Prevent Insider Trading
Internal Regulations
The company's board of directors approved the revision and announced it on August 10, 2023 , the Company has revised Article 10, Paragraph 4 of the "Corporate Governance Best Practice Principles" to prevent insider trading and standardize stock trading control measures for insiders of the Company from the date they learn about the company's financial reports or related performance contents, including (but not limited to) Directors are not allowed to trade their stocks during the closed period of 30 days before the announcement of the annual financial report and 15 days before the announcement of the quarterly financial report.
Implementation of Insider Trading Prevention Measures in 2025
I. Measures for Directors
1. Education and Awareness
● The Company conducts education and training on the Insider Trading Prevention Management Policy and relevant laws and regulations for incumbent directors at least once a year. Newly appointed directors receive such education and training within three months of assuming office.
● In 2025, the Company provided monthly education and training sessions on the Insider Trading Prevention Management Policy and relevant laws and regulations to all directors. A total of 12 sessions were conducted during the year, with 9 participant attendances per month from January to December. Each session lasted approximately 0.5 hours.
● The "Insider Shareholding Awareness Handbook" covered the following topics:
◆ Education on insider shareholding regulations
◆ Laws and case studies related to insider trading
◆ Laws and case studies related to stock price manipulation
◆ Laws and case studies related to short-swing trading disgorgement rights
◆ Large shareholding acquisitions and treasury shares
◆ Changes in insider shareholdings
2. Closed Period Notifications
In 2025, the Company notified and reminded all directors by email on January 24, April 23, July 24, and October 23, that they are prohibited from trading the Company’s shares during the closed periods, namely 30 days prior to the announcement of the annual financial report and 15 days prior to the announcement of each quarterly financial report.
II. Measures for Insiders (Managers and Employees)
1. The company conducts quarterly educational campaigns on "Prohibition of Insider Trading" for managers and employees.
2. In 2025, the company held educational sessions on January 22, April 17, July 14, and October 1, each lasting 0.5 hours, with a total of 432 participants. The topic, "Compliance with Regulations on the Prevention of Insider Trading," was presented to managers and employees. The sessions emphasized that internal staff must not exploit their positions, roles, or access to confidential information for personal or third-party gains. Employees are required to comply with insider trading prevention regulations and are strictly prohibited from engaging in securities trading when in possession of material non-public information.
3. Starting from October 1, 2025, “Insider Trading Prevention” has been incorporated into the onboarding training program for newly hired employees. Each training session lasts 0.5 hours, with 30 participant attendances recorded in 2025. Training topics include:
◆ What constitutes insider trading
◆ Why insider trading is prohibited
◆ Parties subject to insider trading regulations
◆ What constitutes “material information that may affect stock prices”
◆ Prohibited trading periods for insider trading
◆ How to prevent insider trading