In order to strengthen corporate governance and risk control, the Company has established the “Code of Conduct for Integrity Management”, “Procedures and Conduct Guidelines for Integrity Management” and “Code of Ethical Conduct”, which stipulate that directors, managers, employees, and appointees of the Company should comply with the laws and regulations and prevent the occurrence of dishonest behavior. In order to strengthen the corporate culture and sound development of honest management, and to provide a reference framework for establishing good business operations, the General Manager Office and the HR & Admin Center will promote ethical corporate management through an exclusively (or concurrently) dedicated unit that is responsible for the formulation and implementation of ethical management policies and prevention plans, and that regularly reports to the Board of Directors every year. The latest reporting date was December 28, 2023.

Implementation status in 2023:

Training advocacy

• Irregular executive meeting training promotions.
• Email announcements and case advocacy.
• 100% participation rate for new employee education and training.

Audit

• The Audit Office regularly checks the implementation and confidentiality of trade secret management of each department.

Reporting

• 0 cases reported by employees.

Commitments

• As the end of 2023, a total of 46 newcomers had signed a letter of commitment to integrity.
• The Company requires cooperative suppliers to adhere to ethical corporate management concepts. By the end of 2023, 26 suppliers had signed an ethical letter of commitment to integrity, and 26 suppliers had signed a corporate social responsibility and behavior letter of commitment to standards.
• Commitment to develop a corporate culture of ethical corporate management.

Whistleblower Mailbox

• The Company has a whistleblower mailbox (contact.lid@upi-semi.com) for use by internal and external personnel, and the whistleblower should provide at least the following information:

  1. The name and ID number of the person making the report, and the address, phone number and email address where the person can be reached.
  2. The name of the person being reported or other information that identifies the person being reported.
  3. Specific evidence that can be used for investigation.

• The Company’s personnel handling the report shall declare in writing that the identity of the person making the report and the contents of the report shall be kept confidential, and the Company undertakes to protect the person making the report from being improperly treated as a result of the report.

• Upon receipt of a whistleblower report, the Company will follow the following procedures to handle the report.

  1. If the matter involves a general employee, the matter shall be reported to the department head; if the matter involves a director or senior executive, the matter shall be reported to the independent director.
  2. The Company’s specialized unit and the supervisor or officer reported in the preceding paragraph shall immediately ascertain the relevant facts and, if necessary, provide assistance from compliance or other relevant departments.
  3. If it is confirmed that the person being reported has violated the relevant laws and regulations or the Company’s policies and regulations on integrity management, the person being reported shall be immediately requested to stop the relevant conduct and dispose of it appropriately, and if necessary, report it to the competent authorities, refer it to judicial authorities for investigation, or seek damages through legal proceedings to protect the Company’s reputation and rights.
  4. Written documents shall be kept and preserved for five years, and the preservation may be done by electronic means. If a lawsuit related to the contents of the report occurs before the expiration of the retention period, the relevant information shall be retained until the end of the lawsuit.
  5. If a report is substantiated, the relevant unit of the Company shall be instructed to review the relevant internal control system and operating procedures and propose improvement measures to prevent the recurrence of the same conduct.
  6. The Company’s dedicated unit shall report to the Board of Directors on the report, its handling, and subsequent review and improvement measures.