Integrity Management

Business ethics & Integrity Management

CTCI Group Codes of Ethical Conduct

CTCI takes "Most Reliable" as its brand positioning. Its "Codes of Ethical Conduct" and "Ethical Corporate Management Principles", and Ethical Corporate Management Principles, which have been approved by the board of directors, serve as the ethical standards and codes of conduct that CTCI's directors, managers and all employees should follow when performing their duties, manage anticorruption, fair trade, prohibition of insider trading, among other things, so as to prevent dishonest behavior. The Human Resources Department of CTCI is the dedicated unit responsible for promoting integrity management. It conducts annual integrity risk assessments and regularly summarizes "CTCI Corporate Integrity Operations Policy Report", which is submitted to the board of directors. The audit unit formulates relevant audit plans every year based on the risk assessment results of dishonest conduct, prepares an audit report to be submitted to the chairman for approval. The audit results are reported to the dedicated unit for integrity management every quarter to ensure the effectiveness of the integrity policy.
　
　

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Advancing a Culture of Ethical Management

In order to establish a responsible business ethics culture for all internal parties, the Company conducts education and advocacy for directors, managers and employees on the "Measures to Prevent Insider Trading" and relevant laws and regulations at least once a year, and provide timely education and advocacy for new directors, managers and employees. Every year, regular training and signing of the CTCI Codes of Ethical Conduct are held for all employees of the Group (including formal, contracted and dispatched employees) to continue to emphasize CTCI's integrity concepts of anti-corruption, integrity, commitment and honesty. In 2025, the training coverage rate and signing rate are both 100%; for new recruits, courses related to ethical behavior are also arranged in the new employee training. In 2025, a total of 412 new recruits in Taiwan were trained, and the coverage rate is 100%.
　

"Integrity" is one of the core values of CTCI's corporate culture. To embed this value throughout the organization, corporate culture is incorporated into the performance evaluation system for both managers and employees, supported by defined behavioral indicators and a clear reward and disciplinary mechanism. Through this approach, integrity management is effectively integrated into employee performance assessment and human resource management practices, ensuring the implementation of the Company's Code of Conduct.
　
For employees whose duties involve the handling of cash or financial transactions―such as project site managers, site office managers, site administration personnel responsible for petty cash management, and corporate cashiers―the Company provides employee fidelity insurance coverage based on the amount of funds under their responsibility.
　
Project site administration units are required to submit monthly records, including statements of receipts and payments, copies of petty cash account passbooks, and petty cash reconciliation statements, to the Accounting Department for review and recordkeeping. In addition, corporate cashiers prepare annual petty cash reconciliation statements and submit them to the Accounting Department for verification prior to year-end. To strengthen employees' understanding and identification with CTCI's corporate culture of Professionalism, Integrity, Teamwork, and Innovation, the Company organizes annual corporate culture engagement activities. Employees who have questions regarding corporate culture or behavioral indicators may seek guidance through the Employee Mailbox, and the Human Resources Department will provide clarification and support.
　

Anti-corruption and bribery

To prevent bribery and corruption, CTCI requires that employees should not give discounts when conducting trading activities with stakeholders, and cannot ask for, make deals with, give, or accept gifts, entertainment, kickbacks, or bribes for himself/herself or on behalf of others when carrying out his/her job duties. CTCI clearly defines in its Rules for Ethical Conduct the principles and penalties of "rules for gift receiving," "prevention of conflict of interest" and "protection of trade secrets and intellectual property rights." CTCI's Code of Integrity Business prohibits the provision of illegal political donations and prohibits improper charitable donations or sponsorships to avoid disguised bribery. CTCI has checked the 20 lowest ranking countries in the Transparency International's Corruption Perception Index in 2025 and confirmed that it has no construction projects in those countries.

To promote anti-corruption policies, CTCI has incorporated anticorruption and anti-bribery statements into its annual Code of Ethical Conduct training. In 2025, the training achieved 100% employee participation. CTCI regularly reiterates the "no gift acceptance policy" during the three major holiday periods each year through public annoucements. The same standards are implemented across overseas projects and are communicated to suppliers, contractors, clients, and other business partners as necessary.

Since procurement personnel are in direct contact with external manufacturers when handling procurement operations, in order to clarify personal responsibilities, All procurement personnel should sign the Procurement Personnel Code of Conduct, which specifically promises that procurment personnel should comply with legal requirements when performing matters and must not solicit personal improper benefits or accept compensations or any form of remuneration. A questionnaire survey will be conducted when new staff joins the procurement department to collect their personal information, so as to ensure that department work assignments avoid conflict of interest in purchasing operations. Head of procurement-related departments and personnel who serve as bid opening moderators or personnel who have the authority to determine the final awarded bidders and participate in price negotiation shall be subject to reassignment and job rotation every five years in principle. The appointment tenure of head of procurement departments of affiliated enterprises shall be 3-5 years; equipment procurement engineers/ subcontracting engineer shall be reviewed annually and may be promoted to project procurement managers to participate in project work, but they shall be kept isolated from the final bid award pricing during the procurement process; the procurement headquarters of the Group audits procurement orders and contracts on a weekly basis and reviews the procurement process/ prices/procurement authorization to confirm whether the bid award prices are unreasonable or potential frauds exist. The server of the procurement department shall also be subject to access controls. For staff at the construction site, CTCI continues to strengthen relevant publicity and training for them through online meetings, education and training, and post behavioral indicators of corporate culture at each construction site to ingrain the concept of integrity and sustainability among colleagues and contractors. There were zero confirmed incidents of corruption or bribery between 2022 and 2025.Therefore, there were no convictions related to corruption and bribery cases, nor were there any fines related to corruption and bribery cases.
 

Anti-competitive Behavior

CTCI strictly adheres to the principles of fair competition and complies with applicable laws and regulations in both external project bidding and internal procurement activities. The Company has established a Groupwide Antitrust Policy as a guiding principle for major business operations to prevent involvement in activities that violate fair competition principles, including unfair competition, monopolistic practices, market allocation, and price-fixing agreements. In practice, all engineering tenders, external contracting, and procurement activities must follow fair, transparent, and open bidding procedures. In addition, employees in functions with higher exposure to related risks―including business development, procurement, legal affairs, and contract management―are required to participate in annual training programs covering antitrust laws, fair trade regulations, and case studies, as well as pass the required assessments. Colleagues in other departments can also take the courses to improve knowledge of regulations. The 2025 Antitrust Policy Training program covered both new and existing employees, with a total of 105 participants, continuously strengthening company-wide awareness of legal compliance and a culture of compliance. Simultaneously, to further deepen employees' legal awareness of the Fair Trade Act and enable them to appropriately identify and avoid potentially violating the Fair Trade Act in the course of business, a lecturer from the Fair Trade Commission was invited in 2025 to provide explanations on the regulations, types of violations, and practical case analyses. The number of participants and the completion rate for this training course are shown in the table below:
 

When a CTCI employee is found to have violated or is in breach against regulations pertaining to anti-trust laws, the company would conduct a comprehensive and thorough investigation of the employee's work history and immediately suspend the employee's external communications regarding the work. If a criminal offense is involved, the company would deal with it in accordance with the law. There were no anti-competitive behavior cases within CTCI Group in 2025, therefore, the total monetary loss resulting from legal actions associated with anticompetitive behavior or practices was zero.
 

Reporting and Protection

To protect the Company's interests and encourage individuals to report illegal or non compliant activities, CTCI has formulated the Reporting Management Regulations, which defines the purpose, scope, responsibilities of various departments, and management procedures for the whistleblowing mechanism. To prevent misconduct, CTCI has set up an independent internal whistleblower mailbox and a reporting platform operated by an impartial, third-party organization. Internal employees or external parties who discover any illegal or improper conduct within the Group or among its partners, whether ongoing or imminent and potentially harmful to the Group, can choose to report such issues anonymously or under their real name through the appropriate channels. Furthermore, if employees have any concerns regarding ethical business conduct or the Code of Conduct, they may seek guidance from their direct supervisor, the Human Resources Department, or the Compliance Department.

General whistleblowing cases are handled by the Human Resources Department. However, cases involving directors, managers, and/or the Human Resources Department are processed by the Audit Department. In addition to conducting investigations and implementing necessary improvements in accordance with relevant regulations, a summary of the whistleblower cases is compiled quarterly and provided to the independent directors for review.

CTCI is committed to handling whistleblower cases with the utmost confidentiality. All personnel involved in the handling of these cases are responsible for maintaining the confidentiality of the whistleblower's information and identity, the details of the case, and the investigation process. Moreover, a strict "zero retaliation policy" is enforced to ensure that whistleblowers are not subjected to dismissal, demotion, salary reduction, or any other adverse actions as a result of their reporting. Additionally, a reward mechanism has been established to provide whistleblower rewards for verified reports of violations. The amount of the reward is determined by the Reward and Punishment Committee based on the severity of the case, with the aim of encouraging employees to report misconduct and collectively uphold the integrity management of the Company's business culture. In 2025, CTCI received a total of 27 whistleblowing cases. Three case remains under investigation, while none of the rest was found to be in violation of business ethics. Information regarding reporting channels, mechanisms, and whistleblower rights is included in the annual ethics training for all employees.