Status of Implementation

Item Status of Operation Divergence from Corporate Governance Practice Principles for financial holding companies and reasons
1. Shareholding Structure & Shareholders' Rights of Financial Holding Company (the "Company")

(a)Has the Company stipulated internal operation procedures or policies to handle shareholder suggestions, doubts disputes and lawsuits and implemented such procedures or policies?

(b)Has the Company possessed a list of major shareholders and a list of ultimate owners of these major shareholders?

(c)Has the Company established and implemented risk management mechanism and "firewall" between the Company and its affiliated enterprises?
(a)Shareholder suggestions are handled by personnel in charge. Also, the Company's website has an shareholder service area, disclosing relevant contact information for mail or phone contact.

(b)Handled by the Board Secretary. Subsidiary information, handled by the CFO office.

(c)The Company and its major subsidiaries (including bank and securities subsidiaries) each establishes its own independent risk management division to manage its own risks. Credit extension to related parties and any other deals should comply with Articles 32, 33, 33-1~4 of the Banking Law and Articles 44 and 45 of the Financial Holding Companies Act.
No divergence
2. Composition and Responsibilities of the Board of Directors

(a)In addition to Compensation Committee and Audit Committee, has the Company established other functional committee voluntarily?

(b)Has the company evaluated external auditors' independence regularly?
(a)The Company's Compensation Committee and Audit Committee are both composed of three independent directors. Their organization, duties and responsibilities, and operations conform to the Company's "Compensation Committee Organizational Charter" and the "Audit Committee Organizational Charter" respectively.

(b)On yearly basis.
No significant divergence
3. Has the Financial Holding Company establish corporate governance (part-time) unit, or personnel that are responsible for corporate governance matters? The Company's Board Secretary holds main responsibility of corporate governance matters, providing directors any information required for execution of their duties. Per relevant regulations, hold board meetings, audit committee meetings, remuneration meetings, and shareholder meetings, and draft board, audit committee, remuneration committee, and shareholder meeting minutes. No divergence
4. Has the Financial Holding Company established communication channel with stakeholders? Each year, the Company reviews and evaluates all key stakeholder groups, including employees, customers, shareholders (investors), suppliers, media, community groups or NPO and NGOs, and regulators for dedicated communication channels. For example, the Company established a website with a stakeholder area, regularly hold investor conferences, issue press releases, participate in seminars and forums, and work with regulators in policy suggestions, to ensure feedback and stakeholder concerns are considered in SinoPac Holdings and subsidiaries future business development, product design, service channels, and community feedback. SinoPac Holdings hopes to maintain good interaction and engagement with all stakeholders. No divergence
5.Information Disclosure

(a)Has the Financial Holding Company established a corporate website to disclose information regarding the company's financials, business and corporate governance status?

(b)Has the Financial Holding Company established any other information disclosure channels (e.g. maintaining a website in English, designating people to handle information collection and disclosure, appointing spokespersons, webcasting investors' conference, etc.)?
(a)The Company has set up a website to disclose company information including financial updates, business operations and Corporate Governance etc.

(b)The Company has set up both Chinese and English websites and has designated personnel in charge of collecting and disclosing information. The implementation of spokesman system is also well executed.
No divergence
6. Has the Financial Holding Company provided any other material information that may assist in the understanding of corporate governance of the Company. (including but not limited to employee rights, care for colleagues, investor relations stakeholder related rights, board and supervisor training, risk management and risk evaluation standards, execution of customer service and policies, banking participation in liability insurance of directors and supervisors, political and stakeholder and charity donations, etc.) 1. To ensure adherence to corporate governance policies, SinoPac Holdings when received relevant training information, inform directors for participation. In 2016, directors' continued education fulfill the "Directions for the Implementation of Continuing Education for Directors and Supervisors of TWSE Listed and TPEx Listed Companies".

2. The Company holds monthly board meetings. In 2016, attendance rate was an average of 88%.

3. Directors that have stakeholder interests in resolutions are recused from the vote.

4. The Company purchases directors and supervisors' liability insurance for all holding companies and subsidiary directorships.

5. The Company has established risk management procedures as the basic principle for risk management. Each key subsidiary also establish separate risk management procedures in accordance in relevant risk management policies and rules.

6. The Company has established a Call Center Company, with dedicated customer service staff providing free customer service and online customer service, to ensure the most responsive and convenient solutions. We also established subsidiary service units to handle customer complaints at each relevant level and for cross-unit integration, with the aim in achieving excellence in customer service.

7. The Company has established work rules, compensation, and benefits as a basic principle for all subsidiary companies. Each individual subsidiary also has relevant HR policies and rules. To assist in training of employees, the holding company has a dedicated unit with main responsibility for training and career development.

8. To fulfill the spirit of corporate governance, we actively engage with investors in the future vision and strategic plan.

9. Regularly and ad-hoc public disclosures, such as financial statements, material information, investor relations, etc. to assist investors and the market in understanding business operations, financial status, and strategic execution.

10. In investor relations, the Financial Holding Company has established a "Investor Information" area, disclosing in full, all disclosed information, including corporate announcements, press releases, and annual reports. Under the direction of the CFO office, dedicated personnel respond to investor requests.

11. The Company and subsidiaries have feedback mechanisms, providing contact windows to respond to investor complaints and suggestions.

12. The Board of Directors has established "Work Rules" and "Equity Management Policy", prohibiting insider trading. We also establish the "Operating Procedures for Periodic- and Non-periodic Information Disclosure and Material Information Announcement", and disclose such policies and procedures on announcement boards in internal website for perusal by management and employees.

13. The Company and its subsidiaries have not donated to any political parties. Interest parties donated NT$500,000 to the "Eisenhower Fellowships, Taiwan Branch",and NT$3.5 million to the "Yuan T. Lee Foundation Science Education for All". The company donated NT$10 million to help Kaohsiung Meinung earthquake Tainan reconstruction, and also donated $2.5 million to the Taiwan Financial Services Roundtable established special fund, "Financial Industry Charity Scholarship", assisting low-income families in sending their students to school. In addition, it donated NT$137,880,541 to the Small & Medium Business Credit Guarantee Fund.
No divergence
7. The TWSE Corporate Governance Center released its Corporate Governance Evaluation results. Please disclose any improvements done, and plans for future improvements. Improvements:

1. Uploaded shareholder meeting handbook and supplementary meeting information at least 30 days before the 2016 annual shareholders' meeting.

2. The chairman will attend the 2016 annual general meeting.

3. Dividends will be paid out within 30 days after the record date.

4. Upload the English version of the meeting notice, English version of the meeting handbook, and supplementary information at least 30 days before the 2016 annual shareholders' meeting.

Future improvements: Establish rules regarding corporate governance.
No significant divergence