defined as each employee taking the post-training test and correctly answering all ten questions to achieve a perfect score of 100. If an employee scores below 100, they must retake the training and post-training test until they pass to be considered as having completed the training.

In 2023, a total of 6,965 employees from Getac Holdings and its subsidiaries received anti-corruption and anti-money laundering education and training, with a completion rate of 87.3%. Please refer to the training details of each subsidiary.