Fulfillment of the Integrity Management Situation

AES has a dedicated unit affiliated to the board of directors to handle the revision, implementation, interpretation, consulting services, registration and filing of notification content and other related operations and supervision of the implementation of the operating procedures and behavior guidelines. It is mainly responsible for relevant matters and should report to the board of directors on a regular basis. The dedicated unit organizes educational training or internal publicity from time to time to convey the importance of integrity to directors, managers, employees and assignees. And report to the board of directors on March 14, 2023 on the implementation status as follows.

Evaluation Item Status Deviations from the "Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies" and reasons thereof
Yes No Description
Establishment of ethical corporate management
  • Has the Company established the ethical corporate management policies approved by the Board of Directors and specified in its rules and external documents the ethical corporate management policies and practices and the commitment of the Board of Directors and senior management to rigorous and thorough implementation of such policies?
  • Does the company have a mechanism in place to assess ethical risk, to review and identify business activities with higher inherent ethical risk, and to lay out preventive measures accordingly, which should at the minimum include the measures listed in Article 7-2 of the "Ethical Corporate Management Best Practices for TWSE/TPEx Listed Companies"?
  • Does the company have clear procedures, guidelines, penalty for violations, and grievance systems built into the preventive measures for unethical conduct, which are fully implemented, and reviewed, revised periodically?
 V   AES has established policies and procedures such as the "Ethical Corporate Management Best Practice Principles," "Procedures for Ethical Management and Guidelines for Conduct" and "Code of Ethical Conduct" to regulate all business activities of the Company with integrity.
AES has explicit requirements as laid out in the "Procedures for Ethical Management and Guidelines for Conduct" to periodically review and assess business activities with high inherent ethical risks.
AES has rolled out preventive measures which include all the best practices as laid out in Article 7-2 of the "Ethical Corporate Management Best Practices for TWSE/TPEx Listed Companies.
AES has clear procedures, guidelines, penalties for violation, and grievance process as part of the preventive measures for unethical conduct, which are fully implemented, reviewed, and revised periodically.		 No material difference
Implementation of ethical corporate management
  • Does the company evaluate business partners' ethical records and include ethics-related clauses in business contracts?
  • Has the company set up a dedicated unit under the Board of Directors to promote ethical corporate management and regularly (at least once every year) report to the Board of Directors the implementation of the ethical corporate management policies and prevention programs against unethical conduct?
  • For the ethical corporate management to function effectively, does the company have the accounting systems and the internal control systems in place, have the internal audit develop audit plans according to the ethical conduct risk assessment report, and review the implementation progress by the internal audit or a designated external auditor?
  • Does the company regularly hold internal and external trainings for ethical corporate management?
 V   AES has established an evaluation mechanism for its suppliers and contractors with whom it does business. AES has required new suppliers to sign the "Supplier Social Responsibility Commitment Letter," which specifies the terms of integrity.
In order to implement ethical corporate management, AES has formulated the "Procedures for Ethical Management and Guidelines for Conduct," and has a dedicated Ethical Corporate Management Team reporting directly to the Board. The team is comprised of members from the heads of major departments and senior management. The team is convened by the CEO and will report its status to the Board at least once a year.
AES has clearly prescribed policies and procedures such as "Procedures for Ethical Management and Guidelines for Conduct," "Code of Ethical Conduct" and "Procedures for Handling the Reporting of Illegal or Unethical Conduct," to prevent conflict of interests at all levels of personnel. These policies and procedures have been duly implemented.
TAES's accounting systems and internal control systems function properly, and are reviewed periodically or from time to time by the internal audit as well as by the designated auditor.
AES promotes ethical corporate management concepts and regulations from time to time through new employee training, internal conference and educational training.In 2022, AES conducted anti-corruption education training for the first time. Trend Energy and Trend Power only trained IDL personnel, while Trend Power (Changshu) trained all employees, including integrity management and labor ethics training. A total of 1,027 people participated in the training, which contributed to the training rate to 87%. The training lasted for 869 hours in total. In order to improve the training system, the follow-up plan is to retrain existing employees annually, and conduct relevant courses when new employees register to increase the training rate.		 No material difference
Whistleblowing system
  • Does the company establish both a reward/punishment system and an integrity hotline? Can the accused be reached by an appropriate person for follow-up?
  • Has the Company established the standard operating procedures for investigating reported misconduct, for adopting follow-up measures after the investigation, and for ensuring confidentiality of the matter?
  • Does the company provide proper whistleblower protection?
 V   AES has stipulated in Article 21 of the "Procedures for Ethical Management and Guidelines for Conduct" that the Company encourages internal and external personnel to report unethical conduct or malpractice, and a whistle-blowing procedure is in place.
AES has established standard operating procedures for investigating reported misconduct, and the reports and investigations are treated with strict confidentiality.
Henceforth, AES has strict confidentiality policies concerning whistleblower identity and the reported content. AESis committed to protecting whistleblowers from retaliation.		 No material difference
Enhanced disclosure of ethical corporate management information
Does the company disclose the ethical corporate management policies and the results of its implementation on the company website and MOPS?		 V   AES has disclosed relevant contents such as "Ethical Corporate Management Best Practice Principles," "Procedures for Ethical Management and Guidelines for Conduct" and "Code of Ethical Conduct" on the Company's website. Where necessary, AES will disclose its information relating to ethical corporate management on the Company's website and MOPS. No material difference
If the company has established internal ethical corporate management guidelines according to the "Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies," describe any deviation of its implementation from the guidelines: No material difference. No material difference.
Other important information to facilitate better understanding of the Company's ethical corporate management: (e.g., review of and amendments to ethical corporate management policies) The Company has disclosed all information related to ethical corporate management guidelines and procedures.
 


Appointment and Dismissal of Internal Auditors

Appointment, dismissal, evaluation and review, salary and compensation of internal auditors shall be reported to the board of directors or shall be submitted by the chief auditor to the board chairperson for approval.
 

Guard Against Insider Trading

AES has formulated management measures to prevent insider trading. At least once a year, AES conducts education and publicity on the "Administrative Measures for Preventing Insider Trading" and relevant laws and regulations on insiders for current directors and managers.
 

Cyber Security Management

The AES's cyber security policy is "to maintain the confidentiality, integrity, availability and legality of the Company's information and to avoid the risk of loss, misuse, leakage, alteration or destruction of information assets due to negligence, intentional or natural disasters that may affect the normal operation of the Company.
 

Grievance Mechanism

AES attaches great importance to the opinions of employees. In order to build a friendly working environment, we hold regular labor-management meetings, set up e-mails, official line@ as communication channels. AES is committed to collecting employees' suggestions and opinions on the company in a timely manner, and increasing the immediacy and convenience of communication and grievance, thereby promoting the harmonious development of employees.

If it is found that the AES's personnel have violated the integrity of the operation, they can report through the report mailbox to respond and report. AES has established and provided independent reporting mailboxes and dedicated lines on its website and internally, or entrusted other external independent organizations to provide reporting mailboxes and dedicated lines for use by internal and external personnel of the Company. The whistleblower should provide at least the following information:

  • The informant’s name, ID card number, address, phone number, and email address can be contacted
  • The name of the person being reported or other information sufficient to identify.
  • Specific evidence available for investigation.


The relevant personnel of the Company handling the reporting incident shall make a statement to keep their identities and contents confidential. AES also promises to protect the reporting persons from suffering losses due to the situation.
Acceptance units of different whistleblowers and Process:

  • If the report involves ordinary employees, it must be reported to the general manager.
  • If the report involves directors or senior management whose responsibilities are equivalent to the associate level or above, the investigation report should be reported to the independent director or the audit committee.
  • In the event of a serious violation or the possibility of causing major damage to the AES, a report should be made immediately, submitted to the independent director or the audit committee, and proactively notified or reported to the relevant authority.
  • An investigation team is established according to the resolution of the general manager, and the responsible unit reports to the general manager to designate the team members and convener of the investigation team.


Record Keeping

  • Report acceptance, investigation process, and investigation results are all kept in files.
  • Records keep for five years, and could be kept electronically. Before the expiration of the storage period, if a lawsuit related to the reported content occurs, the document shall be kept until the termination of the lawsuit.


Whistleblowing and Grievance Mechanism

  • In order to build an inclusive working environment, we hold regular labor-management meetings, set up complaint hotlines and e-mails, official line@, employee suggestion boxes, and other communication channels.
  • AES is committed to collecting employees' suggestions and opinions on the AES in a timely manner, and increasing the immediacy and convenience of communication and grievance, thereby promoting the harmonious development of employees.

    Whistleblower/Grievance
    Tel.+866-3-5695916