I. Formulation of Integrity Management Policy and Programs: The Company regards integrity and honesty as core values, which are explicitly stated as code of conduct for employees in the Company's Work Rules. Furthermore, on March 30, 2020, the Board of Directors approved the "HR-126 Procedures and Guidelines for Integrity Management," "HR-129 Ethical Corporate Management Best Practice Principles," and "HR-128 Code of Ethical Conduct." Every employee is strictly required to implement integrity management policies and prevent dishonest behaviors, so as to establish a corporate culture of integrity and sound development, fulfilling our policy commitment. The Company has placed the above regulations on the NAS platform's shared area for all colleagues to review. Additionally, the employee work rules are posted on the notice board to remind employees at all times to adhere to the principle of honesty and integrity.
II. Dedicated Unit for Promoting Integrity Management: The Administration Section of the Company is the dedicated unit responsible for promoting and supervising the implementation of integrity management policies and prevention programs. It reports to the Board of Directors once a year, and the Internal Audit Office is responsible for auditing to fully exercise the responsibility of integrity management.
III. Operation and Implementation of Ethical Corporate Management Principles in 2025 (FY114) are as follows:
| Evaluation Item | Status | Summary Explanation | Deviations from the Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies and Reasons | |
|---|---|---|---|---|
| Yes | No | |||
| I. Formulation of Integrity Management Policy and Programs | ||||
| (1) Has the Company formulated an integrity management policy approved by the Board of Directors, and explicitly stated its integrity policies and practices in regulations and external documents, as well as the Board and management's commitment to implementing the policy? | V | (1) On March 30, 2020, the Board of Directors approved the "HR-129 Ethical Corporate Management Best Practice Principles" and "HR-128 Code of Ethical Conduct." The Company will execute accordingly to fulfill corporate governance. | (1) No material difference. | |
| (2) Has the Company established a risk assessment mechanism for dishonest behavior, regularly analyzed and evaluated business activities with higher risks of dishonesty within the business scope, formulated prevention plans accordingly, and at least covered the preventive measures under Article 7, Paragraph 2 of the "Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies"? | V | (2) The Company's "Work Rules" explicitly state that employees shall not directly or indirectly borrow property from or accept gifts and entertainment from vendors, firms, or customers doing business with the Company, which may affect the Company's reputation or normal execution of affairs. In addition, all employees are obligated to keep confidential the business secrets of the Company or others. | (2) No material difference. | |
| (3) Has the Company specified operating procedures, guidelines, disciplinary and appeal systems for violations in the prevention plans, effectively implemented them, and regularly reviewed and revised the plans? | V | (3) When new employees report for duty, they are informed of the relevant provisions of the Company's "Work Rules." Violations will result in disciplinary actions, and severe cases will lead to termination of the employment contract. | (3) No material difference. | |
| II. Implementation of Integrity Management | ||||
| (1) Does the Company evaluate the integrity records of transaction counterparts and explicitly include integrity behavior clauses in contracts signed with transaction counterparts? | V | (1) The Company conducts commercial activities with customers and suppliers in a fair and transparent manner. When signing contracts, the rights and obligations of both parties are clearly specified. | (1) No material difference. | |
| (2) Has the Company set up a dedicated unit under the Board of Directors to promote corporate integrity management, and regularly (at least once a year) reported its integrity policy, prevention plans, and supervision implementation to the Board? | V | (2) The Company's HR section serves as a concurrent unit promoting corporate integrity management, reporting integrity policy, prevention plans, and supervision implementation to the Board at least once a year. The Company reported to the Board of Directors on April 29, 2025. | (2) No material difference. | |
| (3) Has the Company formulated conflict of interest policies, provided appropriate statement channels, and implemented them? | V | (3) The Company has HR and Audit units that provide channels for whistleblowers to report, maintaining confidentiality regarding the identity and content of reports. | (3) No material difference. | |
| (4) Has the Company established effective accounting systems and internal control systems to implement integrity management, and do internal audit units formulate audit plans based on risk assessment results to audit compliance, or entrust CPAs to perform audits? | V | (4) The Company formulates accounting systems and internal control systems in accordance with relevant laws. Internal auditors regularly audit compliance and report to the Board of Directors. | (4) No material difference. | |
| (5) Does the Company regularly hold internal and external training sessions on integrity management? | V | (5) The Company promotes the importance of integrity management during routine meetings and training sessions. (Training on integrity management and code of ethical conduct was held for employees on April 28, 2025.) | (5) No material difference. | |
| III. Operation of Whistleblowing System | ||||
| (1) Has the Company formulated concrete whistleblowing and reward systems, established convenient channels, and assigned appropriate dedicated personnel to handle reported cases? | V | (1) The Company has established an "Employee Complaint Box" as a channel for complaints and reporting procedures, with dedicated personnel assigned to process reports. | (1) No material difference. | |
| (2) Has the Company established standard operating procedures for investigating reported matters, follow-up measures after completion of investigation, and confidentiality mechanisms? | V | (2) The Company has handling procedures for complaints, with confidentiality mechanisms in reporting procedures to protect the whistleblower's data. | (2) No material difference. | |
| (3) Does the Company adopt measures to protect whistleblowers from inappropriate treatment due to reporting? | V | (3) The reporting procedure includes confidentiality mechanisms that strictly prohibit retaliation against good-faith whistleblowers. | (3) No material difference. | |
| IV. Enhancing Information Disclosure | ||||
| Does the Company disclose its integrity best practice principles and implementation results on its website and the Market Observation Post System (MOPS)? | V | The Company has established its website to disclose relevant corporate information and announces relevant information on the Market Observation Post System. | No material difference. | |
V. If the Company has formulated its own ethical corporate management principles in accordance with the "Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies," please state the differences and reasons: The Company has established "HR-128 Code of Ethical Conduct," "HR-129 Ethical Corporate Management Best Practice Principles," and "HR-126 Procedures and Guidelines for Integrity Management," with no material differences.
VI. Other important information helpful for understanding the operation of the Company's integrity management (e.g., review and amendment of the Company's ethical principles): None.