Insider Trading Management

⚖️ Implementation Status of Ethical Corporate Management and Prevention of Insider Trading

Organizational Operations and Institutional Setup

1. The Company conducts its business activities based on the principles of fairness, honesty, trustworthiness, and transparency. To implement the Ethical Corporate Management Policy and actively prevent unethical conduct, the Board of Directors has approved the "Ethical Corporate Management Best Practice Principles" and the "Procedures for Ethical Management and Guidelines for Conduct", which are clearly incorporated into performance evaluations and human resources policies.
2. The Company has designated the "Corporate Governance Officer" to concurrently serve as the dedicated functional unit for ethical corporate management, responsible for formulating and supervising the implementation of ethical management policies and prevention programs.　　
3. Directors who have a personal interest or represent a juristic person with an interest in a proposal presented at the Board meeting shall explain the essential contents of such interest at the meeting. If there is a risk of prejudice to the Company's interests, they shall not participate in the discussion and voting, must recuse themselves, and shall not exercise voting rights on behalf of other directors.　　
Independent Whistleblowing Channels and Grievance Mailbox:
The Company has established an independent reporting and anonymous grievance section on its official website. Both internal and external parties can report illegal acts or violations of ethics through the dedicated ethical grievance mailbox (chonghong@chonghong.com.tw). Reports are handled with appropriate confidentiality and strict investigation procedures to ensure the whistleblower's identity is strictly protected from improper treatment. If a violation of ethical conduct is confirmed through investigation, disciplinary action will be strictly taken in accordance with relevant laws or employee reward and punishment regulations. 　 　
4. The Company has established the "Procedures for Handling Material Inside Information and Preventing Insider Trading," which strictly prohibits insiders and information recipients from trading securities using undisclosed market information. These procedures serve as the basis for our material information handling and disclosure mechanisms. The Company regularly reviews these procedures to ensure compliance with current regulations and practical management needs. Relevant guidelines are available on the Company's website...
5. The Company regularly conducts educational campaigns for insiders, designated managers, and employees regarding the "Procedures for Handling Material Inside Information" and regulations related to "Ethical Corporate Management," actively implementing corporate governance and preventing insider trading.

Implementation Status of Ethical Corporate Management

1. Translation: In the event of unethical conduct, the handling methods and subsequent review and improvement measures are immediately reported to the Board of Directors. Furthermore, an annual report on the implementation status of ethical corporate management is submitted to the Board...
2. Establishment of a comprehensive whistleblowing mechanism:The Company's website features an "Official Website Whistleblowing Mailbox" and an "Internal Employee Grievance Channel," with the Administration Department designated as the independent unit responsible for handling such matters. Based on recent reviews, current corporate governance operations are functioning well, and there have been no whistleblowing reports or violations..
3. The Company regularly organizes internal and external educational training related to ethical corporate management (including business seminars, regulatory compliance, occupational safety and health training, and information security courses) to thoroughly deepen all employees' awareness of ethical management.
4. .As of the most recent fiscal year-end, neither the Company nor its construction sites have been involved in any legal cases concerning corruption, violations of business ethics, bribery, or integrity issues..
5. The Company reported the effectiveness of internal controls regarding ethical corporate management operations for the most recent year to the Board of Directors on December 16, 2025. ..

Implementation Status of Insider Trading Prevention

1. The Company conducts regular annual advocacy programs for managers and employees, distributing relevant information to all managers and colleagues for their reference and compliance.
2. The Company's "Procedures for Handling Material Inside Information and Preventing Insider Trading" stipulates strict closed-period control measures for stock trading"Directors are prohibited from trading their shares during the closed period of 30 days prior to the publication of the annual financial report and 15 days prior to the publication of each quarterly financial report.".
3. The Company's Stock Affairs Division and Finance Department strictly implement internal controls by proactively sending closed-period control notices to remind directors and other insiders 15 or 30 days prior to the publication of quarterly and annual financial reports. The Company also notifies all directors in advance of the expected Board meeting dates for the upcoming year (including the expected approval schedules for quarterly financial reports) to ensure strict adherence to the aforementioned regulations. Internal audits confirm that the Company punctually reports monthly changes in shareholding, and 100% of insiders comply with the regulations, with no instances of overdue reporting or violations...