1. Formulate the Integrity management policy and operation situation


The company has a code of Integrity conduct, and clearly states the management policy of Integrity management in the management regulations, actively publicizes and implements the implementation of the Integrity management policy, clearly defines the rules and complaint system, and promotes and implements it through internal education and training.

The company requires suppliers, contractors or other collaborators to provide a promise that they will not engage in any illegal business activities and will not provide improper benefits or bribes to colleagues of the company. The company also has a reporting system to provide relevant personnel to report any improper practices.


2. Implementing the Integrity management and operation


The company conducts business activities in a fair and transparent manner, ensures the confidentiality of business information, respects the commercial assets and intellectual property of customers and partners, and formulates "Intellectual Property Management and Operational Measures", "Code of Ethics", " Integrity "Business Code", " Integrity Management Procedures and Conduct Guidelines", and reporting channels, the implementation aspects of which are as follows:

Item Progress report
  1. Irregular internal publicity for all staff
A quarterly announcement for all colleagues
  1. Introduce newcomer training and on-the-job training
New recruits: The number of trainees is 169 (from March to November)
Incumbents: The number of trainees is 40.
The training object is the management level supervisor. In order to consider the internal operation of the company, the on-the-job colleagues will be notified in stages to carry out education and training.
  1. Integrity code included as part of annual performance appraisal
In December, the Code of Integrity was incorporated into the appraisal items of the employee performance appraisal method, and the employee performance appraisal was implemented in the current year.
  1. The employee shall not contravene the legal provisions of the Code of Integrity when the labor contract is added.
The labor contract update was completed in August, and employees must not violate the Integrity code.
  1. Submit a report to the board of directors on the implementation at least once a year.
Reported to the board of directors on December 23, 2011.
  1. Introduce the theme of intellectual property management education and training
    courses:
    protection and management of corporate business secrets
New recruits: The number of trainees is 109 (from June to November)
Incumbents: The number of trainees is 151 (the first stage + the second stage)
The first stage is for R&D, engineering, and the second stage is for manufacturing , Quality assurance, business, PM team, operation team, support team.
  1. Implement the propaganda of insiders prohibiting insider trading, and plan three training courses in total, which are as follows: Topic 1. Laws and matters needing attention of the company's internal managers Topic 2. Promotion meeting on prevention of insider trading Topic 3. Integrity Management, Integrity Behavior and Corporate Social Responsibility Promotion
The cumulative number of training sessions is 97
and the cumulative training hours are 6 hours


3. Promoting and fulfilling corporate Integrity management units


The company's dedicated unit for promoting corporate Integrity management is the "Corporate Governance and Sustainable Management Committee", and the "Management Department" assists in establishing relevant rules and appeal systems such as Integrity management policies, and through internal promotion, labor contracts, education and training, Performance appraisal ... fully implemented. Report the implementation situation to the top management at least once a year , and it was reported to the board of directors on December 23, 2011.

The company's accounting system and internal control system operate normally. The audit office conducts audits according to the audit plan, issues audit reports every month and submits them to independent directors for review, and also reports to the competent authority in accordance with regulations.


4. Company whistleblowing system and operation process


Implementation Status:
The Company's "Reporting System Specifications" are listed in the "Guidelines for Operational Procedures and Behaviors of Integrity Management " . Internal and external reports of dishonesty or misconduct, if the report case is accepted, the special unit will initiate investigation procedures according to regulations, and protect the whistleblower from being improperly dealt with due to the report, and there will be no dishonest behavior in 2021. report a case.

Instructions for handling whistleblowers:

5. Enhancing information disclosure Does the company disclose the content of its Integrity management code and promote its effectiveness on its website and public information observatory?

Implementation Status:
The " Integrity Management Code" and related standards set by the company are published on the internal and external websites at any time to provide information from all walks of life , and all employees will be announced and the information on the webpage will be updated when they are revised. The company has a dedicated unit with "information disclosure management measures" and ""Public Information Observatory" Announcement and Reporting Matters Handling Points", which can immediately disclose important information and fulfill the company's responsibility and obligation for information disclosure. In addition, voluntary disclosure matters are announced on the public information observatory and the company's website to strengthen information transparency and improve the timeliness, symmetry and fairness of information disclosure.


6. If a company has its own Integrity management code in accordance with the "Code of Integrity Management of Listed OTC Companies", please describe the differences between its operation and the established code:

Implementation Status:
NA


7. Other important information that helps to understand the Integrity of the company's business operations: (such as the company's review and revision of its Integrity management code, etc.)

Implementation Status:
The company complies with the Company Law, the Securities Exchange Law, the Commercial Accounting Law and other laws and regulations related to business conduct, as the basis for the implementation of honest management.

The company perform Integrity management.