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Code of Ethics and Business Conduct

Ethical management is the top priority of AP Memory.

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Integrity is the most important core value of AP Memory. To implement the Code of Ethics and engage in business activities based on the principles of fairness, honesty, trustworthiness, and transparency, AP Memory’s Board of Directors has formulated the “Codes of Ethical Conduct”, ” Procedures for Ethical Management and Guidelines for Conduct” and “Management Rules on Prevention of Insider Trading”. Assigned Corporate Governance Office as the window responsible for supervision and implementation of ethical management policies and prevention plans. Reporting to the Board of Directors at least once a year on the actual status of operations. (Date of last report: 2024/12/27).


AP Memory advocates the relevant regulations of the Code of Ethics and Business Conduct (the latest conduct date: 2024/11/06). In addition to explaining that all employees must be honest and upright in their words and deeds, personal and company conflicts must be avoided. AP Memory also encourages colleagues to report illegal behaviors through our internal complaint channel.


The Directors of the Board of the Company abide by the rule of conflict-of-interest avoidance. The director with conflict of interest toward any topic will not participate in the discussion and voting to prevent damages or loss of the Company’s interests. Our Corporate Governance Office will remind the Directors and Managers that 15 days / 30 days prior to the announcement of each quarterly financial report / annual financial report that they are prohibited from trading in their stock. 2024 Notices were issued on January 29, April 16, July 8, and October 7, respectively.



AP Memory has zero tolerance for corruption and any form of fraud. Please let us know when you find suspicious behavior or violation of the Code of Ethical Conduct by our employees or any relevant person acting on behalf of AP Memory. Your report will be managed directly by senior executives of the Company. We will respond appropriately to protect your personal data and privacy unless required by law.


Send an email report to the email address:whistleblower@apmemory.com



To ensure efficient investigation, we would like to remind you of the following:

1. Please provide your contact information, including name, phone number, email address and relevant specific information and documents.

2. You must not intentionally fabricate facts knowingly and falsely. If the report proves to be malicious or intentionally fabricated false statements, you shall bear the relevant legal responsibility.


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