Implementation Status of Preventing insider trading

To prevent the directors, managers, and employees from erroneously violating the relevant regulations on insider trading due to their not being familiar with the laws and regulations. Establish better procedures and disclosure mechanisms for handling material inside information to avoid information leakage, and ensure the consistency and accuracy of the company’s information published to the outside. We have established “the procedures for handling material inside information and preventing insider trading rule.” and disclosed it on uPI’s website.

When new directors, managers, and employees take office, uPI has to provide them with relevant education and also irregularly provide the relevant regulatory information in advocacy thereof and remind them of matters to be noted concerning insider trading.

 

In 2024, the implementation of insider trading prevention was as follows:

• A total of 190 emails were sent to the directors and managers to remind them to pay attention to laws and regulations related to insider and short-swing trading by email each month.
• Each half year, promoted the relevant law of Insider Trading to all employees, and annually to directors of the Company by email, with a total of 628 participants.
• Each quarter, physical or online courses were provided to new recruits on the regulations of insider trading, with a total of 96 participants.

In 2025, the implementation of insider trading prevention was as follows:
To prevent insiders such as directors or employees from using non-public information to trade securities, the company revised its Corporate Governance Best Practice Principles, which was approved by the Board of Directors on February 25, 2025. The revision explicitly stipulates that directors are prohibited from trading company shares during the blackout period — 30 days before the annual financial report is announced and 15 days before each quarterly financial report is announced.

Each quarter, emails are sent to remind directors and insiders of the upcoming board meeting dates for the approval of financial reports and the corresponding stock trading blackout periods. A total of 17 email notifications are sent per quarter.