Ethical Management

Corruption Risk Management and Due Diligence

To ensure the transparency and effectiveness of its corruption risk management mechanisms, Wistron regularly has its compliance management system audited and verified by an independent third-party organization to continuously strengthen its compliance culture.

With regard to internal management, the company has identified areas such as Treasury Management & Corporate Communications, Global Supply Chain Management, and Administration Services as potentially risky areas. In addition to undergoing internal audits and regular rotations, supervisory personnel in these areas are also required to participate in training courses offered by external professional organizations to strengthen their compliance awareness.

With regard to external relationships, before establishing business relationships with agents, suppliers, customers, or other business partners, the company will first assess the legality of their business practices, their integrity policies, and any history of dishonest behavior. During business transactions, Wistron will explain its integrity policy and related regulations to its partners in accordance with internal operating procedures. Compliance with Wistron's anti-corruption policies will also be incorporated into commercial contracts. This includes clarifying reasonable payment terms, handling instances of dishonest behavior, and handling violations of contractual clauses prohibiting commissions, kickbacks, or other benefits. We explicitly refuse to directly or indirectly offer, promise, request, or accept any improper benefits in any form or name. Upon discovery of dishonest behavior, transactions will be immediately terminated and the partner will be designated as a target for non-dealing. From 2021 to 2024, no reported cases were investigated, revealing corruption or bribery, and no penalties were imposed by competent authorities for such cases.

Commitment and Support

To ensure that all employees fully understand relevant regulations, Wistron continues to implement education, training, and promotional initiatives. For board members, in addition to having completed and signed the Code of Conduct acknowledgment, Wistron has also arranged training courses on preventing insider trading to ensure corporate governance responsibilities for operating with integrity. All new employees are required to read and sign the Code of Conduct acknowledgment and complete online ethics training, with a 100% signing and completion rate by 2024. For current employees, all personnel across all sites are required to undergo annual Code of Conduct training (including anti-corruption and anti-bribery topics) to instill a culture of integrity, with a 100% completion rate for all employees by 2024.

Code of Conduct signing and training

Reporting and Disciplinary Measures

Internal and external stakeholders may raise any questions regarding the Code of Conduct with the Global Human Resources and Administration department. Subsidiaries and joint ventures over which the Company has significant influence have established consultation channels for stakeholder communication.

Wistron encourages all internal employees and external stakeholders to report any unethical conduct to the Company through its whistleblowing channels. The Company pledges to maintain confidentiality regarding the identity and content of reports and accepts anonymous reports to protect whistleblowers from receiving unfair treatment. The Company has a zero-tolerance policy for any violations of this Code of Conduct, including retaliation against whistleblowers. Any violation will be subject to disciplinary action in accordance with the relevant provisions of the Code of Conduct.

To ensure employees are familiar with reporting channels and related mechanisms, Wistron not only incorporates relevant content into new employee orientation and Code of Conduct training, but also promotes the reporting mechanism for Code of Conduct violations through public information walls and internal website announcements. This provides employees with information on reporting opportunities, reporting channels, handling procedures, and whistleblower rights. This encourages employees to proactively expose dishonest behavior and jointly implement the company's reporting system.

The company has established a dedicated email address for reporting complaints (ethic@wistron.com). Reports of Code of Conduct violations are primarily handled by Global Human Resources and Administration. Annual reports on the handling of these reports are submitted to the Board of Directors, the company's top management body. The Audit department oversees the investigation and handling of these reports.

Important Issues of Ethical Management

Anti-Competitive Behavior

Operating with integrity is a fundamental corporate social responsibility. Wistron has established a "Ethical Corporate Management Best Practice Principles", requiring all employees to conduct their operations in compliance with relevant fair competition laws. These regulations prohibit price fixing, bid manipulation, production restrictions and quotas, or market sharing or division by allocating customers, suppliers, operating territories, or business types. Wistron strictly complies with relevant laws and regulations in all aspects of its operations and management. From 2021 to 2024, the company was not penalized by any competent authority for anti-competitive practices or monopolistic practices.

Political and Charitable Contributions

The Company adheres to the principle of political neutrality and does not actively participate in political parties or political activities, nor does it engage in any lobbying activities. Any political donation plans will strictly comply with relevant laws and regulations, ensuring that they do not seek any commercial advantage or transactional advantage, and avoiding using political or charitable donations as a means of corruption or bribery. While the Company did not make any political donations between 2021 and 2024, we respect our employees' freedom to express their political opinions and encourage them to fulfill their civic responsibilities.

Regarding charitable donations, the Company implements internal regulations that explicitly prohibit disguised bribery and profiteering, ensuring compliance with anti-corruption standards and relevant legal requirements.

Supplier Ethical Management

Wistron has established a Supplier Code of Conduct that clearly outlines the behavioral norms and standards for supply chain partners. In addition to fully disseminating Wistron's anti-corruption policies to suppliers through training courses on the Wistron Global Learning Platform, Wistron also continuously promotes its integrity management policies and beliefs at annual supplier conferences, as well as providing information on a dedicated email reporting channel. Through these promotional measures and management mechanisms, Wistron's suppliers remained free of corruption or other violations of integrity in 2024.

The company also has a dedicated reporting and complaint email channel for suppliers (GSCM_Office@wistron.com). Global Supply Chain Management is the primary recipient of reports of violations of the Supplier Code of Conduct. In 2024, there were zero reported cases, and zero cases of contract termination due to dishonest behavior.

In addition to actively implementing the philosophy and core values ​​of integrity in internal management and external business relationships, Wistron has also introduced an external third-party audit mechanism since fiscal 2023 to help identify blind spots in internal controls and improve operational processes, thereby further reducing operational risks and enhancing the transparency, credibility, and reputation of its operations (Statement of Compliance).