CH. 3 Corporate Governance
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3.5.2
Ethics and Integrity
To upkeep fair trade and prevent bribery and corruption, CTCI
requires that employees should not give discounts when conducting
trading activities with stakeholders, and cannot ask for, make deals with,
give, or accept gifts, entertainment, kickbacks, or bribes for him/herself
or on behalf of others when carrying out his/her responsibilities.
The Company has set up investigation team for corruption and
bribery and reporting hotline to take in information from both internal
and external sources at any time. The unit responsible for handling the
reporting and consulting hotline ((02)2835-5936) or designated email
(
) is the Human Resources division, and these
measures encourage employees to report actions that are illegal or
go against the Employee Code of Conduct. The Company will ensure
confidentiality and protect the identity of the whistleblower so that the
person would not be subjected to threatening. If an employee is unsure
whether an action is illegal or not, he/she could report this opinion to the
hotline or the employee suggestion email immediately, and either the
HR Manager will directly respond or would ask relevant units to respond
to this inquiry.
CTCI also requires all employees from affiliate firms and overseas
subsidiaries to sign "Commitment to Confidentiality, Copyrights, and
Patents" to ensure the rights of stakeholders. And all subsidiaries,
affiliate companies, subcontractors and vendors that CTCI collaborates
with on projects have all signed confidentiality agreement pertaining to
the project executions.
At the same time, should a client ask CTCI to sign anti-corruption
memorandum, CTCI will doubtlessly do so. And the HR Division has also
printed fundamental code of ethics in Employee Handbook as well as
arranged for relevant courses during training for new recruits. A total
of 462 new recruits have accomplished training in 2015, there are still
15 new recruits on construction sites who have yet to complete their
training, and we will require them to undergo training in the future. As of
2015, over 2,500 individuals have received training.
Through stringent regulations and training, CTCI seeks for the
Company's sustainable operations and protects the rights of all firms
in the Group. As of 2015, there has not been any proven corruption
or bribery matters, and our honest image has received widespread
recognition and acknowledgement from our partners.
3.5.3
Fair Trade
CTCI Group maintains visions of legal compliance and honest operations, fully exercises professionalism and
integrity. To ensure fair trade, fair competition and to prevent unfair competition, monopoly, joint inappropriate
behavior, inappropriate market allocations and joint price manipulations, we always abide by a fair trade spirit
whether in project tenders or in external contracted service or procurement projects. We always undertake fair
and open tendering process when competing for business targets, in order to enhance the efficiency and quality
of project tendering and procurement processes. In addition, to spread the spirit of fair trade, CTCI encourages
all employees to report unjust actions and undertakes educational training for all employees. The total hours of
educational training in 2015 have reached 215,877 hours and a total of 10,983 headcount have received training.
Additionally, project, sales, and procurement personnel also undergo fair trade training, as well as reinforcement
training and case analysis from time to time. There has been no breach in this perspective in CTCI in year 2015.
CTCI's anti-trust policy requires the following:
CTCI Group Anti-Trust Policy
If breaches, likely, or possible breaches to this Policy or
relevant legal regulations have been found, one should
immediately report to the Supervisor of the Legal Office
along with evidence to allow for appropriate handling.
If an employee in the Group has found or has reason to
believe that the Group's contractor, supplier, or vendor
has violated or may have violated laws pertaining to anti-
trust and fair competition, he/she should immediately
report to the Supervisor in the Legal Office.
If the Group's suppliers or vendors have breached or
may have breached legal regulations pertaining to anti-
trust, the Group should comply with the government
institution and facilitate in its investigations.
If a person has potential to breach, likely breached,
or may have breached this Policy or relevant legal
regulations in the Company, the Supervisor of the Legal
Office should handle this report and take necessary
preventative measures to prevent breaches in the law.
If the Company has found any personnel who have
breached this Policy, the Company will conduct a
thorough and comprehensive investigation on all work-
related records related to that individual and halt all
of that person's contact with his/her work. If criminal
activity is involved, the Company will show no room for
leniency and will proceed according to the law.
Education and training: the Group offers internal anti-
trust educational courses and training and undertakes
annual fair trade training for all employees and in
addition to fair trade training from time to time,
the project, sales, and procurement personnel also
undertake reinforced training and case studies from
time to time. Anti-trust training material will be uploaded
to internal website for every employee to view. And
anti-trust teaching material will also be included in the
documents for new recruits training.
If the Group has actual conditions of breaching anti-trust
and fair competition, the Supervisor in the Legal Office
should first and foremost report to the highest-ranked
supervisor in the General Management Ofice. External
lawyer should be sought out for professional legal advice
if necessary.
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