Compliance, Ethics and Anti-Corruption

LITE-ON pledges to uphold honesty and integrity in business management, and to obey the laws and ethical standards of the countries in which it carries out its business activities. LITE-ON also commits itself to making complete compliance one of its key policies. LITE-ON has implemented a well-designed management system, and deploys regulation identification and education and training as means to strengthen compliance on an ongoing basis.

The Legal Department at LITE-ON has built an extensive compliance system and devised compliance policies. The department monitors regularly changes in domestic and foreign regulations that may have a potentially material impact on the company's business operations. In the presence of any such change, the appropriate local legal department will proceed to perform regulation identification in order to ensure all business activities around the world comply with the local and international laws and regulations. Meanwhile, LITE-ON's management structure provides a robust risk management framework and an effective implementation roadmap for identifying and managing the risks that require the attention of business managers. In addition, LITE-ON's internal controls prevent potential fraud and inappropriate behaviors in order to minimize related risks. Internal interdepartmental reviews and external inspections are in place to ensure compliance of implementation and performance. Task forces will be created for large investment projects in order to apply certain processes to manage and prevent the risk of fraud and prevent illegal activities. To strengthen compliance and corporate governance practices, the board of directors passed or amended operating procedures including the corporate governance best practice principles, the code of conduct, the ethical corporate management best practice principles, and compliance procedures in 2017.

LITE-ON requires that its employees, supervisors, managers, and directors not engage in or use any reason to instruct another to engage in any illegal or unethical behavior. The rules of integrity must be strictly adhered to and establish explicitly the employee code of conduct in areas including professional ethics, laws and regulations, employee relations, gifts and hospitality, client privacy, intellectual property rights, discrimination, bribery, conflict of interest, protection of corporate assets and reputation and other rules to be observed by employees. Compliance is implemented throughout the business activities, product design, procurement procedures and other processes and discipline is strictly enforced. We state explicitly in the ethical corporate management best practice principles prohibition of offering or taking of bribes; offering of illegal political donations, inappropriate sponsorship or charity donations, and improper gifts, treatments, or other unjustified benefits; infringement of intellectual property rights; and unfair competition as well as prevention measures and procedures that prevent products or services from causing damages to stakeholders. The rules are intended to protect the rights of customers and prevent loss of assets, penalties, and damage of reputation.

LITE-ON requires new employees sign a statement of commitment to ethical conduct when they join the company so to help its employees understand the importance of ethical conduct and the need for it. Furthermore, LITE-ON requires employees complete anti-corruption training. To raise awareness of integrity and self-discipline, LITE-ON advocates compliance education and training on an ongoing basis, and, in addition to various seminars from time to time, organizes courses that help participants learn about the law and key compliance issues, including LITE-ON work ethics, anti-corruption, insider information, and anti-trust issues. The Responsible Business Alliance (RBA and formerly EICC) offers the following in-person courses: business integrity, avoidance of illegitimate gains, protection of confidential information, protection of intellectual property, intellectual property rights, advertising and competition, contract risk management, fair trade, anonymity and confidentiality, anti-corruption, conflict free minerals (metal procurement), environmental protection, privacy, and prohibition against retaliation. The courses are provided to raise awareness of ethical standards in the workplace.

Reporting mechanisms


LITE-ON is equipped with internal and external reporting mechanisms that bypass the management and offer internal and external contacts. The board of directors approved the decision to appoint the Office of Chairman as the contact responsible for handling corruption reports by following the appropriate procedures. In addition, task forces will be created for large investment projects in order to apply certain processes to manage and prevent the risk of fraud and prevent illegal activities.
Regular internal audits are performed to strengthen internal control and prevent fraud.

Internal reporting mechanisms are available so that discovery of unethical behaviors or suspected violation of the code of conduct can be reported internally by calling the hotline at 1234 or by sending email to 1234@liteon.com. LITE-ON will keep informants' identities and their reports confidential, and take action to investigate and handle the cases. Employees who are confirmed to have violated the ethical corporate management best practice principles will be subject to disciplinary action as appropriate.

Corruption reports and complaints that are received by the contact will be assigned to the appropriate units to be investigated according to the report and complaint processing procedures. If a complaint is confirmed to be valid, a committee consisting of department representatives and experts will be created to review and rule on the complaint.

Grievances in 2017


In 2017, LITE-ON received a total of eight grievances through external channels, with one submitted by telephone, one by mail, and six by email. The Office of Chairman report investigation task force received the reports and promptly launched an investigation each time. So far, five of the cases were closed, and three are still under investigation.
Case studies in lawsuits involving employee corruption
Internal controls:
1. Compliance training is given more weight in orientation and on-the-job training. Regular bulletins are published to raise awareness of the rules and help employees understand the importance of internal controls to the company.
2. Closed cases involving more severe violations are described below:
2.1 Case 1: A section chief under a certain business unit was suspected of accepting hospitality from a supplier and padding travel expenses. The case was investigated and the result reported to the head of said business unit. The section chief was dismissed given the severity of the case.
2.2 Case 2: A manager under a certain business unit attempted to solicit a bribe from an existing supplier. The fact was confirmed to be true, and the manager was dismissed.
3. A summary of the above cases was presented regularly to the Audit Committee. In addition, assistance was given to respective business units in taking appropriate disciplinary actions, and said disciplinary actions were announced accordingly.

In 2016-2017, the amount of political or social donations:

圖片

LITE-ON actively participates in the activities of industry associations and organizations, and joining regular or irregular industry association conferences as the intensive communication mechanism with other members in the industry. 圖片

Corporate Governance ▸

Top