Ethical Corporate Management and Anti-corruption Management System

Asia Cement regards integrity as the highest guiding principle for its business development and adopts a zero-tolerance approach to corruption. The management system applies to all Company personnel, suppliers, contractors and business partners. It is implemented in accordance with the Anti-Corruption Management Policy, Principles for Ethical Management, Code of Ethical Conduct, Procedures for Ethical Management and Guidelines for Conduct, and Employee Work Rules.

The Company has implemented an ISO 37001 management system and continues to improve it through planning and establishment, implementation and operation, monitoring and audit, and maintenance and improvement. An internal audit covering all business activities is conducted annually. Asia Cement obtained ISO 37001 certification in 2023 and continues to maintain its certification.

The Board of Directors oversees the anti-corruption management system. The President provides senior management support and authorization. The Secretariat coordinates the system, risk assessments, special audits and education. The head of internal audit conducts internal audits and follows up on corrective actions. Each department implements the relevant policies and procedures and reports irregularities.

Ethical Management and Anti-Corruption Performance

No incidents of corruption or bribery occurred from 2023 to 2025.

No violations involving conflicts of interest, money laundering or insider trading occurred. The anti-corruption management objectives were 100% achieved.

One report was received in 2025 but was not accepted for processing because it did not meet the acceptance requirements. The case was submitted to the Audit Committee for review in accordance with the Procedures for Reporting and Investigating Unethical Conduct. It was not a bribery case.

100% of Asia Cement’s directors and employees in Taiwan signed the Anti-Corruption Policy Compliance Statement.

100% of personnel at all sites completed anti-corruption awareness and training. Total training hours: 1,424; completion rate: 100%; assessment pass rate: 100%.

100% of new employees completed orientation on ethical management and anti-corruption.

Before commencing transactions, 100% of new suppliers and contractors received anti-corruption communication. 100% of key-risk suppliers and contractors completed anti-corruption training.

Ethical Corporate Management and Anti-corruption Management

To implement its anti-corruption policy, the Company prohibits all personnel from directly or indirectly offering, accepting, promising or requesting any improper benefit in the course of business, whether to secure a transaction or to benefit themselves or others. Education and training reinforce employees’ anti-corruption awareness, help manage business risks and support sustainable operations founded on integrity.

Regular Audits of Ethical Standards

To ensure the effectiveness of anti-corruption management, our company has established the "Anti-Corruption Internal Audit Procedures" in accordance with the ISO 37001 management system requirements, mandating an annual internal audit of all business areas. Following the PDCA management system principles ("Plan-Do-Check-Act"), we continuously maintain and improve the system's effectiveness. Asia Cement passed the ISO 37001 anti-corruption management system certification in 2023, with the next certification due in 2026.

Anti-corruption risk assessment and due diligence

In 2025, the Company completed 100% of its corruption risk assessments, identifying 123 risk scenarios and 14 significant internal and external issues. All assessed risks were within acceptable levels, and 100% of improvement measures were completed. The assessment covered 346 personnel, 230 suppliers with transaction values of NT$1 million or more, all 130 customers, and special types of transactions. Two customers were classified as medium risk; training and improvement measures were completed. All other assessment results were low risk.

Communication and Training on Ethical Corporate Management and Anti-corruption

The Company conducts at least one anti-corruption training session each year. Each employee receives at least one hour of training, while internal auditors responsible for the ISO 37001 management system receive at least two hours. Training covers Board members, employees, subsidiary employees, suppliers and contractors. Topics include the Code of Ethical Conduct, Principles for Ethical Management, reporting channels and disciplinary measures.