Grounded in its core commitment to sustainable operations, Hiwin Mikrosystem Corp. ("HMC") has established comprehensive short-, medium-, and long-term sustainability roadmaps aligned with the United Nations Sustainable Development Goals (SDGs). As a dedicated manufacturer of high-precision equipment, HMC is committed to ensuring safe working conditions throughout its global supply chain, upholding ethical and environmentally responsible business operations, and treating all workers with dignity and respect. To this end, HMC has established this Supplier Code of Conduct (the "Code") and requires all suppliers to operate in full accordance with the principles set forth herein. Furthermore, suppliers are expected to cascade these standards to their own suppliers, contractors, and service providers.

Commitment to and compliance with this Code is a fundamental prerequisite for establishing and maintaining any business relationship with HMC. Suppliers' adherence to these standards serves as a critical criterion within HMC's supplier management framework, procurement evaluations, and regular performance reviews. Through proactive collaboration, transparent communication, systematic audits, and continuous improvement, HMC aims to foster a resilient and virtuous supply chain ecosystem, partnering with suppliers to fulfill our collective responsibilities as responsible corporate citizens.

The provisions in this Code are primarily derived from the Responsible Business Alliance (RBA) Code of Conduct and align with international standards, including ISO 45001 (Occupational Health and Safety Management Systems) and ISO 14001 (Environmental Management Systems). This Code encompasses five core pillars: Labor, Health and Safety, Environmental Protection, Ethical Business Practices, and Management Systems, detailing the fundamental requirements and management systems necessary to ensure ongoing conformity.

A. LABOR

Suppliers are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, intern, contract, direct employees, and any other type of worker.

The labor standards are:

A1 Prohibition of Forced Labor

• A1.1 All forms of forced labor are strictly prohibited. Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons shall not be used. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services.
• A1.2 As part of the hiring process, workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms.
• A1.3 All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per worker's contract.
• A1.4 Employers and agents may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Employers can only hold documentation if such holdings are required by law. In this case, at no time should workers be denied access to their documents.
• A1.5 There shall be no unreasonable restrictions on workers' freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities including, if applicable, workers' dormitories or living quarters.
• A1.6 Workers shall not be required to pay employers' or agents' recruitment fees or other related fees for their employment.

A2 Child/Young Workers

• A2.1 Child labor is not to be used in any stage of manufacturing. The term "child" refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest.
• A2.2 Suppliers shall implement an appropriate mechanism to ensure that child labor is not employed, except for legitimate workplace learning programs that complies with all laws and regulations.
• A2.3 Workers under the age of 18 shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.
• A2.4 Suppliers shall provide appropriate support and training to all interns, ensure appropriate management of interns through adequate maintenance of student records, rigorous due diligence of educational partners, and protection of students' rights in accordance with applicable law and regulations. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

A3 Working Hours

• A3.1 Studies of business practices clearly link worker strain to reduced productivity, increased employee turnover and increased injury and illness. Working hours are not to exceed the maximum set by local law.
• A3.2 A workweek should not be more than 60 hours per week, including overtime, except in emergency or abnormal situation.
• A3.3 Workers shall be allowed at least one day off every seven days.

A4 Wages and Benefits

• A4.1 Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Deductions from wages as a disciplinary measure shall not be permitted.
• A4.2 In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted.
• A4.3 For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed.
• A4.4 All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

A5 Humane Treatment

• A5.1 There is to be no harsh or inhumane treatment including any type of gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment.
• A5.2 Disciplinary policies and procedures in support of humane treatment requirements shall be clearly defined and communicated to workers.

A6 Non-Discrimination/Non-Harassment

• A6.1 Suppliers should be committed to a workplace free of harassment and unlawful discrimination.
• A6.2 Companies shall not engage in discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices.
• A6.3 Workers shall be provided with reasonable accommodation for religious practices.
• A6.4 Workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way, including pregnancy or any other physical exams.

A7 Freedom of Association and Collective Bargaining

• A7.1 Suppliers should respect all employees' freedom to organize and participate in worker organizations of their choice (such as labor unions), as well as their right to engage in collective bargaining with one or multiple employer organizations regarding working conditions and employment terms. At the same time, employees' right to choose not to participate in such activities must also be respected.
• A7.2 Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

B. HEALTH AND SAFETY

Suppliers recognize that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. Suppliers also recognize that ongoing worker input and education are essential to identifying and solving health and safety issues in the workplace.

The health and safety standards are:

B1 Occupational Safety

• B1.1 Potential for exposure to safety hazards of the workers are to be identified and assessed, and controlled through the Hierarchy of Controls, including elimination of hazards, use of alternative processes or materials, proper design, engineering and administrative controls, preventative maintenance and safe work procedures, and ongoing safety training.
• B1.2 Workers are to be provided with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards.
• B1.3 Reasonable steps must also be taken to remove pregnant women/nursing mothers from working condition with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments, and provide reasonable accommodations for nursing mothers.

B2 Emergency Preparedness

• B2.1 Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills. Emergency drills must be executed at least annually.
• B2.2 Suppliers shall set up appropriate fire detection and suppression equipment, clear and unobstructed egress, contact information for emergency responders, adequate exit facilities and recovery plans in their plants and public facilities.
• B2.3 Such plans and procedures shall focus on minimizing harm to life, the environment, and property.
• B2.4 Suppliers shall identify the natural disasters that may be encountered in the area, evaluate the possibility and severity of affecting operations, and formulate emergency plans and contingency procedures based on the evaluation results to minimize the impact.

B3 Occupational Injury and Illness

• B3.1 Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting of occupational injuries and illnesses cases.
• B3.2 For occupational injury and illnesses, suppliers shall investigate cases and implement corrective actions to eliminate their causes; classify and record injury and illness cases; provide necessary medical treatment; and facilitate return of workers to work.

B4 Industrial Hygiene

• B4.1 Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled according to the Hierarchy of Controls.
• B4.2 For identified potential hazards, suppliers shall seek opportunities to eliminate or reduce the possibility of the occurrence of hazards, or eliminate or control potential hazards through proper design and administrative controls.
• B4.3 When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment free of charge.

B5 Physically Demanding Work

• B5.1 Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

B6 Machine Safeguarding

• B6.1 Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.

B7 Sanitation, Food, and Housing

• B7.1 Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities.
• B7.2 Worker dormitories provided by the supplier or a labor agent are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting and heat and ventilation.
• B7.3 Suppliers or agents shall provide individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.

B8 Health and Safety Communication

• B8.1 Suppliers shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but not limited to mechanical, electrical, fire, and physical hazards.
• B8.2 Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers.
• B8.3 Training is provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise safety concerns without retaliation.

B9 Natural Disaster Risk Mitigation

• B9.1 Suppliers shall be aware of the natural disasters, such as earthquakes, droughts, floods, typhoons, etc. relevant to its facilities, and assess their likelihood and impact of personnel injury, property damage, and operational disruptions. The risks should be mitigated through establishing hardware protection, developing emergency response procedures, training and drills, and conducting emergency plans.

C. ENVIRONMENTAL

Suppliers recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public.

Environmental Standards:

C1 Environmental Permits and Reporting

• C1.1 All required environmental permits, approvals, and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.

C2 Pollution Prevention and Resource Reduction

• C2.1 Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices such as adding pollution control equipment, modifying production, maintenance and facility processes, or by other means.
• C2.2 The use of natural resources, including water, fossil fuels, minerals and virgin forest products, is to be conserved by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling or other means.

C3 Hazardous Substances

• C3.1 Chemicals, waste, and other materials posing a hazard to humans or the environment are to be identified, labeled and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

C4 Solid Waste

• C4.1 Suppliers shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).

C5 Air Emissions

• C5.1 Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances, and combustion by-products generated from operations are to be categorized, routinely monitored, controlled and treated prior to discharge.
• C5.2 Suppliers shall conduct routine monitoring of the performance of its air emission control systems.

C6 Materials Restrictions

• C6.1 Suppliers are to adhere to all applicable laws, regulations and HMC's requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.

C7 Water Management

• C7.1 Suppliers shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination.
• C7.2 All wastewater is to be categorized, monitored, controlled, and treated prior to discharge or disposal.
• C7.3 Suppliers shall conduct routine monitoring of the performance of wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

C8 Energy Consumption and Greenhouse Gas Emissions

• C8.1 Suppliers are to look for methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.

D. ETHICAL BUSINESS PRACTICES

To meet social responsibilities and to achieve success in the marketplace, suppliers and their agents are to uphold the highest standards of ethics including:

D1 Anti-Corruption

• D1.1 The highest standards of integrity are to be upheld in all business interactions.
• D1.2 Suppliers shall have a zero-tolerance policy to prohibit all forms of bribery, corruption, extortion and embezzlement.

D2 No Improper Advantage

• D2.1 Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted.

D3 Disclosure of Information

• D3.1 All business dealings should be transparently performed and accurately reflected on the Supplier's business books and records. Information regarding suppliers' labor, health and safety, environmental practices, business activities, structure, financial situation, and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

D4 Intellectual Property

• D4.1 Transfer of technical and commercial information is to be done in a manner that protects intellectual property rights; and, customer and supplier information is to be safeguarded.

D5 Fair Business, Advertising and Competition

• D5.1 Standards of fair business, advertising and competition are to be upheld.

D6 Protection of Identity and Non-Retaliation

• D6.1 Programs that ensure the confidentiality, anonymity and protection of whistleblowers are to be maintained.
• D6.2 Suppliers should have communication channels for their personnel to be able to raise any concerns without fear of retaliation.

D7 Responsible Sourcing of Minerals

• D7.1 Suppliers shall prohibit any relevant conflict minerals and develop conflict minerals policies and management systems, exercise due diligence on the source and chain of custody of tantalum, tin, tungsten and gold in the products they manufacture.

D8 Privacy

• D8.1 Suppliers are to commit to protecting the reasonable privacy expectations of personal information of everyone they do business with.
• D8.2 Suppliers are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

D9 Avoiding Conflict of Interest

• D9.1 Business dealings between suppliers and HMC should avoid any potential conflicts of interest. Potential conflicts of interest include, but are not limited to, situations where an employee of HMC or their close relative (parent, child, spouse, or sibling) is employed by the supplier, or holds a significant investment interest in the supplier (as a non-publicly traded company). Unnecessary or overly-frequent socializing between suppliers and HMC counterparts may also create a concern or appearance of a conflict of interest. Therefore, any contact between suppliers and HMC personnel must strictly adhere to standard business boundaries, and any conflict of interest situation must be reported to HMC immediately. If suppliers discover any potential conflicts of interest, they must immediately report them to HMC. Reporting channel: E-mail: honest@hiwinmikro.tw. Whistleblowers should report in their real names, attach their contact information, and state facts or evidence. The HMC Internal Audit office will keep the relevant information of whistleblowers strictly confidential.

D10 Prohibition of Unauthorized Subcontracting

• D10.1 Without special authorization, HMC employees shall not require the supplier to provide the products or services to a third party, or designate the purchase from a specific third party. Upon receive such request from a HMC employee a report should be made immediately to HMC.
• D10.2 Report to the address honest@hiwinmikro.tw with names, contact information, facts or evidence of misconducts. The HMC Internal Audit Office will keep the relevant information of whistleblowers strictly confidential.

D11 Performing Services as Agreed in Contract

• D11.1 Suppliers shall not subcontract or have a third party perform the obligations under the contract or purchase order for products or services that are expected to be fulfilled by the supplier without HMC's prior consent. Furthermore, suppliers shall not provide any products or services to HMC without a validly executed contract or purchase order.

D12 Complying with Export and Import Regulations

• D12.1 Suppliers should understand and comply with relevant laws and regulations related to the import, export, and transportation of goods to and from HMC or on HMC's behalf, including export controls and customs regulations in the country of origin, import and customs regulations in the destination country, duties and other taxes required by payment laws, and relevant transportation regulations. Suppliers should provide operational procedures and training to their employees and subcontractors to ensure their compliance with the aforementioned regulations.

E. MANAGEMENT SYSTEMS

Suppliers shall adopt or establish a management system with a scope that is relevant to the content of this Code. The management system shall be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the supplier's operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement.

The management system should contain the following elements:

E1 Company Commitment

• E1.1 Corporate social and environmental responsibility policy statements affirming suppliers' commitment to compliance and continual improvement, endorsed by executive management and posted in the facility in the local language.

E2 Management Accountability and Responsibility

• E2.1 Supplier clearly identifies senior executive and company representative(s) responsible for ensuring implementation of the management systems and associated programs.
• E2.2 Senior management reviews the status of the management system on a regular basis.

E3 Legal and Customer Requirements

• E3.1 Suppliers shall have an effective compliance process to identify, monitor and understand applicable laws, regulations and customer requirements.

E4 Risk Assessment and Risk Management

• E4.1 Suppliers shall develop a risk management system to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Supplier's operations.
• E4.2 Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.

E5 Improvement Objectives

• E5.1 Written performance objectives, targets and implementation plans to improve the supplier's social, environmental, and health and safety performance, including a periodic assessment of supplier's performance in achieving those objectives.

E6 Training

• E6.1 Programs for training managers and workers to implement suppliers' policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

E7 Communication

• E7.1 A process for communicating clear and accurate information about suppliers' policies, practices, expectations and performance to workers, suppliers and customers.

E8 Worker Feedback, Participation and Grievance

• E8.1 Ongoing processes, including an effective grievance mechanism, to assess employees' understanding of and obtain feedback on or violations against practices and conditions covered by this Code and to foster continuous improvement.
• E8.2 Workers must be given a safe environment to provide grievance and feedback without fear of reprisal or retaliation.

E9 Audits and Assessments

• E9.1 Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code, and customer contractual requirements related to social and environmental responsibility.

E10 Corrective Action Process

• E10.1 A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

E11 Documentation and Records

• E11.1 Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

E12 Supplier Responsibility

• E12.1 A process to communicate Code requirements to next-tier suppliers and to monitor their compliance to the Code.