Supplier Code of Conduct
To build a sustainable and competitive supply chain, the Company comprehensively revised the “Supplier Code of Conduct” and the “General Affairs Supplier Code of Conduct” in 2025, strictly benchmarking against international standards and covering five core dimensions: labor and human rights, health and safety, environmental protection, ethics, and management systems. In addition to requiring suppliers to comply with the laws and regulations of their operating locations, this revision specifically strengthened management mechanisms. Through the supplier conference, net-zero transition and green procurement strategies were communicated to ensure suppliers can effectively identify operational risks and jointly fulfill commitments to environmental and social sustainability.
Rigorous screening to establish long-term partnerships with likeminded suppliers
WT’s goal is to establish long-term partnerships with general affairs suppliers who share common values. Accordingly, at the management level, the Company has established a “Supplier Code of Conduct” for suppliers and requires the signed return of a “Supplier Corporate Social Responsibility (CSR) Commitment Letter” as well as the completion of an online “Supplier Self-Assessment Form.” The procurement unit analyzes the self-assessment forms to identify potential risks across dimensions including human rights, labor practices, consumer rights, business integrity, environmental protection, and occupational health and safety, and plans initiatives accordingly to enhance general affairs suppliers’ sustainability awareness and prevent significant deficiencies or regulatory violations.
In 2025, WT Group’s target overall signing rate for general affairs suppliers was 56%. The number of new general affairs suppliers assessed against environmental and social criteria in 2025 was 98, all of which signed the “Supplier CSR Commitment Letter.” Going forward, the Company will continue to integrate global general affairs suppliers into a unified management system, strengthening commitments and oversight on environmental, labor, and human rights issues to ensure the supply chain complies with the Group’s responsible procurement policy.
To maintain procurement quality, annual assessments are conducted for general affairs suppliers with annual transaction amounts reaching NTD 1 million or transaction frequency of 12 times or more. Assessment items include supplier delivery quality, on-time delivery, service capability, ESG implementation, environmental protection, and occupational safety and health. Assessment results are classified into four grades — A, B, C, and D — as shown in the table below, with deficiency tracking and improvement measures implemented for suppliers rated C and D.
General Affairs Supplier Evaluation Count128
115
176
2023
2024
2025Grade A Supplier Percentage79.7
80.0
73.9
2023
2024
2025General Affairs Supplier Evaluation Score84.07
84.80
82.71
2023
20242025In 2024, four suppliers received a C-grade assessment result. Following evaluation, replacement suppliers were introduced and all transitions were completed to ensure supply stability and procurement quality. In 2025, the assessment scope was further expanded from Taiwan and China (including Hong Kong) to the South Asia region, covering a total of 176 suppliers. The qualified rate (Class C or above) reached 100%, with Class A suppliers accounting for 73.9%. Three suppliers received a C-grade assessment result; guidance and improvement assistance were provided while alternative suppliers were also sought to enhance supply chain resilience and maintain supply levels and quality standards. The Group-wide target supplier assessment participation rate was 56%. The relevant assessment standards will be progressively extended to other overseas operating sites to strengthen supply chain management and the foundation for sustainable operations.
Supplier evaluation overview
Grade Number of Suppliers Subsequent Management Measures A (Above 80) 130 Priority procurement B (70～79) 43 Maintain normal C (60～69) 3 Reduced procurement. Procurement unit notifies suppliers of evaluation results; suppliers make improvements based on evaluation results. If alternative suppliers are available, procurement unit should reduce purchasing as appropriate. D (Below 59) 0 Suppliers should provide written improvement strategies with a deadline for improvement. If requirements still cannot be met after review according to “Supplier Audit Improvement Notice”, qualified supplier status may be canceled.
General affairs supplier human rights due diligence
To fulfill the Company’s human rights management responsibility across the supply chain and jointly uphold corporate social responsibility with suppliers, WT has established the “WT Supplier Management Guidelines,” creating a human rights due diligence mechanism with tiered management based on risk and transaction scale. The implementation mechanism is described as follows:
• Identification and Assessment: Human rights risks are identified through the Online Supplier Self-Assessment Form and the Supplier CSR Commitment Letter. Based on the assessment, the human rights issues with the greatest impact on the supplier side are, in order: (1) health and safety; and (2) wages and working hours.
• Termination and Prevention: New suppliers are required to sign the “Supplier CSR Commitment Letter,” committing to compliance with local labor regulations (including maximum working hour limits, overtime pay calculations, and occupational safety and health requirements). Suppliers that are unable to sign and return the commitment letter will not be engaged in transactions. For suppliers whose self-assessment form responses show anomalies, the Company will proactively follow up and request improvements; failure to improve may result in termination of the business relationship
• Monitoring：Suppliers meeting the annual assessment threshold (annual transaction amount of NTD 1 million or more, or annual transaction frequency of 12 times or more) are monitored through annual assessments to verify compliance with labor, human rights, and occupational safety and health regulations. The assessment also evaluates whether there are any records of labor-related regulatory violations during the assessment period. Suppliers found to have violated the Labor Standards Act, Trade Union Act, Minimum Wage Act, Act of Gender Equality in Employment, Occupational Safety and Health Act, or other relevant regulations are designated for subsequent follow-up and guidance. For suppliers not meeting the assessment threshold, the CSR Commitment Letter and Self-Assessment Form serve as the basic management basis.
• Communication: The Group has established a grievance channel on its official website, available to suppliers and other stakeholders for reporting unlawful conduct.
Regarding the high-risk human rights issues identified above, the Company’s mitigation and remediation measures for suppliers are as follows:
High-Risk Issue Remediation Measures Risk Mitigation Health and Safety Upon the occurrence of an occupational safety incident, the response mechanism is activated in accordance with the incident reporting process, requiring the responsible contractor to undertake compensation measures including group insurance, occupational disaster insurance, labor pension claims, and insurancerelated settlements.
- Supplier annual assessments incorporate “occupational safety and health” and “environmental hygiene” indicators to regularly review compliance and implementation.
- Engineering contractors are required to sign a Safety and Health Commitment Letter before commencing construction to ensure construction safety management.
Wages and Working Hours If a supplier has not established an effective working hour management system, the supplier is required to improve its scheduling system in accordance with the Code of Conduct and submit an improvement plan within a specified timeframe.
- Supplier compliance with local labor regulations is verified through the Supplier Self-Assessment Form and annual assessments.
- New suppliers sign the CSR Commitment Letter, committing to compliance with working hour limits and legally compliant overtime pay calculations.
Regarding the monitoring of due diligence implementation, the Company conducts annual reviews of the effectiveness of mitigation and remediation measures and has established grievance mechanisms and channels for suppliers and other stakeholders to report unlawful or human rights-violating conduct. In 2025, all key general affairs suppliers that underwent assessment were found to be in compliance with relevant laws and regulations, with no regulatory violations identified.
Deepening the supplier management system and implementing green procurement and ESG sustainability governance
To deepen supply chain sustainability transformation, the Company convened a general affairs supplier conference in 2025, focusing on supply chain resilience amid the global net-zero trend. The conference communicated the Group’s ESG practices and implementation strategies and clearly declared the intent to introduce internal carbon pricing to further promote green procurement initiatives, thereby encouraging suppliers to develop materials and equipment with lower carbon footprints. The annual supplier assessment mechanism was also explained at the conference, emphasizing that assessment priorities would focus on environmental protection, labor and human rights, occupational safety and health regulatory compliance, and business integrity. Assessment results will directly influence the Group’s procurement strategy (e.g., Class A suppliers enjoy priority procurement rights). Through concrete oversight mechanisms, the aim is to drive competitiveness improvements across the upstream and downstream supply chain. The supplier conference will continue to be held annually going forward, with plans to expand to other overseas locations, maximizing the benefits of sustainability from the top down.
Continuous monitoring of Environmental and Social management by suppliers
WT is committed to promoting sustainable supply chain development and continuously monitors vendors’ management of environmental protection, social responsibility, and corporate governance. In 2025, WT established business relationships with more than 400 vendors, based on revenue contribution and business significance, identified 36 key vendors accounting for over 80% of total revenue. In 2025, there were no incidents of non-compliance with health and safety regulations related to products and services.
WT continuously tracks vendors’ environmental and social management through business interactions and reviewing their publicly disclosed sustainability reports, product compliance documents, and related policy information, incorporating such information as reference for vendor risk assessment and supply chain management. In 2025, WT completed a review of publicly disclosed information for all 36 key vendors, achieving 100% coverage, strengthening supply chain management and reducing potential risks.
WT continuously monitors vendors’ publicly disclosed policies on product environmental compliance, chemical management, labor rights, and conflict minerals, and provides related information and documents in accordance with customer requirements to assist customers in confirming that products meet regulatory requirements in various countries.
WT also continuously collects and reviews vendors’ publicly disclosed information on environmental management and social responsibility, incorporating it as reference for supply chain management to strengthen supply chain information transparency.
Supplier Environmental Management and International Standard Certifications
WT continuously reviews the publicly disclosed environmental and quality management information of key vendors to understand their operational management. Key vendors have generally adopted international standards management system to strengthen quality management and reduce the environmental impact of their operations. As of the end of 2025, key vendors have achieved the following certifications.
Certification Type Key Suppliers Certified Suppliers Percentage (%) ISO 9001 Quality Management System 36 36 100.00% ISO 14001 Environmental Management System 36 32 88.89% ISO 45001 Occupational Health and Safety Management 36 27 75.00% Employee Rights and Labor Protection
WT continuously monitors vendors’ publicly disclosed human rights policies and labor management information to understand their management of labor rights protection and occupational safety, including:
- Respect for employees’ rights to freedom of association and collective bargaining
- Prohibition of forced labor and child labor
- Prevention of discrimination and ensuring a fair working environment
Responsible Business Alliance (RBA) Code of Conduct
WT supports the principles of the Responsible Business Alliance (RBA) and continuously monitors the RBA-related information publicly disclosed by key vendors.
Indicator Key Suppliers Established RBA Guidelines Percentage (%) RBA Membership 36 29 80.5% As of the end of 2025, among the 36 key vendors, 29 are official RBA members, representing 80.5%.WT continuously tracks vendors’ commitments to labor rights, occupational safety, and environmental management through reviewing their publicly disclosed information, to strengthen supply chain management.
Vendor Risk Assessment and Due Diligence Mechanism
To strengthen sustainable supply chain management, in 2025 WT identified 36 key vendors (accounting for over 80% of revenue) based on revenue contribution and business significance and conducted systematic consolidation and risk assessment of their publicly disclosed sustainability and compliance information. Considering WT’s role in the supply chain as a distributor, without direct involvement in vendors’ manufacturing or upstream operations, WT’s assessment approach is based on publicly available information, including official websites, sustainability/ESG reports, policy statements, and relevant compliance documents. The following aspects were organized and analyzed:
- Status of sustainability information disclosure
- Social responsibility and human rights commitments
- Environmental management, occupational health and safety management, and greenhouse gas disclosure (e.g., ISO 14001, ISO 45001, ISO 14064, or GHG Protocol)
- Conflict minerals policies and responsible sourcing mechanisms
Based on the completeness and consistency of publicly disclosed information, an internal risk classification (low risk / medium risk / relatively higher risk) was performed as reference for sustainable supply chain management and follow-up tracking. The 2025 assessment results show that key vendors achieved 100% coverage for major sustainability disclosure items, with an overall assessment result of low risk, based on internal judgment of the completeness of publicly disclosed information.
No. of Vendors
(No.)Sustainability Disclosure
(No./%)Human Rights Disclosure
(No. / %)Environmental Disclosure
(No. / %)Responsible Sourcing
(No. / %)Low Risk
(No. / %)Medium Risk
(No. / %)High Risk
(No. / %)36 36 / 100% 36 / 100% 36 / 100% 36 / 100% 36 / 100% 0 / 0% 0 / 0% Conflict Minerals Sourcing and Traceability Mechanisms
3TG minerals are essential to product innovation and functionality in the semiconductor industry. Gold (Au) is used in circuit boards and connectors, ensuring excellent conductivity and corrosion resistance; tantalum (Ta) is used in capacitors to stabilize power storage; tin (Sn) is used in circuit board soldering; and tungsten (W) is used in vibration motors and counterweights. To implement responsible mineral management, WT conducts conflict minerals due diligence based on the management principles of the Responsible Minerals Initiative (RMI). The due diligence covers:
- Whether a conflict minerals policy is publicly disclosed
- Whether the scope of 3TG minerals (gold, tantalum, tin, tungsten) and EMRT-tracked minerals (cobalt, mica, copper, nickel) are disclosed
- Whether standardized reporting tools (CMRT / EMRT) are provided
- How the smelter list is obtained and cross-referenced with RMI publicly available data
The number of smelters is counted using the RMI Smelter ID (CID) as the identification basis, distinguishing between RMI Conformant (publicly verifiable) and categories where status has not been publicly confirmed, to ensure consistency and traceability of supply chain information.
No. of Vendors
(No.)Responsible Sourcing
(No./%)3TG Mineral Disclosure
(No./%)CMRT V6.5 / EMRT V2.1 Disclosure
(No./%)Smelter Disclosure
(No./%)RBA Participation
(No./%)36 36 / 100% 36 / 100% 36 / 100% 36 / 100% 29 / 81% As of the end of 2025, results for 36 key vendors: 100% use no smelters associated with conflict minerals. WT will continue to update and track relevant information in accordance with customer requirements or annual management plans to ensure supply chain compliance and transparency.
Conflict Minerals Management Process
Compliance of agency products with global substance regulations
Chemical Management and Product ComplianceWT focuses on product hazardous substance management and environmental compliance. WT continuously monitors international chemical management regulatory trends and tracks the compliance of distributed products compliance environmental regulations in various countries through reviewing vendors’ publicly disclosed product compliance documents and related declarations.
WT continuously collects and reviews key vendors’ publicly disclosed chemical management policies and product compliance information, including the EU Restriction of Hazardous Substances Directive (RoHS) and the EU Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulations, and provides relevant compliance documentation in accordance with customer requirements to assist customers in confirming that product materials meet environmental regulatory requirements.
Chemical Safety Management Process
As of the end of 2025:
EU RoHS (Restriction of Hazardous Substances Directive): Among the 36 key vendors, 26 have publicly disclosed compliance (72.22%); 10 have not publicly disclosed but can provide relevant declaration documents (27.78%).
REACH (Registration, Evaluation, Authorization and Restriction of Chemicals): Among the 36 key vendors, 25 have publicly disclosed compliance (69.44%); 11 have not publicly disclosed but can provide relevant declaration documents (30.56%).
Regulation Key suppliers Publicly Disclosed Compliance Disclosure Rate (%) Non-Disclosed (Available on Request) NonDisclosure Rate (%) EU RoHS 36 26 72.22% 10 27.78% REACH 36 25 69.44% 11 30.56% All key vendors are able to provide relevant declaration documents to confirm that their products comply with international environmental regulatory requirements.Through continuously collecting and reviewing vendors’ publicly disclosed product compliance documents and declarations, and providing compliance information in accordance with customer requirements, WT continuously improves its product compliance information management capabilities and supply chain transparency.
PFAS (Per- and Polyfluoroalkyl Substances) Management: WT continuously monitors international regulatory developments related to PFAS (Per- and Polyfluoroalkyl Substances), with particular attention to the EU REACH proposal, US TSCA, and the Stockholm Convention’s timetable for PFAS restrictions.Considering that PFAS remains technically necessary in the electronics industry and alternatives are not yet mature, WT’s current management focus is on risk awareness and the scope of products potentially involving PFAS through reviewing vendors’ publicly disclosed information and related documents.Going forward, WT will progressively strengthen information collection and supply chain management mechanisms in line with regulatory trends and customer requirements, to support subsequent risk control and substitution assessments.Carbon Footprint and Net-Zero Emission Goals: WT continuously monitors vendors’ publicly disclosed carbon emissions and environmental management information, and tracks industry trends in net-zero emissions development.
As logistics operations is its most important operation
Environment-oriented improvement timeline 201