Code of business conduct and ethics
| Business Conduct & Ethics | Directors | Senior Management | Employees |
| Conflict of Interest | A director should not use his position to profit or gain some benefit or advantage for himself and/or his related interest. If an actual or potential conflict of interest may arise on the part of a director, he should fully and immediately disclose it and should not participate in the decision-making process. | An employee should disclose any relationship or association to the proposed supplier or contractor or its authorized representative to avoid possible conflict of interest. | An employee should disclose any relationship or association to the proposed supplier or contractor or its authorized representative to avoid possible conflict of interest. |
| Conduct of Business and Fair Dealings | A director should not use his position to profit or gain some benefit or advantage for himself and/or his related interest. If an actual or potential conflict of interest may arise on the part of a director, he should fully and immediately disclose it and should not participate in the decision-making process. | They are prohibited from using their authority or position to favor a supplier or contractor in anticipation of a personal gain or benefit. | They are prohibited from using their authority or position to favor a supplier or contractor in anticipation of a personal gain or benefit. |
| Receipt of gifts from third parties | Must not solicit or accept any gift, regardless of value, from any supplier, contractor or business partner, except gifts of minimal value. If it is not practical to return, such gift must be shared with other employees. | Must not solicit or accept any gift, regardless of value, from any supplier, contractor or business partner, except gifts of minimal value. If it is not practical to return, such gift must be shared with other employees. | Must not solicit or accept any gift, regardless of value, from any supplier, contractor or business partner, except gifts of minimal value. If it is not practical to return, such gift must be shared with other employees. |
| Compliance with Laws & Regulations | Ensure the Company’s faithful compliance with all applicable laws, regulations and best business practices. | Ensure the Company’s faithful compliance with all applicable laws, regulations and best business practices. | Ensure the Company’s faithful compliance with all applicable laws, regulations and best business practices. |
| Respect for Trade Secrets/Use of Non-public Information | Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position. Should not reveal confidential information to unauthorized persons without authority of the Board. | Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position. Should not reveal confidential information to unauthorized persons without authority of the Board. | Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position. Should not reveal confidential information to unauthorized persons without authority of the Board. |
| Use of Company Funds, Assets and Information | Observe discretion in use of funds and assets. Confidential information must not be disclosed without the proper authority. | Observe discretion in use of funds and assets. Be mindful of eliminating unnecessary consumption and wasteful practices. Confidential information must not be disclosed without the proper authority. | Observe discretion in use of funds and assets. Be mindful of eliminating unnecessary consumption and wasteful practices. Confidential information must not be disclosed without the proper authority. |
| Employment & Labor Laws & Policies | Ensure the Company’s faithful compliance with employment and labor law & policies. | The Company seeks to reasonably assist its and its subsidiaries and affiliates’ employee and his family in providing for their economic security. | The Company seeks to reasonably assist its and its subsidiaries and affiliates’ employee and his family in providing for their economic security. |
| Disciplinary action | The Company observes the provisions on disqualification and temporary disqualification of directors as provided in the Company’s Manual of Corporate Governance. | Rules and regulations shall be enforced fairly and consistently. Violations shall result in disciplinary actions depending on frequency, seriousness and circumstances of the offense. The employee shall be given the opportunity to present his side. | Rules and regulations shall be enforced fairly and consistently. Violations shall result in disciplinary actions depending on frequency, seriousness and circumstances of the offense. The employee shall be given the opportunity to present his side. |
| Whistle Blower | Reports of wrongdoing may be made directly to the Chairman for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower. | Reports of wrongdoing may be made directly to the Chairman or President for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower. | Reports of wrongdoing may be made directly to the Chairman or President for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower. |
| Conflict Resolution | Amicable settlement through alternative dispute resolution. | Amicable settlement through alternative dispute resolution. | Amicable settlement through alternative dispute resolution. |
The Company has a compliance officer who monitors compliance of ethics or conduct.
Directors submit annually a list of business and professional affiliating through which provide conflicts-of-interest may be determined. Relative to senior management and employees, the Human Resources Department of each subsidiary and affiliate implements and monitors compliance with the code of ethics or conduct.
Related Party Transactions
| Related Party Transactions | Policies and Procedures |
| (1) Parent Company | Ensure that the transactions are entered on terms comparable to those available from unrelated third parties |
| (2) Joint Ventures | |
| (3) Subsidiaries | |
| (4) Entities Under Common Control | |
| (5) Substantial Stockholders | |
| (6) Officers including spouse/children/siblings/parents | Ensure that the transactions are entered on terms comparable to those available from unrelated third parties. Disclosure of relationship or association is required to be made before entering into transaction. No participation in the approval of the transaction. |
| (7) Directors including spouse/children/siblings/parents | |
| (8) Interlocking director relationship of Board of Directors |
Alternative Dispute Resolution System
| Related Party Transactions | |
| Corporation & Stockholders | Pursue settlement outside court and compromise |
| Corporation & Third Parties | |
| Corporation & Regulatory Authorities |