Conflict of Interest

Employees are required to disclose any business interests related to the Company. They must refrain from participating in discussions or voting on matters in which they hold a vested interest. Additionally, they must abstain from participating in discussions and voting on agenda items where employees or directors have a vested interest or where a conflict of interest may arise. Notification of such interests must be provided to the meeting at least 7 business days in advance, and this should be recorded in the meeting minutes.

Employees are strictly prohibited from accepting any form of compensation or gifts that suggest an expectation of reciprocation. However, minor customary gifts received during festivals are permitted, provided they do not imply undue influence.

In cases where the company provides digital asset custody services to digital asset businesses that are affiliated by having common major shareholders, the company must implement additional measures in accordance with the Securities and Exchange Commission (SEC) regulations on criteria, conditions, and methods for operating digital asset businesses, as follows:

(1)   The affiliated digital asset business must not have directors or managers who are the same as those of the company.

(2)   The company must maintain a board of independent directors comprising at least one-third of the total number of directors, with a minimum of two independent directors.

(3)   An audit committee, composed mainly of independent directors, must be responsible for monitoring and reviewing the company's operations. The audit committee must also ensure that reports are submitted to the company's board of directors.

(4)   The compliance department must report the company’s operational performance to the audit committee regularly, at least once per quarter, and without delay in the event of any significant impact on customer assets under custody.

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