Ethical Management

Ethical Management

We have established internal rules and regulations such as the “Code of Conduct”, the “Ethical Corporate Management Best Practice Principles”, the “Implementation Measures for the Whistleblowing System”, and the “Guidelines for Political Contribution Donations”. These clearly demonstrate our commitment to ethical business practices and legal compliance. We require that all activities of the Company and its subsidiaries comply with applicable laws and regulations and adhere to high standards of professional ethics. We are committed to avoiding unfair competition, opposing any form of bribery, and maintaining appropriate management systems, supported by internal training to enhance employees’ awareness and strengthen corporate governance. We report the implementation status of ethical management to the Board of Directors annually. The most recent annual report was presented to the Board of Directors on November 12, 2025.

Education and Training

New Employee Orientation

We have incorporated ethical management into our orientation for new employees to ensure that every new hire understands and adheres to our “Ethical Corporate Management Best Practice Principles”, “Code of Conduct”, and related policies. As of mid-October, a total of 33 new employees joined the Company; 28 have completed the ethical management training, totaling 14 training hours.

External Training

As of the end of October 2025, a total of 21 employees applied for external training on accounting and internal control systems, totaling 85 training hours.

Internal Training

As of the end of October 2025, we conducted internal training sessions on ethical corporate management to raise employees’ awareness, covering topics such as anti-corruption, insider trading, and whistleblowing channels. A total of 375 attendances were recorded, totaling 187.5 training hours. In 2025, we additionally used videos in the public areas of our headquarters to promote ethical management, anti-corruption, and the prevention of insider trading. Six videos with different themes were screened, and the videos were played more than 19,600 times for more than 620 hours in total.

Whistleblowing System

We have established a whistleblowing system and updated the contact information for reporting on our official website since September 30th, 2021. We ensure the confidentiality and protection of the whistleblower’s identity. The specific procedures for complaints and investigation are clearly stipulated in the “Implementation Measures for the Whistleblowing System” and updated on a regular basis.

Declaration and Commitment

As of May 2023, all of our 9 board directors have signed the “Statement of Compliance with Ethical Management Policy” declaring their full adherence to the company’s “Code of Conduct”, “Ethical Corporate Management Best Practice Principles” and any related ethical management policies and regulations. Additionally, all 37 new employees who joined D-Link prior to the third quarter of 2024 have signed and agreed to comply with the “Code of Conduct”.

Supplier Compliance

Our company includes clauses in procurement contracts with suppliers that require adherence to corporate social responsibilities and our ethical management policy. These contracts explicitly prohibit suppliers from offering or receiving bribes or other improper benefits to or from any of our personnel, for commercial or personal gain, or engaging in similar conduct. We further require all suppliers to sign an “Integrity and Anti-corruption Pledge” reiterating these stipulations and stating clearly that any such illegal activities will result in immediate contract termination. Prior to the third quarter of 2024, our company signed a total of 29 procurement contracts, all of which included these provisions. Additionally, our company did not receive any reports of bribery involving suppliers in 2024. 

Political Contributions

We have established “Guidelines for Political Contributions” to serve as a procedural and behavioral guide for legally managing political contributions. In 2024, our company did not make any political contributions.

Anti-Corruption Assessment

We evaluate each operational site based on the latest “Corruption Perceptions Index” to determine if they are located in regions perceived to have a high risk of corruption. If an operational site is situated in a country classified as having a medium to high corruption risk (meaning a score below 50), we enhance relevant anti-corruption education and training. Taking Taiwan, where our headquarters is located, as an example, the score was 67, ranking 28th out of 180 countries, indicating a low-risk area. In 2024, our company did not experience any incidents of employee corruption or internal complaints, and upon assessment, no significant corruption-related risks were identified.

Insider Trading Prevention

Article 6 of our “Procedures for Handling Material Inside Information and Prevention of Insider Trading” and Article 10 of our “Practical Guidelines for Corporate Governance” clearly stipulate that directors and insiders are not allowed to trade their shares during the 30 days prior to the announcement of the annual financial report and 15 days prior to the announcement of each quarterly financial report.
Our quarterly financial reports for the year 2024 were approved by the Board of Directors on February 27th, May 14th, August 13th, and November 13th respectively. Additionally, notifications were electronically sent to directors and insiders on January 26th, May 14th, July 23rd, and October 24th by stock service personnel, reminding them not to engage in stock transactions before the financial report announcements. There were no incidents of insider trading in 2024.