Compliance Integrity & Impartiality Policy

Compliance Integrity

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.

Impartiality Policy

Bao Fu is the legal entity responsible for personnel certification activities. Please refer to Bao Fu Management Consultants Co., LTD as the legal entity mentioned throughout this policy and public statement.

The CEO, employees, and subcontractors of Bao Fu fully understand the importance of impartiality when conducting personnel certification activities. Therefore, Bao Fu ensures that all employees and any individuals involved will remain impartial in all dealings with applicants/candidates/certified individuals for personnel certification services. The following principles of impartiality are implemented:

  • Certificates are only issued upon approval from authorized personnel, ensuring that no vested interests dominate decision-making.

  • Bao Fu maintains (and will not establish) any relationships with applicants/candidates/certified individuals that might give the impression that individuals who have received training from Bao Fu will be given preferential treatment or guaranteed success. Before any relationship is formally established, a risk assessment on impartiality will be conducted by the CEO.

  • Ongoing reviews of any existing relationships with applicants/candidates/certified individuals are conducted to ensure they do not compromise impartiality in certification activities.

  • All individuals employed or contracted by Bao Fu must disclose current and past relationships that may pose a conflict of interest. Any past or current situation that could lead to potential conflicts must be reported. Bao Fu will assess such information and will not assign roles to such individuals unless it is clear that no conflict of interest exists.

  • Personnel certification and those involved in certification activities must not be subjected to pressure or influence that would lead to biased conclusions.

  • Bao Fu does not offer commission, incentives, or referral bonuses to encourage the referral of applicants/candidates/certified individuals for certification services, unless the following conditions are met:

    • The terms and conditions of such referrals are clearly defined and documented, and it is clear that these payments are referral fees. These fees must never influence the certification outcome.

    • A risk assessment has been conducted on such payments to ensure they do not pose an unacceptable threat to impartiality.

    • All such payments are recorded, documented, traceable, and accompanied by purchase orders and invoices.

Impartiality Code

  • Bao Fu shall not employ individuals who are relatives of staff working at service-providing locations.

  • All certifications and Bao Fu policies must be followed.

  • Bao Fu shall not employ professionals whose values conflict with the company’s ethics policy.

  • No certified personnel may promote or sell services offered by the organization.

  • All Bao Fu employees must disclose any issues that could compromise business ethics.

  • Bao Fu shall assign work to its certified personnel within a defined timeframe and avoid overburdening staff to prevent compromising the impartiality of certification.

  • Any observed unethical behavior must be reported to management promptly.

  • Bao Fu personnel are prohibited from accepting gifts from clients/subcontractors/training institutions/applicants/candidates/certified individuals.

  • Examiners shall not assess individuals related to them.

  • Bao Fu acknowledges that income is derived from applicants/candidates/certified individuals, posing a potential threat to impartiality. As a self-financed independent body, Bao Fu has numerous controls in place to safeguard impartiality. Certification decisions are based solely on objective evidence of conformity or non-conformity and are made by authorized personnel who have no conflict of interest.

Bao Fu recognizes potential threats to impartiality, including:

  • Self-interest threats – Acting based on personal gain.

  • Self-review threats – Reviewing one’s own work.

  • Familiarity or trust threats – Being too familiar or trusting of someone being evaluated.

Training Framework

To ensure that educational training courses do not compromise the impartiality of personnel certification or weaken evaluation standards, the following measures are taken:

  • Clear Training Standards:
    Bao Fu outsources training through Huaxia Training and Evaluation Committee, composed of industry experts who define clear standards aligned with best practices and regulatory requirements to ensure consistency with certification standards.

  • Independent Evaluation:
    The Ministry of Labor’s Workforce Development Agency authorizes independent reviews through experts in the Talent Quality-management System (TTQS). Certified institutions must meet national evaluation criteria.

  • Transparency:
    Training course content and certification standards are published on institutional websites for full transparency, enabling applicants to understand the fairness of the evaluation process.

  • Feedback Mechanism:
    Course satisfaction surveys and certification satisfaction surveys are conducted, enabling participants to provide feedback and help improve quality.

  • Continuous Monitoring:
    Compliance audits of training courses are conducted without prior notice by the Legal and Compliance Unit and the Certification Team, based on audit standards and checklists. Training content is updated to stay relevant with industry trends and technological advancements.

  • Record Keeping:
    Supervisors must complete a training course log after each session, maintaining a record for review or investigation when necessary.

Public Declaration

Bao Fu, along with its CEO, Administrative Manager, Certification Manager, employees, and all others involved in personnel certification activities, fully understands the critical importance of impartiality in carrying out its personnel certification services.

Therefore, Bao Fu ensures that all individuals involved in such activities will maintain impartiality in all dealings with applicants/candidates/certified individuals.

To ensure impartiality is upheld and demonstrable, Bao Fu Management Consultants Co., LTD has identified and assessed all potential conflicts of interest and threats to impartiality.

 

 

Copyright © Bao Fu Management Consultants Co., LTD 2025 All Rights Reserved