Committed to ethical standards and a transparent and responsible corporate culture

Integrity is WT’s most important core value and business philosophy. The Group’s executives and employees must abide by clear moral standards and code of conduct, and do their utmost to fulfill WT’s commitments to shareholders, banks, customers, employees, vendors and other suppliers. It is also the core requirement for WT to gain competitive advantage and act correctly.

In 2020, WT formulated the Social Policies and Code of Conduct, United Nations Anti-Corruption Policies, and United Nations Sustainable Development Goals Policies. In 2023, it released Anti-corruption, Anti-bribery and Anti-money laundering Policies, and revised the Ethical Corporate Management Best Practice Principles in line with global corporate governance and anticorruption
concepts and frameworks. The social policies and codes of conduct apply to the Board members, the Group’s employees, independent contractors, suppliers, and all those who do business with WT.

The Ethical Corporate Management Best Practice Principles, Procedures for Ethical Management and Guidelines for Conduct, Codes of Ethical Conduct, and Supplier Code of Conduct that the Board has adopted are available in either the Corporate Governance section or Sustainability Report section of the Company’s official website and the Intranet in Traditional Chinese, Simplified Chinese and English. Information on Ethical Values and Professional Code of Conduct and Insider Trading Prevention Education and Advocacy are made available on the Intranet for all employees’ reference. In addition, relevant personnel are also appointed to participate in lectures and symposiums held by industrial associations or professional groups, so as to strengthen the Group’s ethical operation policies.

 

LINK:

Major Policies

UNCAC Anti-corruption Policy

WT SDGs Policy

Social Policy and Code of Conduct

 

Regular refresher training on Code of Conduct to raise integrity awareness among all employees

An annual refresher training is given to all employees of the Group to ensure they are aware of applicable rules and regulations. In 2023, a total of 2,566note in-service employees were required to receive refresher training and 224 new hires to receive on-board training on Ethical Values and Code of Conduct. All of them have completed the course and passed the test (100% pass rate), with an accumulated attendance of ethical management training reaching 1,486.5 hours.

 

Note: After the merger with Excelpoint in 2022, the management systems are set to be integrated in phases, and the ethical management training is scheduled to be integrated in 2024.

 

WT conducts annual ethical management training for its employees, including full-time staff, contract workers, and subcontractor personnel. In 2023, the training covered 2,790 full-time staff members (accounting for 99.47%) and 15 subcontractor personnel (accounting for 0.53%). As of December 31, 2023, there were no contract workers in the company, resulting in no training participation from this category.

Implementing Ethical Business Practices and Strengthening Risk Management

To enhance the management of ethical business practices, “Ethical Management Team” has been established, comprising representatives from Human Resources, Legal, and Audit departments. The Chief Human Resources Officer (CHRO) serves as the highest authority within the team. Each business unit is responsible for the formulation, execution, and oversight of ethical business policies, management measures, and reporting procedures in accordance with their respective roles, ensuring the effective implementation of the Code of Ethical Conduct.

 

Ethical Business Practices and Anti-Corruption Management

Integrity is one of the core values of WT. We have established robust mechanisms for ethical business practices and anti-corruption management, which are implemented through the following actions:

Implementation Measures:

1.The Ethical Management Team conducts annual training sessions for all employees, including new hires, to promote awareness of ethical business practices and anti-corruption policies and regulations.

2.Operational units regularly monitor and review anomalies, such as conducting periodic supplier account verifications and visits, monitoring illicit transactions, investigating shell companies, detecting unusual payments, and identifying abnormal changes in logistics and delivery locations.

3.High-risk operations are prioritized as key audit items in the annual audit plan.

4.The CHRO reports the execution results to the Board of Directors on an annual basis.

 

WT has established stringent control mechanisms for business activities and operational procedures that are potentially prone to unethical behavior. In addition to regular monitoring and review of processes with higher corruption risks to prevent improper benefits, bribery, or other unethical conduct, internal auditors prioritize high-risk operations in the annual audit plan based on risk assessments. This approach aims to reduce the likelihood of unethical and corrupt practices. Furthermore, all departments and subsidiaries conduct annual self-assessments of their internal control systems to ensure the effectiveness of their design and implementation.

 

The Ethical Management Team reports the results of the previous year’s ethical management implementation to the Board every year. At the Board meeting on January 31, 2024, training on Ethical Values and Code of Conduct, status of professional ethical violation reports, and prevention of insider trading were reported to assist the Board in evaluating whether the ethical management prevention measures established by the Company are operating effectively.

No involvement in political-related initiatives and no political donations

WT has not made any direct or indirect donations to political activities, political parties/associations/NGOs, politically related organizations, individual politicians, or other voting/referendum initiatives in the past five years. The amount of political donations has been NT$0. In addition, WT has not lobbied on specific issues or conducted related activities with interest representative groups.

Compliance with laws and regulations

WT strictly abides by all applicable laws and regulations at each operating location. As of the end of 2023, the Taiwan headquarters was fined NT$50,000 in accordance with Article 24 of the Labor Standards Act after a labor inspection discovered failure to timely complete the handling of an overtime application. Subsequently, the management was reminded to fulfill their management obligations and care for employees at all levels. The working hours management
and overtime tracking mechanisms were strengthened, attention is paid to employees’ labor rights and physical and mental health protection. No violation of laws or regulations were found in economic aspect (investment, securities, taxation, etc.), environmental aspect (air pollution, wastewater, waste, etc.), or social aspect (human rights, disabilities, injuries, etc.) in any operating sites, and thus no resulting penalties from the competent authorities.

 

Whistle-blower ID and the investigation process are kept highly confidential

WT has a whistle-blowing system specified by the provisions of Article 23 of the Ethical Corporate Management Best Practice Principles and Article 21 of the Procedures for Ethical Management and Guidelines for Conduct. Anyone who suspects or discovers a violation should take the initiative to report it to Independent Directors, supervisors, internal audit supervisor or other appropriate person.

WT’s whistleblower channels include an internal whistleblower mailbox and a whistleblower section on the official website for whistleblowers to report illegal conduct of company personnel. The Auditing Office is responsible for accepting external reports, forwarding them to the heads of relevant units for investigation, and following them up until the cases are closed. The identity of the whistleblower, the content of the report, and the investigation process are all kept confidential. A complete record of the case acceptance, investigation process, and results is kept for five years. In addition, an independent hotline, dedicated mailbox, and special handling procedures have been set up for sexual harassment complaints in order to protect the privacy of the complainant. A serious breach of integrity is subject to removal or dismissal in accordance with relevant laws or management regulations, depending on the circumstances of the case.

 

Reporting Channels

Mail to “14F.,No.738, Zhongzheng Rd.,Zhonghe Dist., New Taipei City 235603 , Taiwan (R.O.C.)”

WT Website:”Report Ethical Violation in the Workplace

Receiving Unit

Auditing Office

The global corporate governance philosophy of transparency and anti-corruption has been followed

Integrity is WT’s most important core value and business philosophy‭. ‬Employees must abide by clear moral standards and code of conduct‭, ‬and do their utmost to fulfill our commitments to shareholders‭, ‬banks‭, ‬customers‭, ‬employees‭, ‬vendors and other suppliers‭, ‬and ensure that the rights and interests of all stakeholders are in balance‭.‬

 

In 2020‭, ‬WT formulated the Social Policy and Code of Conduct‭, ‬United Nations Anti-Corruption Policy‭, ‬and United Nations Sustainable Development Goals Policy in line with global corporate governance and anti-corruption concepts and frameworks‭, ‬including Responsible Business Alliance Code of Conduct‭, ‬the UN Global Compact‭, ‬the International Labor Standards‭, ‬the OECD Guidelines for Multinational Corporations‭, ‬etc‭.‬

 

WT has always believed that Social Policies and Code of Conduct are core requirements for conducting all operational activities‭ ‬in order to gain a competitive advantage and to do the right thing‭. ‬The high ethical standards of all members of the leadership‭ ‬team not only inspire employees‭’ ‬confidence in the Company’s operations‭, ‬but also create a supportive working environment for employees‭. ‬The Social Policies and Code of Conduct are also principles for Members of the Board‭, ‬all employees‭, ‬group subsidiaries‭, ‬independent contractors‭, ‬suppliers and all those who deal with WT‭.‬

 

In the past five years‭, ‬WT has not directly or indirectly donated to political activities‭, ‬political parties/associations/NGOs or politics-related organizations‭, ‬individual politicians or other voting/referendum initiatives‭, ‬and the amount of political donations was NT$0‭. ‬Likewise‭, ‬it did not lobby for specific issues or engage in interest group activities‭.‬

 

In order to improve the ethical corporate management, the HR, Legal and Auditing Office jointly formed an Ethical Management Team, the chief human resources officer serve as the leader of the team, decentralizing the formulation and supervision of ethical corporate management policies and preventive measures based on the work responsibility and scope of each unit, to ensure the implementation of the Ethical Corporate Management Best Practice Principles.

 

In order to implementation of ethical corporate management, WT establish mechanisms for assessing the risk of unethical conduct, periodically analyze and assess operating activities within the scope of business with relatively high risk of unethical conduct, establish comprehensive and effective control mechanisms in accounting and internal control systems to prevent potential business activities and operational procedures that may involve higher levels of dishonest behavior. The internal audit team also prioritizes high-risk operations for annual audit plans based on risk assessments to strengthen preventive measures, and reports on the actual implementation of audit plans to regular board meetings. In addition, through annual self-assessment of internal control operations, all departments and subsidiaries of the company are required to self-examine their internal control systems to ensure the effectiveness of their design and implementation.

 

The Ethical Management Team reports the implementation of ethical corporate management in the previous year to the Board of Directors every year. The Ethical Management Team reported to the Board of Directors on January 6, 2023, including Ethical Values and Business Practice Principles training、risk assessment results and whistleblowing for any violation of the code of conduct, etc., to assist the Board of Directors in assessing whether the ethical corporate management measures established by the Company is operating effectively.

WT has formulated the Ethical Corporate Management Best Practice Principles‭, ‬Procedures for Ethical Management and Guidelines for Conduct‭, ‬Codes of Ethical Conduct‭, ‬and Supplier Code of Conduct‭, ‬which the Board of Directors has passed by resolution‭. ‬They are publicized in the Corporate Governance section of the Company’s official website and the Intranet in Traditional Chinese‭, ‬Simplified Chinese and English‭. ‬Information on Ethical Values and Professional Code of Conduct and Insider Trading Prevention Education and Advocacy are made available on the Intranet for all employees‭’ ‬reference‭. ‬In addition‭, ‬relevant personnel are also appointed to participate in lectures and symposiums held by industrial associations or professional groups‭, ‬so as to strengthen the‭ ‬Group’s ethical operation policies‭.‬

 

In order for all employees to fully understand and abide by the applicable regulations and standards‭, ‬relevant on-board training‭ ‬is given to new hires‭, ‬and refresher training is conducted routinely for all in-service employees of the entire Group every year‭. ‬At the start of the 2022‭ ‬refresher training on Ethical Values and Code of Conduct‭, ‬2,532‭ ‬employees across the Group were in-service and thus required to take the course‭. ‬All of them have completed the course and passed the test‭ (‬100%‭ ‬pass rate‭). ‬In 2022‭, ‬a total of 1,956‭ ‬hours of ethical operation training‭, ‬including those given in on-board training for new hires‭, ‬were given to‭ ‬an accumulated attendance of 3,309‭ ‬persons‭, ‬with 100%‭ ‬completion rate‭.‬

 

In terms of contracting company employees, contractors are required to conduct regular training on integrity behavior every year regarding the company’s confidential information, personal data, and avoidance of improper advantage. If the employees become aware of (or suspects) any violation of ethical values and code of conduct, it should be reported to the contractor supervisor and forwarded to WT. WT takes good measures to keep the whistleblower confidential so that he or she will not be maliciously retaliated or harmed for reporting. After reviewing relevant training records, 100% of employees of contracting companies in Taiwan have completed ethical training in 2022.

 

WT’s whistleblower channels include an internal whistleblower mailbox and a whistleblower section on the official website for whistleblowers to report illegal conduct of company personnel‭. ‬The Ethical Operation Management Team is responsible for accepting reports‭, ‬opening cases‭, ‬forwarding them to the heads of relevant units for investigation‭, ‬and following them up until the cases are‭ ‬closed‭. ‬The identity of the whistleblower‭, ‬the content of the report‭, ‬and the investigation process are all kept confidential‭. ‬A‭ ‬complete record of the case acceptance‭, ‬investigation process‭, ‬and results is kept for five years‭.‬

 

In 2022‭, ‬five reports were accepted and handled‭. ‬No serious corruptive activities were found‭. ‬Nevertheless‭, ‬the investigation of‭ ‬one of the cases determined that the employee had indeed violated professional ethics‭, ‬and the employee was therefore dismissed‭ ‬in accordance with the Group’s internal punishment regulations‭.‬

 

An independent hotline and dedicated mailbox have been set up for sexual harassment complaints‭. ‬In order to protect the rights and interests of the complainant‭, ‬a complaint is accepted and handled in a confidential manner‭. ‬The name of the complainant or other relevant information sufficient to identify the complainant will not be disclosed‭. ‬The handling process and information of a‭ ‬complaint case are documented in writing‭, ‬and kept in a sealed archive for five years‭. ‬In 2022‭, ‬no sexual harassment complaints‭ ‬were received‭.‬

 

WT seeks to promote honest and ethical conduct‭, ‬deter illegal conduct‭, ‬and abide by all applicable laws and regulations of the places where it operates‭. ‬As of the end of 2022‭, ‬there were neither violations of laws and regulations in economic aspects‭ (‬such‭ ‬as investment‭, ‬securities‭, ‬taxation‭, ‬etc‭.), ‬environmental aspects‭ (‬pollution-related violations‭, ‬such as air pollution‭, ‬waste water‭, ‬waste‭, ‬etc‭.), ‬or social aspects‭ (‬such as labor regulations‭, ‬human rights‭, ‬disabling injuries‭, ‬etc‭.), ‬nor resulting punishments imposed by the competent authorities‭. ‬The numbers of violations and the amount of penalty were both NTD 0‭.‬

WT has zero tolerance for corruption and has a whistleblower mechanism in place

WT offers transparent and accessible whistleblower channels‭. ‬The channels have been made known through on-board training‭, ‬in-service refresher training‭, ‬answers to suppliers‭’ ‬or customers‭’ ‬questionnaires‭, ‬etc‭. ‬WT encourages all employees to blow the whistle without hesitation when they found a violation of the Company’s ethics policy‭. ‬The whistleblower channels are open to all‭, ‬including suppliers‭, ‬customers and other third parties‭.‬

  • Take the initiative to communicate with employees
  • Put in place an independent whistleblower hotline
  • Set up a whistleblower section on WT’s official website
  • Localize the whistleblower channels in local languages
  • Anonymous tips and reports will be kept confidential
  • Disclose the number of reports received‭, ‬types of misconduct and actions taken‭.‬
  • Conduct integrity and ethics training to ensure employees fully understand company policies‭, ‬procedures and control measures‭.‬

Transparency, anti-corruption Convergence with the global corporate governance business philosophy

In 2020, WT developed the Social Policy & Code of Conduct, UNCAC Anti-corruption Policy, and the SDGs Policy. These standards align with global corporate governance and anti-corruption concepts and frameworks, including Responsible Business Alliance Code of Conduct, the UN Global Compact, the International Labour Standards, the OECD Guidelines for Multinational Corporations, etc.

 

WT has always believed that a social policy and code of conduct are core requirements for conducting all operational activities in order to gain a competitive advantage and to do the right thing. The high ethical standards of all members of the leadership team not only inspire trust in the Company’s operations, but also create a strong and supportive working environment for employees. the social policy and code of conduct are also principles for members of the Board, all employees, group subsidiaries, independent contractors, consultants, suppliers and all those who deal with WT.

 

WT expects employees to be fully aware of company policies, procedures and controls to protect the company and themselves from potential legal, regulatory or disciplinary risks. An annual mandatory course on Ethical Values and Code of Conduct is taught to employees. 2,309 employees of the entire group were listed as trainees at the start of the course in 2021, and 2,309 of them have completed the course and passed the test (100% pass rate). In addition, important management rules and regulations, such as the Corporate Governance Best Practice Principles, the Corporate Social Responsibility Best Practice Principles, the Ethical Corporate Management Best Practice Principles, the Codes of Ethical Conduct, Procedures for Ethical Management and Guidelines for Conduct and the Supplier Code of Conduct, were introduced during orientation training. In 2021, the total number of trainees at each of the Taiwan operations sites reached 206, all of whom have completed training, with a total of 412 hours of training.

 

WT’s reporting channels include an internal reporting mailbox and a reporting sector on the official website for informants to report illegal acts of the company’s personnel. The Ethical Business Promotion Team accepts cases and is responsible for forwarding them to the highest supervisors of relevant units for investigation and tracking the final outcome of the cases. The identity of the informant, the contents of the report and the investigation process will be kept confidential, and complete records will be kept. In addition, there is a sexual harassment complaint mechanism and a reporting hotline for employees to file complaints, and the contents of the reports and the investigation process are treated with strict confidentiality. No cases were received from external parties or directly reported by employees in 2021, and no significant dishonest acts or sexual harassment occurred.

 

WT seeks to promote honest and ethical conduct, to deter wrongdoing, and to comply with the laws and regulations applicable to all locations in which it operates. As of the end of 2021, there were no significant violations in the economic, environmental and social fields (including human rights, disability injuries, etc.) that were sanctioned by the competent authorities.

Zero Tolerance for Corruption! WT’s communication mechanism for whistle blowers

WT responds to whistleblowing incidents, providing a transparent and accessible channel for communication. All employees are encouraged to speak up without fear when they discover a violation of the Company’s ethics policy. It is available to suppliers, customers and other third parties.