Integrity management

■ 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.

    Additionally, in December 2023, the Board of Directors approved the "Management Guidelines for External Donations and Sponsorships" to foster a corporate culture of integrity and promote sound development. Regarding the management of external information, employees are required to sign an employment contract upon onboarding, which includes a confidentiality clause and provisions on intellectual property rights under Article 6. Office software documents and outgoing emails are subject to monitoring, and regulations for encrypting sensitive information before transmission are being developed to prevent the infringement of trade secrets.
  2. Procedures, Guidelines, and Disciplinary and Appeal Systems
    The company’s “Principle of Integrity Management” and “Operating Procedure and Conduct Guideline of Integrity Management” clearly define unethical behaviors, forms of conflict of interest, and systems for rewards, penalties, and appeals. These regulations govern employee conduct during business operations and assign a dedicated unit to uphold and implement ethical business practices.

    Additionally, the company has established the "Whistleblowing System Implementation Guidelines" to investigate reports, findings from internal audits, and significant delayed credit cases. The company conducts an annual review of external regulations and internal practices to ensure timely updates and amendments to relevant provisions.
  3. Provisions on integrity
  4. 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).

Integrity management operation and implementation

■ Declaration of Integrity from Directors and Senior Executives

  1. As of 2024, all 11 directors, 10 senior executives, as well as audit and accounting supervisors of the company have signed the "Statement of Compliance with the Integrity Management Policy."

■ Supplier Commitment to Integrity

As of 2024, in addition to maintaining basic supplier information records, all major procurement suppliers have signed the "Corporate Social Responsibility and Sustainable Operation Commitment." Anti-corruption and corporate social responsibility clauses have also been included in contract agreements.

■ Integrity Management Training

In 2024, the Audit Office organized an online course titled "2024 Infinite Finance Integrity Management Promotion" for employees of Infinite Finance Co., Ltd. By the end of December 2024, 534 employees had completed the course. Additionally, two in-person sessions titled "2024 Infinite Finance Integrity Management Promotion - Preventing Fraud is Everyone's Responsibility" were held in October, attended by 245 participants. Moving forward, integrity management training will be included as a mandatory online course in the onboarding program to ensure that all employees understand the company's commitment to integrity.

■ Integrity Promotion

The company has made the relevant regulations, procedures, and policies available on the corporate intranet for employees to access at any time.

■ Implementation of Whistleblowing System

The company has established a whistleblowing system, complete with specific reporting and reward mechanisms. There are three reporting channels available: telephone, email, and mail. The Audit Office has been designated as the dedicated unit for handling these reports.

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