Ethical Management

Compliance of ethic, sincerity and anti-corruption

The operation concept of “sincerity, diligence, thrift, prudence and innovation” has been deeply rooted in the hearts of the employees. Sincerity refers to open-minded and zealous; diligence refers to hardworking and considerate; thrift refers to frugal and simple; prudence refers to cautious and accurate. In short, “be honest, clear, go to the bottom of things and do the best” has been a part of the corporate culture.

In 2022, Asia Cement did not have any violation behaviors occurred.

Anit-Corruption Policy

Asia Cement implements ESG, and sets the highest ethical standards in accordance with ISO 37001 standards. On November 9, 2022, the board officially approved the "Anti-Corruption Policy," demonstrating a zero-tolerance approach towards corruption and serving as the foundation for our commitment and implementation of various anti-corruption measures.

The 'Anti-Corruption Policy' of Asia Cement applies to all entities within Asia Cement, including the corporate headquarters, Hualien Plant, Hsinchu Plant, and all other units. The policy mandates all company personnel, including directors, managers, employees, appointees, or those with substantial control, to strictly avoid any improper benefits, whether provided, received, promised, or requested, directly or indirectly, for themselves or others in the course of business operations. Through education and training, we aim to enhance our colleagues' awareness of anti-corruption and anti-bribery measures. This builds an ethical foundation, mitigates business risks, promotes our company's core values, and supports our goal of sustainable operations.

In support of the Anti-Corruption Policy, all Asia Cement directors and 487 employees have signed the "Statement of Compliance with Anti-Corruption Policy".


Anti-Corruption Management System 

Asia Cement has implemented the ISO 37001 Anti-Corruption Management System, with the President leading the anti-corruption management efforts. The Secretarial has been designated as the exclusive department responsible for corruption prevention. To ensure the continued effectiveness of our anti-corruption management system, the leadership conducts an annual review and reports to the board.

In February 2023, Asia Cement completed an internal audit of its anti-corruption management system. In March, a management review meeting was held, and an external audit by British Standards Institution (BSI) was conducted. The BSI verification was obtained in June 2023.


Principles of Ethical Management

  1. Prohibit bribery and accepting bribes.
  2. Prohibit providing illegal political contributions.
  3. Prohibit improper charitable donations or sponsorships.
  4. Prohibit offering or accepting unreasonable gifts, hospitality or other improper benefits.

Code of Ethical Conduct

  1. The principle of honesty and credit
  2. Prevention of conflict of interest
  3. No self-interest
  4. Duty of confidentiality
  5. Fair trade


Ethical Management Procedures and Guidelines

  1. Prohibition of offering or accepting any undue benefits
  2. Interest recusal
  3. Organization and obligation of the confidentiality mechanism
  4. Prohibition of engagement in unfair competition
  5. Confidentiality obligation and prohibition of insider trading


Promotion and training of sincere operation and anti-corruption

The company holds at least two anti-corruption education training sessions annually to enhance anti-corruption awareness.The trainees include board members, staff, suppliers and, contractors. The training content includes policies like the Company’s Code of Ethics, Ethical Corporate Management Best Practice Principles, reporting channels, and disciplinary actions, which cover anti-corruption behavior, violation of ethics, violation of law, or breach of fiduciary duty. Both online and on-site training are provided.

In 2022, the Company held 7 categories of courses, with 350 trainees. Such courses include “Ethical Corporate Management Best Practice Principles and Anti-corruption Regulations at Home and Abroad”, “Prohibition of Offering or Accepting Any Undue Interests and Recusal of Conflict of Interests”, “Confidentiality Mechanism and Prohibition of Unfair Competition”, “Prohibition of Insider Trading”, “Ethical Corporate Management Policy”, “Handling of Unethical Conduct and Mechanism for Protecting Whistleblowers”, and “Regulations for Ethical Conduct and Corporate Social Responsibility for Employees”. The company has set the education and training goal: 100% of employees to complete the educational training and pass the post-course assessment.

When new employees report for duty, they will be given the training courses on "Code of Ethics", "Ethical Corporate Management Best Practice Principles", and "Bribery Prevention Management Policy", so they are given the idea of the content and their personal obligations in regards to the concept of corporate ethics.


Bribery Risks and Due Diligence Investigation Findings

The Company has formulated it "Regulations for Bribery Risk Assessment and Due Diligence Investigation" for employees, suppliers, customers, and special types of transactions. Our due diligence covers all business partners, including agents, suppliers, customers. For new suppliers or customers, we assess their record in anti-corruption and bribery behaviour. The Company reports the implementation results to the Sustainability Committee and the Board of Directors every year. Consider the ethical status of business partners may change over time, the Company reassesses their ethical status according to their risk level periodically, e.g., once a year for partners of high risk, once every two years for partners of medium risk, and once every three years for partners of low risk, or at any time wherever necessary.

  • Employees

23 employees with approval authority were assessed and found to be of low risk. In 2023,we will enhance risk assessment and due diligence investigation for the remaining employees.

  • Suppliers

We conducted risk assessments and due diligence investigations on suppliers with transactions exceeding NT$1 million. The assessment results indicated that all 143 assessed suppliers were low-risk. The procurement department will conduct annual risk assessments and due diligence investigations for suppliers with whom transactions exceed NT$27 million.

  • Customers

In 2022,  Corruption risk assessments and due diligence were conducted for all 137 customers, including intermediaries such as distributors and agents, identifying 1 as medium risk and the remaining 136 as low risk. Business units will conduct annual risk assessments and due diligence for customers with transactions exceeding NT$40 million. Medium-risk counterparts will receive education and training, along with biennial progress assessments.

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