We are aware that integrity management and elimination of bribery and fraud are the foundation of corporate sustainability development. Corruption and unethical conduct in business will give rise to loss of goodwill, losses to many stakeholders, and damage to the corporate image.
We advocate integrity and ethical business conduct and follow laws and regulations. In addition to complying with national laws and regulations, we have also established the “Procedures for Ethical Management and Guidelines for Conduct.” Our employees, managers at all levels, and members of the board of directors are all highly self-disciplined to embody ethical behaviors literacy and professional ethics in the workplace. We recognize the integration of labor and capital, provide various remuneration and benefits, reward employees for their hard work and encourage employees to strive to achieve operational goals, and at the same time attract and keep the professional talented people needed by the Company.
Kedge Construction formulated the “Corporate Integrity Management Code,” “Procedures for Ethical Management and Guidelines for Conduct,” “Reporting Procedures for Violations of Integrity Management,” and “Donation Management Regulations” so as to strengthen and implement the integrity management policy, and prevent dishonest behavior and business activities.
The Company has established a Corporate Governance Group under the Sustainable Development Committee. The Corporate Governance Group and the Integrity Management Group, based on the responsibilities and scope of each unit, are responsible for promoting the implementation of integrity management and anti-corruption measures within the Company, ensuring the implementation of integrity management guidelines, and reporting the execution results to the Board of Directors once annually.
The Company has incorporated integrity in business practices as part of its new employee training program. In 2025, the completion rate for the integrity in business practices course for new employees was71%. The completion rate decreased compared with the previous year, as some new employees left the Company during their probationary period.The Company also regularly offers relevant courses each year to ensure employees understand the Company’s values, work rules, integrity standards, conflict of interest guidelines, and personal data confidentiality measures. This enables all employees to conduct business in compliance with laws, regulations, and the Company’s internal control systems, while upholding personal integrity and social ethical standards to safeguard the Company’s assets, interests, and reputation. In 2025, a total of 8 business integrity-related courses were offered, with 858 participant-times recorded―an increase of approximately 90% compared to the previous year. The total number of training hours was 902, representing an increase of approximately 82% compared to the previous year. The scope of these courses covered the following topics:
In addition to educational training, the Company also requires new employees to sign undertaking letters upon employment, requiring compliance with confidentiality obligations and the Corporate Integrity Management Code and other related regulations to implement the Company’s integrity management practices. The employee signing rate was 100% in 2025.
To implement integrity management policies, Kedge Construction has also incorporated supply chain partners into the scope of integrity management promotion. Clauses requiring suppliers to comply with integrity management responsibilities are included in supplier procurement contracts, and suppliers are required to sign related undertaking letters. Violations will result in contract termination and damage compensation, thereby regulating supplier compliance. In 2025, the number of supplier undertaking letters signed was 656, with a signing rate of 100%.
Additionally, Kedge Construction has established an integrity management zone on the Company’s official website, where anyone can follow proper whistleblowing channels and contact designated personnel regarding discovered matters according to the “Reporting Procedures for Violations of Integrity Management.” The complaint hotline is (02)2378-6789 extension 25333. As of 2025, the Company has not been involved in any incidents of unethical business conduct.