Ethical Corporate Management ｜ Sinyi Realty Inc. ｜ Investor Relations

Facts about the Company’s Performance in Ethical Corporate Management

The Company establishes “Corporate Ethics Office” which is responsible for the promotion of ethical corporate management.  The Corporate Ethics Officer ensures the actualization of operation principles of good faith in accordance with the work functions and scope of supervising related matters of each sector and promotes to all colleagues the operation concepts of justice ahead of profit, human oriented and positive thinking and actively constructs and develops a methodology which can absorb its operation concepts to make all colleagues easy to understand and carry them out in daily life.  In addition, the Company conducts several monthly topic discussions and actions such as change management and value-created services and by means of analyzing and sharing at each meeting at all levels to make colleagues be honest internalization and implementation in the daily operation.  In December, 2025, the Office of Corporate Ethics and Sustainability reported the plan and performance of promoting ethical corporate management at the BOD.

Integrate philosophy videos and ethics materials into onboarding, centered on “Dream Fulfillment” and “Say It, Do It.” Through monthly forums and leadership training, the philosophy is embedded in operations. 12 sessions, approx. 6 hours.

Every month, each business unit will arrange the Ethical study group to discuss the concept proposed by the founder.

The Ethical division will periodically podcast the spirit of「Guidelines for the Adoption of Codes of Ethical Conduct for Directors and Managerial Officers」：our priority「treat our client honestly」. In 2024, the "Sinyi Group Procurement Code of Ethics" was updated to a quiz-based signing process, helping employees better understand the guidelines and expected behaviors.

Integrity was emphasized through regional meetings, business reviews, and manager conferences, while daily branch meetings, morning briefings, and one-on-one coaching reinforced Sinyi’s philosophy.

The Sinyi philosophy is integrated into all education and training courses and internal communication materials. In 2025, 31 one-hour sessions, each involving 20-30 participants, were held.

Standard Procedures of Offense Reporting and a Related Confidentiality Mechanism

The Company has established an offense report (such as "Regulations on whistle-blowing of illegal and unethical or dishonest conduct"), for each complaint or offense report shall assign exclusive personnel to be in charge, through different procedures in response to the nature of a case. It would be assigned to the related departments for action or an evaluation committee meeting would be convened, and a response is requested to be replied to the complaint filing party or offense reporting party within a specified period. In case of a major event, it shall be submitted to Corporate Ethics Office or the Board Chairperson. During the disposition process, the information of both a complaint filing party and offense reporting party shall be kept confidential; it is limited to be accessed only by the exclusive handling personnel.

Since the information of a complaint filing party and offense reporting party for a complaint or offense report shall be strictly kept confidential, in case complaint filing party and offense reporting party is a company colleague, upon filing a complaint or report, he/she may choose to be kept confidential or open out of the free will. After it is accepted by exclusive personnel on a project basis and through related procedures and disposition, due management and follow-up shall be filed, to ensure such a party to be free from suffering any improper disposition.

Prohibition of Insiders’ gains from the internal unpublished information

• The Company has expressly stipulated in The Corporate Governance Principles that "the Company's internal control measures for stock transactions from the date of being informed of the Company's financial reports or relevant results, including (but not limited to) directors shall not trade their shares during the closed period 30 days before the announcement of the annual financial report and 15 days before the announcement of the quarterly financial report".
• The specific implementation achievements for the year 2025 are as follows:
  I. Blackout Period Controls for Directors and Insiders (Proactive Notification)
  Prior to the announcement of each quarterly and annual financial report, the dedicated department proactively issues formal notices to directors and insiders to enforce the blackout period (30 days prior to annual results and 15 days prior to quarterly results). Frequency: A total of 4 proactive notifications were issued throughout the year. Recipients: A total of 81 individuals, including all directors and key insiders. Content: The notices explicitly state the scheduled announcement dates and the specific start and end dates of the trading blackout periods to prevent inadvertent regulatory violations.
  II. System-Enforced Mandatory Education (Covering All Employees)
  To ensure that awareness is deeply integrated into daily operations rather than remaining a mere formality, the Company utilizes a system-enforced mechanism: Monthly Mandatory Awareness: On the first day of every month, the ERP system automatically triggers a pop-up notification regarding "Internal Material Information & Compliance Matters," reaching approximately 5,948 employees. Users must manually check each item (including definitions of material information, confidentiality protocols, penalties for violations, and handling procedures) to confirm they have read and understood the content before they can unlock and access their workstations. Annual Specialized Training: In 2025, the Company conducted training sessions on "Internal Material Information Handling Procedures and Relevant Regulations." The participants included all directors, managers, and employees, totaling approximately 4,100 people. New Appointee Mechanism: All directors and employees newly appointed or hired in 2025 are required to complete mandatory legal compliance training within two months of their start date.
  III. Targeted Prevention of Non-Compliance Patterns
  The Company provides focused guidance on high-risk scenarios to enhance the legal literacy of insiders: Specialized Advisories: In 2025, the Company issued 2 specialized advisories to insiders, covering topics such as "Common Patterns of Violations in Insider Shareholding Change Reporting" and "Insider Equity Trading Q&A." Scale of Execution: These advisories reached a cumulative total of 162 person-times, assisting insiders in clarifying regulatory details and preventing reporting violations caused by cognitive errors or misunderstandings of the law.

Other implemented practices

• Routine checks conduction

1. Publicity and Advocacy: Conducted semiannually, primarily scheduled in the first and third quarters (Q1 and Q3).
2. Trade Secret and Personal Data Case Studies: Conducted semiannually, primarily scheduled in the second and fourth quarters (Q2 and Q4).
3. Internal Audits (Staff Units): Conducted semiannually. Key audit focal points include: Ensuring monitors are powered off or locked when personnel are away from their stations; Verifying that confidential documents are stored in locked cabinets; Confirming that confidential emails contain appropriate warning statements. Business Units: Subject to random inspections.