Ⅰ. Compliance with Laws and Regulations

Compliance with national policies and regulations

• 1. We respect national policies and do not engage in illegal activities.
• 2. The company competes in good faith with its competitors based on products and services in business operation and does not engage in unfair competition.
• 3. We do not obtain information in an unethical or illegal way violating related laws.
• 4. Employees who work abroad respect and comply with the laws and social order of the host country so that their performance in the company is not interfered.
• 5. We do not only respect market economy order, trade customs and regulations of domestic territory but also overseas counterparts to ensure legitimate and fair business trades with our business partners.
• 6. As a member of the country and local communities, we comply with various laws and regulations concerning the prevention of corruption, bribery and money laundering, and report any suspicious transactions through due process and method.

Compliance with the corporate regulations and basic corporate ethics

• 1. We share the company’s business philosophy and goals, comply with the corporate management policies and regulations, and focus capabilities to complete the imposed tasks in a timely and accurate manner based on ownership and responsibility at work.
• 2. In performing work-related tasks, the interests of the company are prioritized rather than those of individual person, and the work is carried out objectively and rationally.
• 3. We neither work for third party individuals or companies which have a conflict of interest with the company, nor form any special relationships with them.
• 4. The company’s confidential or sensitive information is strictly protected, and important information is communicated immediately to the relevant person for work. And we neither distort information nor disseminate nay false information.

Ⅱ. Customer-respecting Management

Business trades with customers

• 1. With customer satisfaction as a top priority, we strive to provide the highest-quality products and services and fully comply with our promises with customers.
• 2. We make sure the trades with customers are carried out reasonably in an equal position based on mutual respect.
• 3. We do not abuse our superior position to ask customers for any kind of unreasonable demands.
• 4. We do not advertise and display false or exaggerated information. We do not conceal information and disclose information that customers need to know.

Partnership with suppliers

• 1. We maintain mutual trust and respect with our business partners to promote shared growth and increase benefits among both parties.
• 2. The company provides equal opportunities in the event of bidding and signing contracts and carries out business trades reasonably by signing a contract in an equal position.
• 3. The company maintains constructive relationship with suppliers by finding and fostering excellent suppliers.

Ⅲ. Shareholder-oriented Management

Protecting interests of shareholders and investors

• 1. We strive to make sound profits by efficient management activities and increase shareholders’ value by rational investment.
• 2. We manage and record financial status accurately and transparently in accordance with accounting standards.
• 3. We do not engage in unfair trade practices by using internal corporate information for the private benefit of one’s own or others.

Protecting shareholders’ right to know

• 1. We provide reliable and useful information related to overall business status to stakeholders and investors in timely manner.
• 2. We try to ensure that our corporate value is evaluated properly through active advertisement and IR activities.

Ⅳ. Employee-respecting Management

Respecting individual employees

• 1. We respect individual characteristics of each employee, encourage their creative thinking and autonomy, and provide support for their capacity building as well as educational opportunities.
• 2. We provide equal opportunities to all employees and evaluate them fairly based on their performance and capabilities.
• 3. We do not discriminate on the grounds of nationality, educational background, region, gender, age, religion, political inclination and marital status when it comes to employment, work and promotion.

Facilitating a sound corporate culture

• 1. Employees do not engage in unethical conducts such as gambling, taking improper money, borrowing money, or writing joint and several liability among each other.
• 2. Employees do not conduct defamatory behaviors as well as any verbal, physical, sexual or visual behaviors which may offend other employees, and we respect personal privacy of each individual.
• 3. We do not favor or discriminate against certain individuals or organizations for reasons of nepotism, academic relations, religion, or gender and do not ask for favors to cause disadvantage against other employees.
• 4. The company and employees create a creative and proactive corporate culture in order to achieve shared goals and do not engage in acts that encourage departmental selfishness or conflicts.

Ⅴ. Employees Compliance Management

Transparent and fair work performance

• 1. A supervisor may not give his/her subordinates unfair work orders contrary to legal and corporate regulations. In response, the subordinates can refuse to perform his/her duties by clarifing proper reasons.
• 2. An employee should neither engage in any kind of solicitation that undermines the fair working performance of other employees for the sake of his/her own or others’ interests, nor receive or promise any bribes.
• 3. Employees strive to avoid any conflict of interest between the company and customers or between customers by using their superior status and personal interests. When a conflict of interest arises, they try to seek for resolutions to minimize damages to stakeholders.
• 4. Employees strictly manage and protect corporate or customer data acquired during work, in accordance with relevant laws and corporate regulations, and do not leak it out or use it for personal purposes.

Ⅵ. Suppliers Shared Growth Management

Pursuit of shared growth

• 1. When selecting suppliers, starting and continuing contracts with them, we consider whether they comply with human rights, environmental and social values which the company pursues.
• 2. We ensure that a business trade with a supplier is carried out fairly in an equal position, and we thoroughly discuss trade conditions and process with suppliers and do not commit unfair trade practices, abusing our superior position.
• 3. We create a foundation for shared growth with suppliers by enhancing their sustainability through multi-faceted support activities.

Ⅶ. Social Responsibility Management

Contribution to social development

• 1. We respect the values of the domestic and overseas local communities where the business operates and continue to create employment and fulfill our basic responsibilities as a member of society.
• 2. As an exemplary member of society, we actively respond to social demands imposed to the company such as CSR activities.
• 3. We strive for environment conservation and actively participate in environmental protection in the local communities.

Conflict minerals refer to the metals tin, tantalum, tungsten, and gold extracted in the Democratic Republic of the Congo or its adjoining countries involved in conflicts.
The funds generated from the conflict minerals finance armed groups in such countries, possibly causing violation of human rights through child labor, forced labor, and abuse of women during the mining process. Amid the increasing international concern on the matter, the US Congress passed the Act in 2010 that makes the report on the use of conflict minerals mandatory (the Dodd–Frank Wall Street Reform and Consumer Protection Act). In accordance with Section 1502 of the Act, US publicly listed companies should audit their supply chains and report conflict minerals usage and their country of origin to the US SEC (Securities and Exchange Commission).

- Almac complies with international standards regulating conflict minerals and will not use conflict minerals produced in the Democratic Republic of Congo and neighboring countries.

- Almac does not purchase products containing conflict minerals and will not supply them to domestic or foreign corporations/factories.

- Almac will continue to strive to reflect international laws, government organizations, and customer policies in its conflict minerals policy.

- Almac will receive “Declaration of Compliance on Non-Use of Minerals from Conflict Areas” from all partners so that this policy can be expanded.

- Subcontractors should submit a written conflict minerals report to Almac Co., Ltd. to make sure that the conflict minerals financing armed groups in the Democratic Republic of Congo or its neighbors are not included in the supplied products.

- Subcontractors should make efforts to obtain the information on the smelter and country of origin of their purchased 3TG materials (tin, tantalum, tungsten, and gold).

- If a problem occurs in relation to conflict minerals, subcontractors should take corrective action. Almac Co., Ltd. can cease trading with a subcontractor if it fails to offer the necessary information for the confirmation of conflict minerals usage, provides false information, or fails to take corrective action following the occurrence of a problem.