Ethical Corporate Management

Based on the core value of “integrity,” Diamond Biofund, with the approval of the Board of Directors, has established internal regulations such as the “Ethical Management Code,” “Ethical Management Operating Procedures and Behavioral Guidelines,” and the “Code of Ethical Conduct.” These regulations require the Board of Directors, management, and all employees to adhere to and implement ethical practices. To ensure the implementation of ethical management, the Company has established an effective accounting system and internal control system. Internal audit personnel regularly audit compliance with these practices and report to the Board of Directors. The Human Resources unit under the Administration Department is responsible for promoting ethical management. This includes revising the Ethical Management Operating Procedures and Behavioral Guidelines, conducting ethical management education and training, and promoting ethical management practices. The implementation of ethical management is reported annually to the Board of Directors. On April 17, 2023, a report on the implementation of ethical management for 2022 was presented to the Board, and the implementation for 2023 was reported on February 29, 2024. In 2023, there were no incidents of corruption, bribery, or other violations of ethical management.

1. The company regularly organizes training on integrity management and promotes it through email.
   • In 2025, the company assisted in arranging for board of directors and managers to participate in courses related to corporate governance and integrity management, including at least 7 hours of training on topics such as “2025 Insider Trading Prevention Seminar,” “Treating Customers Fairly: From Regulatory Requirements to Governance Practices,” “Financial Inclusiveness and Protection of Vulnerable Groups: Issues of Inclusive Governance,” “The Financial Inclusion Laundering Act from the Perspective of Judicial Practice,” “Seeing Is Not Always Believing – Virtual Assets and Real-World Money Laundering,” “Risks and Information Security Issues in the AI Era,” and “Legal Liabilities for Greenwashing in Sustainability Reports.”
   • Upon new employees’ orientation, a 1-hour training on the Code of Integrity Management is conducted. This training is part of the onboarding process to implement and communicate the company’s integrity management policies, ensuring that employees understand the company’s integrity management policies and their guidelines and standards.
   • Integrity Management Policy training is held annually. With all employees as the trainees, in December 2025 the courses “Protection of Trade Secrets and Case Analysis of Legal Liabilities” and “Insider Trading Prevention” were conducted, with a combined total duration of three hours and 22 participants (91.7%) attending each course. In addition, the course “Intellectual Property Concepts and Protection of Trade Secrets” was conducted for three hours, with 20 participants (87%) in attendance. The courses used case studies to reinforce the concept of integrity management, as well as to manage and prevent unethical behavior. Employees are also reminded of their confidentiality obligations regarding the company’s intellectual property. To ensure compliance with legal regulations, all employees are required to take an exam, with a passing score of 80 or above.
2. The company’s “Performance Management Guidelines” and performance evaluation system include integrity and honesty as one of the evaluation criteria for employee value development. Employees are required to strictly adhere to the “Code of Ethical Conduct” and all relevant regulations regarding the company’s commitment to ethical business practices. (Example of an Employee Performance Evaluation Form)

3. According to the company’s “Employee Rewards and Disciplinary Policy”, violations of the “Code of Ethical Conduct”, “Ethical Corporate Management Best Practice Principles”, or “Business Integrity Procedures and Behavioral Guidelines” will be reported and handled as breaches of workplace order or rules, in accordance with Article 5.4 of the “Employee Rewards and Disciplinary Policy”. The results of such disciplinary actions will also impact the employee’s annual performance evaluation (Article 5.8 of the “Employee Rewards and Disciplinary Policy”) and subsequent salary adjustments.

Diamond Biofund has established the “Significant Information Processing and Insider Trading Prevention Operating Procedures,” clearly defining the applicable scope, target groups, and related procedures. This is to prevent the company’s directors, managers, and other insiders from unintentionally or intentionally violating insider trading regulations due to unfamiliarity with the law, thereby protecting investors and safeguarding the company’s interests.

Each January, the Company notifies directors of the dates for regular board meetings and reminds them not to trade company stock during the closed period, which is 15 days before the quarterly financial report announcement and 30 days before the annual financial report announcement. In addition, the Company conducted an internal training session on the prevention of insider trading for all employees on December 5, 2025. The training totaled three hours, with 22 attendances, aiming to strengthen compliance awareness and ensure adherence to relevant regulations.

Diamond Biofund has established a “Whistleblowing Policy,” set up and publicized a whistleblowing mailbox, and implemented a whistleblower protection system. The receiving unit is independent and ensures that whistleblower files are encrypted for protection. The company provides channels for internal and external personnel to report illegal acts, violations of the Code of Ethical Conduct, or breaches of the Ethical Management Code. If company employees or external personnel discover illegal activities, violations of company policies, systems, or the Code of Ethical Conduct, or actions that harm the company’s interests, such as fraud, embezzlement of company assets, leaking company secrets, or receiving improper benefits, they can report these incidents, on a named or anonymous basis, via mail or email:

• Mail : Whistleblowing Mailbox, 35th Floor, No. 66, Section 1, Zhongxiao West Road, Zhongzheng District, Taipei City 100, Taiwan.
• Email : Audit@diamondbiofund.com

The company will conduct an investigation based on the “Whistleblowing Policy” and is committed to protecting whistleblowers. The company ensures that whistleblowers will not face dismissal, demotion, salary reduction, damage to legally or contractually entitled rights, or any other adverse treatment due to their whistleblowing. Additionally, the company is responsible for keeping the whistleblower’s identity, the content of the whistleblowing, and the investigation process confidential, and will not disclose any information that could identify the whistleblower.

Diamond Biofund has internally established the “Ethical Management Code” and the “Ethical Management Operating Procedures and Behavioral Guidelines,” which are publicly disclosed on the company website. Specific regulations are outlined as follows:

• Prohibition of Illegal Political Donations (Ethical Management Code, Article 10; Ethical Management Operating Procedures and Behavioral Guidelines, Article 9) Directors, managers, employees, appointees, and actual controllers of the company are prohibited from directly or indirectly providing donations to political parties or individuals involved in political activities unless such donations comply with the Political Donations Act and the company’s internal procedures. Donations must not be made to gain business advantages or preferential treatment.
• Prohibition of Bribery and Acceptance of Bribes (Ethical Management Code, Article 9; Ethical Management Operating Procedures and Behavioral Guidelines, Articles 3 and 4) The company, its directors, managers, employees, appointees, and actual controllers are prohibited from directly or indirectly offering, promising, demanding, or receiving any form of improper benefits during business dealings with customers, agents, contractors, suppliers, public officials, or other stakeholders.
• Company personnel are prohibited from offering or providing improper benefits, such as money, gifts, commissions, positions, services, favors, kickbacks, facilitation payments, hospitality, entertainment, or other valuable items, to public officials, political candidates, political parties, or party officials in order to gain or maintain benefits.

1. Commitment to Privacy Protection
   Diamond Biofund highly value privacy and are committed to ensuring the proper protection of personal data. The privacy policy is formulated by the Administration Department of the company and is implemented and reviewed for continuous improvement. Internal audits of privacy protection are conducted by the Audit Office.
2. Scope of the Privacy Policy
   The privacy policy of Diamond Biofund can be found here (privacy policy). This policy applies to the following individuals and entities:
   • Visitors to the company’s website (https://www.diamondbiofund.com/en/)
   • Stakeholders involved in our venture capital operations and services,
   • Employees of the company’s suppliers and contractors,
   • Job applicants to the company, and
   • Visitors to the company
   The company complies with the “Personal Data Protection Act” and other relevant regulations, using them as the basis for formulating its privacy policy.
3. Integration with Risk Management
   Privacy and personal data protection are incorporated as one of the factors of the company’s risk management assessments. The company conducts annual risk assessments and irregular internal audits on privacy and personal data protection to ensure compliance with its privacy policy and relevant legal requirements.
4. Zero Tolerance Policy Against Violations
   The company adopts a zero-tolerance policy towards violations of privacy and personal data protection. If any violations of the company’s privacy policy or related laws are discovered, the company will review and improve management measures and discipline the personnel involved in accordance with the “Employee Rewards and Disciplinary Policy”.
5. Contact Information
   For any questions, comments, or suggestions regarding Diamond Biofund’s privacy policy, please contact us via the following:
   • Address: 34F., No. 66, Sec. 1, Zhongxiao W. Rd., Zhongzheng Dist., Taipei City 100
   • Email: privacy@diamondbiofund.com