Regulations and Integrity
Purpose
Bao Fu’s mission relies on our core value of “integrity.” Clients, regulatory agencies, and the public trust Bao Fu because we uphold the highest standards of honesty, fairness, and integrity in all business activities. However, everyone at Bao Fu also has roles and relationships outside the company. If external or personal interests appear to influence Bao Fu’s work, it may lead others to question our independence and integrity.
Personal relationships or activities that improperly affect decisions made on behalf of Bao Fu, or create the perception of corruption, are addressed by this Conflict of Interest Policy, which aims to minimize such risks.
Scope
This policy applies to all Bao Fu employees and agents. All personnel must adhere to this policy, as well as Bao Fu’s Gift and Hospitality Policy and Anti-Bribery and Anti-Corruption Policy. Employees must also comply with Taiwan’s national and local anti-bribery and anti-corruption laws.
Policy Statement
Bao Fu personnel must:
- Review their activities and relationships to identify potential conflicts with their responsibilities at Bao Fu.
- Disclose all potential conflicts of interest.
- Develop and implement plans to recuse themselves from work that may be affected by conflicting activities or relationships to avoid conflicts.
- Act properly and reasonably to avoid impairing their judgment or creating the appearance of compromised decision-making.
Bao Fu personnel must not:
- Use their position at Bao Fu for personal gain or benefit.
- Use their role at Bao Fu to benefit family members or any other individual, business, or organization.
- Engage in relationships with Bao Fu clients, suppliers, competitors, or other organizations that could influence business decisions or harm Bao Fu’s reputation.
Employees must complete a Disclosure of Personal and Related Party Interests Form and report potential conflicts to the Ethics and Compliance Department and their manager. Bao Fu may request and collect information on employees’ external activities and interests to prevent or mitigate conflicts of interest.
Employees are required to report any solicitation of bribes to the Ethics and Compliance Department.
Rules and Examples
Employees should avoid any conflicts or potential conflicts between personal and company interests. In situations such as those listed below, employees should proactively and fully disclose any conflicts using the Disclosure Form. Employees below department head level should report to their highest department manager and HR. Department heads and above should report directly to the CEO.
External Employment
- Employees may hold multiple jobs or work for other companies or organizations while working for Bao Fu, provided such employment is unrelated to Bao Fu’s work, disclosed to and approved by their manager and the Ethics and Compliance Department.
- If an external employer is a direct or indirect competitor, supplier, or client of Bao Fu, or seeks business with Bao Fu, employees must follow an approved conflict management plan and recuse themselves from related decisions.
- Employees may not use company resources (e.g., information, assets, or property) for external activities without company approval.
Government or Bao Fu Appointments
- Employees may serve in government positions or Bao Fu-appointed roles while working for Bao Fu, provided such roles are unrelated to their Bao Fu duties and approved by their manager and the Ethics and Compliance Department.
- If the government entity or public institution has or seeks business with Bao Fu, or can otherwise influence Bao Fu’s activities, employees must follow an approved conflict management plan and recuse themselves from related decisions.
- Unless explicitly approved by the Board Governance Committee, senior executives and directors may not accept government appointments while serving at Bao Fu.
Avoiding Conflicts of Interest
Prohibition of Bribery and Improper Payments
- Bao Fu personnel must not directly or indirectly offer, pay, solicit, or accept any form of bribe, illegal rebate, or other improper payments (monetary or otherwise).
- Employees must not offer, pay, promise, or authorize anything of value to any individual, government official, or company to influence actions or gain improper advantage.
- Employees must report any incidents of bribery, corruption, or solicitation of bribes to the Ethics and Compliance Department.
Other Provisions
Bao Fu’s HR Department and Employee Handbook outline additional regulations related to nepotism, workplace relationships, and other potential conflicts of interest. Business units, departments, and locations may also issue supplementary conflict of interest guidelines. Employees must comply with this policy and all applicable laws and regulations (adhering to the most stringent requirements).
Disclosure: Bao Fu publishes this Conflict of Interest Policy on the company website.
Implementation: This policy is effective upon approval by the Board of Directors and applies to all subsequent revisions.