Arcadyan operates with a commitment to integrity, establishing strong corporate governance and risk control mechanisms. Arcadyan implements integrity management through four key aspects: "Policy Formulation," "Education and Training," "Prevention and Protection," and "Complaint and Whistleblowing."
Policy Formulation
In accordance with the "Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies", Arcadyan has established "Ethical Corporate Management Best Practice Principles," "Procedures for Ethical Management and Guidelines for Conduct," and "Code of Conduct for Directors and Managers." In addition, in the personnel regulations, the policies and practices of integrity management have been expressly stated in "Business Ethics Policy." Arcadyan has formulated a prevention plan for dishonest behavior, covering the following areas:
1. Prohibition of bribery and accepting bribes
2. Prohibition of providing illegal political donations
3. Prohibition of inappropriate charitable donations or sponsorships
4. Prohibition of unreasonable gifts, hospitality, or other improper benefits
5. Prohibition of intellectual property infringement
6. Prohibition of engaging in unfair competitive practices
7. Prevention of harm to stakeholders from products or services
In 2023, Arcadyan did not receive any reports related to violations of its integrity management guidelines. There were also no cases involving violations of integrity management guidelines, corruption and bribery, fraud, insider trading, anti-competitive behavior, anti-trust and monopoly practices, or legal proceedings and penalties related to market manipulation.
Education and Training
Arcadyan requires employees to adhere to "Ethical Corporate Management Best Practice Principles" and "Business Ethics Policy." Every new employee must complete "Awareness Training for All Staff," covering topics such as business ethics, codes of conduct, risk management, insider trading prevention, and procedures for handling internal sensitive information. Additionally, all employees receive annual refresher training on these topics to ensure familiarity and vigilance regarding integrity-related issues. In 2023, a total of 4,638 employees completed the training, achieving a completion rate of 90.53%.
Prevention and Protection
In 2022, Arcadyan established "Risk Management Implementation Task Force" to conduct risk assessments for the various business activities of the company. In 2023, integrity-related risks were identified as high-risk items, including anti-corruption and fair competition. High-risk behaviors such as hospitality, money laundering, bribery, fraud, and violations of fair competition were evaluated for their severity and likelihood. Processes identified as high risk included procurement, sales, and financial duties involving direct contact with customers, suppliers, and financial institutions or processes with substantial influence. Arcadyan conducted integrity due diligence on relevant departments, requiring managers and employees to complete the "Anti-corruption Due Diligence Questionnaire," and pledge not to offer or accept bribes, as well as prohibit any form of kickbacks, money, goods, or other valuable items from third-party collaborators, which may influence objective decisionmaking. In 2023, a total of 62 managers and employees from high-risk process underwent investigation and completed the questionnaire, achieving a completion rate of 100%. The investigation found no violations of business ethics or corruption-related issues.
Anti-Competitive Practices
Arcadyan has established the "Ethical Corporate Management Best Practice Principles" and the "Arcadyan Technology Business Ethics Policy," conducting business activities in accordance with relevant competition regulations. Practices such as fixing prices, bid rigging, limiting production and quotas, or sharing or dividing markets through allocation of customers, suppliers, operating regions, or types of businesses are strictly prohibited. Arcadyan strictly prohibits any theft of patent information, handling of trade secrets obtained without the owner's consent, or inducing employees of other companies, whether current or former, to disclose their confidential information. It respects and treats fairly the rights of company clients, suppliers, competitors, and employees. Employees are required not to obtain unreasonable benefits from others through manipulation, concealment, abuse of privileges, dissemination of false information, or other illegal trading practices. Arcadyan encourages both internal and external individuals to report any dishonest or improper behavior. If an employee is involved in dishonest behavior, the incident will be reported to department supervisors immediately, and appropriate action will be taken, including reporting to regulatory authorities or referring for investigation if necessary. In 2023, Arcadyan had no involvement in litigation related to anti-competitive practices, antitrust, or monopoly regulations, nor were there any legal actions concluded during the year.
Complaint and Whistleblowing
Arcadyan advocates for a transparent business ethics culture. It established Violation Reporting Mailbox (ethics@arcadyan.com), allowing both internal and external individuals to report dishonest or unethical behaviors. Arcadyan ensures the confidentiality of whistleblower's identify and the content of the reports, promising to protect whistleblowers from retaliation. When investigating the reported individuals or departments, original or the copies of the report will not be disclosed, whistleblowers' identities will not be exposed. Anonymous reports are treated with discretion, handwriting analysis will not be conducted and the content will not be circulated. Upon verifying instances of dishonest behavior or reported incidents, Arcadyan takes strict disciplinary actions and notifies judicial authorities or government anti-corruption agencies when necessary. In 2023, Arcadyan did not receive any complaints related to corruption or violations of its integrity policies, nor did it face penalties from regulatory authorities for breaches of integrity or corruption-related regulations.
