Business Integrity

The Human Resources Division is the dedicated unit responsible for promoting ethical corporate management. It is charged with the amendment, implementation, interpretation, and advisory services regarding the “Procedures for Ethical Management and Guidelines for Conduct,” as well as the recording and filing of reported cases and the supervision of implementation. For details on key responsibilities, please refer to Article 5 of the “Procedures for Ethical Management and Guidelines for Conduct.” The unit shall report to the Board of Directors periodically (at least once a year); the report for the current year was presented on March 13, 2025.

Performance of Business Integrity in 2025

Completed

Propaganda for Anti-corruption and Business Integrity

No fraud

were found

Internal Control Audits

No fraud

were found

No whistleblower reports have been received

Prevention Measures for Insider Trading and Conflict of Interest

0
Total Hours
0%
Course completion rate
0
Attendees
  • In 2025, the Company conducted a 5-minute briefing on insider trading prevention and conflict of interest measures for incumbent Directors on August 14, and for managers and employees during the August monthly meeting.
  • To strictly prevent insider trading, the Company notifies Directors via SMS regarding the prohibition of stock trading during the closed periods, defined as 30 days prior to the announcement of the annual financial report and 15 days prior to the announcement of quarterly financial reports.
  • In 2025, notifications were sent to all Directors via SMS on February 10 (for the 2024 Annual Report), April 29 (for the Q1 2025 Report), July 29 (for the Q2 2025 Report), and October 28 (for the Q3 2025 Report). These messages clearly specified the closed periods and reminded Directors to refrain from trading to ensure full compliance with relevant regulations.

Anti-corruption and Business Integrity

0
Total Hours
0%
Course completion rate
0
Attendees

Training for all directors was completed on August 13, 2025.  An educational video was shown to employees of the whole group (at 23 monthly meetings in August 2025), reaching 1,759 attendees for a total of 146.6 hours with a 97.8% completion rate.

2024 Execution Results of Integrity and Anti-Bribery Policy Communication to External Parties (Suppliers/Contractors)

Communication completed 97%

We have communicated our integrity clauses with 522 contractors/suppliers and will continue striving toward the goal of 100%.

Everlight has formulated a white paper on business philosophy and operating principles. It reveals our business philosophy of integrity and law-abiding, establishes a corporate image of upright management, and complies with domestic and foreign regulatory requirements and international corporate ethics standards.

Category Ethical Corporate Management Principles Corporate Governance Best-Practice Principles Sustainability Development (ESG) Best-Practice Principles
Highest Level of Approval Board of Directors Board of Directors Board of Directors
Applicable Activities and Scope Directors and All Employees Directors and All Employees Directors and All Employees
Communication Method (Publication Location/URL) Company Website,
Monthly Meetings,
Email Notification		 Company Website,
 Email Notification		 Company Website

Everlight has implemented an “Ethical Corporate Management Principles” and “Procedures for Ethical Management and Guidelines for Conduct.” With the business philosophy of integrity, transparency and responsibility, the Company developed a policy based on honesty and establish a good corporate governance and risk control mechanism to create an operating environment of sustainable development; the board of directors and the management level actively implement the commitment of ethical corporate management policies, and require all employees of the whole group to adhere to the prohibition against accepting or offering any improper benefits. This ensures that the actions of all employees are guided by clear rules.

Everlight has established regulations to ensure that the behavior of its directors and managers (including the CEO, equivalent senior executives, vice-presidents, assistant vice-presidents, heads of finance, heads of accounting, and others who manage corporate affairs and have signing authority) meets ethical standards. These standards are set to help stakeholders understand the Company’s ethical commitments better. The Company has codified these guidelines to be adhered to and discloses its ethical conduct guidelines on the corporate website, annual reports, prospectuses, and through the Market Observation Post System (MOPS). Any amendments to these guidelines are also disclosed in the same manner.

Everlight has legally established procedures that cover how its highest governance body avoids and manages conflicts of interest, ensuring transparent and ethical management across all levels of the organization.

Everlight has implemented the “Operating Procedures for Preventing Insider Trading” to protect the rights and interests of both investors and the Company. The Company carry out educational propaganda on related laws for current directors, managers and employees once a year. Newly appointed directors and managers are scheduled to receive the same training within three months of taking office, and new hires receive the training during orientation training.

The Company enforces anti-corruption and anti-bribery policies through its Code of Ethical Conduct and regular training. In 2024, training on anti-corruption, bribery, and anti-competitive conduct was provided to all employees and Board members. Reported misconduct related to operations or business relationships – including corruption, bribery, insider trading, and conflicts of interest – is addressed in accordance with the whistleblower procedures.

To support the Board of Directors and management in corporate governance and enhancing internal controls, the Company’s Audit Office reports directly to the Board. Led by the Chief Auditor and staffed with two full-time internal auditors, the office audits the design and implementation of internal control systems and reviews the results of internal control self-assessments.

  1. At the end of each year, potential risk factors are identified using the “Internal Audit Risk Assessment Table,” with impact levels assessed and final risk levels determined after evaluating control measures. Based on this evaluation, the annual audit plan is created and submitted to the “Audit Committee” and the Board of Directors for approval. The audit covers major cycles such as sales, legal compliance, sustainability information management, and key internal controls. The goal is to ensure operational effectiveness, reliability, transparency, and compliance with applicable laws and regulations.
  2. The execution of both planned and special project audits involves convening pre-audit meetings, performing audit tasks, drafting internal audit recommendation reports, holding closing meetings, and submitting final audit reports.
  3. Monthly audit reports and quarterly follow-up reports are submitted to Independent Directors for review. The Chief Auditor attends “Audit Committee” and Board meetings to report on audit performance and findings.
  4. In 2024, 63 audit items from the annual plan and 3 special project audits were completed as scheduled. No significant deficiencies were found, but 21 minor deficiencies were identified. By the end of 2024, 18 had been rectified, and the remaining 3 are being addressed through corrective actions and will be tracked until completion.
  5. In 2024, internal control self-assessments were conducted by group unit heads using a digital platform to evaluate internal control design and effectiveness. After review by senior management, audit diagnostic recommendations were issued. The Audit Office consolidated these into the “Internal Control Self-Assessment and Audit Diagnostic Report,” which serves as the primary basis for the Board of Directors and President to assess the internal control system’s effectiveness and issue the “Internal Control System Statement.“
  6. Management systems such as ISO 9001, ISO/IATF 16949, ISO 14001, ISO 45001, ISO 50001, ISO 22301 (BCMS), ISO 27001, and TIPS undergo regular internal audits conducted by qualified auditors, as well as external audits performed by certification bodies.

  • Whistleblower System/Complaint Mechanism

We have issued a “Reporting System for Violation of Ethical Corporate Management Regulations” and the accepting unit is the Audit Office. It specifies the details of the reporting hotline and mailbox. The Audit Committee mailbox is also set up. Upon receiving a report, the accepting unit should register the case, check whether it is a reported incident, and within three working days from the date of acceptance, request instructions whether to file the case and initiate an investigation. The system strictly adheres to confidentiality principles of the identity of the whistleblower and the content of the report, allows anonymous reporting, and protects whistleblowers from retaliation.  A “Violations and Appeal System” is also in place to ensure that If there are any violations, once verified, penalties will be imposed in accordance with company regulations.

In 2024, electronic files of the “Whistleblowing System” in Traditional Chinese, Simplified Chinese, and English were provided and promoted to employees in all regions.

Whistleblowing Channels
Hotline: +886-2-2326-3502
Audit Office Email: [email protected]
Audit Committee Email: [email protected]