The Company’s implementation of ethical management is as follows:

Items Performance Difference with the “Ethical Corporate Management Best Practice Principles for TWSE/GTSM Listed Companies” and the Reasons of such Difference
Y N Summary

I. Stipulation of Ethical Management Policies and Plans

1. Does the Company stipulate the ethical corporate management policy approved by the board of directors, and clearly indicate the ethical operation policy and practice in regulations and external documents, and the commitment of the board of directors and senior management level to actively implement the operating policy?
V   The Company has stipulated the “Procedures for Ethical Management and Guidelines for Conduct” and the “Procedures for Ethical Management”, approved by the Board of Directors and posted on the Company’s official site. No significant difference
2. Does the Company stipulate a risk assessment mechanism for unethical conduct, regularly analyze and evaluate business activities with a higher risk of unethical conduct in the business scope, and stipulate plans to prevent unethical conduct, which at least covers the regulations specified in Paragraph 2 of Article 7 of Ethical Corporate Management Best Practice Principles for TWSE/GTSM Listed Companies. V   The Company has stipulated the “Procedures for Ethical Management and Guidelines for Conduct” and the “Procedures for Ethical Management”, which have covered the regulations specified in Paragraph 2 of Article 7 of Ethical Corporate Management Best Practice Principles for TWSE/GTSM Listed Companies. All company decisions and actions are strictly required to comply with laws and regulations, and the concept of ethical management is management is enhanced via the approaches of education, training, and promotion. No significant difference
3. Does the Company clearly define operating procedures, guidelines for conduct, penalty and complaint systems for violations in the regulations for preventing unethical conduct, fully implement such plans, and regularly review such plans? V   The Company has stipulated “Procedures for Ethical Management and Guidelines for Conduct”, which prohibits the Company and its directors and managers from offering or accepting improper benefits, and clearly specifies the procedures for handling political contributions, charitable donations or sponsorships. No significant difference

II. Implementation of Ethical Management

1. Does the Company evaluate the integrity records of its counterparties and clearly and specifically specify the clauses of ethical conduct in the contracts it signs with counterparties?
V   Before establishing various business relationships with any counterparties, the Company will consider the legitimacy and whether there are records of dishonest/unethical behaviors of such counterparty to ensure that all business activities comply with the principle of good faith. No significant difference
2. Does the Company establish a specific unit under the board of directors to promote ethical corporate management, regularly (at least once a year) report to the board of directors of the policies or plans for preventing unethical conduct, and supervise the implementation? V   The Company’s General Manager’s Office is responsible for formulating and supervising the ethical management policies and prevention plans and regularly submits and reports relevant information to the Board of Directors. The most recent report was during the 15th meeting of the seventh session of the Board of Directors on December 20, 2021. No significant difference
3. Does the Company stipulate policies to prevent conflicts of interest, provide appropriate channels for presentation, and implement these measures fully? V   The Company has stipulated employee work rules, which clearly specify the matters that all staff shall be aware of pay during the period of employment to prevent employees from damaging the Company’s rights and interests due to their personal interests. No significant difference
4. Does the Company establish an effective accounting and internal control system for the implementation of ethical corporate management, have the internal audit unit stipulate relevant audit plans based on the results of the assessment of the risk of unethical conduct, and examine the plans for preventing unethical conduct accordingly or appoint the accountants to perform such examination? V   The Company has stipulated employee work rules, which clearly specify the matters that all staff shall be aware of pay during the period of employment to prevent employees from damaging the Company’s rights and interests due to their personal interests. No significant difference
5. Does the Company regularly organize internal and external education and training on ethical corporate management? V   Internal: In addition to specifying the matters included in “Procedures for Ethical Management and Guidelines for Conduct”, the Company also promotes various relevant standards through employee education and training, internal emails and meetings. The General Manager was responsible for promoting various integrity issues and held 3 sessions with 115 participants and 3 on-line meetings in FY2021. External: The Company provides ethical management courses for directors, managers, and insiders. In FY2021, there were 3 participants attending the courses of 9 hours in total. No significant difference

III. The Operation of the Company’s Whistleblowing System

1. Does the Company stipulate a specific whistleblowing and reward system, provide a convenient whistleblowing channel, and designate appropriate responsible personnel for receiving the reporting??
V   The Company has established a specific whistleblowing and reward system, the internal and external independent reporting mailboxes and hotline, and a dedicated unit to handle related affairs. The whistleblowing site of the Company: https://www.fine-tek.com/investors/p/reporting No significant difference
2. Does the Company stipulate a standard operating procedure for the investigation of reported matters, subsequent measures to be taken after the investigation and related confidentiality mechanisms? V   The Company has established standard operating procedures and related confidentiality mechanisms for investigating and accepting reported cases. No significant difference
3. Does the Company take measures to protect the whistleblowers from being improperly treated as a result of the whistleblowing? V   The Company has a dedicated unit to take necessary protective measures for whistleblowers to avoid improper treatment due to whistleblowing. No significant difference

IV. Improvement of Information Disclosure

1. Does the Company disclose on its official site and MOPs the content and promotion results of its ethical corporate management?
V   The Company has disclosed the contents of its Procedures for Ethical Management at the Company’s official site and MOPs. No significant difference

V. If the Company has stipulated its regulations for ethical corporate management in accordance with the Ethical Corporate Management Best Practice Principles for TWSE/GTSM Listed Companies, please specify the difference between the implementation and the requirements of the established regulations:

The Company has stipulated the “Procedures for Ethical Management and Guidelines for Conduct” and the “Procedures for Ethical Management”. The General Manager's Office is responsible for formulating and supervising the ethical management policies and relevant prevention plan and regularly reports the information to the Board of Directors. The operation of the Company’s mechanism for ethical management has no major differences with the Ethical Corporate Management Best Practice Principles for TWSE/GTSM Listed Companies.

VI. Other supporting information that allows further understanding of the Company’s ethical corporate management:

1.The Company complies with the Company Act, the Securities and Exchange Act, the Business Entity Accounting Act, the relevant regulations for listing and OTC companies, and other relevant laws and regulations on business conduct as the basis for the implementation of integrity management.
2.The company has formulated the “Procedures for Handling Material Inside Information”, which clearly stipulates that directors, managers and employees shall neither disclose any internal material information they know about to any other third parties, nor shall inquire or collect any internal material information from any persons who knows of it. The directors, managers and employees shall not disclose any internal material information undisclosed by the Company which they know about due to reasons other than the performance of business to any other third parties.
The Company always adheres to the principles of honesty and integrity, complies with relevant laws and regulations and internal control systems to operate ethically and lawfully, strictly prohibits dishonesty or violation of laws and regulations, and appoints legal consultants to provide necessary consultation and review basis.
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