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Corporate Integrity

TAIWAN CEMENT CORPORATION (hereinafter referred to as "TCC" or the “Company”) adheres to high standards of integrity under all business interactions, adopts a zero-tolerance attitude towards corruption and bribery, and hereby establishes an " Anti-Corruption and Anti-Bribery Policy" to set forth unequivocal anti-corruption and anti-bribery guidelines, so as to provide guidance to relevant stakeholders and to help them avoid bribery and corruption.

TCC also officially introduced and began implementing ISO 37001, the Anti-Corruption and Anti-Bribery management system (hereinafter referred to as "ISO 37001”), in TCC Headquarters in April 2021, to set ethical corporate management standards into actions.


Anti-Corruption and Anti-Bribery Policy

TCC set three main anti-corruption and anti-bribery policy objectives as the guiding principles for the Company's ethical management, as below:

  1. Explain the prohibited business activities in order to prevent bribery and corruption;
  2. Prevent any form of bribery or corruption in order to comply with the requirements under the relevant laws of anti-corruption;
  3. Implement and develop TCC's ethical management culture through this policy.

The anti-corruption and anti-bribery statements for all activities undertaken by TCC are as follow:

  1. TCC will not engage in or accept any activities that fail to comply with this policy or anti-corruption laws.
  2. When conducting business, TCC and its directors, CEO, managers, employees, mandataries, and substantial controllers, may not directly or indirectly offer, promise to offer, request, or accept any improper benefits in whatever form to or from clients, agents, contractors, suppliers, public servants, or other stakeholders to establish business relations or affect business trading activities, and this also includes but is not limited to briberies to or from political parties or organizations engaged in political activities, or through direct and indirect personal donations, or through charity organizations or sponsorship.

Anti-Corruption and Anti-Bribery Risk Governance and Management Structure

The anti-corruption and anti-bribery governance and management structure of the of TCC Headquarters is composed of three lines of defense, governance, compliance and management. The Audit Committee of TCC is responsible for supervising the implementation of such management system. The task-based "Anti-Corruption and Anti-Bribery Operation Team" is responsible for the operation of such management system of each department, the planning and consulting matters, and the evaluation of the design and implementation. The general manager is the highest level of the management team and is fully responsible for the operation and compliance of this system, ensuring that the responsibilities and powers of each relevant role are assigned, and communicates thoroughly with all levels of the organization. The manager of each department is responsible for the daily operations of their department and shall manage and supervise all related risks of corruption and bribery under the system. The execution of above matters be reported to the Board of Directors at least once a year.

Five Key Points for Implementation
Establishment of Company Policies and Regulations

    TCC introduced ISO 37001, Ethical Corporate Management Best Practice Principles, Anti-Corruption and Anti-Bribery Policy, Procedures for Anti-Corruption and Anti-bribery Management, Anti-Corruption and Anti-bribery System Management Manual and other related regulations, and require employees, business partners, directors, CEO and managers to abide by the principle of ethical management and follow the relevant policies and regulations when performing their duties.
    Training of Ethical Corporate Management

      TCC’s "Procedure of Anti-Corruption and Anti-Bribery Training Program" regularly promotes and provides training courses to enhance the knowledge regarding the Company’s anti-corruption and anti-bribery policies to directors, CEO, managers and employees, in order to ensure a comprehensive understanding of related regulations and the possible risks and outcomes of any violations.
      In addition to the trainings above, TCC shall also promote the Company’s Anti-Corruption and Anti-Bribery Policy and related reporting mechanisms via email or the Suppliers’ Convention to our business partners.
      Commitment
      • The Company’s directors and employees are required to sign relevant integrity declarations or commitments. Depending on the ranking, authority and responsibilities of different senior managers, such declarations or commitments need to be renewed and updated regularly to secure the compliance with the Company's anti-corruption and anti-bribery regulations.
      • Business partners are required to sign the Supplier Corporate Social Responsibility Code of Conduct and Anti-Corruption Statement as a way to show their commitments to abide by all the integrity standards and regulations of TCC Group.
      • The Company's anti-corruption and anti-bribery commitments and determination are announced publicly at external events such as the suppliers’ or investors’ conferences.
      Risk Assessment of Corruption and Bribery

        In order to identify corruption and bribery risks that may occur, the Company has set up the Corruption and Bribery Risk Assessment Policy, which evaluates the corresponding corruption and bribery risks from three major aspects of operation process, business partners, and employee duties, and responds based on the risk assessment results by due diligence or related management and control mechanisms to effectively manage and reduce related corruption and bribery risks.
        Mechanism for Reporting Grievances

          TCC encourages internal and external personnel to report corruption, bribery, dishonesty or misconduct, and promises that if anyone in good faith reports any incident of personnel of TCC or its interested parties having violated TCC’s policies or relevant laws and regulations, the complainant shall be protected from any improper retaliation or treatment due to the complaint or report, and the relevant content of the complaint or report shall be kept confidential.
          TCC establishes and provides information for the independent report mailbox and hotline on the Company’s website for the use of internal and external personnel of the Company.
          • Via e-mail: mp.buster@taiwancement.com
          • Via phone: 02-2531-7099#20636
          • Via post: No. 113, Sec. 2, Zhongshan N. Rd., Zhongshan Dist., Taipei City 104, Taiwan; Attn: Audit Office, Taiwan Cement Corporation
          • In person: The Audit Office
          If internal and external personnel report corruption, bribery, dishonesty or misconduct involving senior managers of TCC, the reporter may choose to report to the Audit Committee of TCC’s Board of Directors in addition to the aforementioned reporting channels.
          Operation Status of Anti-Corruption and Anti-Bribery Management System
          The introduction and adaptation of ISO 37001 launched in April 2021. The main operations since the introduction of this management system are as follow:
          • On April 1, 2021, the relevant operating specifications of the ISO 37001 were officially introduced, and the trial operation had been carried out from April 1 to June 30. Meanwhile, teaching materials of the training courses for ISO 37001 (including governance structure, risk identification and control process inventory, customer/supplier due diligence, and anti-corruption goal setting and performance evaluation) have a reading rate of 100%.
          • On May 7, 2021, the meeting of the Anti-Corruption and Anti-Bribery Operation Team was held. On May 12, 2021, the resolution of related management matters and control mechanisms, along with the operation status were reported to TCC’s Audit Committee and the board of directors.
          • In June 2021, the first internal audit of the anti-corruption and anti-bribery management system was carried out.
          • On May 25, and July 15 to July 16,2021, online learning and video courses on ISO 37001 policies were conducted for employees in TCC Headquarters (including corruption detection indicators, the management of public relations, the procedure and standards of receiving hospitality/gifts, and the findings and improvement methods of internal auditing). In addition, 100% of the new employees in TCC Headquarters signed the Code of Integrity and Ethics Statement.
          • On July 16, 2021, the Anti-Corruption and Anti-Bribery Operation Team meeting was held to discuss the results of the internal audit under ISO 37001, and reported such results and improvement proposal to the general manager for approval.
          • From July 8 to July 9 and July 19 to July 21, 2021, the first stage and second stage of the third-party audit were carried out by an external certification body. TCC completed all the certification work and was successfully awarded the Certificate of ISO 37001 (certificate effective date: August 6, 2021 to August 5, 2024).

          Establishment of Company Policies and Regulations

          Formulating Policies and Regulations

            TCC introduced ISO 37001, Ethical Corporate Management Best Practice Principles, Anti-Corruption and Anti-Bribery Policy, Procedures for Anti-Corruption and Anti-bribery Management, Anti-Corruption and Anti-bribery System Management Manual and other related regulations, and require employees, business partners, directors, CEO and managers to abide by the principle of ethical management and follow the relevant policies and regulations when performing their duties.
            Training of Ethical Corporate Management

              TCC’s "Procedure of Anti-Corruption and Anti-Bribery Training Program" regularly promotes and provides training courses to enhance the knowledge regarding the Company’s anti-corruption and anti-bribery policies to directors, CEO, managers and employees, in order to ensure a comprehensive understanding of related regulations and the possible risks and outcomes of any violations.
              In addition to the trainings above, TCC shall also promote the Company’s Anti-Corruption and Anti-Bribery Policy and related reporting mechanisms via email or the Suppliers’ Convention to our business partners.
              Commitment
              • The Company’s directors and employees are required to sign relevant integrity declarations or commitments. Depending on the ranking, authority and responsibilities of different senior managers, such declarations or commitments need to be renewed and updated regularly to secure the compliance with the Company's anti-corruption and anti-bribery regulations.
              • Business partners are required to sign the Supplier Corporate Social Responsibility Code of Conduct and Anti-Corruption Statement as a way to show their commitments to abide by all the integrity standards and regulations of TCC Group.
              • The Company's anti-corruption and anti-bribery commitments and determination are announced publicly at external events such as the suppliers’ or investors’ conferences.
              Risk Assessment of Corruption and Bribery

                In order to identify corruption and bribery risks that may occur, the Company has set up the Corruption and Bribery Risk Assessment Policy, which evaluates the corresponding corruption and bribery risks from three major aspects of operation process, business partners, and employee duties, and responds based on the risk assessment results by due diligence or related management and control mechanisms to effectively manage and reduce related corruption and bribery risks.
                Mechanism for Reporting Grievances

                  TCC encourages internal and external personnel to report corruption, bribery, dishonesty or misconduct, and promises that if anyone in good faith reports any incident of personnel of TCC or its interested parties having violated TCC’s policies or relevant laws and regulations, the complainant shall be protected from any improper retaliation or treatment due to the complaint or report, and the relevant content of the complaint or report shall be kept confidential.
                  TCC establishes and provides information for the independent report mailbox and hotline on the Company’s website for the use of internal and external personnel of the Company.
                  • Via e-mail: mp.buster@taiwancement.com
                  • Via phone: 02-2531-7099#20636
                  • Via post: No. 113, Sec. 2, Zhongshan N. Rd., Zhongshan Dist., Taipei City 104, Taiwan; Attn: Audit Office, Taiwan Cement Corporation
                  • In person: The Audit Office

                  If internal and external personnel report corruption, bribery, dishonesty or misconduct involving senior managers of TCC, the reporter may choose to report to the Audit Committee of TCC’s Board of Directors in addition to the aforementioned reporting channels.

                  Operation Status of Anti-Corruption and Anti-Bribery Management System

                  The introduction and adaptation of ISO 37001 launched in April 2021. The main operations since the introduction of this management system are as follow:
                  • On April 1, 2021, the relevant operating specifications of the ISO 37001 were officially introduced, and the trial operation had been carried out from April 1 to June 30. Meanwhile, teaching materials of the training courses for ISO 37001 (including governance structure, risk identification and control process inventory, customer/supplier due diligence, and anti-corruption goal setting and performance evaluation) have a reading rate of 100%.
                  • On May 7, 2021, the meeting of the Anti-Corruption and Anti-Bribery Operation Team was held. On May 12, 2021, the resolution of related management matters and control mechanisms, along with the operation status were reported to TCC’s Audit Committee and the board of directors.
                  • In June 2021, the first internal audit of the anti-corruption and anti-bribery management system was carried out.
                  • On May 25, and July 15 to July 16,2021, online learning and video courses on ISO 37001 policies were conducted for employees in TCC Headquarters (including corruption detection indicators, the management of public relations, the procedure and standards of receiving hospitality/gifts, and the findings and improvement methods of internal auditing). In addition, 100% of the new employees in TCC Headquarters signed the Code of Integrity and Ethics Statement.
                  • On July 16, 2021, the Anti-Corruption and Anti-Bribery Operation Team meeting was held to discuss the results of the internal audit under ISO 37001, and reported such results and improvement proposal to the general manager for approval.
                  • From July 8 to July 9 and July 19 to July 21, 2021, the first stage and second stage of the third-party audit were carried out by an external certification body. TCC completed all the certification work and was successfully awarded the Certificate of ISO 37001 (certificate effective date: August 6, 2021 to August 5, 2024).