Business Integrity(Global)

ADATA has established the “Ethical Corporate Management Best-Practice Principles” to foster a corporate culture rooted in integrity and to support sound organizational development. These principles provide a framework for proper business conduct. They clearly prohibit directors, managerial officers, employees, appointees, and persons with substantive control from directly or indirectly offering, promising, requesting, or accepting any improper benefits in the course of commercial activities. They also forbid engaging in any unethical, illegal, or fiduciary duty-violating conduct intended to obtain or maintain business advantages. The Company requires its directors and senior management to issue statements affirming their compliance with the ethical corporate management policy, and it includes compliance requirements in employment terms for all employees. Contracts signed with agents, suppliers, customers, or other business partners must include clauses requiring adherence to the ethical corporate management policy, along with provisions allowing the Company to terminate the contract at any time if the counterparty engages in unethical conduct.

Directors, managerial officers, employees, appointees, and persons with substantive control must perform their duties with the care of a prudent manager, oversee the prevention of unethical conduct, and continually review and improve implementation measures to ensure the effective enforcement of the ethical corporate management policy. To strengthen ethical corporate management, the Company has established a dedicated unit reporting to the Board of Directors that is provided with adequate resources and competent personnel. This unit is responsible for formulating and supervising the implementation of the ethical corporate management policy and related preventive measures. It reports to the Board on a regular basis at least once a year, and its core responsibilities include:

1. Assisting in integrating integrity and ethical values into the Company's business strategy and establishing relevant anti-corruption measures to ensure ethical management in compliance with laws and regulations.

2. Regularly analyzing and assessing risks of unethical conduct within the scope of business operations, formulating corresponding preventive measures, and developing standard operating procedures and conduct guidelines for relevant business activities.

3. Planning organizational structure, staffing, and responsibilities, and establishing checks-and-balances mechanisms for business activities with higher ethical risk.

4. Promoting and coordinating training and communication related to ethical policies.

5. Design and maintain whistleblowing mechanisms, ensuring their effectiveness.

6. Assist the Board of Directors and management in reviewing and evaluating the effectiveness of preventive measures for ethical corporate management, conducting periodic assessments of relevant business processes to ensure compliance, and preparing reports.

ADATA communicates its anti-corruption policies to business partners and requires cooperating suppliers to sign the Declaration of Integrity. Based on long-term cooperation with suppliers and the pursuit of mutual benefit, ADATA is committed to ensuring integrity and compliance in procurement and other collaborative activities, while preventing and deterring illegal or improper conduct at the source. In all business dealings, the Company strictly adheres to relevant laws, regulations, and integrity requirements, consistently upholding the principles of fairness, impartiality, transparency, and good faith to safeguard the Company’s interests. ADATA’s communication with business partners regarding anti-corruption policies is summarized below:

In 2024, ADATA did not experience any incidents of corruption, nor did it violate any laws or regulations related to ethical corporate management or anti-corruption. As a result, the Company was not subject to any administrative penalties.

Furthermore, no contracts with business partners were terminated or not renewed due to corruption-related violations.

ADATA is committed to upholding ethical corporate management and encourages employees to actively utilize the various communication channels provided by the Company to foster positive corporate development. The Company guarantees that whistleblowers will not be subject to improper treatment as a result of reporting misconduct. In 2024, the Company was not involved in any anti-competitive behavior, nor was it subject to any lawsuits related to anti-trust or monopoly regulations. No closed legal action occurred during the year.

In 2025, the Company’s “Ethical Management Procedures and Conduct Guidelines” were administered and overseen by the Human Resources Department, which is responsible for formulating and monitoring the implementation of integrity management policies and preventive measures to ensure full compliance with the Company’s integrity standards. The Company’s 2025 integrity management implementation status was reported to the Board of Directors on 30 December 2025.