Anti-bribery Statement
GigaDevice Semiconductor Inc.
Anti-Commercial Bribery Compliance Policy
GigaDevice Semiconductor Inc. (collectively, "GigaDevice" or the "Company") always adheres to the principles of fairness, integrity, and compliance in conducting businesses globally, dedicated to complying with all applicable anti-corruption and anti-bribery laws and regulations in all jurisdictions where GigaDevice does business, and upholding a "zero-tolerance" attitude towards any form of corruption and bribery, in order to regulate the Company's business activities, continuously enhance GigaDevice's competitiveness in the international market, and ensure compliance operations. To provide a long-term and effective guarantee for the Company's compliance development, GigaDevice has formulated this Policy based on actual situations.
This policy applies to all employees of the Company and its subsidiaries, affiliates, and branches at all levels (including all directors, management personnel, regular employees, and contract workers), as well as to its partners. They are required to comply with this policy and relevant anti-bribery compliance management requirements and guidelines in various areas (such as the GigaDevice’s Anti-commercial bribery management methods and the Code of Conduct Against Commercial Bribery), and uphold high standards of integrity and compliance. Specifically:
GigaDevice prohibits offering, promising, giving, soliciting or accepting any bribery (including, without limitation, cash, commissions, kickbacks, securities, or valuables), directly or indirectly, to or from any public officials, entities or individuals for the purpose of improperly influencing the recipient’s official duties, securing business opportunities, or obtaining other undue benefits.
GigaDevice prohibits participating in any reception and entertainment activities organized by organizations having business connections with the Company or their affiliates which may affect the business fairness or result in acquisition of improper benefits.
GigaDevice prohibits soliciting or accepting any non-business-related travel and training from any partners.
GigaDevice prohibits any off-the-book refund of a certain percentage of the product price to the counterparty or their related personnel in cash, goods, or other means.
GigaDevice prohibits engaging in business sponsorship activities where the legitimacy and rationality cannot be justified, such as sponsoring individuals, government departments, or business partners in sensitive business periods.
For other prohibitions related to commercial bribery, please refer to the Code of Conduct Against Commercial Bribery.
GigaDevice requires all cooperative partners to comply with all applicable anti-corruption and anti-bribery laws and regulations, and will take effective measures to ensure that its cooperative partners and third parties are aware that they are required to adhere to the highest standards of integrity and relevant anti-corruption and anti-bribery compliance requirements in conducting any behavior or business on behalf of GigaDevice.
To ensure the effective implementation of GigaDevice's compliance system, in the aspect of organizational structure, GigaDevice has set up a comprehensive and multi-level anti-commercial bribery management organizational structure, which is led by the Board of Directors, managed and supported by the General Manager's Office, and implemented by the Company's Compliance Committee, Anti-commercial Bribery Management Department, Anti-commercial Bribery Supervision Department, and other departments. The Company's business departments, Anti-commercial Bribery Management Department, and Anti-commercial Bribery Supervision Department jointly build three lines of defense for anti-commercial bribery management, jointly identifying, preventing, and responding to any potential commercial bribery compliance risks. GigaDevice will conduct anti-commercial bribery compliance training as compulsory training program for employees. Such training will promote employees' compliance awareness and help them understand the Company's every anti-commercial bribery compliance requirement.
GigaDevice encourages all employees and cooperative partners to report any suspicious behavior. GigaDevice strictly maintains the confidentiality of whistleblowers’ identities and reporting content, and prohibits any form of retaliation or discrimination against whistleblowers. (Refer to the Reporting and Informant Protection System for details.) Any conduct involving personal gain or breaches of the Company’s compliance standards shall be reported immediately to the Internal Audit Department. The Company’s Internal Audit Department will promptly review and investigate all whistleblowing reports concerning suspected corruption, bribery, or unfair competition. Serious violations will be subject to disciplinary actions, including but not limited to warnings, suspension, or termination of employment. Where laws are violated, the case will be referred to judicial authorities. The Company will conduct irregular review investigation records and outcomes, and report findings to senior management. GigaDevice will not tolerate any behavior that undermines its reputation or interests, nor will it allow anyone to cross legal or compliance red lines.
GigaDevice ensures that whistleblowing channels, including hotline and email, remain open and accessible. Employees and relevant business parties may report concerns through the following designated channels:
Report hot-line: (86) 10 82881666-1166
E-mail: woodpecker@gigadevice.com
Mailing Information:
Mailing Address: Building No.8, IC Park, No.9 Fenghao East Road,Haidian, Beijing, China
Recipient: Internal Audit Department
GigaDevice Semiconductor Inc.
