Prevention of Insider Trading

TU has established the “Procedures for Preventing Insider Trading,” which explicitly prohibit company directors, managers, and employees from using non-public market information to trade securities for personal gain. In addition, to build a robust mechanism for handling and disclosing material information, prevent improper information leakage, and ensure timeliness, consistency, and accuracy in external disclosures, the Company has also adopted the “Procedures for Handling Internal Material Information” for compliance.

Internal Regulations

  1. Procedures for Handling Internal Material Information
    The Company has established the “Procedures for Handling Internal Material Information” to prevent improper information leakage and to ensure the timeliness, consistency, and accuracy of external disclosures. This measure also aims to prevent directors, managers, and employees from using non-public market information to trade securities.
  2. Corporate Governance Best Practice Principles
    The Company has adopted the “Corporate Governance Best Practice Principles,” which stipulate that insiders are prohibited from trading company shares prior to the announcement of financial reports or related information. This includes, but is not limited to, a restriction on directors from trading shares within 30 days before the announcement of financial reports and during the blackout period of 15 days prior to the announcement of quarterly financial reports.

Specific Implementation Measures

  1. Upon onboarding, the Company provides education and awareness training to newly appointed directors, managers, and employees, and requires them to sign a declaration stating that they will not engage in any illegal insider trading.
  2. When a new insider assumes a position, the Company simultaneously provides relevant regulations on the prevention of insider trading and explains key points that the newly appointed insider should pay attention to, in order to avoid violations of laws and related regulations that could result in penalties.
  3. On December 25, 2025, the Company sent an email to all directors, reminding them that during the blackout periods prior to the announcement of each quarterly financial report for the 2026 Board meetings, they are prohibited from trading the Company’s shares, in order to avoid inadvertent violations of relevant regulations.
  4. In 2025, no directors, managers, or employees of the Company were penalized for violating insider trading laws.