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Fulfillment of Ethical Business Practices
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Catcher Technology is committed to strengthening corporate governance by establishing a comprehensive internal control system and working in coordination with the audit department to conduct regular inspections, ensuring the effective implementation of all operations. The Company has established a dedicated unit to closely monitor significant domestic and international policy and regulatory developments. When appropriate, the Company seeks advice from professionals in legal, accounting, and other relevant fields to provide recommendations and formulate responsive measures. These efforts are implemented in both internal management and external business activities, embodying the core spirit of ethical business conduct.
Implementation in 2024
1.Formulation of Ethical Business Policies and Programs
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On March 10, 2021, the Board of Directors resolved to adopt the Procedures for Ethical Management and Guidelines for Conduct. All seven directors and eight senior executives unanimously committed to its implementation and signed the Ethical Management Commitment Letter, thereby setting a strong example of proper conduct. Relevant actions are regularly disclosed in the Company’s Sustainability Report and on its official website. |
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For business activities with potential risks of unethical conduct – such as procurement and engineering – as well as possible improper behaviors (including bribery or corruption, improper donations or sponsorships, offering or accepting unreasonable gifts, hospitality, or other undue benefits), the Company has established preventive measures in accordance with the Procedures for Ethical Management and Guidelines for Conduct and promoted them through multiple channels. In 2024, all 3,074 domestic and overseas employees (100%) signed the Integrity and Anti-Corruption Commitment Letter. The Company has also integrated supplier whistleblowing channels, audit procedures, and employee grievance mechanisms to effectively prevent unethical conduct. |
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For any unethical conduct that occurs, the Company imposes disciplinary actions commensurate with the severity of the case, incorporating the results into performance evaluations. An appeal mechanism is in place, supported by the accounting system and internal control framework, to mitigate the risk of violations of laws and ethical standards. In supply chain management, all partnering suppliers are required to comply with the Company’s Supplier Code of Conduct (including its anti-corruption policy) to ensure that unethical conduct is prevented at all levels. |
2.Implementation of Ethical Business Practices
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Before engaging in business cooperation with any supplier, the Company evaluates the supplier’s integrity record and related circumstances, and requires the supplier to clearly understand the Company’s expectations regarding ethical conduct. Should a supplier violate these requirements, the Company reserves the right to terminate or rescind the contract and impose penalties in accordance with the contractual terms. In addition, the Company has published supplier whistleblowing channels on its official website to ensure the effective implementation of ethical business principles. |
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The Legal Department is responsible for coordinating the promotion of ethical business practices, ensuring the effective execution of relevant policies. On November 6, 2024, the Company reported to the Board of Directors on the operation and implementation of the Procedures for Ethical Management and Guidelines for Conduct for the year. The Audit Department is tasked with overseeing the execution of the policy, auditing reports received through internal and external whistleblowing and grievance channels to identify potential risks of non-compliance or involvement in corruption or bribery, and regularly presenting audit findings to the Board. |
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The Company has established the Social Responsibility Management Procedures and Work Rules, requiring all employees to refrain from engaging in fraudulent or corrupt acts. The Handling Procedures of Employee Complaints and Suggestions also provide formal channels for employees to file complaints or report violations. |
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New employees are required to undergo corporate social responsibility training upon onboarding, which includes guidance on the Company’s anti-corruption and ethical business regulations; in 2024, the completion rate for this training reached 100%. Furthermore, the Company periodically organizes related training programs for existing employees or assigns staff to attend external courses to continuously strengthen and implement ethical conduct. |
Ethical Business Conduct Training in 2024
| Name of Course |
Training Hours and Attendance (Including Local and Mainland Chinese Employees) |
| Ethical Business Conduct Training |
7,960 employees, totaling 1,592.0 hours, with a completion rate of 99.99% |
| Confidentiality Agreements and Anti-Bribery Provisions |
7,982 employees, totaling 1,596.4 hours, with a completion rate of 99.96% |
| Protection of Trade Secrets |
7,983 employees, totaling 1,596.6 hours, with a completion rate of 99.98% |
| Handling of Internal Material Information and Insider Trading |
681 employees, totaling 136.2 hours, with a completion rate of 99.71% |
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To prevent potential risks, the Company will continue to promote measures related to ethical business practices, anti-bribery, and anti-corruption. These efforts are reinforced through training programs, audit supervision, and annual reporting to the Board of Directors, ensuring the effective implementation of the Procedures for Ethical Management and Guidelines for Conduct. |
3.Operation of the Whistleblowing System
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The Company has established the Whistleblowing Procedures and provides accessible and convenient channels for reporting and filing complaints as follows: |
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External |
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✓ http://www.catcher.com.tw/tw/company_contact.aspx |
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✓ audit@catcher-group.com |
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Internal |
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✓ http://www1.catcher.com.tw/wp-content/uploads/2022/09/1663204862-588154158.pdf |
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✓ audit@catcher-group.com |
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The handling process of the Company’s whistleblowing system for illegal (including corruption) and unethical behavior is as follows: |
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Encourage internal and external parties to report misconduct, with rewards provided based on the severity of the case; internal personnel found to have submitted false or malicious reports are subject to disciplinary action in accordance with regulations.
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Establish and publicly announce an independent whistleblowing mailbox through the Company’s internal and external websites.
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Actively implement protections for whistleblowers to ensure the confidentiality of their identity and the content of their report, strictly prohibiting any retaliation against the reporting party.
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In 2024, no cases or concerns related to illegal activities (including corruption), unethical behavior, or breaches of the Procedures for Ethical Management and Guidelines for Conduct were reported through the Company’s whistleblowing channels. |
4.Strengthening Information Disclosure
The Company’s Procedures for Ethical Management and Guidelines for Conduct and its implementation outcomes are disclosed in the Annual Report and Sustainability Report. Principles and standards related to social responsibility – including commitments to ethical business practices, business ethics, and fair competition – are also published on the Company’s official website.
5.Other Important Information
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The Company complies with the Company Act, Securities and Exchange Act, Business Accounting Act, regulations related to listed companies, and other laws governing commercial conduct as the foundation for implementing ethical business practices. |
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The Company’s Rules of Procedure for the Board of Directors stipulate a system for directors’ recusal from conflicts of interest. Where a matter on the meeting agenda involves a director or the legal entity the director represents and may be detrimental to the interests of the Company, the director may present opinions and respond to inquiries but shall not participate in the discussion or voting, and shall recuse themselves during such discussion and voting. The director is also prohibited from acting as a proxy to exercise voting rights on behalf of other directors. |
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The Company has established the “Procedures for Handling Material Internal Information” and communicates them through written documents, internal notices, or training courses. Relevant personnel are prohibited from disclosing any material internal information they become aware of to others, and from inquiring about or collecting material internal information that is unrelated to their duties. |
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