The term “fraud”, used in this Policy, refers generally to any intentional act committed to secure an unfair or unlawful gain including, but not limited to, fraud, corruption, theft and other similar irregularities that reflect actual or potential:
- Misrepresentation in ECC’s publicly released financial statements or other public disclosures;
- Misappropriation or theft of ECC’s asset such as cash, inventories, corporate certificate, plant blueprints, material documents, equipment, tools or supplies;
- Unlawfully obtained revenue, expenses and assets or unlawful avoidance of costs and expenses;
- Claiming reimbursement for fictitious expenses;
- Commercial bribery or bribery of a government official or other violation of anti-corruption laws; or
- Improper payment schemes such as employees or Directors of ECC seeking or accepting from, paying or offering to, suppliers or business partners, kickbacks or gifts intended to or which may appear to influence business judgment.
ECC Whistle-blowing Policy
ECC’s Whistle-blowing Policy is intended to encourage and enable employees and partners in business to raise serious concerns within the company.
The ECC Whistle-blowing Policy identifies who could be whistleblowers, laying down the matters that are reportable hereunder, the procedures for whistle blowing, as well as their rights and responsibilities under the said policy.
ECC Gifts and Gratuity Policy
All ECC employees and officers are prohibited from requesting, accepting or offering any form of gifts or gratuities in connection with any corporate expenditure, sale of goods or services from all vendors, suppliers, customers, co-employees, contractors, consultants, potential employees, politicians, potential vendors or suppliers and any other individual or organization.
Gifts and gratuities include, but are not limited to, cash, tickets to events, sports and entertainment in general, paid vacations, electronic equipment, liquor, food, substantial favors and other items of value given by co-employees and third parties (e.g. vendors, suppliers, customers, contractors, consultants, potential employees, politicians, potential vendors or suppliers, and any other individual or organization to employees or officers with whom they transact, whether directly or indirectly, in relation to ECC business dealings, and regardless of the place where such gifts are offered to or received by an employee or officer.)
All efforts must be employed in the non-acceptance or the act of returning such gifts or gratuities received; these attempts or actual receipt of such favors must be reported/registered to the management and Ethics Committee.
ECC Workplace Ethical Relationship Policy
Employees are prohibited or must refrain from having personal close ties with suppliers, clients / distributors and co-employees in any kind of mutually benefiting relationship (i.e. sponsorship or god-parenting by way of marriage or baptism activities, romantic or sexual ties, etc.).
Superiors (i.e. supervisor, manager) should avoid accepting invitations to be a godparent of a subordinate, colleague or any employee within his scope of influence and vice versa. With that, the company also extremely discourages any romantic relationships between:
- Employee and contractor, supplier, customer;
- Immediate superior and subordinate; Superior with indirect subordinate, but has the power / influence over certain department and / or within the department
These relationships may bring potential conflict to the business interest of the company. In addition, this rule is to maintain an ethical standard and fairness during the job evaluation of any respective subordinate and undue treatment in general working conditions. Affected employees must report to Human Resources via updating their FBID forms or whenever a new entrant / applicant to the company is related.
Employees with direct or indirect contacts with vendors, distributors, contractors should strictly avoid from accepting or soliciting sponsorships / god-parenting from these third parties. For existing relations like this, granting or acceptance of any excessive gifts is also discouraged and should be reported to the company through FBID’s Declaration of Gifts form. This may influence ethical relationships concerning the company’s interaction with vendors, distributors, and contractors.
Related Party Transaction Policy
Electrical Safety Policy
Hazardous Waste Management Policy
Accident in Workplace Policy