Most Reliable Services

Business ethics & Integrity Management

CTCI Group Codes of Ethical Conduct

CTCI takes "Most Reliable" as its brand positioning. Its Codes of Ethical Conduct and Ethical Corporate Management Principles, which have been approved by the board of directors, serve as the ethical standards and codes of conduct that CTCI's directors, managers and all employees should follow when performing their duties, manage anti-corruption, fair trade, prohibition of insider trading, among other things, so as to prevent dishonest behavior.
　 
The Human Resources Department of CTCI is the dedicated unit responsible for promoting integrity management. It conducts annual integrity risk assessments and regularly summarizes CTCI Corporate Integrity Operations Policy, which is submitted to the board of directors. The audit unit formulates relevant audit plans every year based on the risk assessment results of dishonest conduct, prepares an audit report to be submitted to the chairman for approval. The audit results are reported to the dedicated unit for integrity management every quarter to ensure the effectiveness of the integrity policy.
　
　

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Implement Ethical Management - Education and Training Advocacy

In order to establish a responsible business ethics culture for all internal parties, for directors and supervisors, the Company conducts education and advocacy for directors, managers and employees on the "Measures to Prevent Insider Trading" and relevant laws and regulations at least once a year, and provide timely education and advocacy for new directors, managers and employees. Every year, regular training and signing of the CTCI Codes of Ethical Conduct are held for all employees of the Group (including formal, contracted and dispatched employees) to continue to emphasize CTCI’s integrity concepts of anti-corruption, integrity, commitment and honesty.  In 2024, the training coverage rate and signing rate are both 100%; for new recruits, courses related to ethical behavior are also arranged in the new employee training. In 2024, a total of 510 new recruits in Taiwan will be trained, and the coverage rate is 100%.
　

Anti-corruption and bribery

To prevent bribery and corruption, CTCI requires that employees should not give discounts when conducting trading activities with stakeholders, and cannot ask for, make deals with, give, or accept gifts, entertainment, kickbacks, or bribes for himself/herself or on behalf of others when carrying out his/her job duties. CTCI clearly defines in its Rules for Ethical Conduct the principles and penalties of "rules for gift receiving," "prevention of conflict of interest" and "protection of trade secrets and intellectual property rights." CTCI’s Code of Integrity Business prohibits the provision of illegal political donations and prohibits improper charitable donations or sponsorships to avoid disguised bribery. CTCI has checked the 20 lowest ranking countries in the Transparency International's Corruption Perception Index in 2024 and confirmed that it has no construction projects in those countries.
　
To promote anti-corruption policies, CTCI has incorporated anti-corruption and anti-bribery statements into its annual Code of Ethical Conduct training. In 2024, the training achieved 100% employee participation. CTCI regularly reiterates the "no gift acceptance policy" on three occasions every year through public announcements. Overseas projects are also implemented and promoted according to the same standards, and publicity and communication are also provided to contractors, customers, etc. Since procurement personnel are in direct contact with external manufacturers when handling procurement operations, in order to clarify personal responsibilities, all colleagues who belong to the procurement department should sign the Procurement Personnel Code, which specifically promises that procurement personnel should comply with legal requirements when performing matters and must not solicit personal improper benefits or accept compensations or any form of remuneration. A questionnaire survey will be conducted when new staff joins the procurement department to collect their personal information, so as to ensure that department work assignments avoid conflict of interests in purchasing operations. For staff at the construction site, CTCI continues to strengthen relevant publicity and training for them through online meetings, education and training, and post behavioral indicators of corporate culture at each construction site to ingrain the concept of integrity and sustainability among colleagues and contractors. There were no confirmed corruption incidents between 2020 and 2024.Therefore, there were no convictions related to corruption and bribery cases, nor were there any fines related to corruption and bribery cases.
　

Anti-Fair Competition

CTCI strictly abides by the law, practices honest business operations, and fully exercises professionalism and integrity. To ensure fair trade, fair competition and to prevent unfair competition, monopoly, joint inappropriate behavior, market collusions or collective price manipulations, CTCI always abides by a fair-trade spirit, regardless of project tenders or external contracted service/ procurement projects. In addition, whether participating in engineering bidding or external contracting or procurement, all biddings must be conducted in accordance with fair and open bidding procedures. In order to enhance the efficiency and quality of project tendering and procurement processes, CTCI always follows fair and open tendering process when competing for business targets. CTCI continues to extend the spirit of fair trading by encouraging all employees to file reports. Moreover, it continues to carry out employee trainings specifically for marketing and sales personnel, procurement representatives, legal affairs, contract personnel and other relevant department employees that may be involved in related risks and are required to regularly participate in antitrust law, fair trade law education, training and case analysis courses every year and pass the test. Colleagues in other departments can also take the courses to improve knowledge of regulations. According to latest statistics, between 2021 and 2024, the total number of trained employees (including new and current colleagues) who have completed relevant training courses has reached 420, and they are aggressively implementing fair trade and related laws and regulations in their positions.
　
When a CTCI employee is found to have violated or is in breach against regulations pertaining to anti-trust laws, the company would conduct a comprehensive and thorough investigation of the employee's work history and immediately suspend the employee’s external communications regarding the work. If a criminal offense is involved, the company would deal with it in accordance with the law. There were no anti-competitive behavior cases within CTCI Group in 2024.
　

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Reporting and Protection

To protect the Company’s interests and encourage individuals to report illegal or non-compliant activities, CTCI has formulated the Reporting Management Regulations, which defines the purpose, scope, responsibilities of various departments, and management procedures for the whistleblowing mechanism. To prevent misconduct, CTCI has set up an independent internal whistleblower mailbox and a reporting platform operated by an impartial, third-party organization. Internal employees or external parties who discover any illegal or improper conduct within the Group or among its partners, whether ongoing or imminent and potentially harmful to the Group, can choose to report such issues anonymously or under their real name through the appropriate channels. Furthermore, if employees have any concerns regarding ethical business conduct or the Code of Conduct, they may seek guidance from their direct supervisor, the Human Resources Department, or the Compliance Department.