Prevent Insider Trading - GTM 勤益投資控股

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Prevent Insider Trading

The Company established Guidelines such as the “Procedures for Handling Material Inside Information,” “Procedures for Ethical Management and Guidelines for Conduct,” “Procedures for Preventing Insider Trading,” and “Regulations for Management of Related Party Transactions” to regulate the standard operating procedures and guidelines for preventing insider trading by all stakeholders.

The Code of Conduct is promulgated and implemented annually for current directors, managers, and employees. It is reviewed periodically to ensure compliance with current laws, regulations, and management needs. The relevant rules are announced on the Company’s intranet site and are readily available for review.

In order to strengthen stock trading control measures, the company has revised the ““Procedures for Preventing Insider ” in accordance with the “Corporate Governance Best Practice Principles”. According to the procedures, relevant insiders of the company those prohibiting from trading its shares during the closed period of 30 days prior to the publication of the annual financial reports and 15 days prior to the publication of the quarterly financial reports.

The implementation in 2024 as followings:

Financial reports period	Date of Board meeting	Closed period	Implement precautionary measures
2023 financial reports	2024/3/8	2024/2/7-2024/3/10	The company sent an email in advance to notify relevant insiders (including but not limited to directors) that they are prohibited from trading in the company's stocks they hold during the closed period.
1st quarter of 2024 financial reports	2024/5/10	2024/4/25-2024/5/12
2nd quarter of 2024 financial reports	2024/8/13	2024/7/29-2024/8/15
3rd quarter of 2024 financial reports	2024/11/8	2024/10/24-2024/11/10

In recent years, the Company conducted the following educational programs for our staff:

In 2024, the Company conducted 21 hours of education and training for the current directors and managers in April,September, October and November for a total of 8 times.
In 2023, the Company conducted 15 hours of education and training for the current directors and managers in April and October, for a total of 4 times.
The courses cover confidentiality of material information, the reasons for insider trading, the identification process and examples of transactions, the scope of internal material information, confidentiality practices, public practices, and non-compliance handling.
In 2022, the Company conducted 18 hours of education and training for the current directors and managers in April, for a total of 6 times.
The courses cover confidentiality of material information, the reasons for insider trading, the identification process and examples of transactions, the scope of internal material information, confidentiality practices, public practices, and non-compliance handling.
In 2021, the Company conducted 9 hours of education and training for the current directors and managers in August and November, for a total of 3 times.
The courses cover confidentiality of material information, the reasons for insider trading, the identification process and examples of transactions, the scope of internal material information, confidentiality practices, public practices, and non-compliance handling.
In 2020, the Company conducted 15 hours of education and training for the current directors and managers in May, September, and October, for a total of 6 times.
The courses cover confidentiality of material information, the reasons for insider trading, the identification process and examples of transactions, the scope of internal material information, confidentiality practices, public practices, and non-compliance handling.
In 2019, the Company conducted 15 hours of education and training for the current directors and managers in April, May, July, August, and October, for a total of 7 times.
The courses cover confidentiality of material information, the reasons for insider trading, the identification process and examples of transactions, the scope of internal material information, confidentiality practices, public practices, and non-compliance handling.