Ethical Management

Ethical Management

We have established internal rules and regulations such as “Code of Conduct”, “Ethical Corporate Management Best Practice Principles” and “Implementation Measures for the Whistleblowing System”. These clearly demonstrate our company’s commitment to an ethical management policy. We require that all activities of the Company and its subsidiaries comply with relevant laws and regulations and adhere to high standards of professional ethics. We are committed to avoiding unfair competitive practices, opposing any form of bribery, and establishing appropriate management systems. We uphold a zero-tolerance policy against corruption and will continue to actively promote a high-standard business ethical culture. Our legal department is responsible for overseeing all ethical management operations and reports on their implementation to the Board of Directors annually. The latest annual report was presented to the Board of Directors on November 14th, 2023.

Education and Training

New Employee Orientation

We have incorporated ethical management into our orientation for new employees to ensure that every new hire understands and adheres to our “Ethical Corporate Management Best Practice Principles” and “Code of Conduct”. In 2023, a total of 93 new employees each completed 0.5 hours of ethical management training, totaling 46.5 training hours.

External Training

In 2023, a total of 12 employees from our company applied for external training on accounting and internal control systems, totaling 117 training hours.

Internal Training

In October and November 2023, we conducted courses for employees on “Understanding the Responsibilities and Duties of Directors, Supervisors, and Senior Executives under the Securities and Exchange Act” and “Understanding Related Party Transactions and Non-routine Transactions through Practical Cases” to raise awareness of these topics among supervisors and employees at the headquarters and Taiwan branch office. The courses included promoting concepts such as ethical management, anti-money laundering, anti-corruption and prevention of insider trading. A total of 72 participants attended the courses, totaling 180 training hours.

Whistleblowing System

We have established a whistleblowing system and updated the contact information for reporting on our official website as of November 4th, 2022. We ensure the confidentiality and protection of the whistleblower’s identity. The specific procedures for complaints and investigation were clearly stipulated in the “Implementation Measures for the Whistleblowing System”.

Declaration and Commitment

As of May 2023, all of our 9 board directors, and as of March 2022, all 7 senior executives, have signed the “Statement of Compliance with Ethical Management Policy” declaring their full adherence to the company’s “Code of Conduct”, “Ethical Corporate Management Best Practice Principles” and any related ethical management policies and regulations. Additionally, all 93 new employees who joined D-Link in 2023 have signed and agreed to comply with the “Code of Conduct”.

Supplier Compliance

Our company includes clauses in procurement contracts with suppliers that require adherence to corporate social responsibilities and our ethical management policy, These contracts explicitly prohibit suppliers from offering or receiving bribes or other improper benefits to or from any of our personnel, for commercial or personal gain, or engaging in similar conduct. We further require all suppliers to sign an “Integrity and Anti-corruption Pledge” reiterating these stipulations and stating clearly that any such illegal activities will result in immediate contract termination. In 2023, our company signed a total of 12 procurement contracts, all of which included these provisions. Additionally, our company did not receive any reports of bribery involving suppliers in 2023.
 

Political Contributions

We have established “Guidelines for Political Contributions” to serve as a procedural and behavioral guide for legally managing political contributions. In 2023, our company did not make any political contributions.

Anti-Corruption Assessment

We evaluate each operational site based on the latest “Corruption Perceptions Index” to determine if they are located in regions perceived to have a high risk of corruption. If an operational site is situated in a country classified as having a medium to high corruption risk (meaning a score below 50), we enhance relevant anti-corruption education and training. Taking Taiwan, where our headquarters is located, as an example, the score was 67, ranking 28th out of 180 countries, indicating a low-risk area. In 2023, our company did not experience any incidents of employee corruption or internal complaints, and upon assessment, no significant corruption-related risks were identified.

Insider Trading Prevention

Article 6 of our “Procedures for Handling Material Inside Information and Prevention of Insider Trading” and Article 10 of our “Practical Guidelines for Corporate Governance” clearly stipulate that directors and insiders are not allowed to trade their shares during the 30 days prior to the announcement of the annual financial report and 15 days prior to the announcement of each quarterly financial report.
Our quarterly financial reports for the year 2023 were approved by the Board of Directors on February 22nd, May 10th, August 14th, and November 14th respectively. Additionally, notifications were electronically sent to directors and insiders on January 19th, April 24th, July 28th, and October 27th by stock service personnel, reminding them not to engage in stock transactions before the financial report announcements. There were no incidents of insider trading in the year 2023.