The management of preventing insider trading is effectively implemented through concrete operations.

The company conducts at least one annual education and awareness session for current directors and managers on the prevention of insider trading and related regulations. Newly appointed directors, managers, and employees receive training within three months of their appointment or employment.
(1) Educational sessions were conducted on January 19, May 8, July 23, and October 23, 2024, to address common violations of securities trading regulations related to insider shareholding changes.
(2) On February 27, 2024, an educational session was conducted for insiders on relevant regulations, including the prevention of insider trading, stock price manipulation, and material information disclosure. Emphasis was placed on implementing confidentiality measures during the formation of material information.
(3) On October 11, 2024, the "Q&A Guide on Insider Share Trading for Listed Companies" was communicated to relevant personnel.

Insider Trading Prevention Management: Establishing and maintaining records of insiders and shareholders holding 10% or more of the company’s shares.

• Definition and Scope of Insiders
  1. Directors, supervisors, managers, and shareholders holding more than 10% of the company's total shares.
  2. Related Parties of Insiders(Includes spouses, minor children, and those holding shares under another person's name)
• Insiders must report and disclose to the competent authority the types and number of company shares they hold.
• To ensure compliance with regulations and reduce insider violations, newly appointed insiders must submit a declaration. Additionally, the HR department must notify the stock affairs agent at least two days before their appointment or resignation. The stock affairs agent is responsible for promptly entering the new insider’s information into the "Insider Appointment and Resignation Instant Reporting" system. (Download Declaration Form )
• Ensure thorough promotion of the obligations of insiders, including pre-reporting of share transfers, post-reporting of shareholding changes, maintenance of minimum shareholding by directors and supervisors, prohibition on selling treasury shares during buyback periods, reporting of large acquisitions and changes in shareholding, prohibition on short-swing trading, and prohibition on insider trading, among seven items.
• Insiders must report any changes in their shareholding by the 5th of each month. The company is required to consolidate and report this information to the competent authority by the 15th of each month. If necessary, the competent authority may require the company to make a public announcement.
• If an insider transfers more than 10,000 shares on any given trading day, they must comply with the pre-reporting requirements.

Definition of Material Internal Information Affecting Stock Price

• Refers to information related to the company's finances, business operations, or the market supply and demand of its securities, including public offerings, that has a significant impact on its stock price or is of crucial importance to the investment decisions of reasonable investors.
• The scope of material information is defined in accordance with Article 2 of the "Taiwan Stock Exchange Corporation’s Procedures for Verification and Public Handling of Material Information of Listed Companies."

Confidentiality and Prohibition on Trading Measures Before Public Disclosure of Material Internal Information Affecting Stock Price

• Directors, supervisors, managers, and employees who are aware of the company's material internal information must not disclose such information to others. Additionally, they must not disclose any non-public material internal information they learn, unless it is in the course of executing their duties.
• Ensure insiders understand the practicalities of insider trading laws to prevent such activities.
• Strengthen the storage and confidentiality measures for the company’s non-public material internal information files.
• Manage and regulate the share transfers of the company’s insiders.

Content, Timing, Method, and Personnel for the Public Disclosure of Material Information Affecting Stock Price

• The public disclosure of material internal information should adhere to the principles of accuracy, completeness, timeliness, and fairness.
• Spokespersons and deputy spokespersons are authorized by the company to represent a unified voice for external communication, with the Accounting Department handling the release and processing of material information.
• Prior to releasing material information, no details should be disclosed externally to ensure the accuracy and universality of the information.
• The Accounting Department is responsible for information reporting and entering it into the "Public Information Observation Station" in accordance with the "List of Business Matters to Be Handled by Issuers of Listed Securities."
• If media reports contain information that contradicts the company’s disclosure, the company should promptly issue a clarification through the Public Information Observation Station and request the media to make corrections.