Ethical Management
Policies and Organization
To foster a consistent value and culture among all Wistron employees, Wistron has established a "Code of Conduct" approved by the Board of Directors. This Code serves as the highest standard of conduct for all employees within Wistron, its subsidiaries, and its significant joint ventures, ensuring that all employees adhere to it in their business activities. Global Human Resources and Administration have primary authority and responsibility for enforcing this Code and establishing the necessary procedures to ensure its implementation.
To uphold integrity in business operations, Wistron has established a "Code of Ethical Conduct", "Ethical Corporate Management Best Practice Principles", and "Corporate Governance Best Practice Principles". These guidelines require all employees to clearly understand and adhere to this Code of Ethics, respect and strictly observe confidentiality agreements with clients, and refrain from accepting gifts or special entertainment. Furthermore, Wistron strives to connect with customers, suppliers, business partners, and other entities with whom it conducts business, ensuring that they understand and support Wistron's core value of integrity. The Global Human Resources and Administration departments report and review the implementation of Wistron's integrity management practices to the Board of Directors at the end of each year.
Corruption Risk Management and Due Diligence
To ensure the transparency and effectiveness of its corruption risk management mechanisms, Wistron regularly has its compliance management system audited and verified by an independent third-party organization to continuously strengthen its compliance culture.
With regard to internal management, the company has identified areas such as Treasury Management & Corporate Communications, Global Supply Chain Management, and Administration Services as potentially risky areas. In addition to undergoing internal audits and regular rotations, supervisory personnel in these areas are also required to participate in training courses offered by external professional organizations to strengthen their compliance awareness.
With regard to external relationships, before establishing business relationships with agents, suppliers, customers, or other business partners, the company will first assess the legality of their business practices, their integrity policies, and any history of dishonest behavior. During business transactions, Wistron will explain its integrity policy and related regulations to its partners in accordance with internal operating procedures. Compliance with Wistron's anti-corruption policies will also be incorporated into commercial contracts. This includes clarifying reasonable payment terms, handling instances of dishonest behavior, and handling violations of contractual clauses prohibiting commissions, kickbacks, or other benefits. We explicitly refuse to directly or indirectly offer, promise, request, or accept any improper benefits in any form or name. Upon discovery of dishonest behavior, transactions will be immediately terminated and the partner will be designated as a target for non-dealing. Between 2022 and 2025, after investigation, a total of 1 case involving corruption was found, and no cases resulted in penalties from the competent authorities.
Commitment and Support
To ensure that all employees fully understand relevant regulations, Wistron continues to implement education, training, and promotional initiatives. For board members, in addition to having completed and signed the Code of Conduct acknowledgment, Wistron has also arranged training courses on preventing insider trading to ensure corporate governance responsibilities for operating with integrity. All new employees are required to read and sign the Code of Conduct acknowledgment and complete online ethics training, with a 100% signing and completion rate by 2025. For current employees, all personnel across all sites are required to undergo annual Code of Conduct training (including anti-corruption and anti-bribery topics) to instill a culture of integrity, with a 100% completion rate for all employees by 2025.
Code of Conduct signing and training
| Item |
2022 |
2023 |
2024 |
2025 |
| Code of Conduct coverage (%) |
100% |
100% |
100% |
100% |
| Code of Conduct signing (%) |
100% |
100% |
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 |
100% |
100% |
100% |
100% |
Reporting and Disciplinary Measures
Internal and external stakeholders may raise any questions regarding the Code of Conduct with the Global Human Resources and Administration department. Subsidiaries and joint ventures over which the Company has significant influence have established consultation channels for stakeholder communication.
Wistron encourages all internal employees and external stakeholders to report any unethical conduct to the Company through its whistleblowing channels. The Company pledges to maintain confidentiality regarding the identity and content of reports and accepts anonymous reports to protect whistleblowers from receiving unfair treatment. The Company has a zero-tolerance policy for any violations of this Code of Conduct, including retaliation against whistleblowers. Any violation will be subject to disciplinary action in accordance with the relevant provisions of the Code of Conduct.
To ensure employees are familiar with reporting channels and related mechanisms, Wistron not only incorporates relevant content into new employee orientation and Code of Conduct training, but also promotes the reporting mechanism for Code of Conduct violations through public information walls and internal website announcements. This provides employees with information on reporting opportunities, reporting channels, handling procedures, and whistleblower rights. This encourages employees to proactively expose dishonest behavior and jointly implement the company's reporting system.
The company has established a dedicated email address for reporting complaints (ethic@wistron.com). Reports of Code of Conduct violations are primarily handled by Global Human Resources and Administration. Annual reports on the handling of these reports are submitted to the Board of Directors, the company's top management body. The Audit department oversees the investigation and handling of these reports.
Number of reported / filed cases of Code of Conduct
| Number of reported / filed cases of Code of Conduct |
2022 |
2023 |
2024 |
2025 |
| Number of Cases Reported |
Number of Cases Filed |
| Business Ethics and Operations |
Corruption and bribery |
0 |
0 |
0 |
3 (Note 1) |
1 |
| Conflicts of interest |
0 |
0 |
0 |
0 |
0 |
| Fair competition |
0 |
0 |
0 |
0 |
0 |
| Money laundering/Insider trading |
0 |
0 |
0 |
1 (Note 2) |
0 |
| Trade secrets |
0 |
1 |
1 |
0 |
0 |
| Privacy/personal data protection |
0 |
0 |
0 |
0 |
0 |
| Others (Political contributions, charitable contributions, and social participation) |
0 |
0 |
0 |
9 (Note 3) |
1 |
| Total number of cases related to business ethics and operations |
0 |
1 |
1 |
13 |
2 |
| Protection of Human Rights |
Anti-discrimination |
0 |
0 |
0 |
1 (Note 4) |
0 |
| Humane treatment and anti-forced labor |
3 |
1 |
0 |
6 (Note 5) |
0 |
| Occupational safety and health |
0 |
1 |
0 |
1 (Note 6) |
0 |
| Total number of cases related to protection of human rights |
3 |
2 |
0 |
8 |
0 |
| Environmental Protection |
Total number of cases related to environmental protection |
0 |
0 |
0 |
0 |
0 |
| Total |
3 |
3 |
1 |
21 |
2 |
- Note 1: One complaint case alleges that a supplier colluded with Wistron's procurement personnel to obtain illicit gains; however, no concrete evidence was found. Another complaint case alleges that a Wistron manager accepted bribes from equipment suppliers to provide bidding information; however, no concrete evidence was found. A third complaint case alleges that a manager at the Chongqing site falsified bonuses; this was found to be true, and the person involved received a major demerit and was transferred from current position.
- Note 2: One report alleged that an employee in the Taiwan office was involved in insider trading, but the investigation found that the report was not true.
- Note 3: One complaint case alleges that the procurement information of facility equipment was unclear. After being forwarded to the responsible window, the window has explained the relevant progress to the vendor. One complaint case alleges that payment was not received for anti-static clothing transactions with the Kunshan site between 2004 and 2005. An investigation revealed no relevant information within the Company, and the complainant could not provide further evidence; therefore, the case is temporarily closed. One complaint case alleges that the operating procedures at the Texas site did not comply with SOPs; however, the Company found no such situation. One complaint case alleges that an outsourced employee falsified interview details; however, no such employee is currently employed within the Company. One complaint case alleges that Wistron used unauthorized software; however, the Company's use of the software complies with authorization regulations. One complaint case alleges that a waste recycling company at the Hsinchu site may have infringed on Wistron's rights; however, due to incomplete key evidence, no violation could be proven, and the case is temporarily closed. One complaint case alleges potential irregularities in the handling of materials and relationships with outsourced suppliers at the Texas site was closed due to incomplete key evidence, making it impossible to prove any irregularities. One complaint case alleges an employee at the Chongqing site stoled company property and sold it for profit was verified; the employee was dismissed and the case was referred to the police for further investigation. One complaint case alleges an employee at the Malaysia site applied for unreasonable fees for factory facilities certificates was also found to be unsubstantiated.
- Note 4: One complaint case alleges the Mexican site for unreasonably refusing to hire external applicants. Upon investigation, the complainant was a former employee who was not eligible to reapply due to poor performance evaluation results that year.
- Note 5: One employee in the Taiwan office complained that before leaving, her supervisor assigned her tasks exceeding her usual workload and made it difficult for her to arrange vacations. After intervention and communication by the complainant's second-level supervisor, the complainant and her direct supervisor reached a consensus. One employee in the Taiwan office reported being unlawfully dismissed. Investigation revealed that the complainant had violated Wistron's Code of Conduct, work rules, and personnel management rules, and the circumstances were serious. Therefore, the Company dismissed the employee in accordance with the Labor Standards Act without question. One complaint case alleges that a male employee at Kaohsiung Opto-Electronics Inc. harassed a female employee. Investigation revealed that the male employee had no intention of harassment, and the female employee did not feel uncomfortable as a result. Therefore, the case was temporarily closed. One supplier complained that a supervisor in Wistron Taiwan office bullied her. After intervention and communication between the supervisor of the respondent and the supervisor of the complainant, both parties reached a consensus. One complaint case alleges inappropriate behavior by a security guard at the Hsinchu site. Investigation revealed that the security guard in question did not exhibit any abusive behavior. The Company subsequently implemented relevant training and disciplinary requirements in response to this complaint. One complaint case alleges improper management by the supervisor at the Hsinchu site. Upon investigation, it was determined to be a case of impersonation, and the employee whose name was used had no intention of filing a complaint.
- Note 6: One complaint case alleges employees at the Hsinchu site not complying with smoking area regulations. Following the complaint, the Company installed no-smoking signs, required security guards to conduct stricter patrols, and issued a company-wide announcement prohibiting smoking in non-smoking areas.
Important Issues of Ethical Management
Anti-Competitive Behavior
Operating with integrity is a fundamental corporate social responsibility. Wistron has established a "Ethical Corporate Management Best Practice Principles", requiring all employees to conduct their operations in compliance with relevant fair competition laws. These regulations prohibit price fixing, bid manipulation, production restrictions and quotas, or market sharing or division by allocating customers, suppliers, operating territories, or business types. Wistron strictly complies with relevant laws and regulations in all aspects of its operations and management. From 2022 to 2025, the company was not penalized by any competent authority for anti-competitive practices or monopolistic practices.
Political and Charitable Contributions
The Company adheres to the principle of political neutrality and does not actively participate in political parties or political activities, nor does it engage in any lobbying activities. Any political donation plans will strictly comply with relevant laws and regulations, ensuring that they do not seek any commercial advantage or transactional advantage, and avoiding using political or charitable donations as a means of corruption or bribery. While the Company did not make any political donations between 2022 and 2025, we respect our employees' freedom to express their political opinions and encourage them to fulfill their civic responsibilities.
Regarding charitable donations, the Company implements internal regulations that explicitly prohibit disguised bribery and profiteering, ensuring compliance with anti-corruption standards and relevant legal requirements.
Supplier Ethical Management
Wistron has established a Supplier Code of Conduct that clearly outlines the behavioral norms and standards for supply chain partners. In addition to fully disseminating Wistron's anti-corruption policies to suppliers through training courses on the Wistron Global Learning Platform, Wistron also continuously promotes its integrity management policies and beliefs at annual supplier conferences, as well as providing information on a dedicated email reporting channel. Through these promotional measures and management mechanisms, Wistron's suppliers remained free of corruption or other violations of integrity in 2025.
The company also has a dedicated reporting and complaint email channel for suppliers (GSCM_Office@wistron.com). Global Supply Chain Management is the primary recipient of reports of violations of the Supplier Code of Conduct. In 2025, there were zero reported cases, and zero cases of contract termination due to dishonest behavior.
In addition to actively implementing the philosophy and core values of integrity in internal management and external business relationships, Wistron has also introduced an external third-party audit mechanism since fiscal 2023 to help identify blind spots in internal controls and improve operational processes, thereby further reducing operational risks and enhancing the transparency, credibility, and reputation of its operations (Statement of Compliance).
2025 Ethical management implementation status
Complete and transparent corporate integrity governance procedures
- 2025 CommonWealth Magazine CSR Awards - Large Enterprise - Manufacturing - 1st Place.
- Top 5% of Listed Companies in Corporate Governance Evaluation (7th Consecutive Year).
Implementation of corporate compliance and integrity
- The global integrated complaint platform, ethic@wistron.com, received 21 cases filed throughout the year, with 2 cases resulting in conviction.
- The implementation of the ISO 37001 anti-bribery management system was initiated.
Corporate transparency and integrity policies and declarations
- Two policies were revised and one new policy was promulgated in 2025.
- Core values were incorporated into the performance appraisal system: Integrity 4.69/5 points, Core values 4.64/5 points.
- Core values were integrated into the employee engagement survey: Integrity 90.5%, Core values 89.4%.
- Note 1: Data cut-off date 2025/12/31
- Note 2: Information above has been reported in the board meeting on 2025/12/19
