1. Formulating Integrity Management Policies and Plans

(1) Has the Company established policies for ethical corporate management approved by the board of directors and stated such policies and practices in its regulations and external documents and in the commitment made by the board of directors and senior management to actively implement such policies?

Operational Status: 

The company has established the "Corporate Integrity Management Code," which was approved by the board of directors. In 2019, the code was revised in accordance with the latest regulations. Additionally, in 2016, the board approved the "Integrity Management Procedures and Behavior Guidelines," which were updated and amended in December 2022 to align with the latest practices. These internal regulations have been disclosed on the company's website to explicitly state the integrity management policies and practices. The board and senior management are required to submit an annual "Integrity Management Statement" to affirm their commitment to actively implementing the policy. In 2022, the board and senior management signed the statement, with a 100% signing rate. It is expected that all directors and senior management will sign the annual integrity management statement by the end of this month.

(2) Has the Company established an assessment mechanism of risk from unethical behavior to regularly analyze and assess business activities with higher risk of involvement in unethical behavior and preventive programs for unethical behaviors containing at least the preventive measures stated in Paragraph 2, Article 7 of the “Ethical Corporate Management Best Practice Principles for TWSE/TPEx-Listed Companies”?

Operational Status:

The company has established the "Code of Ethical Conduct for Directors and Managers" and the "Code of Ethical Conduct for Employees" to guide the behavior of directors, managers, and all employees in line with ethical standards. These codes help stakeholders understand the company's ethical standards and serve as behavior guidelines for all employees. In addition to including them in the training materials for new employees, all levels of management are required to lead by example in daily operations and management, while also specifying prevention plans. These plans analyze business activities with higher risks of dishonest behavior and strengthen related prevention measures.

(3) Has the Company established in the preventive programs the operating procedures for unethical behavior prevention, penalties and grievance systems of breaching the guidelines for conduct, and implemented and periodically review them?

Operational Status:

Under the framework of the "Corporate Integrity Management Code," the "Code of Ethical Conduct for Directors and Managers," and the "Code of Ethical Conduct for Employees," the company has established "Integrity Management Procedures and Behavior Guidelines," specifying the attention points for employees when conducting business. These guidelines outline operational procedures, behavior standards, disciplinary actions for violations, and a complaint system, applicable to the company, subsidiaries, and other entities or organizations under the company's effective control. In addition to reinforcing these standards for new employees, the company ensures compliance in daily operations. The internal audit department plays a key role in ensuring adherence to ethics and legal regulations. To ensure that employee behavior complies with the regulations, standards, procedures, and laws, internal audits are conducted according to the annual audit plan approved by the board of directors, with the results and follow-up improvement plans reported to the board and management. At the end of each year, when presenting the annual corporate integrity management report to the board of directors, the company reviews whether the "Corporate Integrity Management Code" needs to be revised.

2.Implementation of Integrity Management

(1) Does the Company have the integrity of the trade counterparty assessed and with the code of integrity expressed in the contract signed?

Operational Status:

Before establishing business relationships, the company evaluates the legality, integrity management policies, and any history of dishonest behavior of potential counterparts to ensure that their business practices are fair, transparent, and do not involve bribery or unethical conduct.

(2) Has the Company established a dedicated (concurrent) unit to implement ethical corporate management under Board of Directors and report regularly (at least once a year) to BOD the status of implementation and supervision of ethical management policy and preventive programs of unethical behavior?

Operational Status:

The company designates the "General Manager's Office" as the responsible unit for promoting corporate integrity management, including the implementation of integrity management policies and the establishment and supervision of prevention measures. The company reports annually to the board on the execution of its integrity management policies and measures, assisting the board in assessing the effectiveness of the established integrity management and prevention measures.

Execution in 2024:

• Periodically sending emails to raise awareness about insider trading violations related to stock ownership reporting.
• Sending emails to all employees regarding the company’s integrity management and employee ethical conduct regulations.
• Sending emails to raise awareness about merger disclosure regulations and the company's internal procedures for handling significant information.
• Reiterating on the company website's stakeholder section the regulations prohibiting company directors and employees from profiting from non-public information.
• Providing a whistleblower channel on the company's website, including phone and email, to improve communication with stakeholders.

(3) Does the Company have developed policies to prevent conflicts of interest, provided adequate channel for communication, and substantiated the policies?

Operational Status:

The company has defined policies to prevent conflicts of interest in its "Company Integrity Management Code," "Integrity Management Procedures and Behavior Guidelines," the Code of Ethics for Directors and Managers, and the Code of Ethics for Employees. The company ensures these policies are implemented at all levels. Additionally, for any agenda items at board meetings where there is a conflict of interest, affected directors recuse themselves in accordance with Article 16 of the "Board Meeting Rules." The company also provides contact information on its website for both internal and external individuals to report unethical or improper behavior.

(4) Has the Company established an effective accounting system and an internal control system for the internal audit unit to establish related audit programs based on the results of risk assessment of involvement in unethical behavior to audit and prevent the compliance with the preventive programs of unethical behavior or hire a CPA to perform the audit?

Operational Status:

The company has established and adheres to effective accounting and internal control systems. Internal auditors regularly assess compliance with these systems and report audit results to the board at each meeting. Furthermore, through the annual internal control self-assessment process, each department reviews its internal control systems to ensure the effectiveness of their design and execution.

(5) Has the Company organized corporate management internal and external education and training programs on a regular basis?

Operational Status:

The company’s "Integrity Management Code" and "Integrity Management Procedures and Behavior Guidelines" are published on the company’s website under the "Corporate Governance" section. Periodically, the company sends emails with integrity management-related regulations to all employees, directors, and internal stakeholders. Additionally, training and management meetings are held to promote the principles of integrity management.