Corporate Integrity

Precautionary Measures and Compliance with Integrity

Integrity Management Policy

Ennoconn’s policy on integrity management is set forth in the “Procedures and Conduct Guidelines for Integrity Management” approved by the Board on October 4, 2012. The Procedures and Conduct Guidelines specify the matters to which the company’s personnel should pay attention in the course of conducting business and are posted on the company’s intranet site for review by employees. Dishonesty, as defined in these Procedures and Conduct Guidelines, is defined as the offering, receiving, promising or demanding, directly or indirectly, any improper benefit, or engaging in any other conduct that is dishonest, unlawful or in breach of fiduciary duty, in the course of conducting business, for the purpose of obtaining or maintaining an advantage.

The Practice of Integrity Management

1. Our annual training program for new recruits includes the course “Promoting Honest Management Procedures and Code of Conduct, a total of 3 sessions were held in the first quarter of 2024, 4 sessions in the second quarter, 10 sessions in the third quarter, and 3 session in the fourth quarter, amounting to 35 training hours with 35 participants trained.
2. At least once a year, all directors and managers are given a training course on “Integrity Management and Prevention of Insider Trading”, which was held on June 25, 2024 and August 27, 2024, for a total of 2 hours and 183 people were trained.
3. Every Ennoconn new employee will sign the “Integrity and Intellectual Property Rights Agreement”.

Integrity Management Compliance

1. Ennoconn has established th”General Manager’s Office” as a dedicated unit to implement and supervise the revision, implementation, explanation, consultation service and filing of the contents of the report of the Procedures and Conduct Guidelines, and to report regularly to the Board of Directors on the “Precautionary Measures and Compliance Status of Integrity Management” every year, and the latest reporting date is March 8, 2023.
2. Every Ennoconn new employee had signed the “Integrity and Intellectual Property Rights Agreement” this year.
3. At the Board of Directors’ meetings, all directors who have an interest in the related issues are excused from the meeting and did not participate in accordance with the regulations on interest recusal.
4. As of March 8, 2023, Ennoconn had not received any reports of dishonest acts or misconduct.
5. Our company re-elected directors at the annual general meeting on June 23, 2022, all of directors and managers were issued a statement of compliance with the ethical management.

Reporting System

1. Reporting channels: Ennoconn encourages internal and external personnel to report dishonest acts or misconduct, and has announced and provided information on the reporting channels for internal and external personnel and stakeholders on the company’s official website on September 2015.
2. Whistleblower system: Ennoconn’s whistleblower system is specified in Article 21 of the “Code of Conduct and Procedures for Integrity Management”, which reads as follows:
   • Ennoconn encourages internal and external parties to report dishonest conduct or misconduct, and has established a reporting system on the company’s website for use by internal and external parties. The whistleblower should provide at least the following information.
     1. Name and ID number of the informant can be used to search the address, phone number and email address of the informant.
     2. Name of the person being reported or other information sufficient to identify the person being reported.
     3. The specific evidence available for investigation.
   • The company’s personnel handling the report shall declare in writing that the identity of the whistleblower and the content of the report shall be kept confidential, and the company undertakes to protect the whistleblower from being improperly disposed of as a result of the report. The company shall handle the matter in accordance with the following procedures
     1. If the report involves general employees, it should be reported to the President; if the report involves Directors or Senior Executives, it should be reported to the Independent Board of Director.
     2. The special unit of the company and the supervisors or officers reported in the preceding paragraph shall immediately ascertain the relevant facts and, if necessary, be assisted by regulations or other relevant departments.
     3. If it is proven that the person being reported has violated the relevant laws and regulations or the company’s policies and regulations on integrity management, the person being reported shall be immediately requested to stop the relevant behavior and dispose of it appropriately, and if necessary, seek damages through legal proceedings to protect the company’s reputation and rights.
     4. The receipt of reports, investigation process, and investigation results shall be kept in written documents and preserved for five years, and the preservation shall be done in electronic form. Before the expiration of the retention period, if a lawsuit related to the content of the report occurs, the relevant information shall be retained until the end of the lawsuit.
     5. If the reported cases are found to be true, the relevant units of the company shall be instructed to review the relevant internal control systems and operating procedures and propose improvement measures to prevent the recurrence of the same acts.
     6. The company’s dedicated unit shall report to the Board of Director with their subsequent review and improvement measures.

Prohibition on Insider Trading

In order to prevent insider trading and improper information leakage, the company conducts “Internal Material Information Handling” and related legal education for all directors, In order to prevent insider trading and improper information leakage, Ennoconn conducts annual “Internal Material Information Handling” and related legal education for all directors, managers and employees.

1. Ennoconn has incorporated the “Insider Trading Precautionary Awareness” course into the new employee training program. In 2024, a total of 3 sessions were conducted in the first quarter, 4 sessions in the second quarter, 10 sessions in the third quarter, and 3 session in the fourth quarter, amounting to 35 training hours with 35 participants.
2. On June 25 and August 27, 2024, Ennoconn held the ” Anti-Corruption Series Courses” for all employees, totaling 2 training hours with 183 participants.
3. On December 11, 2024, Ennooconn held 1 hour training course on “Material Information and Insider Trading Precautionary” with 189 participants from all directors, managers and all employees.

Ennoconn shares the course materials on the intranet so that all directors and employees can understand the importance of integrity management and prevention of insider trading.