8.Enforcement of Ethical
Corporate Management
Wistron Corporation 2014 Annual Report translation
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Enforcement of Ethical Corporate Management
Implementation Status
Item
Yes
1. Establishment of Corporate Conduct and Ethics Policy and
Implementation Measures
(1) Does the company have bylaws and publicly available documents
addressing its corporate conduct and ethics policy and measures,
and the commitment regarding implementation of such policy
from the Board of Directors and the management team?

(2) Does the company establish relevant policies which are
duly enforced to prevent unethical conduct and provide
implementation procedures, guidelines, consequence of violation
and complaint procedures in such policies?
(3) Does the company establish appropriate compliance measures
for the business activities prescribed in paragraph 2, article 7 of
the Ethical Corporate Management Best Practice Principles for
TWSE/GTSM Listed Companies and any other such activities
associated with high risk of unethical conduct?
2. Ethic Management Practice
(1) Does the company assess the ethics records of whom it has
business relationship with and include business conduct and
ethics related clauses in the business contracts?

(2) Does the company set up a unit which is dedicated to or tasked
with promoting the company’s ethical standards and reports
directly to the Board of Directors with periodical updates on
relevant matters?

(3) Does the company establish policies to prevent conflict of
interests, provide appropriate communication and complaint
channels and implement such policies properly?



No
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No discrepancy
(1) We establish “Ethical Corporate Management Best Practice
Principles” and “Code of Ethical Conduct”, above contents are
disclosed in our company website and Market Observation Post
System. Integrity is not only the core value of our business but also
a fundamental part of our daily operation, this standard also applies
to our board members, supervisors, employees and other related
person.
(2) In our “Code of Ethical Conduct”, we clearly define the basic rules
that employees must follow and avoid, including the principles
and procedures of conflict of interest, Giving Presents and Treats ,
Legal Political Donations, Charitable Donations.
(3) We determined the units which handles financial/treasury and
procurement as the ones with potential risks. The involved units are
required to undergo specific trainings, internal audit or regular work
rotation to reduce potential risk.
No discrepancy
(1) Prior to any commercial transactions with contractors, suppliers,
customers or any entities, we consider their ethical performance by
reviewing their condition of legitimacy, ethical policy and records
of unethical behaviors. We also convey our policy and ethical
standards to our business partners and refuse to offer, commit,
request or accept any improper advantage in any form, either
directly or indirectly. Once we are aware of any unethical events,
we will terminate the contract immediately and move the entity to
the dishonor list.
Besides that, we stipulate the terms and conditions of ethical
management in contracts such as specific and reasonable payment
terms, handling of unethical conduct including but not limited
to the pertaining to prohibition of commissions, rebates, or other
benefits.
(2) HR department is responsible for the establishment of company’s
integrity policy and the supervision of enforcement, and report
to Board Meeting if there is any severe violation of company’s
integrity policy. So far no incidents of unethical conduct have been
reported.
(3) It is stated in our “Ethic Policy” that we pay high attentions to
conflicts of interest .In our “Code of Ethical Conduct”, we clearly
define the principles and circumstances of conflicts of interest
that related person shall avoid, and we also require them to
report initiatively to their immediate supervisors, highest level of
management of HR or report on board meeting if they face or are
aware of similar situations that may arise conflicts of interest. So
far no incidents of unethical conduct have been reported.
Enforcement of Ethical Corporate Management
Implementation Status
Wistron Corporation 2014 Annual Report translation
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Enforcement of Ethical Corporate Management
Implementation Status
Item
Yes
(4) To implement relevant policies on ethical conducts, does the
company establish effective accounting and internal control
systems that are audited by internal auditors or CPA periodically?

(5) Does the company provide internal and external ethical conduct
training programs on a regular basis?
3. Implementation of Complaint Procedures
(1) Does the company establish specific complaint and reward
procedures, set up conveniently accessible complaint channels,
and designate responsible individuals to handle the complaint
received?

(2) Does the company establish standard operation procedures
for investigating the complaints received and ensuring such
complaints are handled in a confidential manner?

No


(3) Does the company adopt proper measures to prevent a
complainant from retaliation for his/her filing a complaint?
4. Information Disclosure
Does the company disclose its guidelines on business ethics as

well as information about implementation of such guidelines on its
website and Market Observation Post System (“MOPS”)?
5. If the company has established corporate governance policies based on TSE Corporate Conduct
and Ethics Best Practice Principles, please describe any discrepancy between the policies and
their implementation.
No discrepancy
6. Other important information to facilitate better understanding of the company’s corporate
conduct and ethics compliance practices (e.g., review the company’s corporate conduct and
ethics policy).
We deliver our ethical policy and ethical standards to all suppliers while presenting company
profile and address it as well during the annual vendor conference. Meanwhile, supplier can
also know Wistron’s this policy from E-procurement system(WSRM). We examine suppliers’
integrity and ethical performance every year.
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(4) We conduct evaluation and self-audit of the effectiveness of internal No discrepancy
control system, including accounting system, and make appropriate
modifications if necessary, The result will be reviewed by Audit
Office based on good faith.
(5) Employees are required to take ethic e-trainings courses and exams
on the first day of employment.
(1) All employees have the duty to report directly to highest level No discrepancy
of management of HR, Audit Office or Chairman the improper
conduct that is against the ethical conduct of the company, and
we also pledge to protect the employees involved in reporting or
investigation of the events from injustice or revenge. If employees
violate the Code of Ethical Conduct, we will consider the severity
of the violation, and conduct proper action, including dismissal,
based on “Guidelines on Employee Award/Disciplinary”. If
business partners violate our integrity policy, we will consider the
severity of the violation to reduce or terminate our cooperation, or
even report to the judicial authorities.
(2) Wistron establish internal complaint procedure, which provides a
clear process for complaint addressing, investigation, complaint
resolution, etc., All complainants are treated sensitively and
confidentially.
(3) The complainant and respondent who involved in reporting or
investigation of the events are free from injustice or revenge.
In Wistron official website, we disclose the actions and commitments to No discrepancy
our ethic policy and EICC (Electronic Industry Citizenship Coalition)
code of conduct. We also disclose the ethical conduct implementation in
our CSSR Report every year.
Enforcement of Ethical Corporate Management
Implementation Status