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Integrity Management

WNC adopts a "zero tolerance" principle towards corruption. The "WNC RBA Code of Conduct", "WNC Corporate Social Responsibility Practice Standards", "Corporate Governance Best-Practice Principles", "Code of Ethical Conduct", "Ethical Corporate Management Best-Practice Principles", and "WNC Reporting and Handling Procedure" clearly state WNC’s policy for upholding integrity. All WNC subsidiaries and affiliates are required to follow the same corporate compliance guidelines, including anti-corruption legislation from around the world such as the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act of 2010. All employees shall uphold high ethical standards. Employees should avoid any behavior creating unfair competition, refuse to accept bribes, fulfill tax obligations, and establish an appropriate management system to create a fair competitive environment. In the meantime, WNC also requires all employees and major suppliers to sign documents on our code of ethics. They shall not offer or accept any bribe or illegal profit in any other form. WNC established the Integrity Office in October 2018, charged by the Legal & IP Center to enhance integrity management operations ultimately determined by the Chairman. Starting 2019, the top manager of the Legal & IP Center will report to the Board of Directors on a regular basis.

Number of regulatory violations and major lawsuits is 0. Completion rate of courses requested in WNC ethics and anti-corruption code of conduct is 100%. Completion rate of self-evaluation questionnaire for compliance withthe code of ethical conduct is 100%. Zero cases of regulatory violations and major lawsuits (referring to lawsuitsexceeding NT$2,000,000 in amount or related to product trading) 2020 targets 2019achievements

Due Diligence

WNC requires all employees and major suppliers to sign documents on our code of ethics. They shall not offer or accept any bribe or illegal profit in any other form. We also required employees who directly deal with or exert substantial influence over customers, suppliers, and contractors to answer a self-evaluation questionnaire for compliance with the code of ethics every year.

Training and Promotion

To boost employees’ understanding and implementation of ethics and integrity issues, WNC ran the "WNC Ethics and Anti-Corruption Code of Conduct" online training course. This enables employees to understand how to make the right choices when company regulations conflict with social norms, enterprise interests, or personal interests, as well as what to do on discovering illegal activities.

Grievance Mechanisms

The public email for the "interaction on corporate social responsibility" and "reporting violations" are provided for all stakeholders to raise questions or provide suggestions with regard to WNC’s corporate social responsibility policies and practices and for employees and all pertinent parties to file complaints and report violations.

Email for interaction on corporate socialresponsibility p u b l ic @ w n c . c o m . t w This email is provided for all stakeholdersto raise issues or provide suggestionswith regard to WNC’s corporate socialresponsibility policies and practices. E-mail for reportingviolations w n c . i n t e g r i t y @ w n c . c o m . t w This email is provided for employees andall pertinent parties to file complaints andreport violations in a named oranonymous manner.

Reporting and Handling Procedure

WNC established the wnc.integrity@wnc.com.tw email channel for employees and all pertinent parties to file complaints and report violations in a named or anonymous manner. The Integrity Office and the Audit Office are tasked with establishing a task force to handle reports and perform investigations. The reporting procedures are described briefly as follows:

  • Personnel shall, in a named or anonymous manner, report the issue and provide relevant information;
  • The task force should act within seven days after receiving a report and shall complete a report of the investigation within one month. For serious cases, the report may be submitted within two months.
  • After completing the investigation, the task force shall propose measures to address the issue to the CEO of WNC for a final decision. The task force will notify the reporting party of the conclusions following the decision of the CEO.
  • WNC shall ensure that the identities of the reporting parties are kept secret and that they are not open to retaliation.
  • WNC will not terminate or transfer any employee or affect any other unfavorable result due to their reporting an issue unless that employee or supplier has violated the law.
  • Task force members and related members participating in the investigation shall ensure and maintain the confidentiality of the event throughout the entire investigation.
  • The task force shall record the method of resolution in written form, and it shall be sealed and placed in any relevant personnel file for five years.