WNC complies with international regulations and local laws, including internationally recognized human rights standards such as the Universal Declaration of Human Rights, the UN Global Compact, the UN Guiding Principles on Business and Human Rights and the RBA Code of Conduct. We do not discriminate against employees based on their gender, sexual orientation, age, race, nationality, religion, marital status, or political views. In order to implement labor rights, apart from promoting human rights concepts and related regulations during new and existing employee training, we have established diverse, open, and transparent proposal and communication channels. We also review our performance on issues such as the prevention of child labor and minor workers, forced labor, sexual harassment, labor-management communications, and freedom of expression. In 2019, WNC released the WNC Modern Slavery Statement as the foundation of its human rights policy. The statement is reviewed and updated annually.

Human Rights Management

Identify issues related to stakeholders

Regularly review risk outcomes

Formulate risk mitigation measures

Improvement and tracking

At the beginning of each year, responsible units at WNC conduct human rights risk identification based on impact level and probability in compliance with the latest international trends, the RBA Code of Conduct and stakeholder expectations. This ensures that WNC formulates mitigation measures corresponding to each risk and effectively impose the measures. Medium and high-level human rights risks identified by WNC in 2022 and their mitigation measures are as follows:

Issues Risk Description Impact Level Related Policy Management Regulations
Working hours management Working overtime (more than 60 hours per week) High WNC Modern Slavery Statement
  • The Responsible Business Alliance (RBA) Code of Conduct
  • Regulations on the Reporting and Handling of Workplace Harassment
Working more than seven consecutive days Medium
Abuse Sexual harassment/assault, mental or physical coercion, verbal abuse and threats Medium
Freedom to choose employment Charging foreign migrant workers employment fees Medium
Responsible sourcing of minerals Suppliers directly or indirectly use raw materials from conflict-affected mining areas Medium Responsible Minerals Policy Statement Responsible Minerals Policy Statement
Supplier responsibility Key suppliers not meeting RBA requirements Medium Supplier Code of Conduct Supplier Evaluation and Management SOP
Issues Mitigation measures Remedial Measures
Training/Promotion Management System Adjustment Supplementary Measures Disciplinary Actions
Working hours management All new employees are required to complete the WNC Introduction to RBA course to ensure that employees and supervisors are fully aware of regulations about working hours. Set up working-hour alarm on the employee management system, and a monthly review mechanism. Establish multiple communication channels for employees to speak out. Check manpower needs weekly, and establish diversified channels to supplement manpower. Upon receiving notifications of anomalies in employee’s working hours, the HR department contacts the employee’s unit and provides assistance. If a violation of the rule is identified during a monthly working hour inspection, the unit head is required to provide explanations and remedial measures.
Produce accurate production forecasts, regularly analyze industry trends, and check manpower demand. With the working-hour alarm system, the HR department can keep track of employees’ working hours and remind them of taking some rest.
Abuse
  1. All new employees are required to complete the WNC Introduction to RBA" course.
  2. Shift leaders and managers are required to take courses about managing emotions and annual refresher training courses. Reminders about employee’s rights are provided to employees frequently to ensure observance of these rights.
  1. By following the RBA Code of Conduct, WNC is committed to improving employee rights and benefits. RBA VAP is promoted across all WNC sites.
  2. Regulations on the Reporting and Investigation of Workplace Harassment has been formulated. In addition to preventing harassment in the workplace, employees can report the situation in a confidential manner without fear of retaliation.
Regularly review and revise preventive measures against workplace harassment at all sites and related guidelines about complaints, disciplinary actions and protection of complainants.
  1. Employees can raise questions or offer suggestions through channels such as the Employee Suggestions Platform and DL Self-service Platform, and obtain feedback.
  2. WNC has established clinics, arranged on-site doctors for health consultation on a regular basis, and provided psychological counseling on an online consultation platform.
  3. Add content about prevention of workplace harassment (including verbal abuse) in quarterly shift leader meetings and training courses for new shift leaders to raise their awareness of avoiding workplace harassment.
Disciplinary actions are imposed on offenders according to related company regulations based on accountability and severity.
Freedom to choose employment WNC has signed contracts with legally registered recruitment agencies for hiring foreign workers. Hired migrant workers are required to sign a labor contract before coming to Taiwan to ensure they are familiar with the provisions in the contract. Foreign migrant workers can pose questions in a timely manner through asking supervisors, mailing to plant manager’s mailbox, and posting on DL self-service platforms.
  1. The management of recruitment agencies must comply with RBA regulations. WNC also conducts ad hoc audits on these agencies to ensure compliance with human rights policies.
  2. Covenants about fees for entering Taiwan were added to the labor contract which all foreign migrant workers hired by WNC must sign. Inspection mechanisms for foreign migrant workers before they enter Taiwan have been established to safeguard their rights.
Foreign migrant workers can raise their doubts to human resource units. If the doubts involve fees and are confirmed, the fees will be refunded within 90 days of entry. If recruitment agencies are found to violate any rules or policies, they are required to remediate the issues before a specified deadline. These violations are also included in WNC’s agency assessment.
Responsible sourcing of minerals Employees in relevant departments are required to take annual training courses to ensure they are aware of the latest development and actions of responsible minerals. Suppliers are advised and encouraged to use RMI-certified smelters. WNC does not directly purchase metals, and uses the Conflict Minerals Reporting Template (CMRT) developed by RMI to conduct conflict minerals investigations. When a supplier is found to use a non-compliant smelter, the supplier is advised to change to a compliant smelter instead. For suppliers that are unable to meet customer requirements within a specified deadline, WNC asks the business unit to propose a material replacement plan or negotiate with the customer.
Supplier responsibility
  1. Communicate with suppliers on the RBA regulations on a regular basis and check their RBA compliance status.
  2. WNC requires its suppliers to sign the Supplier Code of Conduct and a statement to ensure compliance with international sustainability trends and related RBA regulations.
WNC formulates plans for annual on-site RBA audits for suppliers, and conducts RBA audits and remedial measures accordingly. The audit results are included in the quarterly supplier evaluation (VPE), serving as a reference for suppliers’ strategy adjustment. Every year, WNC selects suppliers who need to undertake RBA inspections and includes them in the audit schedule for the year as a part of implementing sustainability management of suppliers. The Supplier Quality Management Center is responsible for the follow-up of suppliers’ non-compliance items and corresponding remedial measures. The Center also works with the Global Production and Material Management Center to supervise suppliers’ implementation of RBA regulations and continual improvement according to the Supplier Evaluation and Management SOP. Suppliers who do not carry out remedial measures are reported to VPE meetings for review, downgrading and other handling measures. Procurement units are also required to urge suppliers to take necessary remedial measures.

Prevention of Workplace Harassment

To create a safe and harmonious workplace and protect employees from workplace harassment (including physical, linguistic, psychological abuse and sexual harassment), WNC (Taiwan) established Regulations on the Reporting and Handling of Workplace Harassment. The Human Resources Administration Division is responsible for the prevention, correction, complaint handling, and punishment of harassment in the workplace. The Division is responsible for contacting and coordinating related units within 24 hours of receiving reports. A task force consisting of personnel from the HR and legal departments and the units of the involved parties is then formed and will investigate, interview and discuss before they submit a report to the CEO.

In view of the differing cultural and administrative requirements, WNC’s sites in China and Vietnam implemented Regulations on Filing and Handling of Internal Complaints. Employees may file complaints and reports regarding various issues, such as sexual harassment, with the Human Resources Unit. The Human Resources Unit is responsible for receiving, investigating, handling, reporting, and offering feedback on all complaints.

Employee makes anonymous complaint of unlawful workplace infringement.

HR receives the complaint and investigates it.

Disciplinary action is taken and reported back to all parties involved.

Employee education and training is enhanced to create a safe work environment

A Workplace You Can Feel Safe In

WNC introduced the “A Workplace You Can Feel Safe In” initiative at its Taiwan sites in 2021. The goal of this initiative is to create a workplace that ensures and protects the physical and mental wellbeing of WNC employees. Through the Five Elements of Workplace Well-Being listed here, the initiative encourages all WNC employees to work together and create a safe workplace.

Communication Channels

WNC provides open and transparent suggestion and communication channels for employees. Timely communications with employees are enhanced via committees, forums, events, as well as physical and electronic mail, hotlines, and system platforms. In addition, public email addresses for stakeholder interaction and reporting of violations are provided for employees to raise questions, offer suggestions, or make complaints without fear of retaliation.

Communication channels at WNC sites The main channel at each site

Communication Channels Subject Taiwan Sites China Sites Vietnam Sites
Consultative organizations All employees Labor-Management Committee, Employee Welfare Committee and OSH Committee Labor unions Labor unions
Physical mailboxes Plant manager’s mailbox Suggestion box Suggestion box
System platforms Employee Suggestions Platform WeChat public platform
Email addresses Plant manager’s mailboxwecare@wnc.com.tw
Hotlines 8585 employee care hotlines
Forums All employees A Talk with the CEO forum Employee Representative Forum Employee Representative Forum
Production line employees Plant manager’s/Shift manager’s/foreign employees’ forums Shift manager’s forums
New employees New Hire Forums Experiencing WNC culture and a talk with the CEO forum
Management Section level/foreign employees’ forums
Complaint mechanisms All stakeholders