Human Rights Risks and Material Issues

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Human Rights Risks and Material Issues

Human Rights Risks and Material Issues

Human Rights Risks and Material Issues

Human Rights Risk Assessment

To address major human rights issues of stakeholder concern, Wistron initiates a thorough review of policies and internal regulations to ensure the comprehensiveness of management measures. Additionally, we set annual performance goals and regularly track progress of relevant work plans. Continuous adherence to the RBA framework guides daily operational audits, with responsible departments tasked to launch improvement plans for identified deficiencies to ensure that relevant human rights risks are effectively controlled and mitigated.

In 2025, Wistron continued its human rights risk assessments, analyzing RBA audit reports completed between 2023 and 2025. Among all identified findings, 2.24% were classified as medium- or high-risk, with labor-related issues accounting for the majority at 71.82%. Key labor concerns, in order of importance, included “working hours,” “management systems,” and “young workers.” A summary of related risk mitigation and remedial measures is shown in the table below. For details, please refer to the Wistron Human Rights Due Diligence Management Report. The mitigation and remedial measures listed in the table were collected and communicated through the global ESG action information platform. After reaching consensus and resolution, they were shared and rolled out across all Wistron sites. Progress is regularly reported to ensure relevant management principles and standards are implemented faithfully.



Risk Mitigation

Material Issue  Working hours  Labor management systems Young Workers
Description To effectively manage employee work hours, Wistron has implemented proactive measures to ensure the physical and mental well-being of employees in daily operations. To address labor-related management system issues, Wistron has introduced several enhancements to strengthen system-level risk control related to working hours. Wistron’s human rights policy expressly prohibits the use of child labor, and Wistron has taken proactive actions to uphold human rights policies and guidelines in daily management and ensure the protection of the rights and interests of young workers.
Training Wistron’s Human Rights Policy applies to all global operating sites. All new employees are required to complete the Corporate Sustainability and Social Responsibility (CSR) training course (which includes human rights-related topics).
Relevant policies and procedures are published on the Company’s internal website and are available for employees to access at any time to ensure that all employees are aware of and understand these requirements.
Communication
  • Wistron respects the freedom and rights of all employees and has established an open platform for expressing opinions and problem reporting channels at all locations around the world to fully understand employees’ needs and expectations on issues such as working conditions and workplace environments.
  • Employees can express their suggestions or ask questions in confidence and without fear of retaliation.
Systems
  1. Developed a working hour monitoring system that regularly generates reports and automatically alerts high-risk departments. HR personnel are also required to proactively intervene and coordinate improvement measures.
  2. Implemented payroll management systems across global operations, with built-in rules to ensure wages and overtime pay are calculated and paid in accordance with local legal requirements. Headquarters also conducts regular remote payroll audits to ensure payroll processes at overseas sites are accurate and compliant.
  1. The production control department integrates production plans, legal requirements, and management standards to schedule compliant production and overtime plans.
  2. A system was developed to help department supervisors monitor employees’ overtime status. Supervisors can quickly and instantly view employees’ overtime hours, and the system regularly generates reports to support supervisors in focusing on key management areas.
  3. A comprehensive internal management mechanism and standard have been established across the plant. Mid- to senior-level managers regularly convene cross-departmental meetings to stay informed of each unit’s working hour status.
  1. Collaborate with local government authorities to verify the identity and information of new employees through official database platforms, preventing child labor and errors in age verification. Employment agencies are required to verify applicants’ identities and eligibility, while hiring managers receive regular training on minimum age requirements and legal restrictions prohibiting overtime and night work for underage employees.
  2. Implemented the ISO 45001 Occupational Health and Safety Management System to systematically identify workplace hazards and risks, specifically those that may affect young employees. These efforts help prevent work-related injuries that could impact their physical and mental development and ensure the health and safety of all workers.



Other Major Human Rights Issues


Forced Labor

Wistron’s human rights policy strictly prohibits any form of forced labor, including human trafficking, coercion, slavery and other forms of involuntary labor. Wistron has a major presence in Taiwan and other areas in Asia that are considered high-risk areas for forced labor. However, Wistron combats this by ensuring employee work contracts are formulated and signed in compliance with local laws and regulations. Employees have the right to terminate their labor contracts, and there are no restrictions beyond the terms of their contract that limit the relationship between employees and Wistron, such as withholding deposits or identity documents. Through the implementation of various human rights management measures, no instances forced labor or occurred in any of Wistron locations in 2025. There was also no medium- or high-risk forced labor issues identified during the audit process.



Human Trafficking

Wistron’s Human Rights Policy strictly prohibits any form of forced labor, including human trafficking, coercion, slavery and other forms of involuntary labor. As part of our internal control, we have established the “Anti-Slavery and Human Trafficking Management Procedures,” which provide clear guidelines for personnel recruitment, hiring, task assignment, and company management activities, ensuring no use of prisoners, debt laborers, or other workers under forced constraints. Human resources units are responsible for verifying personnel files and work records; if any anomalies or suspicious cases are detected, they are immediately reported to the responsible supervisors and appropriate protective measures are taken. Our suppliers, contractors, joint ventures, and domestic and international labor agencies are also required to strictly comply with our Human Rights Policy and related management regulations. If any illegal activities are confirmed (through interviews, whistleblowers, media reports, or regulatory sanctions), Wistron will immediately terminate business relationships and report to the authorities.

To proactively manage related human rights issues, Wistron has established the Labor Agency Management Guidelines and implements its labor supplier management framework based on four key principles: 1. Establish admission criteria: Legal compliance, regulatory compliance, and the absence of significant labor disputes are adopted as basic requirements for contracting with labor agencies. 2. Implement risk assessment and performance evaluation mechanisms: Regular evaluation procedures are conducted to monitor the service quality and management performance of labor agencies. 3. Conduct periodic audits: Labor suppliers are subject to regular on-site audits to verify compliance in daily operations. Wistron also provides guidance and support to enhance the regulatory knowledge of on-site management and service personnel. 4. Based on the three preceding evaluations and audit results, enforce exit mechanisms, rewarding high-performing suppliers while removing underperforming ones, thereby driving continuous improvement in compliance management.

Through proactive, comprehensive, and ongoing management measures, no cases of human trafficking occurred at any Wistron operating sites in 2025, nor were any medium- or high-risk human trafficking issues identified during audits.



Young Workers

Wistron’s Human Rights Policy expressly prohibits the use of child labor, and none of its major operating sites are located in regions considered high risk for child labor issues. Wistron has taken proactive actions to uphold human rights policies and guidelines in daily management and ensure the protection of the rights and interests of young workers. For example, during onboarding interviews, we work with government agencies to ensure that the age of applicants complies with legal requirements. We require labor agencies to verify the identity and qualifications of applicants, and include the quality of this verification process as a key item in service evaluations, serving as a critical factor in decisions regarding contract renewal or termination. We also regularly communicate with all hiring managers across plants to reinforce the legal minimum age for recruitment and regulations prohibiting overtime and night shifts for young workers. Through the implementation of various human rights management measures, the percentage of medium- to high-risk findings related to young workers in 2025 was 0.14% (same as 2024) indicating effective control.



Non-Discrimination

Wistron’s Human Rights Policy ensures equal employment opportunities for all individuals and prohibits all forms of discrimination. We are committed to evaluating employees based on competency and contributions to ensure equal rights and opportunities. To ensure Wistron’s supervisors and employees are conscious of corporate sustainability issues, the Company requires new employees to complete training courses such as “Corporate sustainability and social responsibility policy (including human rights policy)” and “Corporate sustainability course (basic)” that cover issues such as equitable recruitment, sexual harassment, human rights violations, discrimination, etc. The total training hours at all Wistron locations in 2025 reached 60,6260 hours, with 96.9% of total employees trained. Relevant systems and regulations are announced on the Company’s internal website for employee access. Through consistent advocacy and efforts, no discrimination in violation of company policies occurred in any of Wistron locations in 2025. There also no medium- to high-risk anti-discrimination findings identified during audits.

Wistron has formulated the "Non-Discrimination and Anti-Harassment Policy"

Anti-Harassment

Wistron respects the freedom and rights of all employees and has established an open platform for expressing opinions and problem reporting channels at all locations around the world to fully understand employees’ needs and expectations on issues such as working conditions and workplace environments. Employees can express their suggestions or ask questions in confidence and without fear of retaliation. To address sexual harassment concerns, the Company has formulated independent management measures and incident handling procedures, set up dedicated reporting hotlines, mailboxes and other reporting channels, and ensured the privacy and personal safety of reporters through clear accountability regulations.

In addition, the Company organizes lectures from time to time to invite experts to share and promote issues concerning self-protection and rights. We also set up medical centers or invite doctors to regularly offer counseling services to our employees. Through a range of proactive and responsive measures, Wistron continues to foster a harassment-free workplace.



Freedom of Association

Wistron’s Human Rights Policy respects employees’ right to freedom of association and is committed to providing a channel and environment for expression of opinions. Employees can leverage organizations such as employee relationship promotion committees. Department representatives help colleagues express their opinions in meetings to safeguard employee welfare and workplace safety. None of Wistron’s major operating locations are considered high-risk for matters concerning freedom of association. The percentage of employees joining labor unions at Wistron’s global locations is shown in the table below. In 20245 the percentage of employees covered by collective bargaining agreements was 2.49%. For employees not covered by collective bargaining agreements, we negotiate working conditions and employment terms through labor-management meetings in accordance with local regulations. Furthermore, we maintain comprehensive and diverse communication channels to ensure that all employees are heard and action is taken.

 

Union employees 2022 2023 2024 2025
Union employees% 51.35%    51.53% 51.08% 51.47% 

Living Wage

In 2023, the Company issued "Wistron’s Commitment to Living Wage," affirming that the compensation and benefits provided not only comply with local laws and regulations but also exceed the legal minimum wage. The Company conducts regular salary surveys activities. Wistron uses the Anker living wage methodology to establish Wistron’s living wage calculation formula and data, mainly referring to Cost of Living and MIT-Living Wage Calculator and other methodologies. The calculation items include expenses such as food, clothing, housing, transportation and education, and the data are regularly confirmed and calibrated. All the actions aim to actively encourage the Company, suppliers, and contractors to meet living wage standards of various regions. For more detailed information, please refer to the Wistron Living Wage Management Framework.



Human Rights Concerns of Other Stakeholders

Suppliers/Contractors

Wistron has established a comprehensive supply chain sustainability management process, which consists of five major steps: adherence to sustainability norms, sustainability risk assessment, sustainability assessment, support for improvement and capacity building, and preference and exclusion mechanism. These steps ensure that suppliers comply with our supplier code of conduct. Through sustainability risk assessments, Wistron reviews suppliers for major incidents or legal violations related to social issues, such as breaches of labor rights, occupational safety, or forced labor, and evaluates potential negative social impact factors, including wages below living wage standards or adverse effects on local communities. In the 2025 supplier sustainability audit, 7% of non-compliance cases were related to “Human Rights and Labor Protection,” primarily involving issues of “communication management/anti-discrimination.” Key improvement measures included:

  1. Adding tests and spot checks and requiring regular refresher training to ensure employees fully understand Wistron policies on anti-discrimination and communication channels.
  2. Introducing employee satisfaction surveys and feedback channels, while strengthening privacy protection for employees and contractor whistleblowers.

Customers

In the area of products and customer engagement, Wistron’s material issues primarily concern corporate governance and ethical business practices. Potential risks include violations of environmental, health, and safety-related laws and regulations, as well as failures to implement preventive and detective compliance activities within the internal control system. Customers expect Wistron to align emergency response plans with international standards and regulatory changes across jurisdictions and to establish robust occupational safety management programs to reduce workplace risks for workers. A summary of Wistron’s risk mitigation and response measures are as follows:

  1. Regular regulatory audits.
  2. Implement international standards such as ISO 45001 and ISO 14001 for occupational health and safety, environmental management systems, with ongoing efforts to ensure effective operation.
  3. Regular review of existing systems and personnel to enforce regular audits and encourage personnel to comply with regulations.
  4. Provide training on emergency response procedures.
  5. Establish emergency response management procedures.
  6. Undergo third-party external audits for validation.


Community

With regard to communities, Wistron’s material issues are mainly related to social participation. Potential risks include failure to align site-level social investment with ESG policies and the lack of proper planning for community investment and charitable giving. Communities expect Wistron to fully integrate corporate resources to generate meaningful social impact. A summary of Wistron’s risk mitigation and response measures is as follows:

  1. Implement a system for compiling information so that offices and factories worldwide may regularly upload and review community development investment plans and implementation results. Compiled information will then be reported in the annual ESG report.
  2. Develop and implement charitable donation and sponsorship guidelines, ensuring adherence and regularly reviewing execution results.



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