Whistleblower Reporting System

Whistleblower Reporting System


Article 1 (Purpose of establishment)

In order to carry through the Company's corporate core value of ethical corporate management, and in accordance with Article 2.22 of the Company's "Ethical corporate management best practice principles", a "Whistleblower rep orting system" is formulated to clearly establish the Company's whistleblower channels and investigation procedures so that the Company's "Ethical corporate management best practice principles" can be carried through and the legitimate rights of whistleblowers can be protected.


Article 2 (Scope of application)

The measures shall apply to all directors, managerial officers and employees of Shinfox Energy Co., Ltd. and its subsidiaries (hereinafter referred to as "the Company"). Any director, managerial officer, or employee of the Company involved in any violation of the Company's "Ethical corporate management best practice principles" may be reported.


Article 3 (Authority and responsibility)

The unit responsible for receiving reports shall be the audit office.


Article 4 (Reporting principles)

(I) The principle is to report in real names, but anonymous reports are also allowed; for reporting in real names, such information as the real identity of the whistleblower, the name, unit, and position of the accused, basic circumstances, and the amount of money involved in the case, etc. should be provided; for anonymous reports, the facts of the violation or evidence of the violation should be provided, such as documentary evidence, physical evidence, basic circumstances, the name of the party concerned, time, place, and interested person involved, and after verification, the dedicated unit will conduct an internal investigation.
(II) After the initial review of the information reported, if any one of the following circumstances, the report may not be accepted or replied to.
1. There is no specific content for verification of the subject matter of the report.
2. The content of the report is obviously fallacious or exaggerated, or no evidence is provided to prove the facts of the violation, or it is verified to be inconsistent with the facts, or is purely fictitious.
3. The same subject matter of the report has been properly handled and clearly answered, but still repeatedly reported.
4. For the same reported case, the whistleblower has reported to other channels of the Company for the same reason and has been accepted.
5. If the nature of the reported case is not a violation of laws and regulations, such as labor disputes, customer service disputes, relationship disputes, employee behavior management, gender equality act, etc., the case shall be referred to the authority responsible for the case to be handled in accordance with special regulations.

Article 5 (Reporting channel)

The Company has established and announced an independent whistleblower reporting mailbox for internal and external personnel use: Whistleblower reporting mailbox: [email protected].


Article 6 (Investigation principles)

(I) The dedicated unit that receives reports shall handle all reports that do not fall within the scope of Article 4.2 as soon as possible after receiving them, and shall notify the whistleblower in writing or by other means as appropriate.
(II) If a member of the investigation unit is a lineal or collateral relative by blood, relative within 3rd degree of kinship by marriage of the whistleblower or the accused, or has a conflict of interest with the accused, he or she shall immediately recuse himself or herself from the investigation and shall uphold the principles of fairness and impartiality in the investigation process. If a member of the investigation unit considers that there is a risk of conflict of interest or bias in the execution of duties by a specific person participating in the procedure, he/she may also report to the officer of the audit office for approval and recusal.
(III) The investigation unit shall keep the documents related to the investigation process and results in writing, electronic files, or system approvals for at least five years. Before the expiration of the retention period, when a lawsuit related to the reported content occurs, the relevant information shall continue to be kept until the end of the lawsuit.

Article 7 (Whistleblower protection)

(I) The Company shall handle the reported case in a confidential manner and take a prompt, fair and objective position in handling them. The Company shall keep the personal information and reported information provided by the whistleblower confidential and take appropriate protective measures in accordance with the law.
(II) The Company shall take appropriate protective measures for the whistleblower or participants in the investigation, including but not limited to: the name of the whistleblower or any facts sufficient for identifying the whistleblower shall not be recorded in public documents except with the consent of the whistleblower; the name, work unit, address, telephone number, etc. of the whistleblower shall be kept strictly confidential; the verification of facts from the whistleblower shall be conducted without revealing his or her identity.
(III) If the whistleblower knows that he or she is disclosing untrue evidence, or if the purpose is to obtain improper benefits, he or she shall not be protected by the protection principles of this Article.

Article 8 (Examination procedures)

(I) The audit officer is responsible for receiving and registering the case, and presenting it to the general manager to designate a person in charge of the case or investigation team to find out the relevant facts.
(II) If the reported case involves general employees, it shall be reported to the top supervisor of the department and general manager; if it involves directors or senior officers, the case shall be reported to the independent directors or supervisors or the audit committee.
(III) The following procedures shall be followed in investigating substantiated reported cases：
1. Immediately request the accused to stop the relevant behavior, and make the necessary preventive or emergency measures.
2. The relevant department shall propose written review and improvement measures, and summarize the investigation results, handling methods and follow-up review and improvement measures, and report to the Board of Directors.
3. In the event of a major violation or a risk of significant damage to the Company, the investigation unit shall immediately prepare a report and notify the independent directors or supervisors in writing.

Article 9 (Reward and punishment)

If a report is substantiated, a reward may be given according to the seriousness of the report; if an internal employee makes a false report or malicious accusation, he or she shall be punished in accordance with the relevant regulations of the Company's HR management.


Article 10 (Implementation)

This system will be announced and implemented after the approval of the general manager, and the same applies to revision.