Integrity Management

Integrity Management and Anti-Corruption Regulations

In order to establish a corporate culture of integrity and effectively prevent corruption and improper transactions, the company has formulated the "Code of Integrity" and "Reporting Procedures for Illegal or Unethical Behavior," which clearly regulate all directors, supervisors, managers, employees, and substantial controllers of the company. It strictly prohibits the direct or indirect provision, promise, request, or acceptance of any form of improper benefits during the course of business activities, or engaging in dishonest behaviors that violate integrity, laws, or fiduciary duties. The targets of such actions are not limited to public officials, political parties, or any business counterparties. Violators will be severely punished in accordance with company regulations and relevant laws.
To maintain a sound integrity management, the company is responsible for the formulation and supervision of integrity management policies and prevention plans by the administrative department, and reports regularly to the board of directors.

In addition, the company's chairman, general manager, and senior management receive periodic education and training, and invite relevant personnel engaged in business activities with the company to participate, conveying the importance of integrity.
The company has also integrated its integrity management policy with employee performance evaluations and human resources management policies, establishing a clear reward and punishment mechanism. In 2024, there have been no incidents of violations of integrity management at GMT, and no employees have been dismissed or faced disciplinary action due to corruption.

Communication Channels and Reporting System

The company has established the "Code of Integrity" and "Code of Ethical Conduct", and has integrated them into the employees' "Employment Contracts", which must be signed before joining the company, committing to adhere to the company's integrity-related regulations.
After officially taking office, according to the company's "Employee Work Rules", the company strictly prohibits engaging in private fraud, misappropriation of public funds, accepting bribes or commissions, and other improper benefits. Employees are not allowed to take on external part-time jobs without permission, which may affect the execution of official duties, or to solicit actions that damage the company's reputation in the name of the company.
In addition, in the "Employment Contract", besides stipulating the employee's obligation to perform loyalty and confidentiality duties, it also clearly considers the ownership of documents and items, as well as intellectual property rights, as company secrets, prohibiting the use of original positions or information leaks or engaging in competition after leaving the company, in order to protect the company's business secrets.
For any suspected illegal or unethical behavior, the company has established multiple reporting channels, including a hotline, email, and written submissions to the audit department, which are handled by the spokesperson and the audit department for internal and external reporting cases.
When any illegal behavior is detected, the company will promptly initiate an investigation procedure and report the results to the chairman and independent directors after verification.
The identity of the whistleblower will be kept strictly confidential throughout the process and necessary legal protection will be provided to ensure that the whistleblower is protected from improper retaliation.
It has been verified that there are violations. In addition to immediately stopping the related behavior, disciplinary measures such as dismissal, termination, or legal prosecution will be implemented according to the severity of the situation, and the internal control system will be reviewed to prevent reoffending.
To enhance the overall transparency and integrity culture of the company, the company has established a "Code of Ethical Conduct," which includes basic ethical standards such as preventing conflicts of interest, protecting the company's confidential information, fair trading, and appropriate use of company assets, ensuring that all operational decisions comply with the highest ethical standards and legal requirements.