Conflict of Interest
a. Definition
The Company is committed to preventing conflicts of interest among employees and between employees and the Company’s business partners, suppliers or customers.
A conflict of interest arises when an employee’s personal interests are incompatible, or may appear to be incompatible, with their professional responsibilities or the interests of the Company.
b. Disclosure Obligation
Employees are required to promptly disclose any actual, potential or perceived conflict of interest to their manager or through the “Speak Up” platform.
All disclosures are assessed confidentially, and appropriate measures are taken where necessary.
c. Remedial Action
The Company takes appropriate action to address and manage conflicts of interest.
To resolve a conflict of interest, the Company may modify the employee’s role or responsibilities, restrict certain authorities or implement other appropriate measures.
Anti-Bribery
a. Legal Compliance
The Company fully complies with all applicable legal requirements and strictly adheres to anti-bribery and anti-corruption laws.
Bribery is considered unacceptable conduct and is not tolerated under any circumstances.
b. Definition of Bribery
Bribery is defined as offering, giving, requesting, receiving or accepting money, goods, services or anything else of value for the purpose of obtaining or providing an improper advantage.
Bribery may occur either directly or indirectly.
Employees must not accept gifts valued at more than US$50 from suppliers, customers or business partners. Any such gift must be handed over to the Company.
c. Anti-Bribery Policy and Training
The Company maintains a clear policy stating that bribery in any form is unacceptable.
Employees receive anti-bribery and anti-corruption training to strengthen awareness and support compliance with the Company’s ethical standards.
d. Reporting and Investigation of Violations
Employees are provided with a secure mechanism for reporting suspected bribery or corruption. The “Speak Up” platform is used for such reports.
All reports are assessed and investigated confidentially.
Consequences
a. Consequences of Violations
Appropriate action is taken against employees who violate the Company’s conflict of interest or anti-bribery requirements.
Consequences may include disciplinary action, termination of employment or legal proceedings, depending on the nature and severity of the violation.
b. Protection of the Company’s Reputation
The Company places great importance on protecting its reputation and brand value by upholding integrity and ethical conduct.
Compliance with the Company’s ethical standards remains a key priority for all employees, including those working remotely.
