Integrity management implementation
Integrity in Business Operations" Execution Status
Integrity management implementation
Greenfiltec revised its Code of Integrity and disclosed its implementation status. The third board of directors approved the “Code of Integrity” and “Operating Procedures and Conduct Guidelines,” which were later revised by the fourth board. The management office is responsible for developing and overseeing integrity policies and prevention measures, providing regular reports to the board.
| Assessment project | Operational situation | Differences and reasons from the Code of Integrity Management of Listed Over-the-Counter Companies | ||||||||||||||
| Yes | No | Summary description | ||||||||||||||
一、Formulate integrity management policies and plans | ||||||||||||||||
| (一)Has the company established an integrity management policy approved by the board of directors, clearly stating the policy and practices in its regulations and external documents, along with the commitment from the board and management to actively implement this policy？ | v | On February 9, 2021, the third board of directors approved the establishment of the “Code of Integrity” and “Operating Procedures and Conduct Guidelines.” On November 1, 2023, the fourth board of directors approved revisions to these documents. The management office is responsible for developing and overseeing integrity policies and prevention measures, providing regular reports to the board. The most recent report was presented on November 1, 2023, at the fourth board’s seventeenth meeting. | no significant difference | |||||||||||||
| (二) Has the company established a mechanism for assessing risks related to dishonest behavior? Does it regularly analyze and evaluate business activities with a higher risk of dishonesty within its operations, and develop prevention measures accordingly? Additionally, do these measures at least cover the prevention actions outlined in Article 7, Section 2 of the “Code of Integrity for Listed Companies”？ | v | The company has established the “Code of Integrity,” “Operating Procedures and Conduct Guidelines,” and “Code of Ethical Conduct” to regulate relevant procedures. It has also implemented effective internal control mechanisms and approval processes to ensure the prevention and detection of corruption. | no significant difference | |||||||||||||
| (三) Does the company specify procedures, conduct guidelines, penalties for violations, and a complaint system in its prevention measures against dishonest behavior, ensure their implementation, and regularly review and revise these measures？ | v | The company clearly prohibits dishonest behavior in its Code of Integrity, and the internal control system states that no improper benefits in any form may be accepted during business operations. | no significant difference | |||||||||||||
二、Implement honest management | ||||||||||||||||
| (一)Does the company assess the integrity records of its counterparties and include integrity behavior clauses in contracts signed with them？ | v | The company conducts its business activities in an open and transparent manner. The rights and obligations of both parties are clearly specified in the contract, based on the nature of the transaction. | no significant difference | |||||||||||||
| (二)Does the company have a dedicated unit reporting to the board of directors to promote corporate integrity, and does it provide regular reports (at least once a year) on its implementation？ | v | The management office is responsible for reporting to the board on its implementation. The company adheres to legal requirements to uphold integrity in its operations for sustainable development. The most recent report was given on November 1, 2023, at the fourth board’s seventeenth meeting. | no significant difference | |||||||||||||
| (三)Does the company have a policy to prevent conflicts of interest, provide appropriate channels for disclosure, and ensure its implementation？ | v | The company has established regulations to prevent conflicts of interest in its “Code of Ethical Conduct” and “Operating Procedures and Conduct Guidelines.” When there is a conflict of interest regarding board proposals, the relevant directors must recuse themselves and not participate in the discussion or voting. | no significant difference | |||||||||||||
| (四) Does the company have an effective accounting system and internal control system in place to implement integrity management? Is there an internal audit unit that, based on the assessment of dishonesty risk, develops related audit plans to check compliance with the prevention measures against dishonest behavior, or engages an accountant to conduct the audit？ | v | The company has established accounting and internal control systems in accordance with the law. To ensure the design and execution of these systems remain effective, auditors review and revise them annually. If any verified incidents of dishonesty occur, they must be reported immediately to the audit committee and board members. | no significant difference | |||||||||||||
| (五) Does the company regularly conduct internal and external training on integrity management？ | v | The company has established integrity management policies and periodically promotes the importance of integrity to employees.
| no significant difference | |||||||||||||
三、The operation of the company’s whistleblowing system | ||||||||||||||||
| (一) Does the company have a specific reporting and reward system in place, along with convenient channels for reporting, and assign appropriate personnel to handle complaints against reported individuals？ | v | The company has internal reporting channels and provides a complaint mechanism. Designated personnel are responsible for handling investigations, ensuring confidentiality, and implementing protective measures. | no significant difference | |||||||||||||
| (二) Does the company have established standard operating procedures for investigating reported issues, follow-up actions to be taken after the investigation is completed, and related confidentiality mechanisms？ | v | The company’s “Code of Integrity” clearly states that all reports will be kept confidential and investigated with rigor, outlining the procedure for reporting investigation findings. | no significant difference | |||||||||||||
| (三) Does the company have measures in place to protect whistleblowers from improper treatment as a result of their reports？ | v | The company maintains confidentiality regarding the identity of whistleblowers and the content of their reports, and protects them from improper treatment as a result of their disclosures. | no significant difference | |||||||||||||
四、Strengthen information disclosure | ||||||||||||||||
| Does the company disclose the contents of its Code of Integrity and its implementation results on its website and through public information platforms？ | v | The company’s “Code of Integrity” and “Operating Procedures and Conduct Guidelines” are published on its website and public information platforms, and the annual implementation results are updated regularly on the company’s website. | no significant difference | |||||||||||||
五、Describe the differences | ||||||||||||||||
If the company has its own Code of Integrity based on the “Code of Integrity for Listed Companies,” please describe how it operates and any differences from the established code: The company has established its “Code of Integrity” and “Operating Procedures and Conduct Guidelines,” and there are no significant differences in their operation compared to the “Code of Integrity for Listed Companies.” | ||||||||||||||||
六、Other important information | ||||||||||||||||
Other important information that helps understand the company’s integrity management operations (such as any reviews or revisions of its established Code of Integrity): 1. The company follows relevant regulations and internal control systems, strictly prohibiting dishonest or illegal behavior. 2. The company’s “Board Meeting Rules” include a conflict of interest policy, stating that any board member with a personal or corporate interest that may harm the company’s interests must recuse themselves from discussions and voting and cannot act as a proxy for other board members. 3. The company has established “Internal Major Information Processing Procedures,” published on its website, to create a robust mechanism for handling and disclosing major internal information, preventing improper leaks, and ensuring consistency and accuracy in the information shared with external parties. 4. The company regularly arranges for directors and managers to participate in corporate governance courses to enhance their ability to oversee and govern the company, aiming to improve governance effectiveness and integrity management. 5. Each year, the company reminds directors and insiders via email that they must not trade company stock during the blackout periods, which are thirty days before the annual financial report announcement and fifteen days before quarterly financial report announcements. 6. In the 2023 fiscal year, on October 13, 2023, the company notified directors and insiders via email about the board meeting date for reviewing the Q3 financial report and the corresponding blackout period. | ||||||||||||||||
