Arcadyan upholds the core value of integrity in business operations, establishing a robust corporate governance and risk control framework. Through policy formulation, training, preventive measures, and whistleblowing channels, Arcadyan fully implements integrity management to ensure all business activities are conducted legally and in compliance, thereby strengthening corporate resilience and sustainability.
Policy Formulation
In accordance with the "Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies," Arcadyan has formulated and disclosed the "Ethical Corporate Management Principle", "Procedures for Ethical Management and Guidelines for Conduct", and the "Code of Conduct for Directors and Managers", all approved by the Board of Directors. In addition, the "Business Ethics Policy" is stipulated in the personnel management regulations, clearly demonstrating Arcadyan's commitment to ethical operations. To enforce high standards of ethical risk prevention, Arcadyan explicitly prohibits the following activities:
- Prohibition of bribery and accepting bribes
- Prohibition of providing illegal political donations
- Prohibition of inappropriate charitable donations or sponsorships
- Prohibition of unreasonable gifts, hospitality, or other improper benefits
- Prohibition of intellectual property infringement
- Prohibition of engaging in unfair competitive practices
- Prevention of harm to stakeholders from products or services
In 2024, Arcadyan received a whistleblowing case related to integrity or corruption. Internal investigation found no material violations. Arcadyan was not involved in any litigation or penalties related to corruption, bribery, fraud, insider trading, anticompetitive behavior, antitrust, monopoly, or market manipulation—demonstrating Arcadyan's effective governance and legal compliance.
Training and Awareness
To cultivate a strong culture of ethical conduct, Arcadyan established the Employee Code of Conduct in 2007, which was comprehensively revised in 2021 as the "Business Ethics Policy". The policy covers key topics such as integrity, prevention of conflicts of interest, rules on gifts and hospitality, use of resources, protection of intellectual property and confidential information, fair trade, and anti-money laundering measures. Arcadyan requires all employees to avoid conducting business transactions with parties that have records of unethical conduct. Any such cases must be promptly reported and business relationships terminated to protect Arcadyan's reputation and stakeholder trust. For severe violations of integrity, disciplinary measures—up to dismissal—are enforced in accordance with applicable laws and Arcadyan's personnel regulations.
The "Business Ethics Policy" is incorporated into new employee orientation, and all staff are required to participate annually in the "Company-wide Awareness Training," which covers business ethics, the Code of Ethical Conduct, risk management, insider trading prevention, and handling of material information. In 2024, a total of 3,534 participants completed the training, with a completion rate of 95.5%. In addition, targeted external training sessions were provided for Board members, corporate governance officers, internal auditors, and relevant functional units, enhancing their expertise in integrity-related regulations, financial systems, information security, and internal control. In 2024, these specialized programs accumulated a total of 90 training hours.
Prevention and Control Measures
To effectively prevent fraud, corruption, and unethical conduct, Arcadyan has established a comprehensive internal control system and, in line with the risk management process, continuously monitors and reviews risks related to ethical business operations. Integrity governance is incorporated into the annual audit plan, with the Audit Office responsible for overseeing policy implementation and reporting regularly to the Board of Directors to ensure the effectiveness and transparency of the management mechanisms.
The Finance and Accounting Department implements a regular job rotation system to enhance operational flexibility and reduce the risk of collusion. For high-value transactions or operational processes with significant decision-making impact, Arcadyan follows the Four-eye Principle, introducing multiple layers of review, functional segregation, and cross-checking to strengthen internal control design and ensure the legitimacy and prudence of major operational decisions. Since the establishment of the Risk Management Task Force in 2022, Arcadyan has conducted systematic risk identification and assessment across business activities. In 2024, high-risk ethical business issues identified included anti-corruption and fair competition, with a focus on hospitality, money laundering, bribery, fraud, and unfair trade. Arcadyan assessed the likelihood and potential impact of these risks and, to strengthen behavioral standards and control measures in highrisk functions, conducted a Due Diligence Integrity Survey. In 2024, a total of 84 high-risk personnel—including senior management, sales, procurement, and finance staff—completed the anti-corruption questionnaire, committing not to offer or accept bribes, kickbacks, cash, or other improper benefits that could influence decision-making, and to refrain from any form of improper business dealings. The survey achieved a 100% response rate, with no incidents of unethical conduct, corruption, or other violations detected.
Anti-Competitive Behavior
Arcadyan upholds the principles of integrity management in accordance with the "Ethical Corporate Management Principle" and the "Business Ethics Policy", complying with competition laws and fair trade regulations in all jurisdictions where it operates. Arcadyan prohibits any form of unfair competition, including but not limited to price-fixing, bid-rigging, production or quota restrictions, market or clients' allocation, and other activities that undermine fair market competition. Arcadyan also strictly prohibits the improper acquisition or misuse of patents, trade secrets, and confidential information, including the theft of patent information, unauthorized use of counterparties' trade data, or inducing current or former employees to disclose confidential information from previous employers. Arcadyan is committed to protecting the rights and dignity of all parties in business interactions and adheres to the principles of integrity, transparency, and fairness in dealing with clients, suppliers, competitors, and employees. Employees are prohibited from manipulating information, abusing authority, concealing facts, or using any other illegal means to gain benefits for themselves or third parties.
Arcadyan has established reporting and handling mechanisms that encourage internal and external stakeholders to report any dishonest or improper conduct. Once any employee is found to be involved in unethical behavior, the case is immediately reported to the relevant supervisor, with appropriate measures taken. Where necessary, the matter is reported to competent authorities or judicial bodies, underscoring Arcadyan's commitment to anti-corruption and fair competition. In 2024, Arcadyan had no legal actions, litigation, or penalties related to anti-competitive, anti-trust, or monopoly regulations, demonstrating the effectiveness of its integrity governance and legal compliance.
Supplier Integrity Due Diligence
Suppliers are key partners in Arcadyan's promotion of integrity management and the enforcement of business ethics. To build a transparent and fair supply chain, Arcadyan requires all suppliers to sign the "Arcadyan Supplier CSR commitment", which clearly stipulates adherence to principles prohibiting bribery, illegal donations, gifts, and other improper benefits. Suppliers are also required to promote anti-corruption awareness and provide training to their employees and agents, while encouraging the reporting of any potential corrupt practices.
To strengthen integrity governance across the supply chain, Arcadyan conducts an annual "Anti-corruption Due Diligence Questionnaire" investigation for medium and high risk suppliers based on supplier evaluation results, to identify potential risks of bribery, improper gifts, hospitality, or other transfers of benefits. In 2024, a total of forty-one suppliers underwent the assessment, with a 100% questionnaire completion rate. The results revealed no instances of violations of business ethics, kickbacks, acceptance of cash, or inappropriate hospitality. Arcadyan will continue to enhance supply chain integrity risk management through due diligence and transparent evaluation processes.
Whistleblowing and Reporting Mechanism
Arcadyan fosters a corporate culture of integrity and transparency by establishing a dedicated whistleblowing channel, the Integrity Reporting Mailbox (ethics@arcadyan.com), for employees and external stakeholders to report dishonest or improper conduct. Arcadyan is committed to protecting the confidentiality of whistleblowers' identities and the content of reports during the investigation process and prohibits any form of retaliation. For anonymous reports, Arcadyan does not disclose original documents or copies, nor does it conduct handwriting identification or unauthorized external review. If internal investigation procedures confirm the occurrence of misconduct, Arcadyan will take strict actions in accordance with the law and, when necessary, notify judicial or anti-corruption authorities, demonstrating a zero-tolerance stance against corruption.
In 2024, Arcadyan received one report related to integrity or corruption. After internal investigation, no material violations were found. Aside from this case, there were no incidents in which Arcadyan violated integrity management or anticorruption regulations that resulted in penalties from competent authorities, indicating that Arcadyan's integrity governance mechanisms operate effectively and its risk control measures remain robust.
Political Contributions
Arcadyan strictly adheres to the principle of political neutrality and has not engaged in any political party activities, political donations, or lobbying during its operations. In 2024, Arcadyan had no record of any political contributions. Arcadyan also respects employees' individual civic rights and encourages them to actively participate in democratic processes, such as voting or supporting candidates and public issues they believe in, thereby demonstrating Arcadyan's commitment to social engagement and respect for individual freedoms.