Unlawful Infringement Prevention and Complaints

Unlawful Infringement Prevention and ComplaintsWorkplace Violence & Harassment Prevention

The Breeze Group is committed to fostering a safe, healthy, and respectful working environment, preventing the occurrence of workplace bullying and sexual harassment, establishing comprehensive complaint channels and investigation and handling mechanisms, and duly safeguarding the rights, interests, and privacy of the parties concerned.

Breeze Group Workplace Bullying Prevention Measures

Guidelines for Complaints and Investigation Handling

Announced and effective 2026.07.01

I. Preface

The prevention of workplace bullying is guided by the principle that "prevention is better than remedy." It incorporates the organization's internal psychosocial and interpersonal communication issues into the scope of corporate governance in order to improve organizational climate and business operating efficiency. Policies are formulated at the source and an institutionalized management system is established, thereby shaping a safe, healthy, and respectful working environment and corporate culture.

II. Legal Basis for Enactment

Chapter II-1 of the Occupational Safety and Health Act and the Regulations Governing Workplace Bullying Prevention Measures.

III. Scope of Application

All employees of the Group and all persons who perform labor under the direction or supervision of the person in charge of the workplace (workers).

IV. Definition of Workplace Bullying and Principles of Determination

Pursuant to the definition of workplace bullying under Article 22-1 of the Occupational Safety and Health Act, workplace bullying refers to the situation where a worker, while performing duties at the place of labor, suffers harm to physical or mental health because personnel of the business entity, exploiting duty-related, positional, or other power relationships, exceed the necessary and reasonable scope of business and persistently engage in offensive, threatening, cold-shouldering, isolating, insulting, or other improper words or conduct. However, where the circumstances are serious, persistent occurrence is not required.

The determination of whether improper words or conduct constitute workplace bullying is, in principle, based on repeated or persistent occurrence. Whether a single isolated incident constitutes a serious circumstance shall be assessed by comprehensively considering factors such as the intensity of the infringement, the power disparity, the degree of publicity, the degree of humiliation, and the extent of the impact on the victim's physical and mental health.

The determination of workplace bullying shall, in addition to satisfying the aforesaid definition, comprehensively take into account the background, frequency, and location of the incident, and the actor's motive and purpose. Its forms include, but are not limited to, the following:

1. Social Exclusion

Deliberately ostracizing, ignoring, or cold-shouldering a specific person, or denying them participation in necessary important meetings, matters, or activities. For example, a supervisor deliberately failing to add a specific worker to a communication group necessary for work, or deliberately excluding a specific worker from all work meetings.

2. Interference with Duties

Sabotaging or deliberately obstructing a specific person's work, exploiting one's position to make things difficult for them, deliberately withholding information, or providing false information. For example, assigning a specific worker to perform accounting duties while blocking their access to log in to the company's accounting system, thereby artificially creating obstacles that make it difficult for them to perform their duties.

3. Abuse of Power

Oppressing a specific person through power by deliberately assigning unreasonable work targets or work that clearly does not match their abilities, most typically in the two forms of "excessive demands" and "insufficient demands" (as detailed below).

4. Infringement of Reputation

Deliberately spreading rumors about, or disclosing the privacy of, a specific person. For example, spreading false and negative information about a worker among colleagues in order to undermine that worker's standing in the workplace or their opportunities for promotion.

Typical Forms of Abuse of Power

(1) Excessive Demands | In Terms of Time

Deliberately assigning work that is difficult to complete within the given time. For example, a supervisor who is well aware that the reasonable working time for a task is one week nonetheless deliberately requires, just before the end of the workday, that a specific worker submit it by the following morning, failing which the worker will be issued a demerit or dismissed.

(1) Excessive Demands | In Terms of Ability

Deliberately assigning work that is difficult to accomplish given the person's abilities. For example, requiring an engineer who has never studied a foreign language to negotiate a business contract with a German client in German.

(2) Insufficient Demands

Commonly seen as "underutilization of talent" based on an intent to force resignation or to humiliate. For example, deliberately preventing a senior engineer from handling work in their area of expertise and instead ordering them to handle low-level assistant tasks, thereby undermining their self-esteem or imposing physical and mental burdens.

V. Complaint Handling Procedure

The employer shall take immediate, effective, and appropriate measures (§7): adopt measures to prevent the recurrence of workplace bullying against the complainant; and, in accordance with the complainant's needs, provide necessary consultation, assistance, and protection.

Time limit for filing a complaint: (1) Within 3 years from the time the workplace bullying conduct ended. (2) Where the respondent exploited power relationships, within 1 year from the date on which the bullied worker left employment; where a longer period applies under the preceding item, that provision shall prevail.

A worker considers that they have been subjected to bullying

The bullied worker files a complaint with the employer (§8)

The complainant is notified in writing within 10 working days (§10)

Is the complaint accepted?

The written notice shall state the reasons (§10)

Yes

Initiate the investigation procedure (§12); register in the system within 7 working days (§11); form an investigation team within 15 working days (§14)

Composition of the investigation team: at least 3 members / external professionals shall constitute no less than ½ / the proportion of any one gender shall be no less than ⅓.

The investigation team completes the investigation report within 2 months, extendable by 1 month where necessary (§17)

A decision on whether the bullying complaint is upheld is made within 1 month (§18)

Time limit for making a decision: where fewer than 30 workers are employed → within 3 months from the day after receipt of the complaint; where 30 or more but fewer than 100 workers are employed → within 4 months from the day after receipt of the complaint.

The complainant is notified in writing within 10 working days (§18) | Appropriate disciplinary action against or handling of the actor (§19)

Registration in the competent authority's system within 10 working days (§19)

The investigation and handling procedure concludes

Flowchart of the workplace bullying complaint handling procedure for employers with 100 or more workers (employers with fewer than 100 workers may handle complaints with reference to this procedure)

VI. Appeal Handling Procedure

Appeal investigation team for employers with 100 or more workers: at least 3 members; external professionals shall constitute no less than ⅔; the proportion of any one gender shall be no less than ⅓.

Appeal investigation team for employers with 30 or more but fewer than 100 workers: at least 3 members; at least 1 external professional; the proportion of any one gender shall be no less than ⅓.

The complainant or the respondent objects to the decision on whether the workplace bullying complaint is upheld

An appeal is filed with the employer in writing within 30 days (§22)

An appeal review meeting is convened within 10 working days (§22)

Is a further investigation to be conducted?

Yes

Form an appeal investigation team to conduct a further investigation (§22) → complete the further investigation and make a reasoned decision within 60 days (§23) → notify the appellant and the counterparty in writing of the appeal outcome and the new decision on whether the complaint is upheld within 10 working days, and register in the competent authority's system (§23)

Make a reasoned decision within 30 days (§23) → notify the appellant and the counterparty in writing of the appeal outcome within 10 working days, and register in the competent authority's system (§23)

The appeal procedure concludes

Where the competent authority or the labor inspection agency determines that the employer's investigation results for a workplace bullying incident violate the provisions of the prevention regulations and that the investigation procedure contains one of the material defects, it may require a reinvestigation (§24).

Flowchart of the appeal handling procedure (employers with fewer than 30 workers may handle appeals with reference to this procedure)

VII. Workplace Bullying Prevention Measure Provisions

The Breeze Group (hereinafter the "Company"), in order to provide workers and workers a working environment free from workplace bullying and to safeguard their physical and mental health, rights and interests, and privacy, has enacted these provisions in accordance with Chapter II-1 of the Occupational Safety and Health Act and the relevant provisions of the Regulations Governing Workplace Bullying Prevention Measures.
The workplace bullying prevention measures and complaint handling set forth in these provisions apply not only to workers employed by the Company but also, by analogy, to other persons who perform labor under the direction or supervision of the person in charge of the workplace (such as dispatched workers).
The Company's supervisors at all levels toward their subordinate employees, employees toward their supervisors, and employees among themselves, shall not exploit duty-related, positional, or other power relationships to exceed the necessary and reasonable scope of business and persistently engage in offensive, threatening, cold-shouldering, isolating, insulting, or other improper words or conduct that causes harm to another person's physical or mental health.
The determination of workplace bullying shall satisfy the definition under Article 22-1, Paragraph 1 of the Occupational Safety and Health Act and shall comprehensively take into account the background, frequency, and location of the incident, the actor's motive and purpose, and the following forms of conduct:
- Deliberately ostracizing, ignoring, or cold-shouldering a specific person, or denying them participation in necessary important meetings, matters, or activities.
- Sabotaging or deliberately obstructing a specific person's work, exploiting one's position to make things difficult for them, deliberately withholding information, or providing false information.
- Oppressing a specific person through power by deliberately assigning unreasonable work targets or work that clearly does not match their abilities.
- Deliberately spreading rumors about, or disclosing the privacy of, a specific person.
For workplace bullying incidents, the Company has established the following complaint channels and publicly displays them in a conspicuous location at the workplace and on the internal information platform:
- Complaint email: [email protected], [email protected]
- Complaint hotline: 02-6626-8888 #3324, 3316
All employees of the Company's departments shall receive workplace bullying prevention education and training, and supervisors at all levels shall use various occasions to strengthen the promotion, among their subordinate employees, of workplace bullying prevention and complaint channels; supervisors at all levels and persons responsible for or participating in the investigation, handling, coordination, and appeal of complaint incidents shall additionally receive relevant education and training on communication skills, management, and the handling of complaint incidents (see Schedule 1 for details).
Upon becoming aware that a worker has been subjected to workplace bullying, the Company shall take the following immediate, effective, and appropriate measures:
- 1. Where the Company becomes aware upon receipt of a complaint from the bullied worker:
- (1) Taking into account the complainant's wishes, adopt appropriate measures such as separation to prevent the recurrence of workplace bullying against the complainant, and shall not subject the complainant to any unfavorable treatment.
- (2) In accordance with the complainant's needs, provide or refer them to consultation services such as legal advice, medical care or psychological counseling, social welfare resources, and other necessary assistance or protective measures (Appendices 13 and 14).
- (3) Initiate the investigation procedure and conduct interviews and investigations of the persons involved in the complaint incident; where the complainant is willing, coordination may be conducted, and if the coordination is unsuccessful, the investigation shall continue.
- (4) Based on the investigation results, impose appropriate disciplinary action on or handling of the actor according to the severity of the circumstances.
- 2. Where the Company becomes aware other than through the circumstances described in the preceding item:
- (1) Interview the persons concerned to make the necessary clarification and verification of the relevant facts.
- (2) Inform the bullied worker of the rights and interests they may assert and the avenues of remedy, and, in accordance with their wishes, assist them in coordination or in filing a complaint.
- (3) Appropriately adjust the work content or workplace of the persons concerned.
- (4) In accordance with the bullied worker's wishes, provide or refer them to consultation services such as legal advice, medical care or psychological counseling, social welfare resources, and other necessary assistance or protective measures.
For the purpose of handling workplace bullying complaint cases, the Company has established a complaint handling unit with at least 3 members, in which the proportion of any one gender shall be no less than one-third. The members of the complaint handling unit shall be designated by the head of the Administrative Management Division from among the supervisors of relevant departments or incumbent employees, and external professionals with experience in handling relevant matters may be invited to serve.
The head of the Administrative Management Division may designate 1 member of the complaint handling unit as the convener, who shall serve as the chair of the meeting; where the chair is unable to preside over the meeting for any reason, another person may be designated to act in their stead.
Where a dispatched worker is subjected to workplace bullying by an employee of the Company, the Company shall accept the complaint and, jointly with the dispatching business entity, conduct the investigation, and shall notify the complainant, the respondent (hereinafter collectively the "parties"), and the dispatching business entity of the results.
Where the respondent is the Company's highest-ranking person in charge, the worker may, pursuant to Article 22-3, Paragraph 1 of the Occupational Safety and Health Act, file a complaint directly with the competent authority of the municipality or county (city) where the worker is located; the Company shall nonetheless take immediate, effective, and appropriate measures in accordance with the competent authority's notice and the provisions of the Occupational Safety and Health Act.
A complaint may be filed orally, by email, or in writing. Where it is filed orally or by email, the receiving personnel or unit shall make a record (Appendix 1) and read it aloud to the complainant or allow the complainant to review it to confirm that the content is correct, after which the complainant shall sign or affix a seal. The complaint record shall specify the following matters:
- (1) The complainant's name, work unit, place of residence, contact telephone number, and the date of the complaint.
- (2) Where there is a statutory agent or an appointed agent, their name, place of residence, and contact telephone number; where an agent is appointed, a power of attorney shall additionally be attached (Appendix 2).
- (3) The facts of the complaint and the relevant evidence.
Workplace bullying complaint cases shall be handled in a non-public manner, protecting the privacy of the parties, the persons assisting with the complaint, and those invited to assist with the investigation, and ensuring that the complainant, the persons assisting with the complaint, and those participating in or responsible for the investigation are protected from retaliation or other unfavorable treatment.
A person participating in the investigation, handling, or appeal procedure of a complaint incident who is a party thereto, or who has a spousal, former spousal, blood relative within the fourth degree, relative by marriage within the third degree, head of household, or family member relationship with a party, shall recuse themselves (Appendix 7). Where there are other concrete facts sufficient to establish a likelihood of bias in the conduct of the investigation, handling, or appeal procedure, a party may apply in writing, stating the reasons and facts, for that person's recusal.
The complaint handling unit may decline to accept a complaint upon receipt if any of the following circumstances applies:
- (1) The matter does not fall within workplace bullying as referred to in Article 22-1, Paragraph 1 of the Occupational Safety and Health Act.
- (2) There is no specific content (Appendix 3).
- (3) The complainant has not provided their true name or information sufficient to identify them.
- (4) The same incident has already been declined or has already been given a final substantive disposition.
- (5) The complaint incident has already been withdrawn (Appendix 3).
- (6) The time limit for filing the complaint has expired.
The complaint handling unit shall, within 10 working days from the date of receipt of the complaint, decide whether to accept it and notify the complainant in writing; where it declines to accept the complaint, it shall state the reasons in the written notice (Appendix 4). Where it decides to accept the complaint, it shall, within 7 working days from the day after acceptance, register in the system in accordance with the content and manner announced by the Ministry of Labor, and notify the complainant.
After accepting a complaint, the Company shall conduct the investigation in accordance with the principles of objectivity, impartiality, and fairness, and shall protect the personal privacy of the parties, the persons assisting with the complaint, and those invited to assist with the investigation throughout the investigation process.
When conducting the investigation of a complaint incident, if the complainant is willing to undergo coordination, coordinating personnel shall be arranged on an objective, impartial, and fair basis; the coordinating personnel shall be agreed upon by the parties (Appendix 5). Where either party is unwilling, or where no consensus has been reached within 1 month from the date of coordination, the coordination shall be discontinued; where the coordination is unsuccessful, the investigation shall continue and other appropriate measures shall be taken.
During the investigation, the parties shall be given the opportunity to state their opinions and present a defense, and shall be notified in writing of the purpose, time, and place of the investigation and the consequences of non-appearance; when interviewing the parties and the persons concerned, audio or video recording shall be used as an aid and a record shall be made (Appendix 6); the parties or the relevant persons assisting with the investigation shall not be made to confront one another during the investigation process; the investigators and all persons participating in the handling of the complaint incident shall be bound by a duty of confidentiality (Appendix 7).
The Company shall, within 15 working days from the date of accepting the complaint, have the complaint handling unit select investigation members to form an investigation team responsible for the investigation. The investigation team shall have at least 3 members, external professionals shall constitute no less than one-half, and the proportion of any one gender shall be no less than one-third.
The Company's members of the investigation team shall attend a course organized by the competent authority or the labor inspection agency, or take a digital learning course on the website established by the Ministry of Labor, and complete at least 3 hours of workplace bullying prevention education and training. The external professionals of the investigation team shall have experience in labor rights and interests or in handling related matters.
The investigation of a workplace bullying complaint shall complete the investigation report within 2 months from the day after the establishment of the investigation team; where necessary, it may be extended by 1 month, and the parties shall be notified (the coordination period during the investigation process need not be counted).
The investigation report referred to in the preceding paragraph shall be submitted to the complaint handling unit for review, and its content shall include the following matters:
- (1) The subject of the complaint incident, including the gist of the complainant's complaint.
- (2) The investigation and interview process, including the dates and subjects (Appendix 8).
- (3) The key points of the statements made by the parties and the persons concerned (Appendix 9).
- (4) The findings of fact and reasons, including the key points of the statements made by witnesses and the persons concerned and the examination of relevant physical evidence.
- (5) Recommendations for handling.
The complaint handling unit shall, no later than 1 month from the date of completion of the investigation report, make a decision on whether the workplace bullying complaint is upheld with reference to the investigation results, and may provide the Company with recommendations for disciplinary action or other handling. Such decision shall require the attendance of at least one-half of the members of the complaint handling unit and the consent of a majority of those present.
The Company shall, within 10 working days from the date of making the decision on whether the workplace bullying complaint is upheld, notify the parties in writing of the decision, stating the facts and reasons, and shall register it in the system designated by the Ministry of Labor and provide the methods and time limit for appeal remedy (Appendix 10).
Where workplace bullying conduct is verified through the investigation, the Company shall, according to the severity of the circumstances, impose appropriate disciplinary action on or handling of the actor in accordance with the work rules, the labor contract, the reward and disciplinary provisions, and the relevant laws and regulations; this shall not apply where the actor has already left employment.
The determination of the severity of the circumstances referred to in the preceding paragraph shall take into account the degree of physical and mental infringement of the complainant, the number, frequency, and means of the conduct, the relationship between the two parties, the attitude following the violation, past similar conduct, and the impact on the Company.
The Company shall not dismiss, demote, reduce the pay of, impair the rights and interests to which they are entitled by law, contract, or custom of, or otherwise take any unfavorable disposition against, a worker who files a complaint in accordance with the law or who assists another person in filing a complaint. However, this shall not apply where it is verified that the worker maliciously fabricated the facts.
A party who objects to the decision on whether the complaint is upheld may, within 30 days from the day after receiving the written notice, file an appeal with the Company in writing, stating the reasons (Appendix 11); the same incident is limited to one appeal. After receiving the appeal, the Company shall, within 10 working days, have the members of the complaint handling unit elect a convener and convene an appeal review meeting.
Where the appeal review meeting finds that the investigation and handling procedure contained a material defect or that there is new evidence sufficient to affect the original investigation findings, an appeal investigation team shall be formed to conduct a further investigation. The appeal investigation team shall have at least 3 members, external professionals shall constitute no less than two-thirds, and the proportion of any one gender shall be no less than one-third.
The complaint handling unit shall make a reasoned decision within 30 days from the date on which the appeal review meeting is convened; where a further investigation is required, the time limit for the decision may be extended by 30 days. The Company shall, within 10 working days from the date of the appeal decision, notify the appellant in writing, stating the facts and reasons (Appendix 12), and shall register in the system designated by the Ministry of Labor within 10 working days from the date on which the appeal outcome is made.
The Company shall carry out tracking, evaluation, and supervision of workplace bullying complaint and appeal incidents to ensure that disciplinary action or handling measures are effectively implemented, to prevent the recurrence of the same incident or of retaliation, and shall conduct an overall assessment and review of these provisions and take necessary improvement measures.
The preventive measures adopted, the acceptance of complaints, coordination, investigation, appeal, and other handling processes and results carried out by the Company in accordance with these provisions shall be documented in execution records and retained for 3 years.
Where a workplace bullying complaint incident involves sexual harassment conduct in the workplace, the Company shall handle it in accordance with the procedures set forth in the Regulations Governing Workplace Bullying Prevention Measures and the Regulations Governing Workplace Sexual Harassment Prevention Measures, and shall, in accordance with the complainant's wishes and the content of the complaint, conduct a joint investigation, interview, or fact-clarification under the principle of avoiding duplicative questioning.
These provisions shall take effect after being approved and promulgated by the Administrative Management Division, and the same shall apply to any amendments.

Schedules and Appendices

Schedule 1 and Appendices 1–14 are the relevant forms and documents concerning workplace bullying complaints, investigations, and assistance resources. Click a title to expand and view the image of the original document.

Schedule 1　Recommended education and training content to be provided by the business entity for different categories of persons