Performance of Honest Business Operations

Corporate Governance

Performance of Honest Business Operations

Assessed Items	Operation Circumstances			Differences and its Reasons of the Conducts of Integrity as compared with other listed companies and OTC companies
Assessed Items	Yes	No	Abstracts
1.Establishing integrity management policies and programs
1.1 Does the company establish integrity management policy which is approved by the board of directors, and express its commitment in its regulations and external documents, as well as the commitment of the board of directors and management to actively implement business policies?	●		The Company has established ”Ethical Corporate Management Best Practice Principle” and actively prevent dishonest behavior and clearly stipulate that directors, managers, employees or persons with substantial control over the company shall not directly or indirectly provide, promise, request or accept any improper benefits, or do other things that violate integrity , illegal or breach of fiduciary obligations and other dishonest behaviors that damage the company's interests and reputation...etc. Establish and actively implement a corporate culture of honest management. The company's code of integrity management and related policies have been disclosed on the public information observatory and company website.	No Major differences
1.2 Does the company formulate a risk assessment mechanism to prevent dishonesty, assess and analyze high dishonesty risk operation activities, and formulate procedures to prevent such activities which at least in accordance with seventh paragraph of Article 7 (2) of the “Code of Integrity of Listed Companies”?	●		In accordance with the provisions of the " Ethical Corporate Management Best Practice Principle ", the company's board of directors has approved the formulation of a "Dishonest Behavior Prevention Plan", established a risk assessment mechanism for dishonesty, and regularly analyze and evaluate business activities with higher risks of dishonesty within the business scope. Covering the preventive measures for each behavior in Paragraph 2 of Article 7 of the " Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies ", and formulating a prevention plan for dishonest behavior accordingly. The company's dedicated unit will evaluate and review the current rules and regulations to effectively reduce the risk of dishonesty. The risk of dishonest	No Major differences behavior in 2023 years was found to be low risk.
1.3 Does the company specify the operating procedures, behavior guidelines, disciplinary penalties and grievance system in the plan to prevent dishonesty, and implement it, and regularly review and revise the plan?	●		The company has clearly defined relevant operating procedures and behavioral guidelines in the "Dishonest Behavior Prevention Plan" to prevent the occurrence of dishonest behaviors, and defined relevant disciplinary and complaint systems, also, relevant disciplinary and complaint systems are defined in Article 18 of the "Dishonest Behavior Prevention Plan" and the company's "Reward and Punishment Management Measures". The company does not allow any bribery, fraud, misuse of company assets or sacrifice of company interests in exchange for personal interests, to strengthen and implement integrity management. The company's dedicated integrity management unit keeps abreast of the developments of the competent authorities, timely add or revise various codes and operating procedures related to corporate governance and honest operations, regularly conduct assessments of dishonesty risks, revise prevention plans, and other related operations, and regularly report the progress to the board of directors. In addition, in order to keep colleagues aware of anti-corruption, integrity and ethics, the company has published the above-mentioned relevant regulations on the company's internal website and add integrity clauses to employee contracts for new employees, conduct trainings and tests on integrity management for all employees every year, and actively implement anti-corruption, integrity and moral values to deepen the principle of "integrity".	No Major differences
2. The Implementation of Integrity Management
2.1 Does the company assess the integrity record of the object of the transaction and specify the terms of good faith in the contract with the transaction partner?	●		The company performs business contracts in a fair and ethical manner and abides by relevant laws, regulations and contract terms, and evaluates counterparties’ credit before trading. Contracts signed with transaction partners all stipulate good faith behavior clauses to prohibit any inappropriate business practices such as bribery, corruption, extortion, etc. to ensure compliance with anti-corruption regulations.	differences
2.2 Does the company set up a special unit that promotes the integrity management of the company under the board of directors, and regularly reports (at least once a year) its integrity policy, prevention on dishonesty, and execution to the board of directors?	●		The company has a dedicated integrity management unit to assist in formulating the code of integrity management and is responsible for promoting the implementation of the code of integrity management. It actively implements the concepts of integrity, integrity and moral values through annual training and tests, and conducts annual (at least once a year) report of the implementation status to the Board of Directors. "2024 Integrity management, prevention of insider trading and promotion of material information processing " were reported to the board of directors in writing on August 14, 2024.	No major differences
2.3 Does the company formulate a policy to prevent conflicts of interest, provide a proper presentation channel, and implement it?	●		The company has an interest avoidance clause in the "Ethical Corporate Management Best Practice Principle" and "Code of Corporate Governance Practice", requiring directors, managers and all employees to prevent conflicts of interest and not to take advantage of their positions or influence in the company to obtain unfair benefits. The Company's "Standards of Procedures for the Board of Directors" and "Organizational Rules of the Audit Committee" both specify provisions regarding directors' avoidance of interests to avoid conflicts of interest. Directors or the legal person they represent who have an interest in various matters of the Board of Directors meetings or the legal persons they represent, which may harm the interests of the company, shall execuse themselves from discussions and voting, and shall not exercise their voting rights on behalf of other directors. Independent directors of the company provide suggestions based on their professionalism and experience, the board of directors will fully consider the independent directors opinions, their objections and reservations will be included in meeting minutes to effectively protect the interests of the company. Follow the provisions of Article 17 of the "Corporate Governance Code of Practice", the company's transactions with related parties and related enterprises are based on the principle of fairness and reasonableness, and written regulations are established for mutual financial business transactions, clearly set price conditions and payment methods for contract matters, and strictly prohibit the transfer of benefits. Transactions between major related parties and related enterprises must be approved by the Audit Committee and then submitted to the Board of Directors for resolution.	No Major differences
2.4 Has the company established an effective accounting system and internal control system for the implementation of credit management, and the internal auditing unit will establish audit plan based on the assessment of dishonesty behavior risk, and audit the compliance status of dishonesty behavior or entrust external accountant to perform audit?	●		The company establishes an accounting system and prepares financial reports in accordance with the financial reporting standards for securities issuers and the International Financial Reporting Standards, International Accounting Standards (IFRS Accounting Standards) recognized by the Financial Supervisory Commission, and entrusts Deloitte & Touche to perfrom verification and certification of financial reports. The company has established an integrity operation related internal control system , and the internal audit unit formulates an audit plan based on the assessment results of the risk of dishonest behavior, including audit objects, scope, projects, frequency, etc., and the audit results are prepared into an audit report and submitted to the audit committee and the board of directors to enable the management level understand the implementation of the company's internal control for management.	No Major differences
2.5 Does the company regularly hold internal and external training of integrity management?	●		The Company regularly promotes intergrity management principles to the board of directors, mangers, and all employees. 150 people attened the training, the total training hour is 540. In addition, new employees are required to attend ethical and anti-corruption courses.	No Major differences
3. The Operation of The Company's Reporting System
3.1 Does the company have a specific reporting and reward system, and establish a convenient reporting channel, and assign appropriate personnel to the respondents?	●		The company supports an open and transparent integrity and ethics culture, and encourages internal employees and external personnel to report any behavior that is not in compliance with the company's relevant policies and allows anonymous reporting. Reporting channels: Internal opinion box Email: This email address is being protected from spambots. You need JavaScript enabled to view it.	No Major differences
3.2 Does the company stipulate the operational procedures for reported matters’ investigation, relevant actions and confidentiality mechanism after investigation?	●		The company's "Report and Complaint Management Procedure" stipulates the standard operating procedures for the investigation of reporting matters, the follow-up measures to be taken after the investigation is completed, and the relevant confidentiality mechanism statement, relevant personnel who are aware of the contents of the case should strictly abide by the principle of confidentiality. If there is any leakage, they will be severely punished in accordance with the company's disciplinary regulations to prevent the whistleblower from suffering retaliation or improper treatment.	No Major differences
3.3 Does the company take measures to protect the prosecutor from improper handling due to the report?	●		The safety of the whistleblower should be protected and carefully handled in accordance with the precautions in the confidentiality statement to protect the whistleblower from undue punishment for reporting.	No Major differences
4.Strengthen Information Disclosure
4.1 Does the company exposes the contents of its integrity management code and promotes its effectiveness on its website and public information observatories?	●		The Company will disclose information on the Code of Good Practice in company’s website and the Market Observation Post System.	No Major differences
5. If the company has its own code of conduct in accordance with the Code of Conduct for the Listing of Companies in the Listed Companies, please describe the difference between its operation and the code: The company has established relevant measures and implemented them accordingly. No major difference.
6. Other important information that helps to understand the company's integrity operation: (If the company reviews and amends its established code of conduct, etc.): None.

Anti-corruption, honest management and implementation of moral values are the core values and fundamentals of the Company's operations. The Company's board of directors passed the formulation of the " Ethical Corporate Management Best Practice Principles ", "Integrity Operation Procedures and Behavior Guidelines”, "Supplier Code of Conduct", and "Anti-corruption and Anti-bribery Policy" as the basis for compliance by all employees and business partners.

The above-mentioned main areas of anti-corruption and integrity management and the relevant implementation status of the year are as follows:

Employees:

0 complaints and reports (including anonymous reports) related to honest management in 2023.
No corruption or bribery, conflict of interest, money laundering or insider trading in 2023.
The company prevents employees from committing unethical behaviors through "Integrity Business Operation Procedures and Conduct Guidelines" and strict internal control systems, as well as continuous internal communication and education and promotion. In employee satisfaction surveys in recent years, the "Moral Values" aspect has the highest satisfaction level.
The company conducts education program on integrity management, reporting and complaint procedures, ethical code of conduct, etc. to all colleagues through letters or official documents every year, educates colleagues on matters they should pay attention to when performing business, strengthen the concept and implementation of employee ethics, anti-corruption concepts and prevention mechanisms, and jointly manage and prevent the occurrence of dishonest behaviors.

Business partners:

(1) Before establishing a business relationship with dealers, suppliers or other business partners, evaluations must be made on legality and reasonableness of their business practices, and whether the partners have any records of violating integrity management. Explicitly refuse to accept any improper benefit in business process that are directly or indirectly provided, promised or requested. Once dishonest behavior is discovered, transactions will be stopped immediately.

The Company's has set up a dedicated report and complaint mailbox on official website for business partners, and has dedicated personnel responsible for handling reports and complaints. In order to protect the whistleblower and complainant, investigations will be made in accordance with the principle of confidentiality and disclosing case details is strictly prohibited. When investigating relevant personnel, only the relevant parts of the personnel and the case will be discussed to protect the rights and interests of the whistleblower. There were 0 related complaints and reports (including anonymous reports) in 2023.

Corruption and integrity management risk assessment:

Regularly conducts annual assessments on business activities with higher risks of dishonest, confirms that the current internal rules and regulations can effectively reduce the risk of corruption and dishonest operations, and formulates a plan to prevent dishonest behavior accordingly. 2023 annual assessment result is low risk, and the assessment results are provided to internal audit as a reference for planning the audit plan.

Supervision by the board of directors:

The board of directors implemented anti-corruption, honest management and ethical values by formulating " Procedures for Handling Material Inside Information ", " Procedures for the Prevention of Insider Trading ", and " Procedures for Ethical Management and Guidelines for Conduct ".
The Company’s “Procedures for the Prevention of Insider Trading” prohibits insiders to use undisclosed information in the market to buy and sell securities, and educational promotion to insiders must be held to insiders at least once a year, using undisclosed information to deal is prohibited for insiders to ensure shareholders’ rights.
According to “Corporate Governance Best Practice Principles” and Article 10 of “Corporate Governance Best Practice Principles for TWSE/TPEx Listed Companies” by TWSE, stock trading control measures for insiders of listed companies who are informed of the Company's financial reports or related performance content are made, insiders, including directors, are not allowed to trade their stocks during the closed period of 30 days before the announcement of the annual financial report and 15 days before the announcement of the quarterly financial report.
The audit office conducts internal control audits in accordance with company regulations and reports to the audit committee and board of directors when non-compliance is discovered, assist audit committee and the board of directors to confirm the company's implementation of anti-corruption, honest operations and implementation of ethical values.
The promotion of ethical corporate management, prevention of insider trading and processing of major information in 2023 is as follows:

Conducted educational promotion on “Ethical corporate management, insider trading prevention and major information processing” for all board members.
In 2023, board members attended ethical corporate management courses (including corporate governance related courses). A total number of 20 person-time and 66 hours are taken.
The Company shall notify the insiders before the announcement of each financial report in accordance with the deadline prescribed by laws and regulations. Reminder implementation of the latest annual insider stock trading closure period:

Period of financial statement	Board meeting date	Closing period	Notification	Implementation
2024Q2	113/08/27	113/08/12 to 113/08/27	Insiders (include but not limit to board members)	Email notification within prescribed period by corporate governance unit
2024Q3	113/11/12	113/10/28 to 113/11/12	Insiders (include but not limit to board members)	Email notification within prescribed period by corporate governance unit

˙0 cases related to ethical management issues in 2023.