Ethical Management
In order to implement ethical management, Wistron has formulated the "Code of Ethical Conduct”, " Ethical Corporate Management Best Practice Principles” and "Corporate Governance Best Practice Principles". Apart from requiring all employees to clearly understand and comply with the ethical requirements, employees must respect the confidentiality agreements with customers, and shall not accept gifts or special treatment. We hope to invite all customers, suppliers, business partners, and other cooperating organizations to share and support our core values of integrity. In 2021, Wistron formulated the “Code of Conduct”, which is approved by the board of directors, to establish shared values and a share culture among all employees. The code acts as the highest behavioral regulations for the Company, subsidiaries, and joint ventures where the Company has major influence. All employees are expected to comply with the code when conducting business activities. The implementation status of the annual ethical management is reported to the Board of Directors at the end of each year.
Code of Conduct Training and Promotion (Including anti-corruption training)
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 statement of “Code of Conduct”. The signing rate in 2023 reached 100%. In Taiwan, Wistron asks all new indirect employees to undergo on-line ethics training and implements annual training for all employees, strengthening the culture of integrity. In addition, the Company also classifies Treasury Management & Corporate Communications, Global Supply Chain Management, and Administration Services 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
| Item |
2020 |
2021 |
2022 |
2023 |
| Code of Conduct coverage (%) |
100% |
100% |
100% |
100% |
| Code of Conduct signing (%) |
99.7% |
99.9% |
100% |
100% |
| Coverage of orientation training for new employees (%) |
100% |
100% |
100% |
100% |
| Coverage of periodic training for all employees (%) |
100% |
100% |
100% |
100% |
| Training completion rate |
99.7% |
99.9% |
100% |
100% |
Wistleblowing and Protection
Wistron encourages all internal employees and external stakeholders to report any unethical behavior of commerce to the Company through the reporting channels while anonymous reports are also accepted. The Company has established an email address (ethic@wistron.com) for reporting cases that violate the Code of Conduct. The Global Human Resources and Administration unit acts as the main handling unit and the matters are reported to the Board of Directors each year. The measures state that the whistleblower shall not be unfairly punished for reporting the violation. With our strong and transparent corporate culture, Wistron did not discover material (penalties exceeding NT$1 million) violations of the integrity and ethics of commerce in 2023. No cases of unethical actions or corruption occurred between 2020 and 2023.
Number of reported / filed cases of Code of Conduct
| Number of reported / filed cases of Code of Conduct |
2020 |
2021 |
2022 |
2023 |
| Number of Cases Reported |
Number of Cases Filed |
| Business Ethics and Operations |
Corruption and bribery |
0 |
0 |
0 |
1 (Note 1) |
0 |
| Conflicts of interest |
0 |
0 |
0 |
0 |
0 |
| Fair competition |
0 |
0 |
0 |
1 (Note 2) |
0 |
| Insider trading |
0 |
0 |
0 |
0 |
0 |
| Trade secrets |
0 |
0 |
0 |
2 (Note 3) |
1 |
| Privacy/personal data protection |
0 |
0 |
0 |
0 |
0 |
| Others (Political contributions, charitable contributions, and social participation) |
0 |
0 |
0 |
0 |
0 |
| Total number of cases related to business ethics and operations |
0 |
0 |
0 |
4 |
1 |
| Protection of Human Rights |
Discrimination |
0 |
0 |
0 |
1 (Note 4) |
0 |
| Harassment |
0 |
0 |
3 |
4 (Note 5) |
1 |
| Occupational safety and health |
0 |
0 |
0 |
1 (Note 6) |
1 |
| Total number of cases related to protection of human rights |
0 |
0 |
3 |
6 |
2 |
| Environmental Protection |
Total number of cases related to environmental protection |
0 |
0 |
0 |
0 |
0 |
| Total |
0 |
0 |
3 |
10 |
3 |
- Note 1: Corruption and bribery: There were reports of waste disposal personnel at the Hsinchu site soliciting bribes, but after investigation, no concrete evidence was found
- Note 2: Fair competition: There were reports that the sale of equipment from the India site violated fair competition principles, but it was determined to comply with the Company's relevant operational procedures
- Note 3: Trade secrets: i. Reports of unauthorized software usage at the Kunshan site were investigated and found to be within the Company's legal usage scope. ii. A Hsinchu site employee was reported for circulating photos of the production line on social media. Subsequent investigation confirmed the allegation, and the employee received a disciplinary warning
- Note 4: Discrimination: Allegations of discrimination during the recruitment process at the India site were investigated. It was discovered that the whistleblower had failed a technical test and breached recruitment procedures, contradicting the reported claims
- Note 5: Harassment: i. An employee at the Malaysia site reported being yelled at during a meeting by colleagues, which was verified upon investigation. Senior management intervened, providing counseling and resolving the matter and obtained the understanding of the reporter. ii. An incident where someone impersonated a Taiwan office employee to make a report was investigated. The whistleblower denied involvement, and no intention to report the incident was found. iii. Reports of harassment by employees at the Mexico site were investigated and found to that the person being reported was not an employee of the Mexico site.be unsubstantiated. iv. A bullying report at the Hsinchu site was investigated, but no concrete evidence was found
- Note 6 Occupational Safety and Health: Reports of unsafe driving by the shuttle bus driver at the Hsinchu site were confirmed. The contractor was instructed to promptly address the issue and provide driver safety training as per the contract
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 2020 to 2023, the Company was never penalized by the competent authority for matters related to anti-competitive behavior and monopolistic measures.
Political Contributions
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 2020 to 2023, 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
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. When the Company discovers unethical conduct, it shall immediately suspend transactions and blacklist the entity. Meanwhile, the Company also includes anti-corruption policies into the terms and conditions of business contracts, such as: clear and reasonable payment terms, handling of unethical matters and violations with restriction of commission and rebates, or terms related to other rights and interests.
In addition to actively implementing the spirit and core values of ethical management in internal management and the development of external business relationships, Wistron has also begun to introduce third-party audit mechanism once a year from the year of 2023 to help detect blind spots in the internal control system and improve operating procedures, moreover, to further reduce operational risks while enhancing the transparency, credibility and reputation of corporate operations. The 2023 ethical management verification statement is expected to be obtained and publicly disclosed on the website in mid-July 2024.
2023 Actions for Ethical Corporation Management
Commitment of Suppliers
- Kept promoting adherence to integrity and Wistron Suppliers Code of Conduct through global supplier education and training platform
- Completion rate of Supplier Commitment: 1,302 / 1,302 (100%)
Training
- Simon’s Talk training: 865 new indirect employees (100%)
- Code of Conduct training: 100% of employees
Commitment
- Statement of Compliance with Code of Conduct for 100% of employees
- Statement of Compliance with ethical corporation management for board of directors and senior management
Advocacy
- Core values promotion activities: held in 21 sites around the world, with a total of 14,859 employees participating.
- Whistleblowing system: ethic@wistron.com Cases of breach of integrity after investigation: 1 (Trade secrets case)
- Note 1: Data cut-off date 2023/12/31
- Note 2: Information above has been reported in the board meeting on 2023/12/21
Supplier Anti-Corruption Policy
Wistron communicates its Anti-Corruption Policy to all suppliers through the global supplier education and training platform. We reiterate the Ethical Corporate Management Policy and ideals in annual supplier conferences and the company profile provided to our suppliers. The Company also reviews the implementation status of our suppliers each year. Suppliers can also report through our Company’s reporting and complaint email address. According to the promotion measures and management mechanisms described above, there were no cases of corruption or unethical behavior among the suppliers in 2023.
