SCI Pharmtech Inc., - Implementation of Ethical Corporate Management

Implementation of Ethical Corporate Management

Evaluation Item	State of Operations			Gaps with the Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies and Reasons
Evaluation Item	Yes	No	Summary
1. Stipulating policies and plans for ethical corporate management
(1) Has the company established the ethical corporate management policies approved by the Board of Directors and specified in its rules and external documents the ethical corporate management policies, practices, as well as the commitment of the board of directors and the senior management to rigorous and thorough implementation of such policies?	V		The company’s Board of Directors approved the latest amendment of the Ethical Corporate Management Best Practice Principle on March 13, 2020, with the corporate ethical management policies specified in its contents, which shall be implemented thoroughly in the internal management and external business operations in a fair, just, and open manner. The company’s ethical corporate management policy is “Treating all the stakeholders with honesty and integrity, promoting the transparency of the company management; Internalize honesty and integrity as the core value of the company and have zero-tolerance for any unethical behaviors.” The company’s Directors and the senior executives above the Manager level have signed the Declaration of Ethical Management.	None
(2) Has the company established a risk assessment mechanism against unethical conduct, analyzed and assessed on a regular basis business activities within its business scope which are at a higher risk of unethical conduct, and established prevention programs accordingly, which shall at least include the preventive measures specified in Paragraph 2, Article 7 of the "EthicalCorporate Management Best Practice Principles for TWSE/GTSM Listed Companies"?	V		The company’s senior executive level discussed the progress of reconstruction, operational condition, and future operational risk in the annually convened operational management meeting. The company’s Audit Office conducts audit operations following the annual audit plan enacted after the evaluation of risks every year, and no unethical behaviors were discovered through the audit for 2022. The contents of the company’s Ethical Corporate Management Best Practice Principle include the prevention measures for every item stated under the subparagraphs of paragraph 2, Article 7 of the Ethical Corporate Management Best Practice Principle for TWSE/GTSM Listed Companies. The Audit Office audited the implementation of ethical corporate management in 2022, and no unethical behaviors were discovered. The company actively observes the development of the domestic and international ethical corporate management and encourages the Directors, Managers, and personnel to offer suggestions for the improvement of the ethical corporate management policy and implementation measures, enhancing the efficiency of the company’s ethical corporate management.	None
(3) Has the company specified in its prevention programs the operating procedures, guidelines, disciplinary measures for violations, and a grievance system, and implemented them and reviewed the prevention programs on a regular basis?	V		The contents of the company’s Ethical Corporate Management Best Practice Principle include the operational procedures, guidelines of behaviors, disciplinary actions when violating the rules, and the complaint systems (please refer to Attachment 1), which are implemented accordingly. To prevent any unethical behavior, the company requires the employees to actively propose explanations when they meet any ethical concerns and conflicts of interest and follow the regulation of the Ethical Corporate Management Best Practice Principle. The company has established a complaint channel for employees or related personnel to blow the whistle on any inappropriate business behaviors, which shall be handled by the managerial executives appointed by the company. There were no unethical behaviors discovered or any whistle-blowing incidents in 2022. The company’s Board of Directors enacted the latest amended Ethical Corporate Management Best Practice Principle at the meeting on March 13, 2020, which was proposed to the shareholders’meeting on June 19, 2020.	None
2. Implementing ethical corporate management
(1) Has the Company evaluated ethical records of its counterpart? Does the contract signed by the Company and its trading counterpart clearly provide terms on ethical conduct?	V		Currently, before the company trade with a supplier, the personnel in charge of the case will review the supplier’s past transaction record or conduct Internet searches on the supplier to ensure there is no record of unethical behaviors, and it shall be clearly stated in the agreement that the company may terminate or cancel the agreement at any time if any unethical behaviors are involved.	None
(2) Has the company set up a dedicated unit under the Board of Directors to promote ethical corporate management and regularly (at least once a year) report to the Board of Directors the implementation of the ethical corporate management policies and prevention programs against unethical conduct?	V		The company’s dedicated unit in charge of promoting ethical corporate management is the President Office, which is supervised by the President, while the assigned Head of Corporate Governance is required to report to the Board of Directors annually concerning the implementation progress of the previous year, and the Audit Office shall audit the compliance of above-mentioned systems. The most recent report to the Board of Directors occurred at the Board meeting on March 14, 2023, where the report on the 2022 ethical corporate implementation was conducted by the Head of Corporate Governance, and no fraud or unethical behaviors have occurred in 2022.	None
(3) Has the Company established policies preventing conflicts of interests, provided proper channels of appeal, and enforced these policies and channels accordingly?	V		To prevent any unethical behavior, the company requires the employees to actively propose explanations when they meet any ethical concerns and conflicts of interest and follow the regulation of the Ethical Corporate Management Best Practice Principle.	None
(4) Has the company established effective accounting systems and internal control systems to implement ethical corporate management and had its internal audit unit, based on the results of assessment of the risk of involvement in unethical conduct, devise relevant audit plans and audit the compliance with the prevention programs accordingly or entrusted CPAs to conduct the audit?	V		The company has established effective accounting and internal control systems to ensure the implementation of ethical corporate management, and the Audit Office will audit the compliance of the aforementioned systems following the annual audit plan.	None
(5) Does the Company regularly organize internal and external training courses on ethical corporate management?	V		The company has enacted the Procedures for Handling Material Inside Information and Ethical Corporate Management Best Practice Principle, which strictly prohibits insiders such as Directors or employees to gain profit from trading the company’s shares with information not available to the public. The company has amended the Corporate Governance Principle in the Board of Directors’ meeting on March 18, 2022, with the introduction of new control measures on the share trading by the company insider when acknowledging the financial report or relevant business contents of the company, which includes (but not limited to) that the Directors may not trade their shares within 30 days before the publishment of annual financial report and 15 days before the publishment of quarterly financial report. The company also notifies the directors and all employees of the above-mentioned stock trading control measures by email on a quarterly basis. In order to promote and publicize honest behavior and prevent insider trading, the company regularly conducts physical education and training every year. The 2023 annual educational training was conducted in form of a webinar to 198 of our employees on January 19, 2023, with 30 minutes of Ethical Corporate Management, Procedures for Processing Material Inside Information, Self-Regulatory Rules on Disclosure of Merger and Acquisition Information, Corporate Governance Principles, Sustainable Development Principles, and sample cases of the latest insider trading incident. The related regulations are uploaded to the company’s internal network and websites for employees to reference at any time. Training courses from external institutes for corporate ethical management, corporate governance, and other related topics are provided in 2022, with 10 participants from the company reaching a total duration of 90 training hours.	無
3.Status for enforcing whistle-blowing systems in the Company
(1) Has the Company established concrete whistle-blowing and reward systems and accessible whistle-blowing channels? Does the Company assign a suitable and dedicated individual for the case reported by the whistle- blower?	V		The company has established a channel for complaints with a dedicated unit to handle the related matters, following the process specified by terms enacted in the Best Practice Principle.(Please refer to Attachment 1)	None
(2) Has the company established the standard operating procedures for investigating reported misconduct, follow-up measures to be adopted after the investigation, and relevant confidentiality mechanisms?	V		The company’s Ethical Corporate Management Best Practice Principle has specified the investigation procedures and confidentiality mechanism. (Please refer to Attachment 1)	None
(3) Has the Company adopted protection against inappropriate disciplinary actions against the whistle-blower?	V		The company’s Ethical Corporate Management Best Practice Principle has specified the investigation procedures and confidentiality mechanism. (Please refer to Attachment 1)	None
4. Improvement of information disclosure Has the Company disclosed the contents of its best practices for ethical corporate management and the effectiveness of relevant activities on its official website or the Market Observation Post System (MOPS)?			The company has disclosed its Ethical Corporate Management Best Practice Principle on the company’s official site and the MOPS (Market Observation Post System). The company has uploaded the annual report to the company’s website and has set up a Sustainable Development page to disclose information related to ethical corporate management for investors to reference.	None
5. Where the Company has stipulated its own best practices on ethical corporate management according to the Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies, please describe any gaps between the prescribed best practices and actual activities taken by the Company : None.
6. Any important information to better understand the Company’s implementation of ethical corporate management (for example, any review or amendment to best practices for ethical corporate management of the Company): The company’s Board of Directors approved the latest amendment of the Ethical Corporate Management Best Practice Principle on March 13, 2020.