Ethical Corporate Management

Integrity and honesty have always been the core values of Apex's corporate culture and the foremost principle of its business philosophy. The Company is committed to conducting all business activities with integrity and prohibits corruption and fraudulent behaviour. Apex's board of directors establishes policies and regulations related to integrity management and constantly monitors the development of domestic and international corporate governance systems to review and improve the corporate governance system established by the Company, thereby enhancing corporate governance effectiveness. (Please refer to the company's website: Major Internal Policies)

The company has set up a corporate governance team, which is responsible for the promotion, management and implementation of ethics management matters, and reports the implementation status to the Board of Directors on a regular basis (at least once a year), the latest report on  December 19, 2023.

Promotion and Implementation

• The benefits of external providers
• Commitments to external
• Political donations
• Large-scale donations
• Protection of trade secrets and intellectual property
• Private transactions
• Compliance with international regulations
• Insider trading
• Customer/Supplier ethical issues

The Company held 61,691 person-time and totaling 457,509 hours of education training (including employee professional training, compliance management laws and regulations compliance, accounting system, internal control and corporate governance, etc.) related to Ethical Corporate Management in 2023.

Investigation Procedures and Reporting Channels

The Company has established standard operating procedures for reporting matters, where the reporting acceptance, investigation process, and results should all be documented in writing and retained for five years. Matters involving general employees should be reported to department heads, while those involving directors or senior executives should be reported to independent directors. Upon verifying the validity of reported matters, relevant units must review internal control systems and operational procedures, proposing improvement measures to prevent the recurrence of similar behaviours. The dedicated unit responsible for handling reports should report the reported matters, their handling methods, and subsequent review and improvement measures to the board of directors.

Compliance with Regulations

Apex strictly adheres to local laws at all operational sites and actively participates in various global initiatives or conventions covering multiple areas such as environment and human rights. Through establishing multiple internal regulations by the board of directors, Apex rigorously binds company personnel, demonstrating zero tolerance for unlawful conduct. In the event of suspicious behaviour or potential violations of Apex's code of conduct by any employee or representative, the Company has established a whistleblowing inbox on its website for internal and external parties to report misconduct anonymously. The Company's audit manager directly handles reported matters. In 2023, Apex did not experience any major integrity violations in its operations, nor were there any significant incidents involving infringement of customer privacy, environmental protection violations, or human rights issues.

Prevent Insider Trading

The Company provides relevant education when directors, managers, insiders and employees are newly elected/assigned, and arranges for new insiders to participate in the insider equity transaction legal compliance publicity briefing held by the competent authority. During the term of office, we continued to arrange or provide relevant legal publicity to directors, managers, insiders and employees every year. In addition to hiring external lecturers to provide current directors with relevant seminars including prevention of insider trading, we also arrange personnel to participate in relevant publicity briefings provided by the competent authority to avoid violations of the law and punishment. Relevant departments also notify the directors, managers, insiders, and employees by email when the competent authority issues a new revised law or on a regular basis every year in the form of real cases that violate the law, so as to urge them to follow the regulations. . The company's corporate governance code and measures to prevent insider trading have been updated, including (but not limited to) relevant provisions that directors are not allowed to trade stocks during the closed period 30 days before the announcement of the annual financial report/15 days before the announcement of the quarterly financial report; Inquiry notices and convening notices on the meeting date of the board of directors, advance telling of the period of closed stock trading and related laws and regulations and setting reminders (targets include all directors, meeting staffs and employees who have received relevant information).

Note for Irregular Business Conduct Reporting

Integrity is the most important core value of Apex's culture, and also a top priority of APEX business principles. Apex is committed to act ethically in all aspects of our business, and will not condone any form of corruption and fraud. If you find or suspect any unethical conduct or breach of Apex's ethical standards by an APEX employee or anyone representing Apex, please contact us. Your report will be directly forwarded to Vice Presidents of Apex.

Unless otherwise provided by laws, Apex will maintain the confidentiality of your personal information and protect your identity to the fullest extent permitted by law.

Reminder：

1. Apex may use your personal information, including name, telephone number and email address, to facilitate investigation or to contact you. If necessary, Apex may share your personal information with its subsidiaries.
2. You may not act maliciously or knowingly and willfully make a false statement. You shall assume liability for the allegations that prove to have been made maliciously or knowingly to be false.
3. To promptly act to investigate and/or resolve the issue, please provide as much detailed information and documents as possible. Please note that if the information or documents are insufficient, the investigation may be hampered.
4. You may not disclose any or part of information provided by Apex. Unless otherwise required by law, you may not file a lawsuit using the correspondence between you and Apex.
5. You should state clearly in your report that you agree with this Note, otherwise the company will not accept your reporting.