Integrity Management
Integrity Management System and Implementation
Shih Wei Navigation upholds the principle of integrity and has established the“Corporate Governance Best Practice Principles”, “Procedures for Ethical Management and Guidelines for Conduct”, and “Codes of Ethical Conduct” to prevent improper behaviors such as bribery, illegal political contributions, inappropriate donations or sponsorships, and offering or accepting unreasonable hospitality. Employees receive regular education, training, and advocacy. Implementation status is disclosed on the Company website, in the Annual Report, and prospectus.
The Administration Department promotes integrity in business in accordance with Board-approved rules, implements anti-fraud measures, formulates programs to prevent dishonest conduct, reduces related risks, advances policy advocacy and training, plans the whistleblowing system, and assists the Board and management in evaluating effectiveness. Report annually to the Board. Most recent report submitted on December 23, 2025. The Board fulfills the duty of a good administrator and has set up the Audit Committee, Remuneration Committee, and Internal Audit mechanisms to ensure integrity policies are implemented.
To prevent fraud, Shih Wei has established robust accounting and internal control systems; audit personnel conduct audits regularly per plan. In 2024, the audit plan completed 70 internal-control audits with 49 audit reports issued; no violations such as fraud, insider trading, anti-competitive conduct, monopoly, or market manipulation were identified, and there were no related lawsuits or penalties. During the reporting period, the fleet made zero calls at countries ranked in the bottom 20 of Transparency International’s Corruption Perceptions Index (CPI).
Anti-corruption
The Company’s “Employee Work Rules” require employees to be honest and clean. If an employee is verified to have engaged in fraud, embezzlement, bribery, or other improper benefits, the labor contract will be terminated to eradicate corruption. These rules are communicated during preemployment training.
Through internal-control self-assessments, self-supervision is implemented. The Headquarters (100%) is covered by audits. As of 2024, no incidents of corruption occurred involving the Company or insiders. The Employee Work Rules and Integrity in Business Code are available on the Company website for employee reference.
Prohibition of Insider Trading
Shih Wei prohibits directors, employees, and other insiders from profiting by trading securities using non-public information. Monthly email reminders are sent to insiders not to trade Company stock during blackout periods being 30 days before the annual financial report announcement and 15 days before each quarterly report announcement.
Annual employee education and advocacy cover definitions, purposes, and elements of material inside information and insider-trading prevention, the subjects involved, abnormal situations, and penalties for violations, reinforcing understanding among all employees and directors.
Education and Training
Shih Wei ensures all colleagues fully understand and follow integrity principles through director continuing education, employee training, and written advocacy. At Board level, all 7 members completed communication on the anti-corruption policy. 5 directors completed anti-corruption training (71.43%). For onshore staff, the HQ has 10 senior managers and 64 employees. 100% completed anti-corruption policy communication. Anti-corruption training completion: 10 senior managers 100%, 57 employees (89.06%).
In 2024, the Company organized/participated in 12 integrity-related sessions: 4 courses for directors (18 person-hours, 6 participants) and 8 courses for employees (242 person-hours, 79 participants). To enhance governance transparency, a whistleblowing mechanism has been established with a mailbox on the Company website. One whistleblowing case was received in 2024. After investigation per procedure, the report was found inconsistent with facts and was properly closed. No violations of integrity management policies occurred during the reporting year.
Information Transparency
In order to promote information transparency and meet corporate governance requirements, we promptly provide information related to significant announcements and disclosures. We have also appointed a spokesperson to enhance the transparency and accuracy of external communications. Additionally, our company website is regularly updated with the latest information.
Whistleblowing System and Whistle-Blower Protection
The “Integrity in Business Code of Conduct, Operating Procedures, and Guidelines” include an independent whistleblowing mailbox, legal@swnav.com.tw, and describe the standard operating procedures for handling reports and confidentiality mechanisms. Employees and external parties may report violations of integrity regulations or improper conduct by letter/email. The Company keeps the identity of the whistleblower and the content of the report confidential, and also implements protection measures for the whistleblower.
The Company ensures confidentiality and protection of whistleblower identity and report contents. Whistleblowers should provide at least:
- Name and ID number (anonymous reporting is also accepted), and contact information (address, phone, email).
- The name of the reported person or other identifying information, and specific facts/evidence for investigation.
For the fleet, contact details for Company designated personnel and department heads are posted in key public areas, including the bridge, engine control room, and mess room area, so that crew can readily make contact. In 2024, the HQ received no whistleblowing cases; the fleet received one case, which was investigated and closed.