To ensure a safe working environment throughout WT’s supply chain, uphold respect and dignity for employees, promote environmental protection in operations, and maintain ethical management practices, we have established a Supplier Code of Conduct.This Code outlines expectations for suppliers in five key areas: labor and human rights, health and safety, environmental protection, ethics, and management systems.Suppliers are required to comply with both this Code and all applicable laws and regulations in the countries and regions where they operate.
Supplier Code of Conduct
ALabor and Human rights: Vendors shall, in accordance with laws and regulations, commiting to uphold human rights and dignity of laborers, and shall not employ child labor, discriminate, harass, impose corporal punishment, or allow excessive overtime work.BHealth and safety: Vendors should provide a safe and health management systems. Vendors should also understand that employee feedback, education and training are crucial to identifying and solving health and safety problems in the workplace.CEnvironmental protection: Vendors shall abide by local laws and regulations, mitigate the adverse impact on the environment as a principle, and reduce resource consumption and pollution discharge.DEthics: Vendors shall adhere to the highest ethical standards, including: ethical operation, anticorruption, imformation disclosure, intellectual property, fair trade, privacy, etc.EManagement: Vendors management shall establish a management system of which the scope is relevant to the content of this Code.
Carefully vetting and partnering with like-minded suppliers
WT aims for long-term partnerships with General Affairs suppliers who share our core values. To this end, our management has established a “General Affairs Supplier Code of Conduct” for these suppliers. All General Affairs suppliers are required to sign the “Supplier Corporate Social Responsibility Commitment Letter” and complete an online “Supplier Self-Assessment Form.” Our procurement team evaluates the results of these self-assessments to identify potential risks in areas such as human rights, labor practices, consumer protection, ethical business conduct, environmental protection, and health and safety. We ensure that 100% of new GA suppliers are screened and selected based on environmental and social standards. In addition, we are committed to strengthening sustainability awareness among our GA suppliers to prevent major deficiencies or legal violations.
In 2024, WT Group has completed the signing of Corporate Social Responsibility Commitment Letters with existing General Affairs suppliers in Taiwan and China, achieving a 100% signing rate. Following the merger of Future Electronics into the group, the overall signing rate for target General Affairs suppliers across the entire group is 33.9%. Going forward, we will continue to integrate global General Affairs suppliers into a unified management system, strengthening our commitment and oversight on environmental, labor, and human rights issues to ensure the supply chain complies with the group’s responsible procurement policy.
In alignment with global environmental protection trends, WT revised the General Affairs Supplier Code of Conduct in 2024. New environmental requirements were added to ensure that suppliers comply with international, national, and local biodiversity regulations when conducting their operations and business activities. These requirements include avoiding deforestation and preventing harm to endangered or protected species, while also supporting forest and land conservation.
To maintain procurement quality, annual assessments are conducted for General Affairs suppliers with annual transaction amounts exceeding NT$1 million or with more than 12 transactions per year. The assessment scope includes supplier performance in delivery quality, delivery timeliness, service capability, ESG implementation, environmental protection, and occupational health and safety.
Assessment results are categorized into four levels: A, B, C, and D, we also track and facilitate improvements for suppliers rated C and D. In 2023, two suppliers received a C rating; one was replaced in 2024, while the other improved to a B rating after guidance and assistance, thus maintaining our partnership.
In 2024, the qualification rate (C-level and above) for suppliers in Taiwan and China reached 100%, with Class A suppliers accounting for 80.0%. Four suppliers received a C rating; while we provide guidance and support for improvement, we are also actively seeking alternative suppliers to enhance supply chain resilience and maintain supply levels and quality standards. We plan to integrate these assessment guidelines into our overseas operational sites in the future.
Due to the expanded scope of operations in 2024, the assessment of General Affairs suppliers this year still focused on WT’s existing suppliers, with an assessment rate of 100%. After the inclusion of Future Electronics, the overall assessment rate for target General Affairs suppliers across the entire group is 33.9%. Going forward, we will gradually expand the scope of assessments as planned and continue to improve the assessment processes and indicators to strengthen the sustainable risk management of the global supply chain.
Supplier Assessment Standards
ADelivery Quality: Assesses whether the supplier’s goods meet quality and specification standards, and if product packaging is intact.BDelivery Timeliness and Service: Able to deliver on time or earlier according to company needs, quality of after-sales service and technical service.CESG Implementation: Verifies whether the supplier has published corporate social responsibility-related reports and if they have made declarations or commitments regarding relevant issues.DEnvironmental Protection: Confirms the supplier’s commitment to environmental protection, including the implementation of environmental and energy-saving management measures, effective promotion of environmental sustainability, and ensuring that their operations, products, and services do not cause significant negative environmental impacts or violate environmental regulations.EOccupational Health and Safety: Ensures that the supplier’s employees and working environment comply with labor standards laws and related labor regulations.Supplier Evaluation Overview
Number of suppliers evaluated12820231152024Average supplier evaluation score84.07202384.82024Percentage of A-grade suppliers79.7%202380.0%2024
General affairs supplier meeting: Sharing experiences and fostering growth with partners
To promote the exchange of sustainability knowledge and practices across our supply chain, WT held a General Affairs Supplier Meeting in Taiwan in 2024. The event focused on three core themes: occupational health and safety, greenhouse gas (GHG) emissions, and green procurement, aiming to promote sustainability values among general affairs suppliers. Key topics included the importance of occupational accident prevention, reinforced through real-world incident case studies and an overview of relevant occupational safety regulations; an introduction to Taiwan’s GHG-related regulations and practical procedures for GHG inventory; WT’s energy-saving and carbon reduction strategies, along with short-, medium-, and long-term targets; and the standards used to assess suppliers’ sustainability performance during the procurement process. Through this educational initiative, WT and our suppliers jointly enhanced the quality of green procurement and enabled suppliers to better align their practices with future sustainability goals. The supplier meeting will continue to be held annually, with plans to extend the initiative to other overseas sites, maximizing the impact of sustainable development across the supply chain through top-down collaboration.
Continuous monitoring of Environmental and Social management by major suppliers
WT is committed to promoting sustainable development in the supply chain. We encourage our major suppliers to provide high-quality products and services while complying with national regulations and policies. They must ensure that their products and manufacturing processes adhere to environmental and social responsibility standards. Suppliers are required to prohibit the use of hazardous substances (such as those restricted by the EU RoHS directive), ensure that raw materials do not contain conflict minerals, and sign a Conflict-Free Minerals Declaration, In 2024, there were no incidents of non-compliance with health and safety regulations related to products and services.
Additionally, WT encourages suppliers to adopt ISO certifications to enhance quality management. Suppliers are also urged to implement occupational safety measures, labor rights protections, and environmental protection initiatives, working together to establish a responsible and sustainable supply chain.
WT considers suppliers as long-term partners and maintains close communication with them. Through continuous engagement, we promote the implementation of environmental sustainability, social responsibility, and ethical standards. We also emphasize compliance and corporate responsibility in operations, ensuring that suppliers commit to ethical business practices, human rights principles, and corporate ethics.
Self-regulation of major Supplier Codes of Conduct
The major supplier have established comprehensive business conduct guidelines to ensure compliance with relevant regulations and international standards.
Supplier Environmental Management and International Standard Certifications
WT places strong emphasis on supply chain responsibility. The company has identified and selected 36 key suppliers, which collectively account for over 80% of total revenue. Each year, WT conducts assessments on the status of these vendors’ adherence to the RBA Code of Conduct, chemical substance commitments, and conflict minerals policies, and updates the list of key suppliers at the beginning of each year
The key suppliers have adopted ISO certifications to ensure their operations meet international standards. By implementing strict management systems, they enhance operational efficiency and minimize environmental impact.
As of the end of 2024, key suppliers have achieved the following certifications:
• ISO 14001 Environmental Management System: In the 36 key suppliers, 33 have obtained certification, accounting for 92%
• ISO 9001 Quality Management System: In the 36 key suppliers, 35 have obtained certification, accounting for 97%
Employee Rights and Labor Protection
The supplier must comply with local laws to protect employee rights, ensuring:
• Respect for employees’ rights to unionize, engage in collective bargaining, and enjoy freedom of association.
• Establishment of communication channels to safeguard labor rights and prevent forced labor, child labor, or discrimination.
Responsible Business Alliance (RBA) Code of Conduct
WT supports and adheres to the Responsible Business Alliance (RBA) Code of Conduct, striving to improve labor rights, health and safety, and environmental standards to ensure compliance with international and ethical norms.
As of the end of 2024, WT continuously monitors 36 key suppliers, of which 22 are official RBA members, representing 61% and have established comprehensive RBA guidelines.
Additionally, WT actively tracks whether suppliers undergo RBA audits to promote ongoing improvements in labor conditions throughout the supply chain.
Compliance of Agency Products with Global Substance Regulations
1976TSCAUnited States Toxic Substances Control Act1986Prop 65California Proposition 652003EU RoHSEuropean Union Restriction of Hazardous Substances Directive2004EU POPsEuropean Union Persistent Organic Pollutants Regulation2007EU REACHEuropean Union Registration, Evaluation, Authorisation and Restriction of Chemicals2016China RoHSAdministrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Product2023PFASPer- and Polyfluoroalkyl SubstancesChemical Management and Product Compliance
With increasing global emphasis on environmental protection, WT continues to monitor regulatory developments and ensures that suppliers’ agency products fully comply with relevant global substance regulations. We actively track and update compliance measures to meet customer requirements.
When customers request material substance lists for products, WT assists in obtaining relevant documentation from suppliers, such as non-use declarations, product composition reports, and third-party hazardous substance testing reports.
In 2024, all sold products complied with customer chemical management requirements. All of 36 key suppliers publicly declared full compliance with relevant chemical management regulations.
As of the end of 2024, compliance rates key suppliers are as follows:
• EU RoHS (Restriction of Hazardous Substances Directive): In the 36 key suppliers, 24 have publicly disclosed compliance (66.7%), while 12 have not disclosed, accounting for 33.3%, all key suppliers have provided formal declarations confirming that the materials used in their products comply with major international environmental regulations.
• REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals): In the 36 key suppliers, 23 have publicly disclosed compliance (63.9%), while 13 have not disclosed, accounting for 36.1%, all key suppliers have provided formal declarations confirming that the materials used in their products comply with major international environmental regulations.Chemical Safety Management Process
01.Hazardous Substance Management
• EU RoHS• EU REACH• EU POPs• TSCA• Prop 65• China RoHS• PFAS02.Collect Supplier Information
• Compliance Documents
• Third-Party Test Report
• Supplier Self- Declaration03.Verify Supplier Documents
• Comply with the Latest Regulations04.Full Material Disclosure (FMD)
• Chemical Composition05.Continuous Monitoring of Controlled Substances
• Conduct Compliance Investigation Annually
Monitor Regulatory Updates and RequirementsFurthermore, WT is actively implementing system-based management. In the future, when creating new product materials, relevant departments will be notified to obtain the necessary material substance lists such as product composition reports and third-party hazardous substance testing reports. This will ensure compliance and improve the efficiency of providing relevant material disclosures.
Inventory for the Management of Regulations Concerning Substances · European Union Restriction of Hazardous Substances Directive (EU RoHS) · European Union Registration, Evaluation, Authorisation and Restriction of Chemicals (EU REACH) · European Union Persistent Organic Pollutants Regulation (EU POPs) · United States Toxic Substances Control Act (TSCA) · California Proposition 65 (Prop 65) · Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (China RoHS) PFASPFAS (Per- and Polyfluoroalkyl Substances) Management
In 2023, the EU introduced a proposal to ban PFAS, a broad class of synthetic chemicals known for their persistence, long-range transport potential, and bioaccumulation risks. These substances pose significant environmental and health hazards, including water pollution.
In industries such as semiconductors, no viable alternatives currently exist, and immediate production cessation is not feasible. Therefore, a transition period of 13-15 years will be implemented upon enforcement of the regulations.
WT continues to investigate PFAS usage in supplier products and discloses this information to customers, aiming to mitigate environmental and health risks.
Carbon Footprint and Net-Zero Emission Goals
In response to global carbon reduction initiatives, WT is dedicated to carbon footprint assessments, aiming to reduce, capture, and reuse greenhouse gas emissions. The long-term goal is to achieve Net Zero Emissions by 2050, transforming carbon reduction efforts into competitive advantages and steadily implementing sustainability initiatives.
The customer requests products with conflict minerals traceability, 100% sourced from qualified smelters
Conflict Minerals Sourcing and Traceability Mechanisms
Referencing international concerns about conflict minerals originating from regions with human rights issues, and in support of universal humanitarian values in supply chain practices, WT published its Conflict Minerals Policy on the company website in 2023. The policy mandates that all major suppliers comply with the U.S. Securities and Exchange Commission’s (SEC) conflict minerals regulation – Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFCMA). Vendors are required to fully disclose the sources of conflict minerals used in their manufacturing processes, including gold (Au), tantalum (Ta), tin (Sn), and tungsten (W) – collectively referred to as 3TG – and indicate whether these materials originate from high-risk mines in the Democratic Republic of the Congo (DRC) and neighboring countries.
To ensure conflict-free sourcing, WT regularly reviews major suppliers’ conflict minerals policies and traces the origins of materials in distributed products. The company actively monitors smelter assessment updates published by the Responsible Minerals Initiative (RMI), and requests vendors to submit the latest Conflict Minerals Reporting Template (CMRT), Extended Minerals Reporting Template (EMRT), or Additional Minerals Reporting Template (AMRT), in alignment with customer requirements.
Conflict Minerals Management Process
01.Conflict Minerals Regulation Management
RMI (Responsible Minerals Initiative)
DFCM (Dodd-Frank Conflict Minerals Act, Dodd-Frank)
OECD(OECD Due Diligence Guidance for Responsible Supply Chains of Minerals)
Conflict Minerals Reporting Template02.Collect Supplier Information
CMRT
EMRT03.Verify Supplier Documents
Comply with Conflict Minerals Regulations04.Regular Review of Public Information
List of Qualified SmeltersAs of the end of 2024, the conflict minerals disclosure status of WT’s 36 key suppliers is as follows:
• 29 suppliers (80.6%) publicly disclosed a commitment to the non-use of conflict minerals.
• 7 suppliers (19.4%) did not publicly disclose such information; however, all of them provided formal declarations demonstrating compliance with the RBA Code of Conduct and related standards.
After WT Tracks And Discloses Relevant InformationROHS100%66.7% Public Disclosure (24/36)33.3% Non-Public Disclosure (12/36)
REACH100%63.9% Public Disclosure (23/36)36.1% Non-Public Disclosure (13/36)
CONFLICT MINERAL POLICY100%80.6% Public Disclosure (29/36)19.4% Non-Public Disclosure (7/36)
Public Disclosure: Disclosed on the supplier’s official website, accessible for viewing and downloading at any time. | Non-Public Disclosure: Request Documents from Supplier.
As a leading semiconductor distributor, WT is committed
WT is committed to waste reduction at the source and pr
