Both companies ensure that their respective Code of Ethics is cascaded to new team members as part of their onboarding processes. Team members are also required to sign an affirmation that they have read the Code of Ethics. They are expected to act professionally, fairly, and with integrity in all of their business dealings, and to comply with all applicable laws and regulations, including those against bribery and corruption.
To support the implementation of their respective Manual and Code of Ethics, AEV has a Whistleblowing Policy. Through this policy, allegations of violations of the Manual, the Code of Ethics, or of other illegal conduct can be reported through an internal portal or through the company’s website. Matters reported through the whistleblowing platform are discussed by the Board Corporate Governance Committee and, if necessary, by the entire Board of Directors. Whistleblowers have the option of addressing complaints to any of the following officers: Chairman of the Board of Directors, President or Chief Executive Officer, Lead Independent Director, Compliance Officer, or Internal Audit Head. It is noteworthy that no corruption-related incidents were reported in 2018.
The Revised General Trading Policy supplements the commitment under the Code of Ethics to prevent the misuse of inside information, emphasizes reporting and disclosing material information, and the rule on prohibited insider trading. AEV, as a listed company, is required to report transactions of company shares by their directors and officers. To ensure the strict compliance with this requirement, directors and officers are advised of their disclosure obligations during their onboarding with the Group. The company’s Compliance Officer also sends out a monthly reminder to directors and officers to disclose their transactions. In 2018, there was no incident of non-compliance with this requirement.