Internal Regulations for Preventing Insider Trading 

The Company has established the "Procedures for Handling Material Internal Information and Preventing Insider Trading," which clearly stipulates that directors, managers, and employees shall not disclose any material internal information they become aware of to others, nor inquire about or collect undisclosed material internal information of the Company from persons who are aware of such information and which is unrelated to their duties. Furthermore, those who learn of the Company's undisclosed material internal information not in the course of performing their duties shall not disclose such information to others. Personnel of the Company shall comply with the provisions of the Securities and Exchange Act and are prohibited from using undisclosed information to engage in insider trading or disclosing it to others to prevent them from engaging in insider trading.  Regarding directors, they are prohibited from trading the Company's stock during the blackout period prior to the announcement of financial reports. This is specified in Article 10, Paragraph 4 of the "Corporate Governance Best Practice Principles." This regulation should include control measures for the trading of the Company's stock by insiders from the date they become aware of the Company's financial reports or related performance results, including (but not limited to) prohibiting directors from trading the Company's stock during the 30-day blackout period prior to the announcement of the annual financial report and the 15-day blackout period prior to the announcement of each quarterly financial report. These procedures and principles have been publicly disclosed on the Company's corporate website. 
 

Implementation Status

  • The Company periodically conducts advocacy sessions for directors and management on insider trading and shareholding-related laws and precautions for insiders. For new employees, the Human Resources Department provides guidance upon onboarding on the Company’s code of ethics, management measures, and regulations. All measures are disclosed on both the Company's internal and external websites for employees' reference. 
  • When notifying the Board of Directors of meeting times via email, the following reminder is added: 
    "Pursuant to Article 10 of the Corporate Governance Best Practice Principles, insiders of the Company are subject to stock trading control measures from the date they become aware of the Company's financial reports or related performance results, including (but not limited to) the prohibition on directors trading the Company's stock during the 30-day blackout period prior to the announcement of the annual financial report and the 15-day blackout period prior to the announcement of each quarterly financial report."
  • On December 6, 2024, the Company arranged for managers to attend the course "Practical Cases of Insider Trading and Related Legal Liabilities," which covered topics such as understanding insider trading, viewing insider trading from a corporate governance perspective, an introduction to Article 157-1 of the Securities and Exchange Act, and practical case studies. 
  • On December 18, 2024, the Company held a company-wide training course on "Trade Secret Protection and Prevention of Insider Trading" to further strengthen employees' understanding of ethical business practices and insider trading prevention.