Ethics and Integrity

Code of Conduct

Unimicron upholds rigorous compliance principles, guided by the “Legal and Other Requirements Identification Procedure” and the “Guides to the US Antitrust Law.” Divisions must regularly review and improve their processes while cooperating with audits to ensure adherence. Suppliers are updated on Unimicron’s Anti-corruption Policy through email and other channels. We also disclose anti-corruption related statements on Unimicron website.

Given the increasing importance of trade secret protection, Unimicron introduced the “Trade Secrets Registration Bonus Measures” and the “Trade Secrets Protection Audit Regulations” from 2021 to 2023. The former incentivizes innovation and strengthens intellectual property management, while the latter focuses on preventive measures to protect core competitive advantages. These initiatives collectively drive sustainable development.

The ESG Committee, Unimicron’s top corporate sustainability body, directs sustainability efforts and reports annually to the Board of Directors on ethical management and integrity. The 2023 report was delivered on December 19, 2023, as follows:

Legal Compliance Status

We adhere strictly to laws and regulations, and under stringent management, did not incur any material regulatory fines exceeding NT$1 million in 2023. Additionally, no major incidents of corruption or anti-competitive practices occurred.

In 2023, there were 19 violation cases related to environmental protection, labor health/safety, and labor, and these were not major cases. All deficiencies were promptly addressed. Most labor violations, including those of Articles 22(2), 24(1), 32(2), and 38(2) of the Labor Standards Act, stemmed from issues with scheduled leave or overtime. The Company revised its internal regulations to improve management and communication regarding hourly wages. Violations of the Occupational Safety and Health Act, particularly Articles 6(1), 26, and 27, improved procedures at each plant to better manage safety and reduce accidents. Environmental issues included two breaches of the Air Pollution Control Act, which were swiftly remedied following an audit by the Environmental Protection Bureau to prevent future occurrences.

Penalties for Violation of the Laws in 2021-2023

Responding to Media Inquiries - Fulfillment of Dreams Leave

Description

Describe the measures taken against the Fulfillment of Dreams leave and follow-up policies.

Measures

The Fulfillment of Dreams leave is an additional benefit beyond the Labor Standards Act, designed to let employees plan and take time off for rest and personal development. This benefit supports colleagues in managing their schedules and growing with the Company. To safeguard employees' rights during voluntary leave, "temporary unpaid leave for business" may be implemented with project approval.

• However, after reviewing employee applications, it was found that some colleagues applied for "Fulfillment of Dreams leave" to "conform to company policy."
• We value employees' intentions, but using "Fulfillment of Dreams leave" to "conform to company policy" was not our intention and does not bypass labor laws or infringe on rights. To address this, we are suspending "Fulfillment of Dreams leave" applications from May 3, 2023, and will revert to regular and unpaid leave options. In the future, any new policies will be communicated to labor representatives beforehand, and unit supervisors will ensure clear communication with employees to avoid misunderstandings. Employees with questions should reach out to their supervisor, plant manager, or HR Department for clarification.

Management of Business Ethics

Unimicron has established the "Code of Integrity" and the "Personnel Code of Conduct" to guide the employment of relatives, interactions with associated suppliers, and dealings with customers. These standards are enforced annually across Taiwan and Mainland China Facilities. Stakeholders can express concerns through the grievance mechanism, accessible via the Contact Us on the Unimicron website and Chapter 6 of the ESG Report.

Supplier	Ethics training programs for board members are conducted via email.
Manager Level	Employees are required to sign the "Employee Agreement of Integrity Regulation Compliance" annually, achieving a 100% signing rate in 2023.%
Above of Engineer/Administrator	Unimicron conducts an annual "Integrity Survey" to assess the "Investment and Employment Status of Employees and Relatives in the Company, Associated Suppliers, or Competitors." In 2023, the survey included engineers and administrators in Taiwan and varied by plant in Mainland China. It involved 6,789 individuals from Taiwan and 10,813 from overseas facilities, with no violations reported.
New Recruit	The "Company Integrity Regulations" are included in new recruit training and incorporated into employment contracts.
All Employees	The completion rate for training on the Personnel Code of Conduct, RBA Code of Conduct, Code of Integrity, Antitrust Law, Ethical Corporate Management, Trade Secrets Law, and Insider Trading Prevention was 99.30% in 2023..30%
Suppliers	We perform annual audits and self-assessments of legal compliance to ensure robust control and adherence to regulations. In 2023, there were no incidents of corruption or bribery. The whistleblower mechanism is communicated to suppliers via an integrity letter. In 2023, no integrity-related whistleblower cases were received or investigated.

Public Disclosure

In compliance with regulations, investors can access Company information through the “Market Observation Post System.” In addition to general details, technology R&D, and ESG disclosures, the Unimicron website offers an investor relations section with documents and regulations on financial information and corporate governance.

We hold semiannual Institutional Investor Seminars to review financial results, operational status, and quarterly prospects. Information and video recordings are available on the Unimicron website and the "Market Observation Post System." The Company also connects with investors via meetings, overseas visits, and dedicated investor relations channels. In 2023, we attended 22 investor conferences and held over 200 meetings, including interviews.

Market Observation Post System

Provide access to Unimicron-related information

Corporate Governance Zone

Provide documents and regulations related to corporate governance

Institutional Investor Conference

We hold semiannual institutional investor conferences to present quarterly financial results, operational status, and prospects.

Financial Information

Quarterly or full-year financial information

Stakeholders

Communication channels include shareholders and investors, employees, authorities, communities, suppliers,whistleblower system, and the ESG Committee.

Training of Integrity Management

We enforce numerous integrity management regulations and conduct annual training courses. The Company also provides periodic reminders and maintains a consultation channel to ensure employee compliance and understanding.