Company Policy

Regulations of Whistleblowing System

Article 1 (Purpose and Basis)

These Regulations are established in accordance with the Ethical Corporate Management Best Practice Principles, Procedures for Ethical Management and Guidelines for Conduct, Code of Ethical Conduct and applicable laws in order to guide members of the Company towards high-level ethical standards, prevent the occurrence of any conduct in breach of the law, streamline the whistleblowing channel and ensure that a whistleblower’s complaints and issues are handled in a timely manner.

Article 2 (Scope and Type)

Anyone who discovers any concern of criminal offense, cheating, lack of ethics or breach of the law may file a whistleblowing report to the Company, including but not limited to (1) any conduct in breach of any law or regulations applicable to the Company or any applicable provision of any company policy, system or code of ethical conduct, (2) any conduct that jeopardizes or that may jeopardize the Company’s interest, such as corruption, cheating, embezzlement of company asset or receipt of undue benefit, etc.

Article 3 (Definition)

“Whistleblower” is a person who files a whistleblowing report.
“Accused Person” is the director, employee or mandatee of the Company that is accused of having committed an act of criminal offense, cheating or breach of law in the whistleblowing report.
“Whistleblowing Handling Unit” (hereinafter the “Handling Unit”) is the President’s Office of the Company.
“Whistleblowing Investigation Unit” (hereinafter the “Investigation Unit”) is the investigation team formed by the relevant executive under the instruction of the President’s Office to engage in an investigation. Members of such team shall include at least the audit director.

Article 4 (Whistleblowing Channel)

By email: gm@lcygroup.com
By letter to: Whistleblowing Mailbox, LCY Chemical, 3F, No. 85, Section 4, Bade Road, Songshan District, Taipei City
Whistleblowing Conditions:
The Whistleblower must provide at least (i) the Whistleblower’s real name, telephone number, email address or contact address; (ii) the name of the accused, employment unit (department) or other personally identifiable details; (iii) specific evidence or reasonable doubt that can be used for investigation.
For any anonymous whistleblowing case or if the real name or contact details of the Whistleblower is not provided, if clear and specific information is provided, the Handling Unit should still prepare a whistleblowing record and submit it for the record, together with a recommendation as to whether an investigation should take place. However, after the whistleblowing case is confirmed following verification, Article 8 of these Regulations will not be applicable for lack of true whistleblowing information.

Article 5 (Handling Procedure)

Acceptance of the Case:
The Handling Unit shall make a record of the case upon reception and shall conduct verification by telephone, in writing or through an interview as required by the whistleblowing details, provided that the case shall be handled and recorded in a confidential and full manner.
If the whistleblowing conditions are satisfied, the President shall instruct the investigation team to conduct an investigation immediately.
If the case involves a director or high-level management, it shall be submitted to the board of directors.
Investigation:
After a whistleblowing case is registered, the investigation team shall carefully plan the verification manner and the evidence to be verified based on the whistleblowing case. The Accused Person shall be provided the opportunity to give a statement or make a complaint in the verification process. If required, assistance may be sought from other departments or external experts. External units shall also keep the information confidential in accordance with the Company’s rules.
Relevant personnel and parties have an obligation to cooperate with the investigation.
The investigation team shall make clear and full records of the verification process, statements by the Accused Person, verification results, subsequent handling or improvement recommendations, etc., in the investigation report.
It is advisable for the investigation team to complete the initial investigation report within 3 months of receipt of the case. If the investigation cannot be completed in time or if further verification is required, the period may be extended once (up to 3 months), with the reason stated in the investigation report and the estimated completion date.
Upon discovery of a material breach of regulation or potential material damage to the Company during an investigation, the investigation team shall prepare the investigation report immediately and give written notice to the board of directors.
Sanction and Precaution:
If an investigation shows that the Accused Person has breached applicable law or company regulation, the Company shall ask the Accused Person to stop the relevant conduct immediately, undertake proper disposition and seek compensation for damages through legal proceedings as required in order to protect the Company’s reputation and interest.
If the whistleblowing case is confirmed by the investigation, the relevant unit shall review the relevant internal control system and procedure. It is advisable for specific review and rectification measures to be provided within one month in order to avoid the reoccurrence of the same situation.
Case Closing and Report:
After the investigation team completes the investigation report, the verification results shall be submitted to the Chairman for approval and a report shall be made to the board of directors depending on the details of the case.
If a whistleblowing case involves a judicial case, the board of directors authorizes the President to submit the evidence and materials verified by the Company to the prosecution authority for investigation.

Article 6 (Confidentiality and Protection)

Information related to a whistleblowing case (including but not limited to receipt of whistleblowing document, verification process, investigation result and report) shall be kept in written or electronic documents under confidential management and shall be maintained for at least 5 years. In case of litigation relating to the whistleblowing details, the information shall continue to be maintained until the end of litigation.
Other than disclosure of identity with the party’s consent or in accordance with the law, the Company shall keep strictly confidential the Whistleblower and relevant personnel handling the whistleblowing case and shall not disclose the identity of the relevant person that is identifiable with individual cases.
The Company shall duly protect Whistleblowers and relevant personnel handling whistleblowing cases from unfair treatment or disposition due to the whistleblowing case. If any person related to the whistleblowing case is subject to threat, intimidation or other negative conduct, the Company shall provide assistance and report to the police authority for further handling.

Article 7 (Recusal for Conflict of Interest)

If a relevant person handling a whistleblowing case discovers that he/she has a personal interest in the whistleblowing case, a written statement shall be provided to identify such interest and to seek recusal.

Article 8 (Whistleblowing Reward and Discipline)

Upon confirmation of a whistleblowing case following verification, if the Whistleblower is an employee of the Company, a reward may be granted depending on the level of gravity of the whistleblowing details.
If verification shows that a whistleblowing case comes from a false statement, malicious accusation, slander or falsification of a document by an employee of the Company, disciplinary sanctions shall be imposed in accordance with the Company’s internal rules following verification.

Article 9 (Enforcement)

These Regulations of Whistleblowing System, including any amendment hereto, are established by the President’s Office and shall be published and enforced following approval by the board of directors.