投資人&利害關係人

The Code of Conduct of HIWIN Group (including subsidiaries) outlines the ethical standards and behavioral expectations that guide all employees and business partners. In alignment with our corporate values and global best practices, the management team of HIWIN and its subsidiaries are expected to lead by example. All employees are required to understand and adhere to these standards in their daily work.

Corruption and Bribery

HIWIN upholds a zero-tolerance policy against all forms of corruption and bribery. We are committed to conducting business with integrity, transparency, and the highest ethical standards.

Prohibited corrupt practices include, but are not limited to:

• • Bribery
• • Facilitation payments
• • Kickbacks
• • Collusion
• • Embezzlement
• • Fraud
• • Theft
• • Any actions intended to unduly influence third parties or secure improper personal gain at the expense of the Company.

This policy serves as a guideline for employees and representatives to avoid unethical behavior during business activities and to support international anti-corruption efforts.

Employees and all individuals acting on behalf of the Company are strictly prohibited from offering, promising, soliciting, or accepting any form of improper benefit(includes all tangible and intangible benefits and gifts, including but not limited to products, services, cash and cash equivalents, checks, traveler's checks, gift cards, gift certificates, vouchers, stocks, and all business courtesies, tips, discounts, entertainment, travel, meals and accommodations, hospitality, loans or favors and other things of value for which the recipient does not pay the fair market value.) regardless of whether the counterpart is a government official, corporate entity, business partner, individual or within the Company. Any such behavior will be subject to disciplinary actions in accordance with Company regulations and applicable laws.

Discrimination

The Company is committed to respecting and promoting fundamental human rights in line with internationally recognized standards and is committed to creating a friendly, harmonious, and respectful workplace that upholds equality. We have implemented a "zero tolerance" policy towards any form of discrimination and harassment in the workplace. As such, the Company has developed an "Anti-Discrimination and Anti-Harassment Policy" to ensure that all employees are treated with the dignity and fairness they deserve in the workplace.

The Company strives to foster an inclusive and respectful workplace culture that values openness, fairness, and equal opportunity. We adopt a zero-tolerance stance toward any form of discrimination. To ensure equal employment opportunity, no employee shall discriminate in hiring or the performance of work based on race, class, language, ideology, religion, political affiliation, place of origin, birthplace, sex, sexual orientation, age, marital status, physical appearance, facial features, physical or mental disability, ancestry, blood type, or any other identity protected by applicable law.

Confidentiality of Information

To safeguard the information security of our customers, suppliers, and employees—and to ensure the continuity of business operations—the Company has established and implemented an “Information Security Policy and Objectives” as the foundation for our information security governance framework.

From the perspective of corporate governance, we actively promote the protection and management of information security to ensure the confidentiality, integrity, and availability of the Company’s information assets. We are committed to complying with relevant laws and regulations and responding appropriately to external information security incidents.

Over the years, the Company has developed a comprehensive information security management system and adopted various system management tools. To assess the effectiveness of our security measures and to ensure alignment with international standards, we have passed the ISO/IEC 27001 certification audit and obtained the corresponding certification. This certification covers key personnel, systems, production sites, and data centers.

Conflicts of Interest

Conflicts of interest may arise when individuals are required to make decisions or perform duties that are influenced by personal interests, relationships, or external pressures. Such conflicts can compromise objectivity, impartiality, and integrity, potentially leading to decisions that favor the individual or related parties rather than the Company’s best interests.

Situations that may constitute a conflict of interest include, but are not limited to:

A. Employees or their immediate family members holding positions at the Company’s clients, suppliers, or competitors.

B. Employees or their related parties having a direct or indirect financial interest in the Company’s customers, suppliers, or competitors.

C. Employees utilizing Company resources for personal matters or gaining personal benefits without prior authorization.

In cases where a conflict of interest is unavoidable, the Company will take appropriate measures—such as reassignment of duties or adjustment of business relationships—to mitigate the conflict and maintain ethical standards.

Antitrust/Anti-competitive Practices

The Company strictly prohibits any form of collusion, price-fixing, market allocation, bid-rigging, or manipulation of production or sales volumes with competitors, industry peers, or trade associations. We fully comply with all applicable domestic and international antitrust, competition, and fair-trade laws and regulations.

In all commercial dealings, the Company maintains a clear separation from any anti-competitive behavior. Distributor agreements explicitly require partners to preserve the confidentiality of pricing and other sensitive commercial information, prohibit disclosure to unauthorized third parties, and restrict sales within designated geographic territories to prevent market distortion.

To ensure compliance, the Company has implemented a comprehensive internal control framework, including clearly defined governance policies, authorization procedures, and assigned functional responsibilities. These are reinforced through regular internal audits and training programs designed to detect, prevent, and address any conduct that violates competition laws or ethical business standards.

Through these measures, the Company fosters a transparent, competitive, and lawful business environment that supports fair market practices and protects the interests of all stakeholders.

Money-laundering and/or Insider Trading/Dealing

The Company is fully committed to complying with all applicable anti-money laundering (AML) laws and regulations. We only engage in legitimate business activities and accept funds exclusively from lawful sources. The Company strictly prohibits any involvement in money laundering activities, including the concealment, conversion, transfer, or handling of illicit assets. We are determined to prevent any circumstance that may contribute to the money laundering cycle and do not tolerate or support such actions in any form.

To prevent insider trading, the Company has established the “Procedures for Preventing Insider Trading and Handling of Material Internal Information.” Directors, managers, and employees who possess material internal information are strictly prohibited from disclosing such information to others. Additionally, Company personnel must not attempt to inquire about or collect undisclosed internal information unrelated to their job duties. Likewise, individuals who become aware of such information during the course of their duties must not disclose it to unauthorized parties.

Offering any item of value improperly influence decisions or behavior in order to obtain or retain business, regulatory, or personal advantage constitutes bribery. This includes kickbacks and facilitation payments. A facilitation payment refers to a bribe intended to expedite routine administrative actions by government officials.

Environment, Health and Safety

The Company systematically integrates environmental protection, occupational health, and safety management into its daily operations by deploying appropriate management tools and allocating necessary resources, with disaster prevention as a key priority. We are dedicated to minimizing risks through comprehensive mitigation measures and cultivating a proactive safety culture aimed at achieving a zero-incident workplace.

To ensure employees’ health and safety, the Company regularly conducts comprehensive training programs, rigorously evaluates and controls workplace hazards, and provides adequate personal protective equipment (PPE). Each facility has a dedicated Occupational Safety and Health (OSH) management team responsible for developing, implementing, and continuously improving OSH plans. These teams conduct thorough risk assessments, perform pre-operational inspections of machinery, monitor environmental factors, and maintain safety infrastructure to foster a safe, healthy, and supportive work environment.

In addition to occupational health and safety, the Company actively addresses environmental management by monitoring environmental conditions and implementing practices to minimize environmental impact across all operations. This holistic approach ensures the protection of both employee well-being and the surrounding environment.

Through these integrated efforts, the Company strives to maintain a workplace that is safe, healthy, environmentally responsible, and conducive to employee comfort and productivity.

Whistleblowing

Professional ethics form a fundamental pillar of our corporate culture. The Company has developed the Whistleblowing Policy to operate with integrity and honesty in all business dealings and maintains a zero-tolerance toward corruption and fraud. We expect the same from our affiliates and partners.

The Company has established a formal whistleblowing system under its “Employee Code of Ethics” and outlines relevant reporting and reward/disciplinary mechanisms. Independent email addresses are available on the Company website for internal and external stakeholders to report concerns directly to the Chairman, General Manager, Human Resources Department or Audit Office.

If you suspect that any Company employee or representative is engaging in unethical conduct or violating the Code of Conduct, you can report it can report in a named or anonymous manner through the whistleblowing channels provided below.

When a report is received by the Chairman or General Manager, they will assign the audit office or human resources department to establish an internal independent third-party investigation team to conduct the investigation and handling discreetly.

The reporter or complainant may provide specific details of the incident or relevant documents, either by providing their name or remaining anonymous. The Company is committed to maintaining the confidentiality of personal information and the content of the report or complaint. The Company will not take any action to discharge, transfer or otherwise discriminate against the reporter or complainant because of the report or complaint. If there is any retaliation against the whistleblower, disciplinary action will be taken. The Company will provide legal support and necessary protective measures to ensure that the whistleblower can report without fear of retaliation.

Breaches of the Code of Conduct

In 2024, there are four harassment cases occurred under the table titled "Procedures for Handling Unlawful Infringement Cases – Number of Substantiated Cases" which breach the Code of Conduct as follows:

Note: The four substantiated harassment cases involved the following forms of misconduct:

• (1) Physical and verbal unlawful infringement and stalking harassment
• (2) Verbal unlawful infringement and sexual harassment
• (3) Verbal unlawful infringement
• (4) Psychological and verbal unlawful infringement