Ethical Management

Ethical Corporate Management and Anti-corruption Management System

  • Corporate vision: "Ethics" as the highest guiding principle for business development.
  • Scope of application: All employees of the Company, suppliers, and contractors. We have a zero-tolerance approach to corruption and strictly prohibit practices including bribery, facilitation, fraud, extortion, blackmail, collusion, and money laundering. We prohibit the offering or acceptance of gifts, loans, fees, incentives, or other benefits. We do not tolerate corruption, influence-peddling, abuse of authority, unlawful enrichment, concealment, and obstruction of justice.
  • Management system:
  1. The Board of Directors has approved the "Anti-Corruption Policy" as the basis for ethical corporate management and anti-corruption management measures. The Company has also implemented the ISO 37001 anti-bribery management system and adopted the "planning and establishment, implementation and operation, supervision and audit, maintenance and improvement", ensuring its effective operation and continuous improvement and that a zero-tolerance attitude is adopted.
  2. “Principles for Ethical Management of Asia Cement Corporation” stipulate that the Company's personnel shall not directly or indirectly offer, promise, request or accept any undue or improper advantages in the course of conducting business.
  3. “Codes of Ethical Conduct of Asia Cement Corporation” regulates the recusal of employees and the prevention of conflicts of interest when performing duties.
  4. The "Procedures for Ethical Management and Guidelines for Conduct" stipulate the prohibition of offering or accepting undue or improper advantages, recusal due to conflicts of interest, organization and responsibility for confidentiality, prohibition of unfair competition, prohibition of insider trading, and obligation of confidentiality.
  5. The "Employee Work Rules" outlines the employee code of conduct. The supervisor of the responsible department is responsible for educating, advising and leading the employees so that they fully understand the code of conduct and ethics.

Ethical Corporate Management and Anti-corruption Implementation Results

 

There were no incidents of corruption or bribery in 2023.

There were no incidents of conflicts of interest, money laundering, insider trading, or other violations, and the anti-bribery management objective was 100% achieved.

A total of 2 whistleblowing cases were received in 2023. One case: no circumstances described by the whistleblower were found after investigation;while the other case was rejected due to incomplete information.Both cases, handled according to the Company's “Measures for Reporting of and Investigating Unethical Conduct”, were submitted to the Audit Committee for review.

All the directors and employees of ACC in Taiwan have signed the "Corruption Prevention Policy Compliance Statement".

 

All employees at each site completed 100% of the anti-bribery awareness and education training. Total training hours: 965 hours, completion rate: 100%, pass rate: 100%.

100% of new employees completed ethical corporate management and corruption prevention promotion.

All new suppliers and contractors undergo 100% anti-corruption awareness before conducting transactions.

Key risk suppliers/contractors completed 100% of anti-corruption education and training.

The scope of application of anti-corruption and bribery prevention measures were expanded. Except for ACC as an entity, subsidiaries in Taiwan are being assessed to be included in the bribery prevention management system.

Ethical Corporate Management and Anti-corruption Management

To implement the bribery prevention policy, all employees of the Company are strictly prohibited from entering into transactions or offering, accepting, promising or requesting, directly or indirectly, any undue or improper advantages for themselves or others in the course of performing duties. Through education and training, the Company strengthens colleagues’ anti-corruption and antibribery awareness, so as to build an ethical foundation to avoid business risks, unleash corporate positive values, and achieve the goal of sustainable operations.

 

Regular Audits of Ethical Standards

To ensure the effectiveness of anti-corruption management, our company has established the "Anti-Corruption Internal Audit Procedures" in accordance with the ISO 37001 management system requirements, mandating an annual internal audit of all business areas. Following the PDCA management system principles ("Plan-Do-Check-Act"), we continuously maintain and improve the system's effectiveness. Asia Cement passed the ISO 37001 anti-corruption management system certification in 2023, with the next certification due in 2026.

Anti-corruption risk assessment and due diligence

To effectively identify bribery risk scenarios and risks faced by the Company in the course of operations, each unit performs a risk assessment. The process involves identifying risks along the lines of their respective business processes and characteristics, taking into consideration the authorization of practitioners, decision-making authority, location and department, business activities and complexity, business model, and business partners, etc. We have identified 174 risk patterns, 28 internal and external material issues, and evaluated them based on likelihood, degree of impact, and the effectiveness of the control measures. In 2023, the Company completed 100% of all bribery risk assessments and the results were all low risk, at an acceptable level, with 100% of the improvement measures were completed.
Our company has established the "Anti-corruption Assessment and Due Diligence Procedures," which cover all business areas and partners, including employees, suppliers, customers, and special types of transactions. The results are reported to the Anti-corruption Management Review Committee, the Corporate Sustainability Committee, and the Board of Directors. Considering that the integrity status of business partners may change over time, our company regularly re-evaluates risks with frequencies of annually for high-risk, every two years for medium-risk, and every three years for low-risk areas.

Communication and Training on Ethical Corporate Management and Anti-corruption

Twice a year, we organize anti-corruption education and training. Each employee is subject to receiving at least 2 hours of training; while internal auditors of corruption prevention must receive a minimum of 3 hours of education and training to enhance the Company's anti-corruption awareness. Board members and all employees, suppliers, and contractors are provided with the training. The training content includes the Company's Code of Ethical Conduct, Principles for Ethical Management, whistleblowing channels and disciplinary measures, and covers all aspects of anti-bribery, breach of integrity, violation of law or breach of fiduciary duty and other unethical conducts. The "Code of Ethical Conduct", "Principles for Ethical Management", and "Anti-Corruption Policy" are explained to newcomers so that they understand their contents and personal obligations, while conveying corporate ethics.

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