To implement sound ethical corporate management (ECM), our HR Department has been given the responsibility of establishing and supervising our ECM policies and prevention programs, and reports to the Board of Directors on a yearly basis.
The primary responsibilities of our ECM unit are to:
Each year, we engage in ECM-related education and testing, actively implement ethical values and integrity, and strengthen our corporate governance and risk management to deeply embed our ECM culture into all employees.
In 2020, our ECM lectures, director and supervisor corporate governance courses, and legal/auditor corporate governance courses were attended by 269 people from our investment and management companies for a total class time of 365 hours. Our company had no incidents of unethical behavior in 2020.
Our Board of Directors has passed a resolution on “Procedures for the Prevention of Insider Trading”, which requires any staff participating in projects involving confidential information that may have a major impact on share prices to sign an “Prevention of Insider Trading Letter of Undertaking” and “Non-disclosure Agreement”.
If a meeting of the Board of Directors involves major issues or motions that may have an impact on the company’s share price, our legal department will remind the directors and managers present of the regulations prohibiting insider trading under Article 157-1 of the Securities and Exchange Act.
When carrying out ECM-related training, personnel from our legal department will educate staff on the regulations prohibiting insider trading.