Risk management policy and procedure

On April 21, 2018, the Board of Directors approved the Risk Management Policy as the highest guiding principle for the Company’s risk management to ensure the Company’s sound operation and sustainable development, and as the basis for various risk management and implementation of the Group’s headquarters and subsidiaries. The Company’s risk management policy is in accordance with some of the provisions of the Financial Supervision and Administration Commission’s Circular No. 10000621315 dated December 21, 100, amending the “Guidelines for the Establishment of Internal Control Systems by Public Companies”, formulating appropriate risk management policies and procedures, and establishing an effective risk management mechanism to assess and supervise its risk taking capacity, the current status of risks it has tolerated, and the determination of risk response strategies and compliance with risk management procedures.

Every year, at the Group Summit, the directors of each center and the general manager of each subsidiary of the Company conduct risk factor judgment, so as to identify the relevant risks that may affect the sustainable development of the company, screen out the scope of risk management, monitor potential risks and implement preventive measures, in addition to strengthening risk management, and formulate annual operation strategies as the key implementation work for the next year.

At the end of the year, the conclusions of the summit will be submitted to the CEO and the CEO for approval, and then sent to the “Investment Risk Decision Committee” for review before submitting a report to the board of directors.

Risk management scope

The Company’s risk management area analyzes various strengths and weaknesses, as well as opportunities and threats from the external environment, through the four aspects of financial aspects, customer aspects, internal process aspects and learning and growth aspects, and formulates countermeasures in each risk area. The Company’s risk management scope includes “credit risk”, “market risk”, “liquidity risk”, “operational risk”, “supply chain risk”, “financial and accounting risk” (including risks such as high-risk and highly leveraged investment, capital lending to others, endorsement guarantee and derivative commodity trading operations) and “other risks” (including information security risk). The management center and the technical research center undertake, according to the impact of each risk characteristics in each region, each subsidiary formulates countermeasures and carries out the implementation plan.

Organizational structure

The company’s risk management system is organized by the chief executive officer’s office to coordinate the annual operation, through the first stage of analysis and discussion by the directors of the three major centers of the group, and in the second stage, the heads of each subsidiary at or above the vice president level and above discussed with each other according to the characteristics of the region, and then submitted to the group’s risk management and investment decision-making committee before submitting to the board of directors of the group, the organizational chart is as follows:

風險管理組織架構3.jpg

operation status and implementation results in 2025

Since 2018, the Company has held a Group Summit in the fourth quarter of each year, during which senior executives such as the CEO, directors of each center, audit supervisors, and general managers of subsidiaries discuss major risk policies and response strategies for the next year, and report the conclusions to the Board of Directors at the end of the year.

The Company’s risk management project for 2025 was held on September 3-4, 2024 by the directors of the three centers and the audit supervisors of the first phase of the summit to formulate the company’s overall SWOT for 2025, and the second phase of the discussion was held at the subsidiary of Wuxi Sanneng in mainland China from September 26 to 28, where the group’s three center directors, audit supervisors, and vice presidents of each subsidiary discussed risk policies and response strategies. Through the cross-impact analysis of the SWOT internal organization and the external environment, the risk assessment issues are summarized item by item, and the impact is analyzed by analyzing the level of “incidence P” (level 1~3) and “impact degree I” (level 1~3), when the multiplier of the two exceeds 6, it is defined as having a higher risk, so it is necessary to formulate countermeasures and set strategic measurement goals to generate a “risk assessment countermeasure table”. Then, based on the generated “Risk Assessment Countermeasure Table”, the “2025 Key Indicators and Action Plan” is formulated. Finally, it will be confirmed by the CEO and implemented as the basis for the group’s and subsidiaries’ operational strategy and key work plans in 2025. and report to the group’s “Investment Risk Decision-making Committee” meeting before submitting it to the group’s board of directors. and submitted to the Group’s “Investment Risk Decision-Making Committee” on December 25, 2024, and then submitted to the Board of Directors of the Group.

The implementation status of risk management projects in 2025 will be reported on the implementation results of the three centers and subsidiaries on September 4 and 5 in the first phase of this year’s (2025) summit. At the same time, PEST analysis was also used to formulate the company’s overall SWOT for 2026, and the second phase of the discussion was held at the Taiwan Sanneng subsidiary from October 8th to 10th, where the group’s three center directors, audit supervisors, and vice presidents of each subsidiary discussed risk policies and response strategies (1~3 levels), when the multiplier of the two exceeds 6, it is defined as having a higher risk, so it is necessary to formulate countermeasures and set strategic measurement goals to generate a “risk assessment countermeasure table”. Then, based on the generated “Risk Assessment Countermeasure Table”, the “2026 Key Indicators and Action Plan” is formulated. Finally, it will be confirmed by the CEO and implemented as the basis for the group’s and subsidiary’s operating strategy and key work plan in 2026. and submitted to the board of directors of the group after reporting to the meeting of the group’s “Investment Risk Decision-making Committee” on December 23, 2025.

The Company’s statistics for 2023 and 2024 are as follows, and the data boundary is the parent and subsidiary of the Company’s consolidated financial statements:

Unit: t CO2 e/ year

annual Scope 1 Scope 2 Total greenhouse gas emissions
2023
2,284.54
6,619.50
8,904.04
2024
2,616.64
5,479.02
8,095.66

Unit: t CO2 e/ year

annual Category 3 Indirect greenhouse gases from transportation-
3.3 Emissions from employee commuting
2024
0.015

Note 1: The Company has gradually compiled Scope 3-related data since 2024.

Note 2: Covers 3.3 emissions from employee commuting of indirect greenhouse gases generated by Category 3 transportation, and other activities will be gradually arranged to be built and supplemented.

Note 3: The data boundary is the company and Taiwan Sanneng, and the data of other companies and regions will be gradually arranged to be built and supplemented.

Unit: metric tons (t) / year

annual Water Consumption (metric tons)
2023
58,055.03
2024
50,094.00

Unit: metric tons (t) / year

annual Hazardous waste Non-hazardous waste Total weight of waste
2023
20.00
675.72
695.72
2024
19.28
707.56
726.84

Reduction target:

1. Greenhouse gases: Reduce greenhouse gas emissions by 6% in 2027 compared to the base year (FY2022)

2. Water consumption: 2% reduction in water consumption in 2027 compared to the base year (2022)

3. Waste: 2% reduction in total weight of waste in 2027 compared to the base year (FY2022)

Promotion measures:

1. Greenhouse gases:

SANNENG adheres to the core values of “sustainable development” and “environmental friendliness” and is deeply aware of the impact of climate change on the global ecology, society, and economy. Therefore, we are committed to:

(1) Carbon reduction responsibility: Take the initiative to take corporate responsibility for reducing greenhouse gas emissions and actively cooperate with domestic and foreign carbon reduction policies and regulations.

(2) Energy-saving innovation: Combining energy efficiency with innovative technology to promote green processes and smart energy management;

(3) Sustainable management: Incorporate greenhouse gas management into corporate operational decisions, balancing economic growth with environmental protection to achieve long-term value.

To effectively manage greenhouse gases and energy, Saneng has established the following strategies and goals:

(1) Greenhouse gas inventory and disclosure: Establish a comprehensive carbon inventory system and regularly disclose carbon emission information in accordance with ISO 14064.

(2) Carbon reduction path planning: Formulate medium- and long-term carbon reduction goals, adopt measures such as low-carbon technologies, renewable energy use, and process improvement to gradually achieve net-zero emissions;

(3) Energy-saving construction: Implement ISO 50001 energy management system to continuously track energy efficiency and set energy-saving improvement indicators.

(4) Low-carbon transformation of supply chain: Collaborate with suppliers to promote green procurement and low-carbon production, and work together to build a sustainable supply chain.

However, Wuxi Sanneng, an important operating base, has completed the installation of solar power generation in the A/B/D/E/ administrative building in February 2024, generating a total of about 116 kilowatt-hours of electricity, accounting for about 13.96% of Wuxi Sanneng’s electricity consumption, reducing the proportion of purchased electricity. Subsequently, the situation of other companies will be evaluated to strive to increase the proportion of renewable energy used by Saneng.

2. Water Consumption:

In order to improve water efficiency and reduce outsourcing, Wuxi Sanneng, an important operating base, has equipped sewage treatment equipment and water resource reuse equipment to improve the efficiency of water resource utilization.

(1) Update pure water equipment, improve water use efficiency, and reduce tap water consumption.

(2) Water recycling and reuse: Treating wastewater into reusable water resources and reducing the need for tap water.

(3) Promote water conservation: effective conservation of water use through the promotion of water-saving appliances, facilities, technologies and behavioural changes.

3. Waste:

In order to ensure that the waste generated during the company’s operation can be properly disposed of, Wuxi Sanneng has established the Waste Classification, Storage and Removal Management Regulations as the management guidelines for waste disposal, and conducts regular and irregular audits. Waste generation is properly stored and disposed of by qualified treatment plants.

(1) Waste sorting and recycling, promoting recycling and reuse, and reducing the impact of waste on the environment.

(2) Reduce unnecessary packaging and develop recyclable or reusable packaging materials.

(3) Strengthen education and publicity to raise awareness and awareness of waste management and reduction, and promote waste reduction.

Achievement status: Greenhouse gas, water consumption, and waste reduction targets were set for the first time in FY2024, and the achievement status of each year will be reviewed in subsequent years.

In 2021, the Company established a dedicated unit for sustainable development management under the Office of the Chief Executive Officer and reported to the Board of Directors on its implementation at least once a year. In addition, at the annual Group Summit, a number of senior executives from different fields will jointly review the company’s core operating capabilities and formulate a sustainable development plan.

The head of the “Sustainable Development Management” unit and the project leader regularly report to the board of directors on the results of sustainable development implementation and future work plans. A total of 2 meetings will be held in 2025, and the contents of the resolutions include:

(1) Prepare a budget related to sustainable development;
(2) Compile the 2024 “Sustainability Report” and complete the declaration after passing the board of directors;
(3) Organize the planning and implementation of greenhouse gas inventory operations;
(4) Review the solar power generation results of important subsidiaries;
(5) Important subsidiaries apply for and obtain relevant certificates for environmental management systems and occupational health and safety management systems, while continuously optimizing and maintaining the on-site environment, and regularly caring for the physical and mental health of employees;
(6) Plan and organize internal company activities to strengthen the ESG concept of internal employees;
(7) Review whether the product complies with laws and regulations, purchase product liability insurance for the product, and conduct regular customer satisfaction surveys to protect consumer rights;
(8) Important subsidiaries completed the “Supplier Sustainability Management Policy” and completed the strengthening of supply chain management.

The Board of Directors of the Company shall regularly listen to the report of the sustainable development management unit on a quarterly basis, which must propose the Company’s strategy to the Board of Directors and report on the implementation results, and the Board of Directors shall supervise the Company’s implementation results and future sustainable development matters, and the relevant major issues and expenditures shall also be submitted to the Board of Directors for discussion and resolution in accordance with the specifications of the Company’s approval authority.

ESG aspect Type of risk Risk Management Execution Instructions

environment

Environmental protection, energy conservation and carbon reduction

1. In 2022, the Company established an environmental issues project to organize greenhouse gas inventory and verification in accordance with the policy of organizing greenhouse gas inventory and verification in accordance with the “ISO14064 Sustainable Development Roadmap for Listed and OTC Companies” issued by the Financial Supervisory Commission. In 2025, the Group (the parent and subsidiary of the consolidated financial statements) has completed the disclosure of the 2025 sustainability report and the annual report of the shareholders’ meeting and the announcement on the Public Information Observatory based on the Scope 1 and Scope 2 data in the “ISO14064-1:2018” greenhouse gas inventory. In addition, in 2025, the first inventory of employee commuting greenhouse gas emissions in Scope 3 will be conducted and announced on the official website.

2. Wuxi Sanneng, an important subsidiary of the Company, completed the installation of solar power generation in the A/B/D/E/administrative building in February 2024, generating 139 kilowatt-hours of electricity from January to November 2025, accounting for approximately 17.82% of Wuxi Sanneng’s electricity consumption.

3. Wuxi Sanneng, an important subsidiary of the Company, once again passed the annual re-evaluation certification of the “ISO 14001:2015” environmental management system in 2025, and again obtained the “High-tech Enterprise” certificate in Jiangsu Province in 2025, both valid for 2025-2028, representing the company’s recognition in terms of environmental protection. It has also obtained Wuxi City’s specialized and new small and medium-sized enterprises, with a period of 2023-2025.

society

Social welfare

1. In order to strengthen the ESG concept of internal employees, the company organizes and participates in the following activities: beach cleanup, tree planting, mountain cleanup, lake cleanup, blood donation, and other activities. We hope to achieve the goal of internalizing employee ESG concepts through actual participation in activities.

2. After completing the signing of the “Supplier Sustainability Responsibility Commitment” of the top 10 suppliers of its important subsidiaries Taiwan Sanneng and Wuxi Sanneng in FY2024, we will further complete the “Supplier Sustainability Management Policy” of our important subsidiaries Taiwan Sanneng and Wuxi Sanneng in FY2025 to strengthen supply chain management.

Occupational safety

1. The company provides employees with regular annual health check-ups in accordance with regulations, and strengthens hearing protection and various inspection operations for on-site colleagues, and implements them in a way that exceeds 85 decibels, and is committed to creating a healthy and safe working environment.

2. Since 2020, Taiwan Sanneng, an important subsidiary, has started on-site medical and nursing services, formulated a labor health service plan, and handled on-site health services according to the plan.

3. Wuxi Sanneng, an important subsidiary, obtained the “ISO 45001:2018” occupational health and safety management system certification in 2025, with a validity period of 2025-2028, representing the company’s recognition in occupational safety and health.

Product safety

1. At the same time, in order to ensure the customer service hotline and communication website, we regularly conduct customer satisfaction surveys every year to strengthen the cooperative relationship with customers, and become the cornerstone of the sustainable development of the enterprise through a mutually beneficial and prosperous relationship with customers.

2. In order to transfer the risk of commodity liability, improve product safety, protect the rights and interests of consumers, and realize the responsibility of corporate sustainable development, the company has insured product liability insurance for its products.

Company Goverance

Strengthen the functions of directors

1. In order to enable directors to understand the relevant rights, responsibilities and legal responsibilities, annual training is planned for directors every year, and the latest regulations and regulations of the competent authority are provided to directors. In FY2025, all directors and independent directors met the training hours required by the competent authority.

2. Purchase directors’ liability insurance for directors, when the directors have performed their duties as good managers, and protect them from lawsuits or claims.

Stakeholder communication

1. The Company analyzes the situation of important stakeholders and important issues of concern to various stakeholders from the perspective of various stakeholders, including shareholders, employees, customers and suppliers.

2. Establish communication channels with various stakeholders, actively communicate, and set up investor mailboxes and corresponding windows for employees, customers and suppliers, and have specialized personnel responsible for responding. In case of important issues, relevant meetings of stakeholders will be held, and the corresponding units will communicate and coordinate.

3. Report to the Board of Directors annually on the communication with stakeholders.

Employment-employment relations

In accordance with the annual manpower demand plan, the Company recruits outstanding talents through multiple recruitment channels, formulates talent training plans, strengthens talent training, and attaches great importance to the cultivation and retention of talents.

Integrity Management

The Company has set up a dedicated unit to be responsible for the promotion of integrity management, and reports to the Board of Directors at least once a year on the implementation of the integrity management to assist the Board of Directors in evaluating whether the implementation of integrity management is effective. In addition, we have formulated the Code of Ethics and Ethical Conduct, the Code of Ethical Conduct, the Ethical Management Procedures and Conduct Guidelines, the Internal Control System, and the “Measures for the Management of Duties and Agents”, cooperated with audit operations, internal control self-assessment, etc., and provided reporting channels to implement anti-corruption and other measures.

Customer Privacy

The Company strictly abides by the confidentiality of trade secrets, attaches great importance to intellectual property such as trademarks, patents, and copyrights, and formulates the “Intellectual Property Management Measures” to implement and protect the privacy of customers.
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