Ethical Management Responsibility Unit

M31 Technology’s cross-departmental Ethical Management Team is a dedicated unit for promoting ethical management. Based on the responsibilities and scope of each department, this team is responsible for assisting the Board of Directors and management in formulating and implementing the Ethical Corporate Management Practice Principles. The implementation status of the 2022 Ethical Management Plan was presented to the Board of Directors every year, along with the submission of the Ethical Management Plan.

In order to establish a corporate culture of ethical management that promotes healthy development, as well as a framework for excellent business operations, the Company has established the “Ethical Corporate Management Practice Principles”, “Code of Ethical Conduct”, and “Complaint and Whistleblowing Procedure”.

The Company conducts ethical management-related training for managerial officers and all employees at least once a year; new employees sign a declaration of integrity during the orientation training. Each department of the Company follows the “Ethical Corporate Management Practice Principles” and “Internal Controls” to ensure ethical management in accordance with areas of responsibility.

The Company has established complaint and whistleblowing channels to ensure the fulfillment of the above commitments to ethical management and to protect the legitimate rights and interests of informants or complainants.

The Company’s “Internal Material Information Handling and Insider Trading Prevention Operational Procedure” provides specific guidelines for conducting business, including points to be observed, and strictly prohibits company personnel from engaging in insider trading using undisclosed information they are aware of and must not be disclosed to others to prevent the misuse of such undisclosed information for insider trading.

Corporate Governance Performance

For three consecutive years, the Company has received the honor of being ranked among the top 5% of listed companies in the “Corporate Governance Evaluation System”, demonstrating our achievements in various aspects, including “Protecting Shareholders Rights and Interests and Treating Shareholders Equally”, “Strengthening Board Structure and Operations,” “Enhancing Information Transparency”, and “Practicing Corporate Social Responsibility”.

Annual status of complaints and whistleblowing are as follows:

Complaint and Whistleblowing Channels Significant Employee Complaints / Whistleblowing (Uncategorized) Sexual Harassment Complaints of Unlawful Incidents Confidential Information Protection Control Procedure Cases Established After Investigation
2022 0 0 0 0 0
2023 0 0 0 0 0
2024 0 0 0 0 0

On December 20, 2024, the Ethical Management Team presented the implementation status of the 2024 Ethical Management Plan to the Board of Directors, along with the submission of the 2025 Ethical Management Plan and conducted insider trading awareness promotion for the board of directors.

Regularly remind directors and managerial officers via email that they are prohibited from trading the company’s stock 30 days before the annual financial report announcement and 15 days before each quarterly financial report announcement.

In 2024, the Company organized a training program for managerial officers and all employees related to ethical management. The course includes online training on ethical management practices and the prohibition of insider trading, with a total of 241 participants and an attendance rate of 87%. Course materials have been uploaded to the internal education and training platform for employees’ reference.