


To implement sound Ethical Corporate Management (ECM), the HR Department has been assigned the responsibility of establishing and supervising the ECM policies and prevention programs, and reports to the Board of Directors on an annual basis.
The primary responsibilities of the ECM supervisor are to:
4.1. Regularly hold seminars related to ethical corporate management
The Legal Department and external lecturers jointly conduct seminars on topics such as "Prohibition of Receiving Improper Benefits," "Recusal Due to Conflict of Interest," and "Prohibition of Insider Trading" every year, which are mandatory for all employees. New employees are required to complete the digital course "Procedures for Ethical Management and Guidelines for Conduct" during the probation period. Through these seminars, the Company promotes sound ethical principles, actively upholds the values of honesty and integrity, strengthens corporate governance and risk management, and firmly embeds a culture of integrity at the core of the organization.
In 2025, the Company conducted integrity and ethical management–related seminars, including “Operating Procedures and Code of Conduct for Ethical Management.” The seminars covered topics such as the prevention of improper benefit transfers and the prohibition of insider trading. A total of 305 participant attendances were recorded, with cumulative training hours reaching 373 person-hours.
In 2025, the Company did not experience any incidents of unethical or dishonest business practices.
4.2. Formulation of "Procedures for Prevention of Insider Trading"
The Company's Board of Directors has adopted a resolution requiring employees involved in projects containing confidential information with the potential to materially affect the Company's stock price to sign a "Letter of Commitment to Prevent Insider Trading" or a "Non-Disclosure Agreement."
The Legal Department ensures that directors and managers are reminded of the prohibition against insider trading as stipulated in Article 157-1 of the Securities and Exchange Act when discussing significant matters or proposals that could impact the Company's stock price.
Furthermore, the Legal Department conducts periodic seminars, specifically addressing the theme of "Insider Trading Prevention Procedures," to reinforce awareness among employees. These seminars emphasize the prohibition against trading the Company's shares based on material nonpublic information that could influence the stock price.
The Board of Directors has adopted a resolution titled "Procedures for the Prevention of Insider Trading," mandating that all employees involved in projects containing confidential information with potential material impacts on share prices must execute a "Prevention of Insider Trading Letter of Undertaking" and a "Non-Disclosure Agreement."
For Board meetings addressing significant issues or proposals that could influence the company’s share price, the Legal Department is responsible for reminding directors and managers in attendance of the prohibitions against insider trading outlined in Article 157-1 of the Securities and Exchange Act.
Additionally, the Legal Department provides a quarterly presentation to the Board of Directors, which includes the "Common Violations in Insider Share Transfers" memorandum issued by the Taiwan Stock Exchange Corporation.