Ethical Management

Code of Conduct training and promotion

In order to ensure that our employees fully understand the related regulations, Wistron implemented education, training, and promotion, including asking all foreign plants to conduct ethics training for all new employees. The new employees are asked to sign the “Code of Ethical Conduct”. The signing rate in 2021 reached 99.9%. In Taiwan, Wistron asks all new employees to undergo online ethics training and implements annual training for all employees, strengthening the culture of integrity. In addition, the Company also classifies capital, procurement, supply chain management, and administrative units as units with potential risks. Such units are subject to internal audits or job rotations at regular intervals, and the Company also invites professional entities to provide compliance awareness training to supervisors at Wistron.

Code of Conduct Signing and training

Reporting and Protection

Wistron encourages all internal and external employees to report any unethical behavior to the Company through the reporting channels. The Company has established an email address for reporting cases that violate the Code of Conduct (ethic@wistron.com). The administrative and human resources units act as the main handling unit and the matters are reported to the Board of Directors each year. The measures state that the whistleblower will not be unfairly punished for reporting the violation. With our strong and transparent corporate culture, Wistron has not discovered major violations of the integrity and ethics in 2021. No cases of unethical actions or corruption occurred between 2018 and 2021.

Anti-competitive behavior

Ethical management is the most fundamental social responsibility of companies. Wistron has established the Ethical Corporate Management Best Practice Principles which require the Company to conduct business activities in accordance with applicable competition laws and regulations. The Company may not fix prices, rig bids, restrict output or set quotas, or share or divide markets by allocating customers, suppliers, territories, or businesses. The Company understands that compliance with fair-trade practices is crucial in business activities. Wistron strictly complies with all related laws and regulations in every matter. From 2018 to 2021, the Company was never penalized by the competent authority for matters related to anti-trust/anti-competitive practices.

Political donations

The Company has always remained politically neutral. Wistron has always maintained an objective and discreet stance on public policies. We do not actively participate in political parties or political activities, and do not actively participate in lobbying. From 2018 to 2021, the Company did not make any political donations. Employees have the freedom to express their political beliefs, and are encouraged to fulfill their civic duty, and vote for their preferred candidate during elections.

Ethical management and anti-corruption management mechanisms

With regard to the operations of the Board of Directors, Directors may express their opinions and respond to inquiries for meeting agendas that conflict with interest between the Company and themselves or the legal entities they represent. Directors may not participate in discussions or exercise their voting rights, and they are required to recuse themselves from discussions and voting. They also may not exercise voting rights on behalf of other Directors. Wistron pays close attention to anti-corruption management. We have established an internal control system that includes the accounting system in accordance with related laws and regulations. We evaluate the effectiveness of the design and implementation of the system each year and perform self-inspections. The auditors are responsible for reviewing the results. The Company always evaluates the legality, ethical policies, and records of unethical conduct of distributors, suppliers, customers, or other transaction counterparties before establishing business relations with such entities.

When engaging in business activities, our employees are required to explain the Company's ethical management regulations to the transaction counterparty. They must also expressly refuse to provide, promise, request, or accept, directly or indirectly, any illegitimate interests in any form or name. Where the Company discovers unethical conduct, it shall immediately suspend transactions and blacklist the entity. At the same time, the Company also includes anti-corruption policies into the terms and conditions of business contracts: Clear and reasonable payment terms, handling of unethical matters, commission restriction for violations, rebates, or terms related to other rights and interests.

Supplier anti-corruption policy

Wistron communicates its Anti-Corruption Policy to all suppliers through the Wistron Supplier Relationship Management (WSRM). We reiterate the Ethical Corporate Management Policy and ideals in annual supplier conferences and the company profile provided to suppliers. The Company also reviews the implementation status of suppliers each year. According to the promotion measures and management mechanisms described above, there were no cases of corruption or unethical behavior among the suppliers in 2021.