￭ Integrity management policies and prevention plans

1. Policy formulation
   In order to establish an integrity management culture, the Company formulated a new “Principle of Integrity Management” and “Operating Procedure and Conduct Guideline of Integrity Management” in April 2023, which had been approved and adopted by the Board of Directors. The provisions contain the policies and practices of the Company’s integrity management, and the duties of the Board of Directors and the management of the Company. It is stated that during the corporate governance and the conduct of its business, nobody shall request any improper benefits, or engage in other acts that violate integrity management, are unlawful or breach of authorized duties. In addition, it requires that directors and the senior management shall provide a statement of compliance with the integrity management policy.

￭ Preventive measures

1. The Company has established the “Operating Procedure and Conduct Guideline of Integrity Management” as a guideline for evaluating and implementing integrity management, and regularly reports to the Board of Directors on the promotion of integrity management every year. Preventive measures have been made for business activities with a high risk of dishonest conduct. In addition, internal control mechanisms, such as Measures for the Implementation of the Whistleblowing System, have been established to monitor and prevent fraud or misconduct. Both insiders and outsiders can use a variety of channels such as dedicated phone line , correspondence, and email to report misconducts, frauds, illegal acts, and violations of the Company’s discipline or work rules.
2. Operating procedures, conduct guidelines, disciplinary and appeal systems for violations
   In the “Principle of Integrity Management” and “Operating Procedure and Conduct Guideline of Integrity Management”, the Company clearly stipulates the types of dishonest conducts and related interests, the reward and punishment system and the appeal system, specifies regulations on the behavior of the Company’s personnel in the process of business, and assigns a dedicated unit to maintain and implement the conducts of integrity management. The Company regularly reviews external regulations and internal practices every year, and timely amends the relevant regulations.
3. Provisions on integrity
   In accordance with the provisions of the “Operating Procedure and Conduct Guideline of Integrity Management”, the Company shall fully understand the integrity management status of the other party when entering into a contract, and incorporate compliance with the integrity management into the terms of the contract. In addition, it shall be required that the contract shall have clear terms on compensation for damages, termination or rescission of the contract in case of acceptance of improper benefits.

￭ Dedicated unit of integrity management

In order to improve the management of integrity management, the Sustainable Development and Corporate Communication Department is designated as the Company’s dedicated unit of integrity management (hereinafter referred to as the “dedicated unit”), which is responsible for promoting the integrity management policy, and coordinating with relevant departments to complete the revision and implementation of relevant regulations or work procedures related to integrity management. The Auditing Office is the dedicated unit to accept complaints of dishonest conducts. It is responsible for the notification and filing of complaints and dishonest conducts, and it also supervises the promotion of the integrity management policy. After the dedicated unit summarizes the annual implementation results, the Auditing Office shall make a report on the promotion of integrity management together with the complaints and supervision, and report to the Board of Directors regularly (at least once a year). In April 2023, the Company formulated the new “Principle of Integrity Management” and “Operating Procedure and Conduct Guideline of Integrity Management”, willed complete the 2023 annual report on the implementation of integrity management in accordance with relevant measures.

Integrity management operation and implementation

￭ Education and training of integrity management

1. In 2022, although the Company has not yet developed the Principle of Integrity Management, in the training of new employees in the year, the term of “integrity”, one of the Company’s core values, has been advocated to all new employees that they shall be honest and ethical in all businesses. At least once a month training for new employees has been held in 2022.
2. In April 2022, the Company held an advocacy course on integrity management (IBT Leasing Corporation before the merger), which lasted about one hour and covered ESG, integrity management, cases of dishonest enterprises, regulations on corporate integrity management and description of frauds, with a total of 320 personnel from IBT International Financial Leasing Corp. attending the course. In June 2023, online courses such as “Insider Trading and Information Disclosure”, “ESG and Integrity Management” were provided to all staff, with each course lasting about 40 minutes.

￭ Operation of the whistleblowing system

The Company has formulated the Measures for the Implementation of the Whistleblowing System and established a specific whistleblowing and reward system. There are three reporting channels including telephone, email and correspondence, and the Auditing Office is designated as the dedicated unit for accepting and handling complaints. There were no complaints in 2022.