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Zhen Ding Tech. Group

Business Ethics

Promoting Integrity Management Working Group

The group established the "Ethical Corporate Management Work Group" under the Board of Directors. This group is jointly formed by the Chairman’s Office, the Human Resources Division, Legal Affairs Division, and Corporate Governance and Investor Relations Division. The Chairman’s Office is responsible for the implementation of ethical corporate management policies and preventive solutions. The execution unit and related task force are tasked with supervising the operation of business ethics and are required to report to the Board of Directors at least once a year on the status of implementation for the current year.

Promoting the annual plan of the Integrity Management Working Group

According to “Ethical Corporate Management Best Practice Principles” and “Integrity Management Operating Procedures and Behavior Guidelines”, the annual targets were set at the beginning of the year and the results were reviewed at the end of the year. The following are the goals in 2026 and outcomes in 2025, respectively.

Goals in 2026:
(1) The goals of internal and external education on business integrity are achieving 185,000 training hours and 102,000 participants.
(2) All of our employees have completed business integrity, anti-corruption, confidentiality and ethical education and training, and all of them have passed the examinations.
(3) Major suppliers accept the group's Sunshine Policy promotion and sign a letter of commitment.
(4) The group has no major violations.

Outcomes in 2025 (Reported to the Board of Directors on March 12, 2026 and to the Perpetual Executive Committee on January 20, 2026 respectively) :
(1) The indirect and direct employees have fully completed business integrity, anti-corruption, confidentiality and ethical courses with 100% examination participation rate and 100% pass rate.
(2) All directors attended courses on integrity management and insider trading prevention.
(3) 1,754 newly recruited indirect and direct employees have completed the operation rules training with the 83% passing rate.
(4) The group has promoted business ethics and highlights the concepts of business integrity in 522 suppliers’ meetings.
(5) Over 1,208 suppliers (coverage rate: 95%) participate in the Sunshine Policy and have made commitment to comply with Sunshine Policy.
(6) In 2025, various internal and external training programs were held on topics such as integrity management, including training for new employees, quality management, professional skills, management capabilities, integrity and compliance regulations, ethical behavior, internal sensitive information, food safety and hygiene management, accounting systems, internal controls, significant information, insider trading, anti-corruption, ethical issue, etc., the total duration of these training sessions amounted to 167,380 hours, with more than 120,313 participants.
(7) Business ethics and integrity index was included in employee’s performance evaluation.
(8) The group promotes integrity through platform in internal areas and factories. Each month, two themes are selected and displayed four times a day, resulting in an annual reach that exceeds 1.8 million.
(9) In 2026, two articles on integrity management were published in the Dingsheng Journal in March and September.
(10) Ding+ application promote integrity management initiatives on a monthly basis.
(11) The group has no major violations, and no relevant reports have been received by the competent authority.
2025 Implementation Result of Business Ethics

Formulate policies to prevent conflicts of interest and provide appropriate representation channels

The group's "Code of Ethical Conduct" clearly stipulates that personnel should handle business objectively and efficiently, avoiding the abuse of their positions to obtain undue benefits for themselves, others, or other companies, thus preventing conflicts of interest. Furthermore, our "Integrity Management Operating Procedures and Behavior Guidelines" details the procedures for conflict-of-interest avoidance for stakeholders when there is a conflict of interest regarding board resolutions. Reports involving ordinary employees should be submitted to their department heads; reports involving directors or senior executives should be submitted to the independent directors or the audit committee. If an investigation uncovers significant violations or a situation where the company is at risk of significant damage, a report should be immediately prepared and notified in writing to the independent directors or the audit committee.

Integrity management and implementation with transaction partners

Before engaging in business transactions, the group, in accordance with the "Integrity Management Operating Procedures and Behavior Guidelines " and the " Policy on Preventing Fraud and Corruption " considers the legality of its agents, suppliers, customers, or other transaction counterparties and whether they have a history of dishonest behavior. We avoid conducting transactions with those with a history of dishonest behavior and implement these measures. We also encourage the reporting of any illegal or unethical behavior and stipulate that the importance of honest behavior should be regularly promoted to boards and employees.

Whistleblowing Policy and Procedure

According to the “Integrity Management Operating Procedures and Behavior Guidelines”, the group has established an independent mailbox (zdt@zdtco.com) and hotline (03-3835678) for both internal and external reporting. All reports are anonymous, and the identity and related information of the reporters will be kept confidential. A specific agency is responsible for handling the reports, and once there is supporting evidence, penalties will be imposed. If necessary, the case will be referred to the judicial authority for further investigation. All cases will be submitted to the Board of Directors for review and improvement.

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In accordance with the global political and economic development trends and changes, we adhere to the tenet of "long-term attention, sustainable development, and striving for the best", actively implement the policy of "prevention-oriented control of source, full participation for comprehensive control", and fully carry out the principle of "whoever is in charge must be responsible".