Ethical Corporate Management

The company has established “Ethical Corporate Management Practice Principles,” “Ethical Corporate Management Operating Procedures and Conduct Guide,” and “Code of Ethics,” etc. and is active in conveying its underlying rationale to the employees. In order to promote honest business, the General Administration Division supports the Executive Secretary to take charge of honesty relevant system and maintenance and supervision and execution, it shall report to the Board periodically every year and the promoting situation of 2023 has been reported to the Board on November 8, 2023. In 2023,  no notification of violations of the integrity clause was received. Upon discovering or receiving reports of dishonest conduct, the General Administration Division investigates immediately and demands immediate cessation if such conduct has been verified to have violated laws or the corporate ethical principles. In which case, the violator will be subject to disciplinary action and legal claims if necessary in order to protect the company’s reputation. For dishonest conduct that has already occurred, the General Administration Division will help identify weaknesses in the internal control systems or procedures that led to the incident, and instruct the responsible department to rectify so that such incidents do not recur. All departments are required to report to the board of directors on dishonest conduct discovered, actions taken, and subsequent improvements made.

The Company would promote the company management concept and requirements by educational training and internal meetings to let the employees understand well and follow accurately. Year 2017, we have introduced the integrity standards into the E-learning system and included it as the annual required course since 2018. In 2023, a course was opened to enhance the attentions of all the employees as follows:

• Course name: “Ethical Corporate Management and Sexual Harassment Prevention”
• Course outline: The ethical corporate management and sexual harassment prevention promotion, the explanation of employee ethics (including the prohibition of insider trading), and the compliance of code of ethics.
• Number of trainees: A total of 349 employees completed the training (the number of trainees should be 383,) the completion ratio is 91.12%
• Education hours: 349 hours

The company assigns employees to participate in ethics training whenever deemed appropriate.

Whistleblower Policy

The company established a “Code of Ethics” and “Employee Ethical Business Guidelines.” All employees shall abide by the rules and regulations, all executives of each unit shall carry out and ensure that all department employees understand, accept and comply with the relevant regulations with all its strength. Employees shall be cautious about any behavior that violates the code of conduct, on occasion that any inquiry or discovery of behaviors relating with violating any rule and the norm serious violation cases shall be reported to the Board and then given the corresponding punishment according to the “Employee Reward and Discipline Guidelines,” and a proceeding will be brought up once there is any relevant violation to the law. Employees who violated the regulation with a post under the level of manager for any personal punishment and measure considered as violation of law or impairment of interest and right as unjustified cause, it may submit concrete matter of fact and enclose with related information to appeal to Investigation Unit of General Administration Division, while the person who violated rules with post of above manager, it can conduct according to the regulation about appealing in Code of Ethics.

For the reporting channels of the company, in addition to employee personal opinion or claim box, it also set up auditing commission mailbox for completing the function of supervision.

In order to reinforce the protection on the interest and right of reporter and avoid the revenge occurred by improper personnel measure, it built "whistleblower protection" relevant measures, for the staff and relevant personnel who denounced someone who has violated regulation or participated with the process of investigation, it will give appropriate protection measure for refrain in them from suffering unfair treatment and revenge. In case that the whistleblower has suffered from revenge, it can seek remedies at specific responsibility unit or Office of the Chairman. Concerning "Whistleblower Protection," it safeguards the reporter’s position and rewards from degradation or expelling due to reporting, as for the case of suffering the revenge via normal reporting, in addition to providing compensation, a punishment will be imposed on the revenging party according to “Employee Reward and Discipline Guidelines.”

Avoid insiders trading with undisclosed information

The company has established “Procedures for Handling Material Inside Information and Avoiding Insiders Trading” to avoid insiders trading with undisclosed information and revealed the procedures on the company’s website. In 2017, the company introduced the integrity standards into the E-learning system and included it as the annual required course since 2018 to enhance the attentions of all the employees constantly. In 2023, a course was opened as follows:

• Course name: “Ethical Corporate Management and Sexual Harassment Prevention”
• Course outline: The ethical corporate management and sexual harassment prevention promotion, the explanation of employee ethics (including the prohibition of insider trading), and the compliance of code of ethics.
• Number of trainees: A total of 349 employees completed the training (the number of trainees should be 383,) the completion ratio is 91.12%
• Education hours: 349 hours

Besides, the company provides information of insider trading, including laws and regulations and case analysis to its insider (directors and managerial officers) by E-mail semiannually. For new insiders, information will be provided for six consecutive months since their appointment. Information has been sent on Mar. 31, 2023 and Sep. 28, 2023, respectively. Directors of the company also irregularly participate in external training courses such as corporate governance and insider trading policies organized by external organizations.

The amendment to the “Corporate Governance Practical Rules” was approved by board resolution on February 24, 2022. The amended provisions stipulate the adoption of stock trading control measures from the date insiders of the Company become aware of the contents of the company’s financial reports or relevant business results. Such measures include, but are not limited to, the prohibition of stock trading by directors during closure periods 30 days and 15 days prior to the release of annual and quarterly financial reports, respectively. We notified our insiders of the aforementioned closure periods by e-mail on the date the amendment took effect. In the future, insiders will be reminded of upcoming closure periods by e-mail 5 days in advance. In 2023, e-mail was sent out on Jan. 19, Apr. 19, Jul. 20 and Oct. 18, respectively.