Implementation of Awareness Education and Training for Prevention of Insider Trading

CHT has formulated the Control Guidelines for Prevention of Insider Trading, which prohibits insiders such as company directors, managers or other internal employees from using undisclosed information in the market to buy and sell securities to make profit. In addition, to establish a sound mechanism for material information processing and disclosure, avoid improper information leakage and ensure the timeliness, consistency and accuracy of CHT's information announced externally, CHT has established the Material Information Processing Procedures for compliance. Relevant measures are as follows:

1. Directors:
   CHT regularly holds insider trading prevention task force meetings every year. In 2023, the meeting minutes and awareness training information (identification process of insider trading prevention, trading examples, etc.) were delivered a total of 26 times to all directors on July 24th and December 21st, as to achieve the goal of preventing insider trading through education and promotion. Directors and managers are also regularly notified by letter that it is forbidden to trade their shares during the closed period of 30 days before the publication of the annual financial statements and 15 days before the publication of the quarterly financial statements. Furthermore, when new directors take office, the Control Guidelines for Prevention of Insider Trading are delivered by CHT for them to peruse, understand and abide by. They are also asked to sign a declaration agreeing to comply with all the regulations, fulfill their responsibilities as directors and avoid violations or insider trading.


2. Managers:
   Twice a year, CHT conducts education and training on laws and regulations related to insider trading prevention for incumbent managers using digital teaching materials. Incumbent managers must read the digital teaching materials on " Insider trading and Short-swing trading prevention awareness and penalties" and take a test on such materials. The course topics include confidentiality of material information, prohibition of short-swing and insider trading, causes, identification process and examples of short-swing and insider trading, scope of material internal information, confidentiality operations, disclosure operations and handling of violations. In 2023, CHT conducted 2 hours of legal awareness courses and training for 196 incumbent managers by June 16th and December 7th. In addition, the new managers of CHT are required to complete the “Insider trading and Short-swing trading prevention awareness and penalties" education and training program via CHT’s digital learning platform and must pass the associated test before taking office.


3. All employees:
   Every year, CHT regularly shares insider trading prevention examples with employees through official documents or the Announcement website to effectively raise awareness on insider trading prevention and implement relevant education and training. From October 2nd to October 31st, 2023, CHT's digital teaching materials were used to conduct one-hour awareness training for 19,839 employees and implement the annual Code of Conduct Comprehensive Test. The topics of the course included the confidentiality operations for material information to prevent insider trading, the causes of insider trading and the handling of violations. For new employees, the above-mentioned awareness education and training are arranged by the Organization and Talent Development Department during the new employee orientation.


4. After the relevant courses are over, the presentations and audio-visual files are saved in the internal e-Learning system for reference of those who did not attend that day. The responsible unit regularly tracks and inspects the test results of managers and all employees, actively implements the prevention of insider trading, fosters integrity, honesty and moral values, strengthens corporate governance and risk control and builds a corporate culture of rectitude to improve the entire business operations.