Ethics and Integrity
Behavioral Specifications
Unimicron upholds the principle of compliance to operate the business, and has formulated the “Legal and Other Requirements Identification Procedure” and the “Guides to the US Antitrust Law.”, it also requires all divisions to conduct regular reviews, improvements and cooperate with the auditing operations to ensure full implementation of regulatory requirements. We regularly communicate with suppliers about our Anti-corruption Policy through Email and other channels and disclose Anti-corruption Statements on our website.
Unimicron operates in strict compliance with laws and regulations. Under strict management, Unimicron has not been fined a large amount (over NT$1 million) by the authorities for violating laws and regulations in 2022. There were no corruption or anti-competitive incidents in 2022. The violations of the Occupational Safety and Health Act in 2022 were mainly related to the installation of facilities. In response to the violations, the Company has removed the unsuitable facilities and strengthened the safety devices on site and the safety of the tools used in the workplace. In response to the violations of the Labor Standards Act, the main reason was the poor control of working hours, and the company has fully reiterated the working hour regulations to prevent the recurrence of the same violation.
The ESG Committee is the highest-level corporate sustainability organization in Unimicorn, coordinating the direction and objectives of corporate sustainability, and reporting to the board of directors on the relevant content and implementation results (such as ethical management, integrity ...) every year. (Report Date is Dec. 19, 2022.)
Unimicron have implemented the relevant actions of ethical corporate management operation, and the implementation in 2022 is as follows:
- A. Education training course and test Conduct e-learning training courses such as Professional code of ethics, code of integrity, propagation of the integrity management, and RBA, etc., and test after the course. For further information, please refer to the ESG Report.
- B. Regular check To audit the corruption-related matters annually, and do self-assess of the laws/ regulations to achieve effective control, and audit by the audit office unit to prevent the occurrence of integrity violations. No corruption and bribery happened in 2022.
- C. Whistleblower system and whistleblower protection In 2022, there were no violations of integrity occurred in the cases of internal and external prosecution.
Fine for Violation in 2021 & 2022
Code of Conduct
Unimicron creates "Integrity Regulations" and "Personnel Code of Conduct" for all employees, clearly sets rules for the employment of relatives and associated suppliers, and upholds integrity in dealing with customers. Unimicron will also ensure the implementation of the mechanism through the following measures every year, and the relevant practices cover Taiwan Facilities and Mainland China Facilities. All stakeholders can report various opinions to the Company through the grievance mechanism, and various communication channels link to Contact Us on Unimicron’s website.
New Recruit
The "Company Integrity Regulations" are taught during the training of new recruits, and the relevant terms are included in the employment contract.
Above of Engineer/Administrator
Every year, we conduct "Integrity Survey" and "Investment and Employment Status of Employees and Relatives in the Company, Associating Suppliers, or Competitors" for personnel above the engineer/administrator level of each unit. Respondents who accepted the survey of employment of relatives and integrity regulations in 2022 were personnel in engineering management positions in Taiwan, whereas personnel in Mainland China were different for each plant; the number of people surveyed was 5,461 from Taiwan Facilities and 12,228 from the overseas Facilities, without any violations.
Manager LevelNote
Supervisors above the manager level sign the "Employee Integrity Code Compliance Contract" every year, and the signing rate in 2022 reached 100%.
All Employees
Grievance and Whistleblowing Mechanism
If employees find any violation of ethical corporate management, they can file whistleblowing or grievance anonymously to Unimicron’s Audit Team or Human Resources Division through telephone, email or suggestion box in accordance with the "Code of Integrity" (the information on the grievance channel is posted on the Company's intranet site, and is also promoted at the same time during the new employee education and training), or raise the issue at labor-management meetings/employee discussion forums in each factory, and the handling unit shall set up a task force to investigate.
Grievance Channel
• Telephone, email, or employees’ suggestion box
• Human Resources Division’s supervisor grievance hotline
• Labor-management meeting/ each factory’s employee discussion forum
• Audit Office’s grievance (appeal) hotline
Clarification / Acceptance / Investigation
• Human Resources Division
• Audit Office
• Chairperson of the ESG Committee
• Handling team formed by relevant persons invited on a case-by-case basis
Reporting and Decision
• Employee Grievance Investigation Record and Closing Report
• Punishment for violations of the "Work Rules"
• Strengthen internal and external advocacy and education training
• Refer the grievant to professional counseling or medical institutions if counseling or medical treatment is necessary
Whistleblowing Handling Process
Whistleblowing Channel
• Whistleblowing hotline: +886－3－3500386 ext.13307
• Whistleblowing email address: whistleblower@unimicron.com (Emails to this email address will be automatically forwarded to the level 1 supervisor of Audit Division and the level 1 supervisor of Human Resources Division.)
Clarification / Acceptance / Investigation
Clarify whistleblowing/complaints and general whistleblowing/complaints of violations of professional ethics (involving fraud, anti-corruption, and antitrust). Whistleblowing/complaints of violations of professional ethics are accepted and verified by the Audit Office
Reporting and Decision
•Take punitive and follow-up measures according to the severity of the case, if necessary, report to the competent authorities or referred to the judicial authorities for investigation
•If the whistleblowing matter involves a director or senior executive, the handling unit shall report the matter to the independent director or supervisor of the Group
Protection Mechanism
The identity of the whistleblower/grievant is kept confidential. Appropriate protection measures are taken to protect the personal information and privacy of the whistleblower/ grievant in accordance with the law, and the whistleblower/ grievant is protected from improper disposal due to whistleblowing/grievance matters. In order to ensure that the whistleblower is reprimanded for his or her kindness in whistleblowing, the Company’s acceptance unit must take the initiative to concern the whistleblower/grievant by telephone or mail whether the whistleblower/grievant is reprimanded; once a complaint of retaliation is received and there is concrete evidence, it will be called to the police immediately. The total number of grievances received in 2022 was 8. No ethical management-related grievances were received, and no corruption and bribery cases occurred.
Complaint Cases in Recent Years（Unit: Cases）
2022 Complaint Cases
Note: Unimicron organizes regular professional ethics training courses. Regarding the professional ethics training courses for members of the relevant governance units, as the COVID-19 pandemic was still spreading in 2022, considering the pandemic, the Company advocated it to the members of the Board of Directors by e-mail.
Public Disclosure
In compliance with the regulations of the competent authorities, investors can access Company-related information through the Market Observation Post System. In addition to disclosing our general information, technology R&D, and ESG, the Unimicron website also has an investor relations section, providing relevant documents and regulations on our financial information and corporate governance.
We hold Institutional Investor Seminars semiannually to explain the consolidated financial results, operational status, and prospects of every quarter. We also provide relevant information and video recordings on Unimicron's website and the "Market Observation Post System" for investors. The Company also communicates with investors through various investor meetings, overseas visits, and investor relations points of contact. In 2022, we participated in 29 external and self-organized investor conferences, for more than 200 meetings, including interviews with investors. There were no material violations caused by competent authorities for environmental protection, OSH, and Labor/management relations/human rights in 2022 and after examination and confirmation, all deficiencies have been improved.
Training of Laws and Regulations
There are many integrity management regulations in Unimicron, and we hold relevant training courses every year. The Company also provides reminders of relevant regulations from time to time and creates a consultation channel so that the regulated objects can understand and comply with them.
Note 1: RBA, Personnel Code of Conduct, Code of Integrity and Prevention of Insider Trading have all been planned to be included in new employees’ training courses to implement the training mechanism and increase the training rate. Those who have not completed the training in 2022 will be included in the training list for the following year.
Note 2: The training starts from July to Sep. in 2022.
Note 3: The scope of the above table includes QunHong Technology Inc.
