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Ethical Corporate Management

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Communication with independent director

Communication between Independent Directors and Head of Internal Audit

‧ 2026

Communication method: Independent Directors communicate with internal auditors through a meeting without the presence of general directors and the management.

Date of the meeting	Communication with head of internal audit
Date of the meeting	Discussion	Results of the communication
2026.03.10	Assessment of the Effectiveness of Internal Control System for Year 2025	The independent Director agreed to proceed with the recommended improvement actions.

‧ 2025

Date of the meeting	Communication with head of internal audit
Discussion	Results of the communication
2025.11.11	1. Explanation of Recommended Improvement Measures for 2025 2. Key Revisions to Internal Control System in the Current Year 3. 2026 Audit Plan – Quantitative Assessment Explanation	The independent directors have no additional comments
2025.03.11	1. Specific measures to strengthen the external publicity of the company's integrity management policy 2. Use industry news to review the specific measures of the internal control system in real time 3. Supplementary explanation of recent audit report matters	The Independent Directors have no objection.

‧ 2024

Date of the meeting	Communication with head of internal audit
Discussion	Results of the communication
2024.11.11	Major audit matters of the first three quarters	1. Agree to strengthen the relevant internal control operations. 2. The independent directors recommend that internal and external personnel, including clients, be more aware of the company's integrity management policy, so that they can fully understand the company's determination and practices to operate with integrity and the consequences of violating dishonest behaviors.
2024.03.13	Assessment for effectiveness of internal control for 2023	The Independent Directors have no objection.
Draft amendment of internal control standards	The Independent Directors recommend paying attention to the information released by the competent authorities to adapt to the revision of the internal control.

‧ 2023

Date of the meeting	Communication with head of internal audit
Discussion	Results of the communication
2023.03.13	The delivery methods for internal audit report.	The Independent Directors agree to deliver the report by e-Signature Platform.
The effectiveness assessment of internal control systems - The self-evaluation results of each division and subsidiary and follow up on problem solution to suggest.	The Independent Directors have no objection.
2023.12.21	Internal audit plan FY 2023	The Independent Directors have no objection.
Amend internal control systems and part of audit implementation rules	The Independent Directors recommend viewing and strengthening internal control systems for the risk events happened in the industry recently.

‧ 2022

Communication method: Independent Directors communicate with internal auditors through a meeting without the presence of general directors and the management.

Date of the meeting	Communication with head of internal audit
Date of the meeting	Discussion	Results of the communication
2022.03.15	Complete the audio version of the E-Learning textbook in English, which will be extended to overseas locations in the near future; prepare the Operating Instructions regarding Competition Law for Operation & Marketing Colleagues, which will be extended to marketing colleagues at domestic and abroad for reference.	The Independent Directors encourage to continue with the practice. No other suggestions are made by the Independent Directors.
2022.03.15	Stylize the verification report of the average price per ship to speed up the output of the report; analyze the customers whose loading freight per ship in a specific area is lower than the average price within a certain period of time to provide reference for operation and marketing, so as to strengthen customer contribution.	The Independent Directors encourage to continue with the practice and think it would be of considerable benefit to the Company.
2022.12.12	Internal audit plan FY 2023	The Independent Directors have no objection.
2022.12.12	Amend internal control systems and part of audit implementation rules	The Independent Directors recommend referring to SOX risk control matrix to view and intensify internal control systems to risk.

Communication between the Independent Directors and CPAs

‧ 2026

Communication method: Independent Directors communicate with the CPAs through a meeting without the presence of general directors and the management.

Date of the meeting	Communication with CPAs
Date of the meeting	Discussion	Results of the communication
2026.03.10	Ethics and Independence	KPMG maintains strict policies to safeguard its independence in accordance with the IESBA Code of Ethics. When assessing independence, matters that may affect integrity, independence, and objectivity are considered.
	Firm’s Quality Management System	Please refer to the firm’s Transparency Report and the conclusion on the effectiveness of the quality management system.
	Responsibilities of Auditors for Auditing the Financial Statements	The auditor’s responsibility is to conduct the audit in accordance with auditing standards and to form and express an opinion on the financial statements prepared by management under the oversight of those charged with governance. The audit does not relieve management or those charged with governance of their responsibilities for the financial statements.
	Types of Audit Opinions Issued	Standard unqualified opinion audit reports were issued for individual and consolidated financial statements for fiscal years 2025 and 2024.
	Audit Scope	The audit was performed in accordance with regulations governing CPA audits of financial statements and auditing standards, based on materiality determined for the engagement and the use of expert opinions where appropriate.
	Audit findings	Business condition: Individual and consolidated financial statements. Key Audit Matters: Percentage-of-completion revenue recognition and freight revenue based on manifest data showed no irregularities. Accounting Entry Testing: No irregularities were noted in preparers’ entries or revenue-related journal entries.

‧ 2025

Communication method: Independent Directors communicate with the CPAs through a meeting without the presence of general directors and the management.

Date of the meeting	Communication with CPAs
Date of the meeting	Discussion	Results of the communication
2025.12.16	Integrity and Independence.	KPMG enforces rigorous policies to safeguard its independence in accordance with the requirements of the IESBA Code.
	Contingent Matters	The accounts have reflected the best possible estimate, which does not have a material effect on the company
	Audit Scope and Key Audit Matters	Freight revenue is recognized based on the proportion of voyage completion. As the calculation of voyage days involves estimation, this has been identified as one of the key audit matters in the financial statement audit. The primary audit procedures include understanding the method used to estimate voyage days, and performing system sampling and recalculation to assess its reasonableness. 3. Both computer-assisted audit techniques and traditional audit procedures were applied. The computer-assisted audit focused on reviewing the information environment and automated controls within the revenue recognition system.
	The statements of independence to non-assurance services	Disclosure of Non Assurance Services Provided in 2025
	Major Updates to Accounting Standards	Companies with paid-in capital exceeding NT$10 billion are newly required to disclose gender pay information. In 2028, with the adoption of IFRS 18, the structure of the income statement will undergo significant changes.control systems. The company is continuing its assessment, reporting transition, and preparation for assurance.
2025.03.11	Ethics and Independence	KPMG has strict regulations to maintain its independence in compliance with the requirements of the IESBA standards.
	The responsibility of auditors in auditing financial statements.	The accountant's responsibility is to review the financial statements prepared by management under the supervision of the governance unit in accordance with auditing standards, and to form and express an opinion. The audit work cannot relieve the management and governance unit of their responsibility for the financial statements.
	Communication of the firm's quality management system.	KPMG conducts an annual evaluation of its quality management system as of September 30, 2024, and the conclusion of the evaluation is that its quality management system provides reasonable assurance in achieving the objectives of the quality management system.
	The statements of independence to non-assurance services	Explanation of assurance services and non-assurance services, and the non-assurance services provided in 2024.
	Types of audit opinions	Accountants issued standard unqualified opinion audit reports for financial statements in 2024 and 2023.
	Audit coverage	The audit work is performed in accordance with the rules for auditing and attesting financial statements and auditing standards, with relevant audit procedures carried out based on the calculated materiality amounts, and the use of expert opinions when necessary.
	Audit findings	Business condition: Separate and consolidated financial statements Major audit matters: There are no unusual circumstances regarding revenue recognition and collections. Accounting entry testing: There are no unusual circumstances regarding the preparers and revenue entries.

‧ 2024

Communication method: Independent Directors communicate with the CPAs through a meeting without the presence of general directors and the management.

Date of the meeting	Communication with CPAs
Date of the meeting	Discussion	Results of the communication
2024.11.11	Matters after the third quarter review period	Explanation of significant review period events.
	Major audit matters	Revenue Recognition: Freight revenue is recognized based on the completion percentage of the voyage, as determined by the number of days of the voyage. Since the calculation of voyage days involves estimates, it has been included as one of the key audit matters for the financial statement audit. The main audit procedures include understanding the method used to estimate the voyage days and performing system-based sampling and calculations to assess its reasonableness.
	TWSA600	Emphasize two-way communication between the group and its component auditors, and ensure that documents such as instructions to component auditors, responses, meeting minutes, and reviewed working papers are included in the audit working papers. In addition to group auditors performing risk assessment procedures at the group level, individual auditors should also assess whether RMMs exist based on their operational activities and report them to the group auditors.
	The statements of independence to non-assurance services	Descriptions of assurance services and non-assurance services can be provided, as well as non-assurance services provided in 2013.
	IFRS sustainability disclosure standards implementation plan	The competent authority issued amendments in April 2024 to the 'Guidelines for Establishing Internal Control Systems for Public Companies' and the 'Criteria for Evaluating the Effectiveness of Internal Control Systems for Public Companies.' Listed companies are required to incorporate the management of sustainability information into their internal control systems. The company is continuing its assessment, reporting transition, and preparation for assurance.
	Pillar 2 global minimum tax system	Pillar 2 scope of application, safe harbor provisions, and implementation status.
	Expression and disclosure in financial statements under IFRS 18	Explanation of possible changes in the classification of revenues and expenses in the income statement.
2024.03.13	Independence	After evaluation, it is concluded that there are no relationships and other matters between the firm/alliance firms in 2023. It is available to offer explanation of assurance/ non-assurance services and the content of non-assurance services in 2023.
	Major audit matters	Revenue Recognition: Freight revenue is recognized by percentage of completion method, and because freight shipping days refer to estimation, it is down for one of key audit matters to financial statements. Audit procedures include realizing the accounting method of freight shipping days and auditing by systematic sampling in order to evaluate the rationality of each freight shipping days. Impairment Assessment: Because global economic situation and highly competitive shipping market affect the industry, we assess the assets whether they have the indication of impairment. Main audit procedures include realizing the cash generating unit and benchmark that the company adopt to assess impairment of assets, and assess the indication of impairment by each benchmark.
	New rules of cyber security management to Listed/Over-The-Counter Company	Financial Supervisory Commission supervise TWSE and TPEx and promote eight improvement measures for cyber security management from ''Strengthen Supervision'' and ''Assistance&Guidance'' two aspects recently. The related measures and details still study and plan, and will release successively.
	Introduce of International Sustainability Disclosure Standards	Authorities bring in line with''Adoption'' and put the information of ISSB in shareholder annual report. The company should prepare for related evaluation,report transformation and assurrance.

‧ 2023

Communication method: Independent Directors communicate with the CPAs through a meeting without the presence of general directors and the management.

Date of the meeting	Communication with CPAs
Date of the meeting	Discussion	Results of the communication
2023.03.13	Independence	After evaluation, it is concluded that there are no relationships and other matters between the firm/alliance firms in 2022. It is available to offer explanation of assurance/ non-assurance services and the content of non-assurance services in 2022.
	Audit coverage	Key Audit Matters : Freight revenue is recognized by percentage of completion method, and because freight shipping days refer to estimation, it is down for one of key audit matters to financial statements. Executive way and results : Compare the freight shipping days of the system with the actual voyage by systematic sampling。No major abnormality was found in using computer audit and general audit.
	Audit findings	No major abnormality was found in adjusting the company's organizational structure and operation in 2022. The CPAs answer the questions from the Independent Directors, both sides have complete discussion and communication. The Independent Directors have no objection.
2023.12.21	Key audit matters and audit procedures	Revenue Recognition: Freight revenue is recognized by percentage of completion method, and because freight shipping days refer to estimation, it is down for one of key audit matters to financial statements. Audit procedures include realizing the accounting method of freight shipping days and auditing by systematic sampling in order to evaluate the rationality of each freight shipping days. Impairment Assessment: Because global economic situation and highly competitive shipping market affect the industry, we assess the assets whether they have the indication of impairment. Main audit procedures include realizing the cash generating unit and benchmark that the company adopt to assess impairment of assets, and assess the indication of impairment by each benchmark.
2023.12.21	CFC	Definition: 1) Control Elements 2) Low-tax Jurisdiction Exemption Threshold: 1) Substantial Operating Activities 2) The earnings of the CFC are no more than the standards. Subject of Taxation: The enterprise shareholder of CFC; calculate CFC investment income and the tax authority for Profit-seeking Enterprise Income Tax Avoidance of Double Taxation: 1) When actually receiving dividends or earnings, the amount shall not be included in taxable income again. 2)Foreign Tax Credits 3) When disposing of CFC shares, the cost can be increased

‧ 2022

Communication method: Independent Directors communicate with the CPAs through a meeting without the presence of general directors and the management.

Date of the meeting	Communication with CPAs
Date of the meeting	Discussion	Results of the communication
2022.03.15	Independence	Statement of compliance with independence norms by the firm to which the auditors are affiliated, its personnel, and its alliance firms. After evaluation, it is concluded that there are no relationships and other matters between the firm/alliance firms and the Company that may be deemed to influence the independence.
	Responsibility and scope of auditors in auditing financial statements	he responsibility of the accountants is to perform audits on the financial statements prepared by the management under the supervision of the concerned unit in accordance with the Statement of Auditing Standards, and then form and express their opinions thereof. Nevertheless, the audit shall not relieve the management and the concerned unit of their responsibilities for the financial statements. Communicate on key audit matters in the audit report. The Company's financial statements are prepared in accordance with the "Regulations Governing the Preparation of Financial Reports by Securities Issuers, "IFRS, IAS, IFRIC Interpretations, and SIC Interpretations as endorsed and issued by the FSC, whereas the audit is carried out in accordance with Rules Governing Auditing and Certification of Financial Statements by Certified Public Accountants and Generally Accepted Accounting Principles. The accountants shall carry out relevant audit work according to the critical amount determined through calculation and adopt expert opinions.
	Key audit matters (KAMs) and audit findings	No major abnormality was found in the key audit matters (revenue recognition - ratio-of-completion method, increase of fixed assets). Updates on individual profit and loss statements, adjusting profit and loss entries, IFRS16 remeasurement, and litigation cases after the audit.
	Matters of concern to competent authorities	Critical audit matters of financial reports for OTC companies. Evaluation of the impact of COVID-19.
	Conditions for mandatory setting up of an asset security unit	Set up an asset security officer and a dedicated asset security unit. Strengthen the internal audit function
	Updates on important accounting standards or their explanation letters, securities regulation laws, and tax laws and regulations.	Amend the standards for Corporate Governance Supervisor of TWSE/ TPEx listed companies
2022.12.12	Key audit matters and audit procedures	Key Audit Matters: Freight revenue is recognized by percentage of completion method, and audit the rationality of each freight shipping days. Audit Procedures: Auditing the sources of information by systematic sampling and get the accounting method of system data in order to evaluate the rationality of each freight shipping days that management sets .Realize the internal control system of revenue to the Company and execute cycle tests of internal control. Use computer audit and general audit to review at the same time.
2022.12.12	The statements of independence to non-assurance services	The International Ethics Standards Board for Accountants amend the rules of non-assurance service and audit fee, and take effect on the fiscal period since December 15,2022.