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Human Rights Policy

To protect the basic human rights of employees, SKFH complies with the “Universal Declaration of Human Rights”, the “UN Guiding Principles on Business & Human Rights”, the “UN Global Compact”, the “ILO Declaration on Fundamental Principles and Rights at Work”, and abide by local laws and regulations in Taiwan in order to create a working environment that values personal dignity and value. SKFH has formulated the "Statement on Human Rights" in order to fulfill its corporate social responsibilities and protect the basic human rights of all employees, customers, suppliers, and stakeholders.

 

In 2023, SKFH and its subsidiaries held a total of 134 human rights-related education training sessions, including training for human rights statement, business secrets and whistleblower protection, consumer protection, prevention of sexual harassment at the workplace, protection of CRPD (The Convention on the Rights of Persons with Disabilities) disabled people's rights and interests, workplace stress adjustment and emotional management, prevention of workplace violence, etc. for more than 59 thousand trainees. All employees have completed education and training related to legal compliance and human rights statement.




 

Human Rights Due Diligence Process

SKFH values human rights issues. To regularly examine the implementation of human right protection, the Company established not only Human Rights Statement but also the Human Rights Due Diligence Procedures Process. Through the internal and external communication channels and under the development trends of the domestic and overseas human rights issues, we collect the potential human rights issues in the operating process, value chain activities and even the new business development relationships, assess the high and low possibilities of various issues with the relevant units, the severity of the impact on the value chain and the stakeholders who may be impacted (such as all employees, customers, suppliers, investing and lending subjects, etc.). For the human rights issues with higher probability of occurrence and more severe impact on the organization, SKFH shall assign the relevant business units to conduct regular risk assessments, formulate mitigation plans and remediation actions to manage and reduce the identified risks and have proper responses when the risk occur. SKFH shall regularly review and amend the current human rights policy and strategies to meet regulations and prevail moral standards of the society. SKFH shall annually investigate and verify the effectiveness of the execution, compile results into the Human Rights Due Diligence Report for public disclosure.







 

Human Rights Due Diligence Results and Management measures

In 2023, in compliance with the human rights due diligence process, SKFH and its subsidiaries jointly conducted risk assessments for those who may be affected in the course of operations, including employees, suppliers, customers, and other stakeholders. Five major human rights issues, including "labor-management relations", "Forced Labor", "anti-discrimination & equal remuneration",  "privacy protection", and " occupational health and safety" have been identified by the assessment. At the same time, we also conducted ESG audits of our investing and lending subjects as well as joint ventures to assess whether there were potential human rights risks. For high-risk groups, the Company and subsidiaries established related management and mitigation plans for implementation. In 2023, SKFH and its subsidiaries have all performed the implementation management and mitigation plans and taken the relevant actions and compensations in response to the actual incidents. 

 

Human right risk matrix diagram






 

Human Rights Due Diligence Survey Table

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Stakeholders Risk Issues Risk ratio Mitigation Plans Implementation Ratio of Mitigation Plans Remediation Actions
Employees
Labor Relations
 0.00%
  • Comply with labor laws and regulations, and clearly set out in work rules and personnel regulations.
  • Regularly hold labor-management meetings and set up a “Sales personnel  Opinion Mailbox”.
  • Regularly organize labor law courses to help employees understand their own labor rights and assist managers in establishing appropriate management approaches.
  • Provide diverse communication channels. Not only timely communicate operations-related information to employees but also collect employee opinions to promote harmonious labor-management relations.
   100% 
  • Provide compensation according to the mediation plan.
  • Strengthen internal communication mechanisms.
  • Establish internal employee complaint handling guidelines to assist employees in filing complaints about personal rights or unfair treatment in the workplace. 
 
Forced Labor 5%
  • Comply with labor laws and establish normal work hours in the work rules and personnel regulations. Strengthen and promote education and training on work-life balance for employees.
  • The attendance management system monitors attendance records on a weekly basis and checks for any abnormal work hours.
  •  Review the overtime status of each department on a monthly basis and provide support to employees whose monthly overtime hours exceed 40 hours through their respective supervisors.
  • Provide a flexible work hour system, a leave system, and a pre-scheduled vacation mechanism, and regularly review the usage of special leave  by employees.
 100%  
  • Provide the overtime pay or overtime compensatory leave. Employees can choose the compensation method for their overtime.
  • Unused annual leave can be converted to wages.
  • Implement a daily overtime reminder system to help employees and managers monitor work hours and overtime hours.
Diversity and Equality (Anti-Discrimination)   0.00% 
  • Establish a "Statement on Prohibition of Discrimination, Harassment, and Violence in the Workplace" to protect all employees against discrimination based on gender, sexual orientation, and other conditions in the work environment.
  • Conduct prevention education and training on sexual harassment and violence, including:
    • Workplace violence and handling methods (internal complaint reporting mechanism, awareness of potential risks in the workplace, communication skills for dealing with potential risks, and knowledge of relevant laws on violent  behavior).
    • Prevention of workplace sexual harassment and stalking harassment.
    • Education on gender equality and diversity.
  • SKL assigned colleagues to serve as " DEI Ambassadors" and participate in courses on understanding unconscious bias. 
  • Develop guidelines for preventing and investigating sexual harassment complaints, establish a dedicated section for receiving sexual harassment complaints, and assign designated personnel to effectively handle these cases.
  • A sexual harassment complaint handling committee was established to review relevant cases, and 2/3 of the committee members are female.
  • In regard to the individual involved in the established investigation case, disciplinary actions will be carried out according to personnel management regulations, and unit changes shall be implemented according to the circumstances.
  Privacy Protection  0.00%    
  • Develop the "Reference Guide for the Privacy Protection Statement of SKFH and Its Subsidiaries", the "Personal Data Management Policy", the "Data Sharing Policy", and the "Management Guidelines for Joint Marketing among Subsidiaries", in order to establish a comprehensive mechanism, defense, and management process for personal data confidentiality.
  • Incorporate personal data protection practices into the risk management system and assessment of compliance with relevant laws and regulations.
  • Establish the "Personal Data Protection Management Team" to plan and promote personal data protection practices and set up a comprehensive mechanism to safeguard personal information.
  • Offer training and education on personal data protection, and conduct assessments on relevant laws and regulations.
  • Introduce the ISO 27001 Information Security Management System. 
     100%  
  •   Create a comprehensive reporting procedure for personal data breaches.
  • Strengthen internal promotion mechanisms for privacy protection.  
Occupational Health and Safety 7%
  • Implement annual health checkups for on-site employees, and are graded according to the health results. SKL even expands the scope of health checkups to include field sales agents. MLS provides employees with deferred health check-up benefits: Unused quota from the previous year will be upgraded for health inspection in the next year.
  • Regularly perform investigations into the link between abnormal workloads and illness to examine the employees' status in terms of "personal-related overwork" and "work-related overwork.”
  • Introduce the ISO45001 Occupational Health and Safety Management System.
  • Conduct annual health promotion activities to promote and improve employee health.
  • Arrange occupational health consultations and health guidance for high-risk health management cases to avoid disease deterioration.
  • Organize annual health promotion activities for the sub-healthy group to improve the physical health of employees.
  • Provide on-site physician consultation services to offer advice on health and disease prevention to employees.
Female Employees Occupational Health and Safety -Maternity Protection 1%
  • Continue to implement the workplace maternal health protection plan and implement occupational doctor interviews and health guidance.
  • Provide maternity leave, paternity leave, flexible working hours and leave without pay that are superior than the statutory requirement.
  • Set up Pregnancy Gift, Mother Gift, and Parenting Gift to increase the number of protected female employees to apply for inclusion in the protection and care targets.
  • Perform the maternal risk identification of the operating environment and operating process to ensure that control measures are available for the response to the main risk sources.
 100%
  • Provide follow-up care for female employees during pregnancy and after childbirth.
  • For those who are pregnant, within one year after delivery and those who continue breastfeeding one year after childbirth, the health manager will provide telephone health care and arrange professional doctors to conduct face-to-face on-site services based on their needs.
  • Provide high-quality breastfeeding rooms and childbirth (child raising) subsidies.
Suppliers Labor Relations 2.9%
  • Establish "Supplier Management Regulations".
  • Require new suppliers to sign a "Supplier ESG Commitment Letter", promising to abide by the corporate ethics, protect the rights and interests of employees, and protect the local community environment.
  • Require new suppliers to sign the "Confidentiality Consent Form for Corporation" and "Confidentiality Consent Form for Individual" to ensure the confidential information of the Company and customers is properly used and not leaked.
  • Distribute the CSR Risk Assessment Self-assessment Questionnaires (including risk assessment of human rights issues) to assess whether suppliers have human rights issues.
  • Organize the supplier conferences and conduct sustainability education and training for suppliers.
  • Set up "Regulations on Contractor Work, Safety and Health Management" to manage contractor operations and safety.
 100% of new suppliers have signed the ESG Commitment Letter
  • Conduct on-site audits of medium and high-risk suppliers to understand the actual labor rights situation and pay attention to their follow-up processing.
  • Where a supplier violates the Management Regulations, it shall be requested to implement corrections; where necessary, the contract may be cancelled or terminated.
  • It is stated in the contract that if there is a breach of confidentiality agreement, the supplier shall be responsible for compensation for the damage.
Privacy Protection
Occupational Health and Safety
Customers Privacy Protection 0.00%
  • Develop the "Reference Guide for the Privacy Protection Statement of Shin Kong Financial Holdings and Its Subsidiaries", the "Personal Data Management Policy", the "Data Sharing Policy", and the "Management Guidelines for Joint Marketing among Subsidiaries", in order to establish a comprehensive mechanism, defense, and management process for personal data confidentiality.
  • Sign the "Joint Statement on Customer Data Confidentiality Measures of Shin Kong Financial Holdings and Its Subsidiaries" and the "Confidentiality Agreement for Customer Data of Shin Kong Financial Holdings and Its Subsidiaries" to establish clear responsibilities and obligations for the Company and its subsidiaries.
  • Incorporate personal data protection practices into the risk management system and assessment of compliance with relevant laws and regulations.
  • Establish the "Personal Data Protection Management Team" to plan and promote personal data protection practices.
  • Offer training and education on personal data protection, and conduct assessments on relevant laws and regulations.
  • Introduce the ISO 27001 Information Security Management System and the ISO 10002 Customer Complaints Quality Management System.
 100% of employees have completed training and legal tests related to privacy protection
  • Report and take appropriate actions based on the personal data breach reporting process.
  • Individuals who violate the regulations will have their authorization to use company information suspended, and depending on the severity of the situation, will be disciplined according to relevant HR regulations and held legally accountable.
  • Improve and review through education and training, and performance management.
  • Enhance customer list control mechanism and increase employees' awareness of personal data protection.
Investment and Financing Subjects ESG Evaluations on Corporate Customers 0.00%
  • Formulate the "SKFH Sustainable Finance Policy".
  • Incorporate ESG issues into the investment analysis and decision making process, and check whether the investment and financing subjects breach the principles of environmental, social (including labor human rights) and corporate governance, so as to assess whether the subject is exposed to human rights risks.
  • Subsidiaries have signed the "Stewardship Principles for Institutional Investors" compliance statement.
  • Subsidiaries have established Sustainable Investment Policy.
  • SKB established Perpetual Credit Policy. During credit investigation, SKB evaluate whether customers comply with the Equator Principles and ESG issues by filling in Equator Principles and ESG Credit Granting Checklist. Also, implemented post-loan tracking management in order to maintain good credit asset quality.
 100% completion of evaluation on the investment subjects
  • After ESG risk evaluation, new transaction may be declined for the industries listed in the exclusion with potentially controversial issues until their improvement or remediation actions have been approved; Comprehensively evaluated industries with potentially controversial issues, high carbon emission and climate change issues, , no new transaction may be made before improvement: Before any improvement is made, no new transactions shall be added. In the case of continued deterioration, decisions such as position underweight or divestment shall be taken.
  • Continue to monitor whether there are material ESG issues in the invested company. Engage with the invested company that has experienced material ESG issues, follow up on the improvement, and adjust trading strategies if necessary.
  • Participate in the shareholder meeting of the invested company to follow up on ESG implementation. Vote against proposals with negative ESG impact (including human rights violations).
  • Adjust the credit line utilization and liquidation conditions of the creditor according to the seriousness of its abnormal situation.




 

Diverse Communication

SKFH encourages employees to express their ideas and provides diverse labor communication channels, so that employees' personal opinions can be adequately supported and understood. These channels include: employee communication mailboxes, employee complaint mailboxes, employee discussion forums, labor-management meetings, and regular employee opinion surveys (such as sexual harassment, diversity and inclusion, privacy protection,  etc.) to enhance employees' sense of identity and cohesion with the company. In addition, SKFH and its subsidiaries hold labor-management meetings every quarter to fully communicate about important labor-management issues and implement the issues accordingly. 



 
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Employee communication channels Major Practices in 2023

  • Complaint channels

    1. Employee complaint mailbox

    2. Sexual Harassment Complaint Hotline and Mailbox

  • The whistleblowing channel

    1. Independent director mailbox

    2. Internal Audit Mailbox

  • Labor-management meeting

  • Employee Suggestion Mailbox

  1. Through the "Human Resources e-Newsletter", we regularly publicize employee complaint channels.

  2. Information on employee communication, complaints, and whistleblowing channels are disclosed in the stakeholder area of the official website as well as the company's internal website, where the information is regularly updated and maintained.

  3. Announcements are made before the quarterly labor-management meeting, which provides a channel for employees to express their opinions and make proposals.




 

Freedom of association

SKL values to the communication between labor unions, and encourages employees to join and protects their freedom of association. Employees have established labor unions in Taipei City, New Taipei City, Hsinchu City, Nantou County, Yunlin County, Kaohsiung City and other regions. Held a labor-management meeting quarterly to actively interact with employees and maintain good relations. No collective bargaining agreements have been signed.



 
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2021 2022  2023
Number of people 854 854 665
Number of people in the unions 8% 8.7% 7%
 
  • Note: SKFH does not have any business location or supplier that may violate the workers' freedom of association or the right to collective bargaining, or pose significant risks to their rights.


 

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