Ethical Management

UPC shall abide by the operational philosophies of honesty, transparency and responsibility, base policies on the principle of good faith, and establish good corporate governance and risk control and management mechanism so as to create a sustainable business environment.The company's human resources department is responsible for formulating the integrity management policy and prevention plan. The internal audit supervises and checks compliance from time to time to ensure the implementation of the integrity management policy.The implementation of Ethical Management in 2025 has been reported to the Board of Directors on January 15, 2026.

Integrity are the highest principle toall emploees of UPC . The Principle of Integrity shall be implemented with the approval of the board. When engaging in commercial activities, directors, supervisors, managers, employees, and mandataries of the Company or persons having substantial control over such companies shall not directly or indirectly offer, promise to offer, request or accept any improper benefits, nor commit unethical acts including breach of ethics, illegal acts, or breach of fiduciary duty for purposes of acquiring or maintaining benefits.

The Principle of Integrity include the following rules,

1. Prohibition of offering and acceptance of bribes.
2. Prohibition of illegal political donations.
3. Prohibition of improper charitable donations or sponsorship.
4. Prohibition of offering or acceptance of unreasonable presents or hospitality, or other improper benefits.
5. Prohibition of misappropriation of trade secrets and infringement of trademark rights, patent rights, copyrights, and other intellectual property rights.
6. Prohibition of engaging in unfair competitive practices.
7. Prevention of damage directly or indirectly caused to the rights or interests, health, or safety of consumers or other stakeholders in the course of research and development, procurement, manufacture, provision, or sale of products and services.

The status of UPC's implementation of training sessions on ethical management and the prevention of insider trading:

UPC has formulated a clear and detailed plan to prevent unethical behaviors. Based on this plan, it formulates procedures and behavior guidelines, and provides training on the principle of integrityof UPC for current employees and new hires who just report to their duties, so that they can fully understand the Company's determination, policies, prevention plans and the consequences of violations of unethical behaviors.

UPC Group has continued todeliver the ethics related courses. For 2025, a total of 1,810 people passed the courses and received a total of 1,810 training hours, accounting for 98% of the total employees, and 98% for signature Employees code of Ethics conduct Agreement.Directors, managers and related coworkers are provided with regulatory compliance advocacy on preventing insider trading from time to time. A total of 4 people participated in 2025, and the training hours totaled 12 hours.

For strengthen the prevention of insider trading, providing the compliance brochure and guide to regulations governing for reference, when the directors and managers taking office. In addition, when sending the meeting scheme for next year, the prohibited stock trading period before publication of the quarterly financial reports to be reminded at the same time in case of violation.

The Company strictly complies with all applicable anti-bribery and anti-corruption laws and regulations and adopts a zero-tolerance approach toward any violations of business ethics. Demonstrating its commitment to promoting ethical business practices and sustainable supply chain management, in 2025 the Company added 1,112 new suppliers, of which 94% completed the signing of ESG Commitment Letters and Integrity Pledges.

With respect to personal data protection, the Company according to thePersonal Data Protection Management Policy and established formulated the Personal Information Protection, which applies to all branches, operating sites, subsidiaries, as well as customers and suppliers. To ensure effective implementation of the personal data privacy policy, the Human Resources and Information Technology departments are responsible for overall coordination, while other departments cooperate in execution. Together, they promote and monitor compliance with personal data protection measures. The implementation status for the year is summarized as follows:

1. Regular training programs are conducted annually. In 2025, 92% of all employees completed training on the Personal Data Protection Act.
2. Data access authorization reviews are conducted semi-annually, with a 100% completion rate achieved in 2025.
3. No personal data–related complaints were received in 2025.

In order to correct behaviors that violate relevant moral regulations and endanger the Company's interests, grievance filing measures are established to respond to violation of moral regulations and the Company's interests.

All employees should be vigilant for any violation of the principle of integrity or fraud. When internal and external personnel discover violations of the Company’s regulations, they should file a report. The Company is responsible for protecting the safety of the whistleblower. The investigating members should protect the report and related materials to avoid unfair treatment or retaliation.The Company has not discovered or received any whistleblowing report related to violations of professional ethics in 2025.

The content of the report must cover the following items:

1. The name, title, department of the whistleblower and the name, title, and department of the person being reported.
2. Reported facts.
3. Evidence and relevant information.

For each reported case, NT$200,000 or 5% of the loss amount will be given to the whistleblower as a reward for resolving the case to encourage ethical conduct.

Procedure of【Rules on Reporting Corruption and Malfeasance】

confidential.tw@upc.com.tw