Ethical Conduct and Behavioral Standards

To implement ethical conduct and ethical business practices, and to facilitate the Company's goal of sustainable development, SEEC has established and maintained a robust corporate governance system. The Company has formulated various guidelines and standards, including the "Corporate Governance Best Practice Principles," "Code of Ethical Conduct," "Ethical Corporate Management Best Practice Principles," "Sustainable Development Best Practice Principles," "Sustainability Development Committee Organization Regulations," and the "Charitable Donations and Sponsorship Management Procedures." These serve as the framework for the Company in fulfilling its corporate social responsibility, outlining the relevant standards and behavioral norms.

Whistleblowing Mechanism and Whistleblower Protection System

The Company’s "Ethical Corporate Management Best Practice Principles" explicitly outline mechanisms for promoting ethical and lawful behavior and organizational integrity. The principles state: "The Company continuously monitors the development of domestic and international regulations on ethical management and encourages Directors, Managers, and employees to make suggestions for reviewing and improving the company’s ethical management policies and implementation measures to enhance the effectiveness of ethical management".The "Sexual Harassment Prevention Measures, Employee Grievance, and Disciplinary Rules" clearly stipulate the mechanisms and procedures for general grievances or sexual harassment complaints. It promises protection for whistleblowers against any improper treatment due to their reporting.

The Company has established an Independent Internal Whistleblowing Mailbox (audit@seec.com.tw), internal hotlines, and fax lines for use by internal and external personnel. Dedicated staff members assist in handling complaints. The complainant and those handling the Complaint must maintain strict confidentiality and must not disclose any information related to the complaint.Measures are in place to protect whistleblowers from improper treatment due to their reporting.

According to the "Ethical Corporate Management Best Practice Principles," if a report involves a Director or senior executive,it should be reported to the Independent Directors. If an investigation reveals significant violations or potential major harm to the Company, a report must be made immediately, and the Independent Directors must be notified in writing. Additionally, the Company’s "Code of Ethical Conduct" stipulates: "Employees are encouraged to report to the Board of Directors, Managers,Internal Audit Supervisors, or other appropriate personnel if they suspect or discover any violations of laws, regulations, or the Code of Ethical Conduct, and to provide sufficient information for the Company to appropriately handle subsequent matters."

The Company expects to encourage employees to uphold the Company's social and corporate responsibility regulations through these systems and regulations. If there is suspicion of any violations by employees, an investigation should be conducted first to confirm the facts, preventing any harm to the company or society. In 2023, the company did not receive any complaints or whistleblower reports.

Integrity Management Communication and Training

To prevent corruption, the Company has established a corporate culture of ethical management and robust development, setting standards for Directors and Managers to adhere to ethical behavior. The "Code of Ethical Conduct" and "Ethical Corporate Management Best Practice Principles" have been established and are disclosed on the Company website. These guidelines require Directors, Managers,employees, appointees, or those with substantial control to adhere to the following behaviors:

In 2017, the company revised the "Ethical Corporate Management Best Practice Principles" to prohibit Directors, employees, appointees, or those with substantial control from engaging in unethical behavior in commercial activities. Employee work rules and ethical declarations prohibit the misuse of job-related convenience for personal gain or accepting gifts from others and leaking any company technical and business information. Related control measures include establishing internal control systems and conducting regular and irregular audits.

SEEC conducts irregular anti-corruption education and training for the headquarters, branches, subsidiaries, and new employees to strengthen their awareness of the rule of law. Through preemptive education and training, employees are informed of the potential criminal and civil liabilities of violating laws to reduce the risk of legal infractions. Anti-corruption policies are promoted through department heads and procurement and sales staff, serving as communication bridges to internal employees and external suppliers. Practical examples of corruption from other companies are used to initiate dialogue in departmental and external business meetings to emphasize the Company’s stance against corruption. In 2023, there were no significant corruption risks, such as government procurement scandals, nor any corruption incidents or judicial investigations involving SEEC.

Regarding policies against unfair competition, the company’s "Code of Ethical Conduct," disclosed on the website, prohibits unfair trading practices. All external distribution contracts explicitly state that distributors set their prices independently, and the company does not manipulate market prices. Preventive measures include legal training for new employees, annual legal education for sales and procurement personnel, and e-Learning courses to enhance regulatory awareness. In 2023, SEEC did not engage in any unfair competition practices.

Implement Internal Control Audit Management

The Board establishes an audit team to assist in identifying and assessing company risks, examining and reviewing the effectiveness of internal control system design and operations. The audit team annually develops an audit plan based on the COSO (Committee of Sponsoring Organizations of the Treadway Commission) internal control framework's five elements, considering past audit experiences,the following year's budget, and the existing organizational structure. This plan is used to assess management's understanding of overall internal and external environmental risks, operational risk control in business units, and the effectiveness of internal control system design and implementation. After completing audit reports, the team regularly tracks improvement outcomes, reporting them to the Audit Committee and Board Of Directors.

In addition to internal control systems, specific management systems such as ISO 14001, ISO 45001, and ISO 9001 are established at each factory site for compliance audits with relevant regulations.Departments and subsidiaries maintain management report platforms as required by management system regulations, periodically conducting internal audits and management reviews to ensure regulatory compliance. The corporate staff unit posts relevant regulations on the Company's internal website and promotes awareness among employees via email, providing regulatory compliance training for new hires to mitigate legal risks for both the Company and its employees.

In 2023, audit focuses included operational procedures, regulatory compliance with Financial Supervisory Commission requirements, Internal Control Systems, etc. The audit team completed annual audits,and deficiencies identified in each unit were rectified within specified deadlines. Audit frequency adjustments were made based on the varying impacts of risks across business units to minimize operational risks company-wide.

Regulatory Compliance

The Company strictly adheres to governmental laws, international conventions, and regulations.It not only complies fully with local laws at operational sites but also stays abreast of global sustainability issues. Through company regulations and compliance training programs,it ensures all business operations and activities comply with relevant laws, fulfilling its corporate social responsibilities. In 2023, the Company had no significant compliance incidents, only minor fines were promptly paid and addressed by SEEC.

NOTE: Definition of "Major Violation" A "major violation" is defined as a fine of NTD 1,000,000 or more.

Contact：Sustainable Development Division ESG@seec.com.tw