Integrity Management and Legal Compliance
Brogent has established the Ethical Corporate Management Best Practice Principles, the Code of Ethical Conduct for Directors and Managerial Officers, the “Employee Code of Conduct”, the Operating Procedure for Prevention of Insider Trading, and the Reporting Policy of Unlawful or Unethical Actions in order to guide our directors, managers, and employees in upholding integrity, complying with the law, and fulfilling their fiduciary duties in conducting business activities, maintaining operational soundness.
Internally, Brogent requires employees to abide by the Employee Code of Conduct in all business activities around the world, regulating all internal and external business and non-business dealings. Through establishing these management rules and working procedures, we have created a set of rules for our employees to follow during business operations, lowering the risk of corruption. New employee training courses and regular annual educational and training courses are used to teach employees about the Company's rules on internal and external, business and non-business interactions. Through an after-training evaluation, employees would be assessed on whether or not they understand the Company's rules.
Externally, we use the "Supplier's Commitment" to require suppliers to not agree to or bribe related personnel, and require suppliers to comply with Brogent's sustainable development requirements. We also established the Reporting Policy of Unlawful or Unethical Actions. If Brogent employees violate the integrity clause by demanding or accepting improper benefits from a third party, or directly or indirectly benefiting themselves or related parties, it may be reported through the reporting channel on the official website. Brogent provides a dedicated e-mail: legal@brogent.com for handling reports and complaints regarding any business conduct. Brogent keeps the sources of reports strictly confidential, investigates and handles all contents of reports, and takes special measures to protect whistleblowers, in order to reduce corruption and fraud.
It is the basic responsibility of a company to comply with the law in its operations. Brogent strictly abides by the regulatory requirements of relevant competent authorities in corporate governance, product R&D, manufacturing, installation and testing, and after-sales service. The Legal & IP Department provides the latest regulations to each unit on a monthly basis. Each unit strictly abides by relevant regulations and orders when performing their duties in accordance with the "Legal Compliance Management Guidelines," and conducts annual evaluations according to the "Self-Evaluation Form on Legal Compliance."
Brogent organizes education and training on legal compliance awareness and legal knowledge for our employees every year. The departments may consult with the legal unit for professional opinions when in doubt of applicable laws. The competent authority or external consultants may be consulted when necessary.
Brogent also requires its suppliers to commit to abide by Brogent's sustainable development requirements, and verifies the laws and regulations of the manufacturing and importing country. The laws and regulations of the importing country and those required by the customer are provided to supplier in the product specifications, so that suppliers will produce compliant components and the products will comply with international conventions. We ensure that the products we deliver do not use conflict minerals from the Congo and surrounding countries and regions, and that the products provide positive benefits.
In 2023, the Company was not found in violation of laws related to ethical corporate management or corruption, nor did it accept or provide any political donations. We have not incurred any major fines or non-monetary penalties for violating environmental protection, social, or economic laws and regulations.