Ethical Management

BenQ Materials has established a comprehensive Anti-Bribery and Anti-Corruption Policy, which is incorporated into the company's Code of Integrity approved by the Board of Directors. This policy explicitly prohibits all forms of bribery and improper benefits, including directly or indirectly offering, promising, soliciting, or accepting cash, gifts, political contributions, inappropriate hospitality, or donations. The policy applies to directors, senior executives, employees, subsidiaries, suppliers, customers, agents, and contractors, and includes, but is not limited to, the following key elements (please refer to the full Code of Integrity for details):
 

• Prohibition of bribery and acceptance of bribes
• Prohibition of illegal political contributions
• Prohibition of improper charitable donations or sponsorships
• Prohibition of unreasonable gifts, hospitality, or other improper benefits
• Prohibition of unfair competitive practices
• Annual integrity, anti-bribery, and anti-corruption training for all employees and senior executives

Code of Conduct

BenQ Materials has established a comprehensive Anti-Bribery and Anti- Corruption Policy, which is incorporated into the Company's Code of Integrity approved by the Board of Directors. This policy explicitly prohibits all forms of bribery and improper benefits, including directly or indirectly offering, promising, soliciting, or accepting cash, gifts, political contributions, inappropriate hospitality, or donations. The policy applies to directors, senior executives, employees, subsidiaries, suppliers, customers, agents, and contractors, and includes, but is not limited to, the following key elements (please refer to the full Code of Integrity for details):
 

1. Prohibition of bribery and acceptance of bribes
2. Prohibition of illegal political contributions
3. Prohibition of improper charitable donations or sponsorships
4. Prohibition of unreasonable gifts, hospitality, or other improper benefits
5. Prohibition of unfair competitive practices
6. Annual integrity, anti-bribery, and anti-corruption training for all employees and senior executives

The Risk Management Committee regularly conducts risk assessments for major operating sites each year to proactively identify potential anticorruption risks. In 2025, the assessment coverage rate reached 100%, and the assessment results were all classified as low risk.

Promotion Work Item	Responsible Department	Execution Method
Regulation establishment and educational promotion	Human Resource Division	Employee Code of Ethical Conduct "emphasizing the ethical management culture has been established, and the Regulations for Disciplinary Actions for various violation events have been specified
Assessment and Inspection of integrity risk	Human Resource Division	Enhance each operation process, implement responsibility allocation, and reduce occurrence of fraud through system control.
	Risk Management Committee	Risk assessments are conducted regularly each year for major operating sites to proactively identify potential anti-corruption risks.
	Procurement Department	All tier 1 key suppliers and tier 1 suppliers were required to sign the code of conduct; for further details, please refer to Supply Chain Management.
Handling of violation of ethics	Senior supervisors form the Major Disciplinary Committee to perform review	For major violation of integrity, the execution status is reported to the Board of Directors according to relevant regulations and operation procedure

Integrity Education Promotion and Training

 

Training Program	（Hrs）	Description	Number of Participants	Total Training Hours
New Employee Integrity Course (including AntiCorruption)	0.5	Mandatory for all new hires	1,057	584.0
Code of Conduct Online Course (including AntiCorruption)	0.25	Mandatory online course for all employees	2,790	1127.9
Insider Trading Prevention	2	Regularly conducted for managers and relevant employees	624	346.7
Trade Secret Regulation Awareness	2	Promoted via internal newsletters for managers and relevant staff	828	713.1
Data Confidentiality (Personal Data Protection Act)	1	Mandatory for all indirect employees and department assistants	1,030	1311.8

Note 1 : The above data include subsidiaries GeneJet, Cenefom, and Web-Pro (including the Vietnam Site).
Note 2: In accordance with the 2025 training plan, no antitrust-related courses were offered; therefore, no relevant training data are available for this year.
Note 3: Employees receive regular training on the Company's whistleblowing mechanism, including available reporting channels, procedures for raising concerns, anonymous reporting options, confidentiality protections, and non-retaliation requirements.

 

Code of Conduct (including Anti-Corruption Policy) Communication and Training Results

The Company provides employees with training on the use of its whistleblowing and grievance channels as part of ethics and compliance education. The training covers available reporting channels, anonymous reporting, confidentiality safeguards, non-retaliation protections, and the process for handling reported concerns.



 

Antitrust Red Flags: 10 Behaviors to Avoid

It is the individual responsibility of our employees to ensure their conduct and that of their peers fully complies with the antitrust laws. At BMC, we are committed to upholding all applicable laws and regulations, including strict compliance with Taiwanese and foreign antitrust laws. We expect our employees to adhere to these laws, and the Legal Department is available to provide guidance and support as needed.
 

1. DO NOT engage in any contact with competitors.
2. If contact is necessary, DO NOT discuss any business-related topics, including price, shipment, customer, or marketing. Please contact the Legal Department if approached by any competitor.
3. DO NOT contact competitors for prices or market information.
4. DO NOT share pricing or shipment information with any third party, including any market research firms.
5. DO NOT attempt to reach any consensus, understanding or agreement with competitors through third parties such as suppliers or market research firms.
6. The source of the information (from a specific customer or supplier, etc.) MUST be stated in writing if competitor pricing information is obtained.
7. DO NOT match competitors’ prices based on any consensus, understanding, or agreement with competitors.
8. DO NOT require customers to purchase a product as a condition of buying another product (“tying”).
9. DO NOT sell product below cost without consulting with the BMC Legal Department.
10. DO NOT impose controls over a customer or distributor’s resale prices.

 

Business Ethics Violation Mechanism

 

The Company explicitly commits to maintaining whistleblower confidentiality and has implemented anti-retaliation measures to ensure that individuals raising concerns are not subject to any form of punishment or adverse treatment. If any violation of integrity cooperation principles is verified, the Company may terminate the partnership in accordance with the agreement or permanently blacklist the party involved. Related handling procedures, contact information, and statistical data are disclosed regularly in the sustainability report or on the Company's official website. If the reported matter involves general employees, it should be submitted to the department supervisor. If it concerns directors or senior executives, it should be submitted to the Audit Committee. In 2025, there were no cases of violations related to business ethics & integrity or anti-corruption.

https://www.benqmaterials.com/tw/investors/information/16/regulations/