TSMC is committed to conducting business honestly and ethically. This commitment to integrity, our most basic and most important core value, has been the cornerstone of TSMC’s robust compliance efforts, which is comprised of legislation monitoring, compliance policies, training and an open reporting environment.
TSMC operates in many countries. Therefore, in order to achieve compliance with governing legislation, applicable laws, regulations and regulatory expectations, we closely monitor domestic and foreign government policies and regulatory developments that could have a material impact on TSMC’s business and financial operations. We are also a proactive advocate for local legislative and regulatory reform and have achieved remarkable results in strengthening trade secret protection in Taiwan. TSMC is increasingly dedicated to identifying regulatory issues and will continue to be involved in advocating public policy changes that foster a positive and fair business environment.
In addition to TSMC’s Code of Ethics and Business Conduct, TSMC has also established policies, guidelines and procedures in other policy areas, including: Anti-bribery/corruption, Anti-harassment/ discrimination, Antitrust (unfair competition), Environment, Export Control, Financial Reporting/Internal Controls, Insider Trading, Intellectual Property, Proprietary Information Protection (“PIP“), Privacy, Record Retention and Disposal, as well as procuring raw materials from socially responsible sources (“Conflict-free Minerals“). With respect to PIP, it is one of the six key corporate strategies of TSMC (as announced in June 2010). TSMC and its employees are expected to comply with all laws and regulations that govern our businesses.
Training is a major component of our compliance program, conducted throughout the year to refresh TSMC’s employees’ commitment to ethical conduct, and to get updated information on any changes to the law. Highlights of our compliance training program include the following:
In addition to the above programs, a variety of resources and compliance campaigns are made available to our employees. For example, compliance education and articles on different topics are published regularly on TSMC’s Legal Organization website. Furthermore, employees can familiarize themselves with TSMC’s internal policies through easy access to our intranet channels.
To ensure that our conduct meets the highest legal and ethical standards, TSMC provides multiple resources for reporting business conduct concerns. We encourage employees to report suspected wrongdoing within the organization or any parties with whom we do business. The system is also open to external reporting. Auditing employees for PIP policy compliance is conducted regularly to ensure protection of TSMC’s proprietary information, including information that suppliers, customers and others have entrusted to us. Disciplinary actions are taken against employees who have violated the policy. Below is a summary of the Number of Reported Incidents:
|
FY 2012 |
FY 2013 |
---|---|---|
Incidents Submitted to the Ombudsman System (Note 1) |
20 |
35 |
Incidents Submitted to the Audit Committee Whistleblower System |
- |
- |
Incidents Reported to the “Hotline“ |
8 |
19 |
3 |
1 |
|
Sexual Harassment Investigation Committee |
6 |
7 |
- |
5 |
|
PIP Violations |
108 |
84 |
104 |
84 |
|
4 |
- |
Note 1: There is no case for ethics, finance and accounting matters.
Note 2: More than one-third of the cases reported were for minor errors or noncompliance with our PIP Policy.
Major Accomplishments
In 2013, TSMC’s excellence in regulatory compliance achieved several major accomplishments, including: