Ethical Operation

Dedicated (responsible) unit for promotion of enterprise ethical operation:

The Present’s Office of the Company is responsible for promoting enterprise ethical operation and shall report the status of execution to the board of directors at least once a year.

Promotion and execution status of enterprise ethical operation:

To implemental ethical operation policy, the Company has specified in its Work Rules that no member of the Company with access to clients or suppliers shall have any unethical conduct such as accepting any gift, kickback or loan. The Code of Ethics also requires directors and managers of the Company to strictly abide by the principles of honesty and good faith. It is strictly prohibited to seek or attempt to seek personal interest through the use of the Company’s asset, information or by taking advantage of job duties.
In addition, the execution unit shall regularly evaluate the Company’s ethical operation policy and the status of implementation, including whether consideration has been given to the legality and ethics records of the suppliers, clients or other business trading counterparts, whether members of the Company having access to company secrets and commercially sensitive information in the course of business have been bound by confidentiality obligations, with the undertaking of precautionary measures, whether the Company has established specific whistleblowing and reward systems and put in place convenient whistleblowing channels and other ethical operation items. The internal audit report shall be submitted to independent directors for review every month.
With the operational growth of the Company, other responsible units may be added to join the operation in the future in order to reinforce the performance of enterprise ethical operation.

Implementation of preventing insider trading:

The Company provides “Compliance Brochure for Director and Supervisors” to newly elected directors and managers while they are on board, and also offers education propaganda about prevention of insider trading from competent authority to directors and managers at least once a year. The Company has set an insider trading prevention management procedure, procedures for handling material inside information, etc. Upon actual learning of material information about the Company having an impact on its share price, directors, supervisors, managers, related parties to the persons under the previous subparagraph, and any person who has learned about the information due to professional or controlling relationship shall not, after the information is confirmed, before it is rendered public or within 18 hours after the publication of the information, purchase or sell any shares or other equity securities of the Company listed on the stock exchange or over-the-counter market in its own name or in the name of any other person. The Company amended its “Corporate Governance Best Practice Principles” to prohibit all directors from trading its shares during the closed period of 30 days prior to the publication of the annual financial reports and 15 days prior to the publication of the quarterly financial reports.To avoid violating regulations, the Company sends e-mails to its directors to remind the dates of the Board of Directors and the blackout period of the Company's financial statements.

In 2023, the Company sent e-mails on Feb. 16th, Mar. 20th, May 8th, and Oct. 27th separately to notify the dates of the Board of Directors and the blackout periods of the Company's financial statements to remind directors to avoid violating regulations.

Execution Status in 2023

1. Education and Training:

Continuously conducting relevant issue and legal update advocacy to directors, senior managers, and colleagues through diverse formats to deepen understanding of ethical conduct and regulatory compliance. For instance, the Company condensed concepts related to corporate information confidentiality, prohibition of insider trading, and associated legal responsibilities into a 3-minute video uploaded onto the Company's learning platform for dissemination to all colleagues. In 2023, internal education and training sessions related to integrity in business (including compliance with integrity-related regulations, protection of trade secrets, and behavioral ethics guidelines) were held, totaling 611 participants across 87 hours of online courses.

2. Whistleblowing Channels and Investigative management:

The Company provides physical suggestion boxes, email addresses, and a reporting hotline for reporting unlawful incidents. We take appropriate measures to protect the identity of whistleblowers and the content of their reports during investigations. Throughout 2023, the Company did not receive any reports of illegal activities. Furthermore, there were no significant incidents of legal violations resulting in major penalties (fines exceeding NT$1 million).

3. Reported to the Board of Directors:

On May 8^th, 2023, the Company reported to the Board of Directors the execution results of internal significant information handling and measures taken to prevent insider trading. Additionally, on November 13^th, 2023, a report was submitted to the Board of Directors outlining the results of operations regarding compliance with risk management policies and regulatory adherence.