Ethical Management

We will be a company that creates the highest value with honesty and trust.

CEO Message

Ethical Management Policy

We will be a company that creates the highest value with honesty and trust through ethical management.

In fulfilling its corporate ethical responsibilities, AnaPass strives to fulfill its economic and legal responsibilities. In addition, we are committed to educating and encouraging all employees to share and comply with the company's ethical management policy based on the ethics regulations distributed internally and externally.

Ethics Policy

Last revised February 10, 2022

• Chapter 1. General Rules

  Article 1 (Purpose)

  The purpose of this regulation is to define the standards of behavior that employees of AnaPass (hereinafter referred to as the “Company”) shall comply with in terms of ethics and integrity as well as legal and social aspects.

  Article 2 (Ethical Management)

  • The Company applies the highest ethical and legal standards in conducting its business and requires strict ethics and honesty from all employees in order to comply with these policies.
  • Employees shall familiarize themselves with and comply with the ethical regulations and be held responsible for any violations.
  • Employees shall immediately notify the Company if they discover or suspect a violation of the Code of Ethics, and the Company shall take action in accordance with the disciplinary provisions if a violation is confirmed.
  • The CEO, executives, director of department, and team leaders have a duty for managing and supervising their own employees.
  • Operation of the Ethics Committee
    • Composition: The Ethics Committee shall be composed of the auditor, the director of the business support department, and the director of the business management department.
    • Duties: The Ethics Committee shall conduct an inspection for the management and supervision of ethical management related to compliance with ethical regulations, and employees shall cooperate with it as best they can.
  • Education and Bulletin Board Posting:
    • Regular training: The Company shall conduct ethics training for all employees at least once a year.
    • Bulletin Board Posting: The Company shall post the Ethics Regulations and Code of Ethics on the Company's bulletin board so that employees can continuously read and recognize them.
  • Operation of Internal Reporting System
    • The Company operates an internal reporting system to promptly report and follow up on any violations of ethics regulations.
    • The Company shall protect the identity of employees who report violations of ethics regulations.
    • The Company guarantees that there is no form of retaliation or disadvantage for reports made in good faith, and disciplinary measures will be taken in the case of intentionally making a false report.
    • If there is a concern about the exposure of the reporter's information, anonymous reporting is possible. However, the company may not proceed with an inspection, if the contents of the report are excessively slanderous or unclear.
    • Details of the internal reporting system shall be in accordance with the separate internal reporting system regulations.

  Article 3 (Compliance with Laws and Regulations, etc.)

  The Company and its employees shall comply with the laws, conventions and regulations of all countries where the Company conducts its business, and shall comply with international conventions and regulations on investment and transactions, such as the OECD Anti-Bribery Convention, and respect the laws and culture of those countries.

  Article 4 (Environmental Protection, etc.)

  The Company and its employees shall recognize the importance of environmental issues, fully understand and comply with domestic and foreign environmental laws and regulations, and try to protect the environment and prevent pollution.

  Article 5 (Material Management, etc.)

  • In the process of acquiring materials such as minerals, strategic materials, and illegal wood from conflict areas, the Company shall prohibit the use of those material in the supply chain that may cause serious human rights violations and environmental destruction, and shall endeavor to comply with national laws and international regulations.
  • The Company shall endeavor to comply with all relevant laws, regulations and customer requirements for the regulation of substances in its products.

  Article 6 (Community Contributions, etc.)

  The Company and its employees shall contribute to the development of the country and local communities by creating social wealth through responsible management.

• Chapter 2. Creating a Healthy Climate

  Article 7 (Mutual Respect)

  • Employees shall treat each other as dignified human beings and follow basic courtesies necessary for work life, and shall not engage in behaviors that cause distress, such as disrespectful language or slandering other employees.
  • The Company shall grant equal opportunities to employees according to their individual abilities and qualities in training and promotion, and fairly evaluate and reward their performance and achievements.
  • The Company and its employees shall respect religious and political opinions and privacy and shall not create cliques or discriminate on the basis of any reasons, such as gender, education, age, religion, region of birth, and physical disability.
  • The Company shall establish a system to enable employees to perform their duties fairly and create conditions for all employees to make suggestions and express their opinions freely.
  • The Company shall prevent infringement of personal privacy and comply with information protection laws and regulations.
  • Executives and employees shall not engage in sexual harassment and any sort of behaviors that significantly cause sexual shame to each other.
  • Executives and employees shall not engage in unfair solicitation, excessive gift giving or monetary transactions in accordance with social conventions.
  • The superiors shall not give unfair instructions to the inferiors and the inferiors shall follow the legitimate instructions of the inferiors but refuse unfair instructions.

  Article 8 (Safety Guarantee)

  • The Company shall create a working environment where employees can work comfortably and safely.
  • Employees shall do their best to prevent disasters and risks by maintaining the cleanliness of the workplace and complying with all laws and standards regarding safety.

  Article 9 (Protection of Assets and Information)

  • Employees shall protect the Company's tangible and intangible assets and information and use them appropriately for legitimate business purposes, and shall do their best to do so.
  • Employees shall not cause material damage to the Company by using the Company's assets for personal use or the Company's budget for purposes other than those intended.
  • Employees shall pay sufficient attention to the use of computers and network systems to maintain security and protect the proprietary and confidential information of customers and the Company.
  • Employees shall endeavor to protect the personal information of customers and employees, and shall comply with relevant laws.

  Article 10 (Protection of Interests)

  • The Company and the employees shall endeavor to provide the best products and services to customers, and shall handle customer opinions, suggestions, and complaints as promptly and fairly as possible.
  • Employees shall protect the assets, intellectual property rights, trade secrets, customer information, personal information of customers and the Company, and shall not infringe on the interests of customers and the Company through immoral behavior.
  • The Company and the employees shall acquire competitive information in a legal and ethical manner.
  • The Company and the employees shall comply with relevant laws to avoid infringing on the interests of customers through unfair transactions such as collusion.

  Article 11 (Transactions with Business Partners)

  • Employees shall grant equal opportunities to all qualified individuals or organizations and conduct transparent business in the purchase of services and goods, bidding, contracting, and contract fulfillment of the Company.
  • All transactions shall be fairly conducted on an equal position and shall be conducted transparently in public and daily places of business.
  • The company and the employees shall not make unfair demands, such as demanding money or forcing unfair trade condition by using their superior position.
  • Employees shall not leak information provided by suppliers to the outside without the consent of suppliers or use it unfairly.

  Article 12 (Provision of Information)

  • The Company shall announce management information based on facts in accordance with relevant laws and generally recognized principles for management records and other financial information to enhance transparency and reliability.
  • The Company shall establish and implement reliable internal control procedures.
  • Employees shall acquire and manage all information transparently, and the Company's account and records shall be fairly recorded and properly kept based on the facts of the transaction without intentional omission or falsification.
  • Employees shall not make false or exaggerated reports for the benefit of a particular individual or department, and shall not conceal or monopolize important information.
  • Employees shall not leak or unfairly use internal information acquired in connection with their duties without proper authorization from the Company.

  Article 13 (Conflict of Interest, etc.)

  • Employees shall prioritize the interests of the Company over personal interests when performing their duties.
  • Employees shall not hold an additional jobs or outside jobs that may impair the efficiency of the Company's business or impair the fairness of business. However, this clause excludes the additional job due to the company's management needs.
  • Employees shall consult with the Ethics Committee if they have a conflict of interest with a customer or the Company, or if they need to perform work in a situation where a conflict of interest may arise.
  • Employees shall not engage in property transactions or investments related to securities, real estate, using information acquired in connection with the performance of their duties, and provide such information to others to assist them in property transactions or investments.

  Article 14 (Voluntary Report of Criminal Prosecution, etc.)

  Employees shall report to the Ethics Committee without any delay if they have been indicted in a criminal case or have been sentenced to a fixed term of imprisonment or higher.

• Chapter 3. Prohibition of Receiving Unfair Gains

  Article 15 (Restriction on Receiving Money, etc.)

  • Employees shall not accept money, real estate, gifts, or any sort of convenience (hereinafter referred to as “money, etc.”) from interested parties, except for of meals, gifts, and convenience that are generally accepted in social convention. In addition, if the stakeholders or their spouse is a public official, the employees shall comply with Improper solicitation and graft Act.
  • Spouses and lineal ascendant and descendant of employees shall not accept money, etc. prohibited from receiving from interested parties under clause 1.

  Article 16 (Prohibition of Providing Money, etc.)

  • Employees shall not provide money, etc. to public officers or politicians who are related to their duties for the purpose of the company's interests.
  • Employees shall not provide money, etc. that may impair fairness beyond the scope accepted by social convention to the person interested.
  • Spouses and lineal ascendant and descendant of employees shall not provide money, etc., prohibited by clause 1 to public officers or politicians who has their interest on their duty.

  Article 17 (Handling of Prohibited Gifts, etc.)

  • If employees receive money etc., that violate the provisions of Article 15, they shall immediately return it to the provider. In this case, the return cost may be charged to the Company with documentation.
  • If there is a risk of loss, decomposition, deterioration of the money etc., to be returned under clause 1, or if the provider or the address of the provider is unknown, or if there are any reason that make it difficult to return it to the provider, employees shall immediately transfer it to the Ethics Committee.
  • The Ethics Committee shall handle the money etc., transferred pursuant to the provisions of clause 2 in accordance with the following criteria.
    • Money etc., that have no economic value due to loss, decomposition, deterioration shall be scrapped.
    • Other Money etc., shall be donated to a social welfare corporation.
  • The Ethics Committee shall keep a record of the provider, recipient, delivered Money etc., date of delivery and the details of the delivery in a designated form, and notify the provider of the relevant facts. However, if the address of the provider is unknown, it shall not be notified.
• Chapter 4. Measures in case of violation

  Article 18 (Consultation on Violation)

  Employees shall immediately notify the Company if they discover or suspect a violation of these Regulations in the performance of their duties, and if the violation is not clear, they shall consult with the Ethics Committee. If a violation of ethics regulations is confirmed, measures shall be taken as stipulated in the disciplinary provisions.

  Article 19 (Reporting and Confirmation of Violations)

  • When employees become aware of a violation of these regulations, they shall report it to the Ethics Committee or report it through the website.
  • In accordance with the provisions of Article 18, the reporter shall specify the personal information of itself and the violator and the details of the violation.
  • The CEO and the Ethics Committee to whom a violation has been reported pursuant to the provisions of clause 1 shall ensure confidentiality of the reporter and the contents of the report, and shall ensure that the reporter does not suffer any disadvantages as a result of the report.
  • The Company shall ensure that no form of retaliation is taken against a report made in good faith, and shall take disciplinary action if intentionally making a false report.
  • The Ethics Committee shall confirm the violation reported pursuant to the provisions of clause 1 and report it to the CEO with documentation submitted by the violating party.

  Article 20 (Discipline, etc.)

  • The CEO can take necessary measures such as disciplinary action against employees who violate these regulations, and if the reporter suffers retaliatory acts from the violator, The CEO can additionally take separate disciplinary action for the retaliatory acts to the violator. Disciplinary action will follow the Employment Rules.
  • In addition to the disciplinary action in clause 1, when determining whether to pay bonuses and incentives and the amount of payment, the Company can restrict payment or apply separate standards to employees who violate the ethics regulations.

  Article 21 (Applicable Rules)

  Matters not specified in these Regulations shall be governed by the Company's management regulations, the EICC Code of Conduct, relevant laws and regulations, and convention.

• Chapter 5. Supplementary Rules

  Article 22 (Approval Procedure)

  These Regulations shall be approved by the CEO and posted on the website.

• Additional Rules
  • (Effective Date) These Regulations shall take effect on April 1, 2017.
  • (Amendment Date) These Regulations shall be amended as of May 1, 2018.
  • (Amendment date) These Regulations shall be amended from June 29, 2021.
  • (Amendment Date) These Rules shall be amended as of February 10, 2022.

Ethical Management Organization

The Ethics Committee for Ethical Management is composed of the Auditor, Director of Business Support Department,
and Director of the Business Management Department, and the Ethics Committee conducts audit work
for compliance with ethical regulations, management, and supervision.

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  Ethics Committee

  Auditor
  Director of Business Support Dep.
  Director of Business Management Dep.

• 

  Ethical Management

• 

  Practicing Ethical Management

  Employees

Code of Ethics

AnaPass employees are committed to building the No. 1 company leading the world's display semiconductor design technology
by valuing relationships with all interested parties, complying with social responsibility, and practicing sustainable management.

• AnaPass employees

  shall not engage in any unethical behavior with a sense of mission as “leading people leading display semiconductor technology”.

• AnaPass employees

  will comply with social norms and laws, stick to principles, and create a sound corporate culture where all members can trust each other.

• AnaPass employees

  shall not use company assets for personal interest, and shall not accept or request any money, rewards, or entertainment in performing their duties.

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