Ethical Corporate Management and Regulatory Compliance

Ethical Corporate Management

Uni-President Assets Management has established an ethical governance framework overseen by the Board of Directors. The Company regards integrity and honesty as the cornerstones of corporate governance and sustainable operations and has incorporated behavioral indicators of integrity and honesty into performance evaluations to ensure that integrity principles are concretely reflected in management systems and daily operations. At the same time, through education, training, and awareness campaigns, the Company instills the philosophy of ethical corporate management and verifies employees’ understanding of relevant industry regulations and codes of conduct to enhance the entire workforce’s sensitivity to compliance and ethical risks. The Company is committed to fostering a corporate culture rooted in integrity. Based on business characteristics and practical needs, the Company has established relevant guidelines and operational procedures that clearly define the scope of application and standards of conduct. These apply to all employees of the Company and all parties subject to the relevant regulations, ensuring that the principles of ethical governance are consistently and effectively implemented at all organizational levels.

Conflict of Interest Management

The Company has established comprehensive policies for conflict-of-interest management, including the Manager Code of Conduct, the Uni-President Asset Management Passive ETF and Active ETF Allocation Procedures, the Sales Personnel Remuneration System, and the Policy on the Implementation of the Fair Treatment of Customers Principles, which serve as the basis for identifying, disclosing, and managing conflicts of interest. Uni-President Asset Management upholds the duties of care and loyalty of a prudent manager and continues to implement management mechanisms for various types of conflicts of interest. No significant conflicts of interest occurred during 2025.

Whistleblowing System

To ensure that the Company’s principles of ethical corporate management and compliance are institutionalized and effectively implemented, Uni-President Asset Management has established reporting channels and procedures in accordance with the Uni-President Asset Management Whistleblowing System. We conduct regular compliance tests for internal employees to remind them of the relevant reporting channels and regulations, proactively raising awareness and reinforcing their understanding of these channels, codes of conduct, and legal responsibilities. Additionally, we have established a dedicated link on the homepage of the Company’s official website to provide external parties with a convenient and accessible reporting channel.


There were 0 reported incidents during the year. Under the current whistleblowing mechanism, anyone who discovers misconduct such as criminal activity, fraud, illegal acts, or breaches of integrity may file a report through established channels. The Compliance Department is responsible for handling all reports, which are processed in strict confidence throughout the entire process. The identity of the whistleblower is rigorously protected, while the legitimate rights and interests of both the whistleblower and the subject of the report are safeguarded. Through this institutionalized and trustworthy reporting mechanism, the Company continues to strengthen its corporate culture of ethical management, enhance governance transparency and internal control effectiveness, and support sound corporate governance and sustainable development.

Reporting Contact

Whistleblowing Hotline: +886-2-2747-1622

Whistleblowing Email: upamc.200a@uni-psg.com

Written Reports: Please mail or send documents to the Company’s designated receiving unit - the Compliance Department.

Establishing a Corporate Compliance Culture

To establish a robust and forward-looking compliance culture within the Company, we not only rigorously implement internal control systems, but also integrate compliance into daily operations and management processes. This approach helps prevent insider trading, combat money laundering, and counter terrorist financing, thereby strengthening the overall foundation for compliance and risk management. At the same time, in response to the continuous evolution of the regulatory environment and financial practices, Uni-President Asset Management regularly conducts awareness campaigns and arranges internal and external education and training sessions based on new regulatory developments and common industry violations. This aims to enhance employees’ sensitivity to compliance issues and their practical judgment capabilities, thus continuously deepening the organization’s overall compliance awareness.


Externally, the Company also prioritizes governance and reputation risk management by rigorously ensuring the compliance of all external documents and promotional materials. We ensure that all publicly disclosed information and related operations meet the regulatory requirements of the competent authorities to protect investor rights, enhance information transparency, and support the Company’s sound operations and sustainable development.


For details regarding any penalties, legal proceedings, non-litigation matters, or customer dispute incidents incurred by the Company in 2025, please refer to the disclosure items specified in Article 9 of Appendix 3-1 of the Rules Governing the Preparation and Filing of Sustainability Reports by Securities Investment Trust Enterprises.

 

Regular Communications

  • Deficiencies within the industry: Examples of deficiencies within the industry are shared on a monthly basis to help prevent similar issues from occurring.
  • Regulatory updates: Updates on major regulatory developments are provided periodically through in-person meetings or e-mails.
 

Education and Training

  • Conduct relevant training: “Anti-Money Laundering and CounterTerrorist Financing,” “Financial Consumer Protection Act,” “Personal Data Protection Act and Ethical Corporate Management Best Practice Principles,” and “Board Compliance and Regulatory Response under Corporate Governance 3.0.”
  • Internal and external training courses for new employees: “Pre-employment Education and Training for Investment Trust Practitioners,” “Pre-employment Training for Futures Trust Business Personnel,” “Financial Consumer Protection Act,” and “Personal Data Protection Act and Ethical Corporate Management Best Practice Principles.”
  • Participation in statutory courses organized by training institutions such as the Securities Investment Trust & Consulting Association: “Regulations Related to Investment Trusts and Investment Consulting Services,” “Personal Data Protection Act,” “Analysis of Insider Trading and Unusual Trading Cases,” and “Promotion of Anti-Money Laundering and Counter-Terrorist Financing Regulations.”

Prevention of Insider Trading

To uphold the duty of loyalty and the principles of integrity and professionalism, and to prevent insider trading, the Company has incorporated controls over personal trading activities of personnel handling transactions into its internal control system. It has established the Uni-President Assets Management Manager Code of Conduct and the Uni-President Assets Management Guidelines for the Use of Company or Personal Communication and Information Equipment by Internal Personnel at the Workplace. First of all, the Manager Code of Conduct is reinforced during onboarding training and through monthly e-mails. Compliance awareness is further strengthened through periodic compliance tests and internal e-mail communications. Additionally, individual guidance and dedicated briefings are arranged upon resignation or transfer to mitigate ethical risks and conflicts of interest among department heads, fund managers, discretionary investment managers, researchers, traders, and other relevant personnel.

The Company’s Manager Code of Conduct designates the Chief Compliance Officer as the supervisor responsible for oversight. Operating independently of all units, the Chief Compliance Officer maintains an objective audit function to ensure that business operations and management practices comply with legal requirements. The Chief Compliance Officer reports annually to the Board of Directors and supervisors, covering:

(1) employees’ compliance with the Manager Code of Conduct in the previous year, (2) disciplinary actions against personnel who violated regulations, (3) management of personal trading accounts held by personnel handling transactions, and (4) proposed amendments to the Manager Code of Conduct. This assists the governance bodies in understanding internal conditions and serves as a basis for subsequent improvements.

Anti-money Laundering and Counter-terrorism Financing Prevention

Uni-President Asset Management has established the Uni-President Asset Management Corp. Anti-Money Laundering and Counter-Terrorist Financing Policy, integrating anti-money laundering, counter-terrorist financing, and countering the financing of proliferation into the Company’s overall risk management and sustainability governance framework, with the Board of Directors serving as the highest decision-making and supervisory body. The Compliance Department serves as the dedicated unit, with the head of the Compliance Department reporting directly to the President. In accordance with the Risk Assessment Report Operating Guidelines and relevant procedures, the department has established mechanisms for risk identification, internal assessment, and periodic review to ensure the effective operation of the system.


In addition to requiring partner sales institutions to sign anti-money laundering and counter-terrorist financing due diligence questionnaires, the Company regularly conducts regulatory compliance tests to educate internal employees on relevant regulations and reporting channels. The Company has also established an “Anti-Money Laundering Awareness Section” on its official website and provides clear explanations to external parties through fund subscription forms and related interfaces. At the same time, we have designated supervisory managers in frontline units to enforce customer due diligence and beneficial owner identification, conduct enhanced reviews for high-risk customer groups, together with list screening and ongoing transaction monitoring. Suspicious transactions are reported in accordance with regulations to ensure the implementation of operational procedures.


In addition to continuously strengthening operational processes, the Company has adopted digital technologies to enhance the effectiveness of anti-money laundering and counter-terrorist financing efforts. These include utilizing digital identity verification to support customer due diligence and beneficial owner identification, establishing automated real-time screening against sanctions and terrorist watchlists, and employing an in-house anti-money laundering system to continuously monitor transactions based on transaction amounts, transaction types, and fund flows. The system generates periodic reports of suspicious activity for staff analysis and assessment. Suspected cases are immediately investigated and reported as suspicious transactions in accordance with regulations, thereby effectively improving detection accuracy, reducing human error, and enhancing processing efficiency.


Employees participated in anti-money laundering regulatory training sessions and briefings organized by competent authorities such as the Securities Investment Trust & Consulting Association and the Securities & Futures Institute, with a total of 324 training hours and 80 participant attendances. In 2025, all employees completed internal and external education and training on anti-money laundering and counter-terrorist financing, with a total of 570 training hours and 326 participant attendances, achieving 100% training coverage.

Course Type

Course Title

Training Hours

Number of Participants

External Training

Anti-Money Laundering and Counter-Terrorism FinancingOJTAML/CFT
Training Hours

12

Number of Participants

4

Anti-Money Laundering and Information Security AwarenessInformation Security Promotion
Training Hours

18

Number of Participants

6

Anti-Money Laundering Regulations and Case Study Workshop
Training Hours

165

Number of Participants

55

Analysis of Anti-Money Laundering/Counter-Terrorist Financing Regulations and Case Study Seminar
Training Hours

15

Number of Participants

5

Impact of Amendments to the Company Act on Internal Audits and Corporate Anti-Money Laundering
Training Hours

6

Number of Participants

1

In-Service Training Program for Anti-Money Laundering and Counter-Terrorism Financing Personnel
Training Hours

108

Number of Participants

9

Internal Training

2025 Anti-Money Laundering and Counter-Terrorism Financing Training
Training Hours

246

Number of Participants

246

Total

 
Training Hours

570

Number of Participants

326