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Ethical Corporate

Ethics and Integrity

Code of Conduct

Unimicron upholds the principle of compliance to operate the business, and has formulated the “Legal and Other Requirements Identification Procedure” and the “Guides to the US Antitrust Law.” In addition to regular inspections by the legal affairs unit, it also requires all business management units to conduct regular reviews and improvements, and cooperate with the auditing operations of the audit unit to ensure full implementation of regulatory requirements. We regularly communicate with suppliers about our anti-corruption policy through Email and other channels and disclose anti-corruption statements on our website. In 2021, we did not cause material regulatory violations (where a fine exceeds NT$1 million), nor did we cause corruption and anti-competitive behavior.

The ESG Committee is the highest-level corporate sustainability organization in Unimicorn, coordinating the direction and objectives of corporate sustainability, and reporting to the board of directors on relevant content and implementation results (such as integrity management, integrity ...). Unimicron have implemented the relevant actions of integrity operation, and the implementation in 2022 is as follows:

A.Education training course and test
Conduct e-learning training courses such as Professional code of ethics, code of integrity, propagation of the integrity management, and RBA, etc., and test after the course. For further information, please refer to the ESG Report.

B.Regular check
To audit the corruption-related matters annually, and do self-assess of the laws/ regulations to achieve effective control, and audit by the audit office unit to prevent the occurrence of integrity violations. No corruption and bribery happened in 2022.

C.Whistleblower system and whistleblower protection
In 2021, there were no violations of integrity occurred in the cases of internal and external prosecution.

Professional Ethics Guidelines

Unimicron has "Integrity Regulations" and "Personnel Code of Conduct" for all employees, clearly sets rules for the employment of relatives and associated suppliers, and upholds integrity in dealing with customers. Unimicron will also ensure the implementation of the mechanism through the following measures every year, and the relevant practices cover Taiwan facilities and Mainland China facilities.


New Recruit

• The "Company Integrity Regulations" are taught during the training of new recruits, and the relevant terms are included in the employment contract.


Employee Above the Engineer/
Administrator Level of Each Unit

• Every year, we conduct "Integrity Survey" and "Investment and Employment Status of Employees and Relatives in the Company, Associating Suppliers, or Competitors" for personnel above the engineer/administrator level of each unit.
• Respondents who accepted the survey of employment of relatives and integrity regulations in 2021 were personnel in engineering management positions in Taiwan, whereas personnel in Mainland China were different for each plant; the number of people surveyed was 4,962 from Taiwan facilities and 12,806 from the Overseas facilities, without any violations.


Supervisors Above the Manager Level

• Supervisors above the manager level sign the "Employee Integrity Code Compliance Contract" every year, and the signing rate in 2021 reached 100%.


All Employees

• If employees find any violations of ethical management, they can submit an anonymous whistleblowing report or complaint to the Unimicron Audit Team or the Human Resources Department via telephone or suggestion box in accordance with the provisions of the "Integrity Regulations". The undertaking unit will set up a special project team to investigate. If the whistleblowing report involves a director or senior executive, the undertaking unit shall report it to the independent director or supervisor of the Group.
• Complaints Line: +886-3-3500386 ext.13307
• Complaints Mailbox: whistleblower@unimicron.com
• There were no integrity-related reporting cases received and no related corruption and bribery cases occurred in 2021.



Public Disclosure

In compliance with the regulations of the competent authorities, investors can access Company-related information through the Market Observation Post System . In addition to disclosing our general information, technology R&D, and corporate social responsibility, the Unimicron website also has an investor relations section, providing relevant documents and regulations on our financial information and corporate governance.

We hold Institutional Investor Seminars semiannual to explain the consolidated financial results, operational status, and prospects of every quarter. We also provide relevant information and video recordings on the Unimicron website and the Market Observation Post System for investors. The Company also communicates with investors through various investor meetings, overseas visits, and investor relations points of contact. In 2021, Unimicron participated in 9 external and self-organized Institutional Investor Seminars and more than 200 institutional investor interviews and meetings.

There were no material violations caused by competent authorities for environmental protection, occupational health and safety, and Labor/management relations/human rights in 2021, and after examination and confirmation, all deficiencies have been improved and there is no risk of further violations.



Market Observation Post System

Provide access to Unimicron-related information

Corporate Governance Zone

Provide written documents and regulations related to the corporate governance

Institutional Investor Conference

Financial Information  Quarterly or full-year financial information

Financial Information

Quarterly or full-year  financial information

Stakeholders Zone

Communication channels such as shareholders/investors, employees, authorities and communities, suppliers, whistleblower area, ESG Committee contact box, etc.



Training of Laws and Regulations

There are many integrity management regulations in Unimicron, and we hold relevant training courses every year. The Company also provides reminders of relevant regulations from time to time, and has a consultation channel so that the regulated objects can understand the laws and regulations and comply with them accordingly.

Course

Content

Participants

Plants

Staffs Should Be Trained

Staffs Trained

Total Staffs Should Be Trained

Total Staffs Trained

Completion Ratio (%)

Personnel Code of Conduct

• Purpose
• Applicable objects
• Environmental, safety and health policies
• For the society
• For investors
• For customers

• For suppliers
• Commitment to employees
• Expectations for practitioners
• Whistleblower system and complaint system
• Discipline

• All of the Company’s employees must be trained (Including Taiwanese employees stationed in Mainland China who have been employed for 3 months)

Taiwan

13,454

13,392

13,643

13,581

99.55%

Mainland China

189

189

The Responsible Business Alliance (RBA) Code of Conduct

• The Responsible Business Alliance (RBA) Code of Conduct
• ESG Executive Summary

Taiwan

13,454

13,392

13,643

13,581

99.55%

Mainland China

189

189

Integrity Best Practice Principles

• Code of Integrity

Taiwan

13,454

13,392

13,643

13,581

99.55%

Mainland China

189

189

Antitrust Law

• Case study
• Unimicron standard operating procedure
• Fair Trade Act

• Job level 5 (inclusive) and higher in Taiwan (Including Taiwanese employees stationed in Mainland China who have been employed for 3 months)

• (1) Employees with job level 11 and higher in QunHong Technology Inc.

(2) PCB and Carrier's business/strategic market: Employees with job level 7 and higher in plants in Taiwan and Mainland China

Taiwan

4,034

4,006

4,211

4,183

99.34%

Mainland China

177

177

Analysis of the Law and Ethics of Business Secrets

• Example of leakage of trade secrets
• Trade Secrets Act
• The introduction of tortious act
• Other civil and criminal liabilities

• Confidentiality obligations of employees
• The concept of Non-competition
• Summary

• Job level 5 (inclusive) and higher in Taiwan (including DL and Taiwanese employees stationed in Mainland China).

• Employees with job level 5 and higher (Not included DL) in QunHong Technology Inc.

Taiwan

4,288

4,260

4,465

4,437

99.37%

Mainland China

177

177

Advocacy of the Ethical Corporate Management Best Practice Principles

• Code of Conduct on Integrity

Taiwan

4,046

4,018

4,223

4,195

99.34%

Mainland China

177

177

Prevention of Insider Trading

• Equity trading regulations for senior management
• The elements of Insider Trading

• Legal liability of Insider Trading
• Case study

Taiwan

4,288

4,260

4,465

4,437

99.37%

Mainland China

177

177

Note 1: RBA, Personnel Code of Conduct, Code of Integrity and Prevention of Insider Trading have all been planned to be included in new employees’ training courses to implement the training mechanism and increase the training rate. Those who have not completed the training in 2021 will be included in the training list for the following year.
Note 2: The scope of the above table includes QunHong Technology Inc.
Note 3: The training starts from Aug 31 to Nov 30 in 2021.

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