Performance of Business Integrity in 2023

Completed

Propaganda for Anti-corruption and Business Integrity

No fraud

were found

Internal Control Audits

0
Whistleblower Case

There was one report received concerning a former salesperson from a subsidiary. After investigation, no credible evidence was found suggesting any dishonest or unethical behavior.

Prevention Measures for Insider Trading and Conflict of Interest

0
Total Hours
0%
Course completion rate
0
Attendees

A five-minute educational video was shown to current directors (On August 10, 2023) and managers and employees (at monthly meetings in August 2023), reaching 1,158 attendees and a total of 96.5 hours with a 100% completion rate. The Company also has other regulations and practices in place to prevent and manage conflicts of interest at the highest governance levels.

Anti-corruption and Business Integrity

0
Total Hours
0%
Course completion rate
0
Attendees

Training for all directors was completed on August 10, 2023. An educational video was shown to employees of the whole group (at 20 monthly meetings in August 2023), reaching 1,707 attendees for a total of 142.2 hours with a 100% completion rate.

The Company communicated its integrity and anti-corruption policies to 406 contractors and suppliers in 2023.

Communication completed 98%

They are committed to striving towards the goal of reaching 100% communication to ensure all external partners are aligned with their ethical standards.

Everlight has formulated a white paper on business philosophy and operating principles. It reveals our business philosophy of integrity and law-abiding, establishes a corporate image of upright management, and complies with domestic and foreign regulatory requirements and international corporate ethics standards.

Category Ethical Corporate Management Principles Corporate Governance Best-Practice Principles Sustainability Development (ESG) Best-Practice Principles
Highest Level of Approval Board of Directors Board of Directors Board of Directors
Applicable Activities and Scope Directors and All Employees Directors and All Employees Directors and All Employees
Communication Method (Publication Location/URL) Company Website,
Monthly Meetings,
Email Notification		 Company Website,
 Email Notification		 Company Website

Everlight has implemented an “Ethical Corporate Management Principles” and “Procedures for Ethical Management and Guidelines for Conduct.” With the business philosophy of integrity, transparency and responsibility, the Company developed a policy based on honesty and establish a good corporate governance and risk control mechanism to create an operating environment of sustainable development; the board of directors and the management level actively implement the commitment of ethical corporate management policies, and require all employees of the whole group to adhere to the prohibition against accepting or offering any improper benefits. This ensures that the actions of all employees are guided by clear rules.

Everlight has established regulations to ensure that the behavior of its directors and managers (including the CEO, equivalent senior executives, vice-presidents, assistant vice-presidents, heads of finance, heads of accounting, and others who manage corporate affairs and have signing authority) meets ethical standards. These standards are set to help stakeholders understand the Company’s ethical commitments better. The Company has codified these guidelines to be adhered to and discloses its ethical conduct guidelines on the corporate website, annual reports, prospectuses, and through the Market Observation Post System (MOPS). Any amendments to these guidelines are also disclosed in the same manner.

Everlight has legally established procedures that cover how its highest governance body avoids and manages conflicts of interest, ensuring transparent and ethical management across all levels of the organization.

Everlight has implemented the “Operating Procedures for Preventing Insider Trading” to protect the rights and interests of both investors and the Company. The Company carry out educational propaganda on related laws for current directors, managers and employees once a year. Newly appointed directors and managers are scheduled to receive the same training within three months of taking office, and new hires receive the training during orientation training.

[ No incidents of anti-corruption, anti-competitive, antitrust, and monopoly practices ocured in 2023.]

  • Everlight strictly adheres to anti-corruption and anti-bribery policies, with clear guidelines on Business Integrity and conducts relevant employee training and education on a regular basis.
  • In 2023, anti-corruption, anti-bribery, and anti-trust/anti-competitive training was conducted for employees and directors of the whole group.
  • 24 factories/divisions and 13 subsidiaries of the Company conducted assessments on corruption-related risks in their internal control system and no business activity involving corruption risk had been identified.

Internal audit work has been completed as planned

[ The key points of the internal audit in 2023]

To assist the board of directors and managers in implementing corporate governance and enhancing internal control and audit operations, the Company’s Audit Office reports directly to the board of directors. It is headed by a Chief Auditor, with two full-time auditors under his jurisdiction. The scope of work includes auditing the design and execution of internal controls and reviewing the self-assessment of internal controls. The operation of audit tasks is as follows:
  1. Risk Assessment of Internal Audit Plan: Identify potential risk factors using the “Risk Assessment Form for Internal Audit Plan” before the end of each year, assess the level of impact, consider the effectiveness of control measures, and determine the terminal level of risk. Formulate an annual audit plan based on the evaluation results, submit it to the Audit Committee and the board of directors for approval, and then declare it in accordance with the law.
  2. Planned and Project-Based Audit Work: Convene pre-audit meetings, perform audit tasks, write internal audit recommendations, hold closing meetings, and submit audit reports.
  3. Internal Audit Work: Monthly Reports and Quarterly Tracking Reports are reviewed by independent directors. The Chief Auditor attends meetings of Audit Committee and the board of directors and reports on the execution results of internal audit work.
  4. Internal Control Self-Assessment for 2023: The supervisors of each unit use an electronic platform to conduct internal control design and execution effectiveness assessments. These are reviewed by senior supervisors and diagnostic recommendations are issued. The Audit Office then reviews and compiles these into a “Self-Assessment of Internal Control and Review of Diagnostic Report,” which serves as the main basis for the board of directors and the general manager to evaluate the effectiveness of the internal control system and issue an “Proposal for Management’s Reports on Internal Control.”

▌The key points of the internal audit in 2023 are as follows:

  • Compliance with Laws and Regulations
    Key Points and Description: Monitoring and adherence to applicable laws across units

  • Procurement and Payment Cycle
    Key Points and Description: Inquiry, negotiation processes, and supplier management

  • Production Cycle
    Key Points and Description: Chemical and production safety management

  • Sales and Collection Cycle
    Key Points and Description: Quoting processes, receivables management, and bad debt recovery

  • Payroll Cycle
    Key Points and Description: Recruitment and retention, and salary payment operations

  • Computer Operations Management
    Key Points and Description: Implementation of SAP ERP, firewall policies, and access control

  • Supervision and Management of Subsidiaries
    Key Points and Description: Quoting processes and seal management

  • Whistleblower System/Complaint Mechanism

Everlight has issued a “Reporting System for Violation of Ethical Corporate Management Regulations” and the accepting unit is the Audit Office. It specifies the details of the reporting hotline and mailbox. The Audit Committee mailbox is also set up. Upon receiving a report, the accepting unit should register the case, check whether it is a reported incident, and within three working days from the date of acceptance, request instructions whether to file the case and initiate an investigation. The system strictly adheres to confidentiality principles of the identity of the whistleblower and the content of the report, allows anonymous reporting, and protects whistleblowers from retaliation.  A “Violations and Appeal System” is also in place to ensure that If there are any violations, once verified, penalties will be imposed in accordance with company regulations. In 2023, the whistleblower system was promoted in Traditional Chinese, Simplified Chinese, and English to ensure wide understanding among employees across regions.

Whistleblowing Channels
Hotline: +886-2-2326-3502
Audit Office Email: [email protected]
Audit Committee Email: [email protected]