Highest Guiding Principle

Code of Conduct

Scope

Management System

1. Conflict of interest stipulated in the Rules of Procedure for Board of Directors – Donations from stakeholders or major donations to non-stakeholders: Rules of Procedure for Board of Directors stipulates that such conduct shall be reported to the Board.
2. The whistle-blowing and disciplinary method of violating ethical conduct and ethical management.
3. Provisions of anti-money laundering measures under Control System on Preventing Economic Sanction from Financing of Terrorism.
4. Remuneration system.
5. Internal control system and provisions governing its implementation, including management policy, authorization system and segregation of duties.
6. Risk assessment mechanism, which applies to dealings with governmental entities.
7. Anti-bribery clauses included in procurement contracts to strictly forbid the acceptance of kickbacks, handling charges or financial gains in any form.

Classification of Report Acceptance Level 

According to the identity of the accused, investigation reports are classified and submitted based on the following principles:
 

1. For personnel at the level of Assistant Manager and above, the report should be submitted to the business unit head. In cases of significant severity, it should be submitted to the General Manager.
2. For personnel at the level of Assistant Vice President and above, the report should be submitted to the General Manager and notified to the Chairman.

Protection Measures of Whistleblower 

1. The identity of the whistleblower, the contents of the report, and the personnel involved in the investigation shall be kept confidential by the company.
2. The whistleblower shall be protected to prevent any adverse actions such as dismissal, removal from position, demotion, salary reduction, or any other disadvantageous treatment due to the act of whistleblowing. If there are suspicions or indications of improper treatment, these should be investigated. If improper treatment is confirmed, appropriate disciplinary actions shall be taken against the responsible parties based on the severity of the situation and in accordance with relevant regulations.

Audit System

1. Integrity and anti-corruption practice are listed under mandatory audit in the internal audit system.
2. Self Evaluation on Corporate Corruption is conducted quarterly based on the scope of anti-corruption policy. The result is presented to the Board for review to ensure the implementation of the anti-corruption policy.
3. FENC shall conduct investigation in the presence of the likelihood that suppliers and subcontractors, including agents and trade companies, violate integrity practice. Once verified, said company will be removed from FENC’s list of eligible suppliers.

Training and Promotion

1. A minimum of one anti-corruption training for Board members and all employees to promote the scope of FENC anti-corruption policy and possible effects at the individual and corporate levels.
2. Require corporate ethics in new employee training.
3. Conduct anti-corruption training tailored to procurement units that involve direct interests in procurement projects.
4. Prior to being included in FENC’s list of eligible suppliers or engaging in business transactions with FENC, suppliers and subcontractors, including agents and trade companies, must undergo anti-corruption training or education.
5. Internal publication, meetings, signage at the plants.