Ethical management policy
The Ethical Management Unit, within the company’s corporate governance group and under the aegis of the corporate sustainability committee, is expressly responsible for implementing the company’s corporate governance tasks related to ethical management, anti-corruption, anti-bribery, and legal compliance. The unit also reports on the implementation status of such to the board of directors every year. In addition, the company’s Ethical Management Best Practice Principles are set by the ethical management unit, and any formulation, amendment, or annulment of these principles must be passed by the board of directors. The company’s board of directors has a duty as good caretakers to oversee the company and prevent unethical conduct, in order to guarantee the implementation of ethical management policy. In order to further strengthen the company’s ethical management, the auditing unit also includes compliance with the principles within its scope, and periodically reports to the board of directors regarding efforts made to remedy lapses.
Ethical management procedures and guidelines
The Company abides by the operational philosophy of honesty, transparency, and responsibility, bases policies on the principle of good faith, and establishes good corporate governance and risk control and management mechanisms so as to create an operational environment for sustainable development. The Company engages in commercial activities in a fair and transparent manner based on the principle of ethical management. The Company has established a risk assessment mechanism against unethical conduct, analyzes and assesses on a regular basis business activities within our scope of business that are at a higher risk of being involved in unethical conduct, establishes prevention programs accordingly, and reviews their adequacy and effectiveness on a regular basis. Prior to any commercial transactions, the Company takes into consideration the legality of agents, suppliers, clients, or other trading counterparties, and whether any of them are involved in unethical conduct, to avoid any dealings with persons involved in such. Faraday also makes a statement to trading counterparties about the Company's ethical management policy and related rules, and the company clearly refuses to provide, promise, request, or accept, directly or indirectly, any improper benefit in whatever form or name.
Prohibition against offering or accepting bribes
Prohibition against illegal political donations
Prohibition against improper charitable donations or sponsorship
Prohibition against unreasonable gifts, hospitality, or other improper benefits
Prohibition against infringing intellectual property rights
Prohibition against disclosure of confidential information
Prohibition against unfair competitive conduct
Prohibition against insider trading
Legal compliance
In response to the internationalization of organization and operations, Faraday continues to monitor and track changes in relevant national policies and laws. At the same time, it has a legal department that provides legal consultation and assistance to various departments through a systematic contract review process, and arranges legal affairs personnel participate in external training courses, in order to grasp the changes and new knowledge of regulations in real time, check whether the company's internal operating regulations are adequate or remind them to update, to ensure that the company's policies or regulations are compliant and appropriate.
To enable company staff to understand and truly abide by and implement various regulations and policies, Faraday regularly arranges relevant training courses for staff, including ethics and anti-corruption, fair trading, insider trading, information security management and confidential information protection, and the protection of intellectual property rights, the protection of personal data and privacy, the non-conflict minerals and quality management policies, etc. In addition to face-to-face courses, various internal activities such as seminars, newcomer training, executive meetings, etc. are also implemented on the company’s internal website. Provide relevant guidelines to establish the correct understanding through multiple channels, and the audit unit also includes various compliance conditions into the scope of inspection to implement compliance with laws and regulations.
Process of whistleblowing
- Any violation of Faraday “Ethical Management Best Practice Principles” and “Ethical Management Procedures and Guidelines” can be reported.
- All procedure strictly follow Protection on whistleblower principle (anonymous reporting/non-retaliation).
Whistleblowing channels
Protection on whistleblower principle (anonymous reporting/non-retaliation)
- Top Principle: Confidential, fair, and objective
- The whistleblower's name, organization, address, phone, and e-mail address must be kept in completely confidential.
- All inquiries and investigations must be done with the whistleblower' anonymity guaranteed
- If the whistleblower is employee of the company, the company will ensure that the employee is protected from inappropriate actions due to whistle blowing.
Performance of ethical management policies
The company works hard to implement the ethical management policies and bring them into effect. All employees sign the Code of Conduct & Workplace Ethics, and commit to abide by the company’s regulations. The company also periodically undertakes training and legal compliance education for all employees every year. The company continually follows up on and reviews the administrative measures, in order to enhance the effectiveness of the company’s ethical management. Relevant implementation results for 2023 are as follows:
Code of Conduct & Workplace Ethics
- Include “Code of Conduct & Workplace Ethics” into the employment contract and training material for new recruit
- Signing rate for “Code of Conduct & Workplace Ethics” of new recruit in 2023: 100%
Training
- New recruit training, and training and propaganda on related ethical management every year
- Training course hours of ethical management in 2023: 688.5 hours in total
Legal compliance declaration
- Declare and announce the concepts on ethical management in new recruit training and on job training
- Added real-time updates on internal websites to disclose and remind ethical issues from 2020
Periodic evaluations
- Business unit proceeds the regular self-check and self-evaluate legal compliance
- Audit unit proceeds the regular audit
- Unethical conduct and anti-competition behavior in 2023: 0
Whistleblower procedure and protection
- Establish a specific whistleblower procedure and handle by the dedicated unit
- All flows should strictly follow the whistleblower protection principle
- External whistleblowing in 2023: 0; direct reports by employee in 2023: 0
