Ethical management

Policy

• TCC attaches great importance to business ethics and has established regulations such as Ethical Corporate Management Best Practice Principles, Anti-corruption and Anti-bribery Policy, Reporting Mechanism for Violation of Code of Conduct, and Code of Ethical Conduct.
• Zero tolerance for bribery and corruption
• Directors, managers, employees, appointed persons, and substantive controllers shall not use non-public information to engage in insider trading or money laundering activities.

Management Approach

• Established an "Anti-corruption and Anti-bribery Promotion Team" led by the President, reporting to the Audit Committee and Board of Directors at least annually.
• Incorporate integrity management indicators such as corruption, bribery, and legal compliance into employee performance evaluations.
• Conduct corruption and bribery risk assessments of employees and business partners annually.
• Established the Related Party Transaction Procedure Management Directions to strengthen the supervision of related party transactions.
• Under its "Business Partner Corruption Risk Assessment and Due Diligence Procedures.”, TCC conducts due diligence on suppliers, contractors, and customers, and stipulates countermeasures for partners that decline to cooperate.
• To comply with emerging legal compliance issues, such as anti-money laundering, anti-corruption, environmental safety and health, etc., these are included in standard contracts, becoming regulations for business partners' commercial cooperation with TCC.
• Integrity management related policies are permanently posted on the company's official website and internal employee platform, allowing access to full information at any time, continuously strengthening belief.

Performance

ISO 37001 Anti-Bribery Management System Certification

TCC is the first company in Taiwan to obtain the ISO 37001 Anti-Bribery Management System certification

TCC Taiwan and its European subsidiary CIMPOR and OYAK CEMENT have both achieved ISO 37001 Anti-bribery Management System certification

ISO 37301 Compliance Management System Certification

CIMPOR and OYAK CEMENT further obtaining ISO 37301 Compliance Management System certification

2024 Corruption Incidents

0case

Employee Signature Rate for the Statement of Integrity and Ethical Conduct

99.9%

Signature Rate for the Integrity Code by Medium and High-risk Personnel at Operational Headquarters

100%

Education and Training

• TCC regularly promotes integrity and ethics education training through physical/ online courses (TCC Lyceum) or educational document reading. The number of trainees reached 9,729, with a total of 11,937 hours
• In 2024, integrity management training was provided to directors, business partners, employees, new recruits, and interns, extending to global operational sites (except CIMPOR Cameroon plant, where implementation is expected in 2025)
• Education and training have been gradually extended to suppliers and contractors, with a total of 305 suppliers trained across sites in Taiwan and Mainland China in 2024, totaling 1,220 hours.
• Headquarters sta prioritize participation in ISO 37001 anti-corruption management system online policy promotion and training, covering corruption detection, public sector interaction management, and hospitality and gift guidelines
• Subsidiaries CIMPOR and OYAK CEMENT implement integrity and ethics education aligned with ESRS indicators
  adopted by CSRD, covering 100% of employees in high-risk functions, including sales and marketing, procurement, human resources, finance, and audit compliance-related units.

New employees (including part-time and student workers)

New recruits are required to sign the Statement of Integrity and Ethical Conduct on their first day and receive one-on-one training on anti-corruption and anti-bribery policies within ninety days of employment, with training records duly maintained.

Current employees (including senior managers, part-time and student workers)

All employees participate in anti-corruption and anti-bribery education and training at least once a year, with records maintained to ensure they understand the relevant operational regulations and the potential consequences and risks of non-compliance. For employees involved in customer and supplier interaction or departmental operational process corruption assessments, additional specialized training on related themes is provided.

Directors

At least once a year, communicate anti-corruption and anti-bribery education and training materials are sending to directors via email or print, with a requirement for them to sign the Commitment to Compliance with Integrity Management, Anti-Corruption, and Anti-Bribery.

Suppliers

Communicate the spirit of integrity management to suppliers through emails, supplier conventions, and other channels, and require all suppliers to sign the Supplier Code of Conduct, which includes provisions related to integrity management.

Contractors & Customers

• Integrity management awareness is promoted to all contractors, including outsourced personnel such as security guards.
• Conduct credit evaluations for cement customers that include integrity management clauses.

Prohibition of Unfair Competition Practices

Upholding fair business competition is a core commitment of TCC’s integrity management. TCC strictly prohibits employees from engaging in activities that violate the Fair Trade Act, such as forming monopolies or colluding to divide markets, which would undermine the principles of free market competition.

• Dedicated Unit：The Compliance & Legal Office supervises the compliance of company members with competition laws and their handling procedures.

• Handling Procedures：

  

  Reports to Regulatory Authorities Should Be Made Promptly

  If a TCC member investigated by regulatory authorities for competition law compliance, they shall immediately report the matter to the following personnel: their unit's direct and highest supervisors, as well as the Compliance & Legal Office.

  

  Compliance & Legal Office Handling and Risk Response

  The Compliance & Legal Office should understand the specific circumstances and applicable competition law provisions. If there is a potential risk of violation, the Compliance & Legal Office should report to management, seek assistance from external lawyers, and promptly implement responsive measures.

  

  Supply Chain Competition Law Violation Reporting Mechanism

  If TCC's suppliers, distributors, or business partners violate or are suspected of violating competition law provisions, all relevant units should report to the Compliance & Legal Office and require the vendor to cease the illegal activities and cooperate with government authorities' investigations.

• Regulatory Framework：Employees should comply with the Code of Ethical Business Conduct and the Code of Fair Trade and Anti-trust Compliance to maintain a fair competitive market and reduce the legal risks and negative impacts that violations of the law may bring to TCC's business.
• Education and Training：Senior managers, managers, and business-related employees must regularly receive fair trade education and training.
• Stay Alert：During daily business operations, avoid discussing sensitive information with competitors, such as prices, quantities, production capacity, trading partners, or market share allocation. Politely decline invitations to social events that may involve the discussion of such information, and stay alert if industry peers attempt to initiate such discussions.

Whistleblower System

1. TCC promotes reporting of misconduct and has established a Reporting Mechanism for Violation of Code of Conduct, which clearly outlines the handling procedures and reporting channels. The mechanism explicitly lists applicable scopes including: corruption, theft, embezzlement, private gain, fraud, improper provision or receipt of benefits from others and other corrupt bribery behaviors, violations of TCC's established systems, regulations, and policies, as well as violations of laws and regulatory orders.
2. Reports can be anonymous but must include complete information and evidence to deter malicious claims. Whistleblower identities and report details are kept confidential, and retaliation is strictly prohibited. If it involves senior managers, reports can be made to the Audit Committee.
3. CIMPOR has established a third-party whistleblowing mechanism, managed by an independent external unit through the online whistleblowing platform Ethi.co. The platform operates year-round, regardless of time, location, or time zone, supports multiple languages, and allows anonymous reporting. Employees and suppliers can submit reports via telephone, email, or the online platform (cimporglobal.speakup.report), and the audit department regularly monitors these channels and reports to the management level.

TCC's official website and internal employee suggestion box

Table of Whistleblowing and Grievance Cases