Ethical Management

Corruption Risk Management and Due Diligence

To ensure the transparency and effectiveness of its anti-corruption risk management mechanisms, Wistron has established a Board-approved Anti-Corruption and Anti-Bribery Policy, which expressly prohibits all forms of bribery and improper benefits. The Company has also established reporting, investigation, and internal control mechanisms to prevent corruption risks and uphold business integrity. In addition, Wistron launched a project in 2025 to implement the ISO 37001 Anti-Bribery Management System. The initial certification scope covers supply chain management-related processes at the corporate headquarters. The Company has passed external verification in June 2026 and planned to strengthen its culture of compliance through annual external surveillance audits.

In 2025, Wistron conducted anti-corruption and anti-bribery risk assessments across all global operating sites (100% coverage). Among 28 identified risk categories, two medium- to high-risk categories were identified: Supplier Management and Designated Supplier Procurement Management. To mitigate and effectively control potential corruption and bribery risks, the Company developed and implemented three action plans.

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. Between 2022 and 2025, after investigation, a total of 1 case involving corruption was found, and no cases resulted in penalties from the competent authorities.

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 2025. 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 2025.

Code of Conduct Signing and Training

Reporting and Disciplinary Measures

Internal and external stakeholders are welcomed to contact the Global Human Resources and Administration Division for any questions regarding the Code of Conduct. For different categories of issues, Wistron has also established reporting and inquiry channels (as shown in table below) to communicate with internal and external stakeholders.
 

Institutionalizing a Culture of Integrity through the Grievance and Reporting System

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 maintains dedicated email and reporting platform channels for whistleblowing and grievance reporting. Reports of Code of Conduct violations are primarily handled by Global Human Resources and Administration. Each quarterly report summarizing the progress of handling appeals is submitted to the independent directors. 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 adheres to all applicable laws in business operations and incorporates topics related to fair trade into Code of Conduct training to ensure that all employees understand relevant regulations. From 2022 to 2025, the Company has not been penalized by authorities for anti-competitive conduct or monopolistic practices, and monetary losses due to lawsuits related to anti-competition laws were zero.
        

Political and Charitable Contributions

Under the Company’s Code of Conduct, all political contributions—direct or indirect—by employees to political parties or politically active organizations or individuals must comply with the following principles:
1. Comply with applicable laws and regulations; contributions may not be used to seek business or transactional advantages. Any legitimate political donations made in Wistron’s name, regardless of amount, must be approved by the Chairman. 
2. Employees may not, without authorization, make political contributions on behalf of the Company. 
3. Company property, facilities, or work hours may not be used for any political activities.

From 2022 to 2025, the Company did not make any political contributions. However, Wistron respects employees’ freedom of political expression and encourages them to fulfill their civic responsibilities. In terms of public welfare and charitable giving, all donations and sponsorships are governed by internal management regulations, which strictly prohibit disguised bribery or personal gain. These rules ensure compliance with anti-corruption standards and 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 2025.

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 2025, 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).