Implementation Status

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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) SinoPac Holdings establish Audit Committee and Compensation Committee. Both Committees are composed of the whole three independent directors. The Company also establish Ethical Corporate Management Committee, which is compose of SinoPac Holdings' three independent directors and independent directors from Bank SinoPac and SinoPace Securities. Their organizations, roles and responsibilities, and operations conform the Company's "Compensation Committee Organizational Charter", the "Audit Committee Organizational Charter," and the "Ethical Corporate Management Committee Charter" respectively.

(b) On yearly basis. SinoPac Holdings evaluated external auditors' independence and suitability on yearly basis and the Accounting Division take charge with the evaluation process. The evaluation criteria includes not the Company's related party, not the Company's shareholders, not holding any position within the Company, with no demerits or more severe disciplinary action been recorded, and not engaging the same auditor for 7 years consecutively. The assessment results have submitted to the Audit Committee on March 22, 2018 and to the Board of Directors on March 23, 2018. All auditors meet the our independence and suitability evaluation criteria, and the Company has received the Confirmation of independence from auditors.

No 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. The eight Directors have met requirements specified in the "Directions for the Implementation of Continuing Education for Directors and Supervisors of TWSE Listed and TPEx Listed Companies" in 2017.
2. The Company holds monthly board meetings. In 2017, attendance rate was 92.9%.
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. In order to prevent insider trading, the Company has prohibited directors、managers、insiders and employees to deal with insider trading pursuant to "Work Rules" and "Equity Management Policy". We also announced the above-mentioned rules and policy in internal website for all members to follow and achieve the purpose of banning insider trading.
13. The Company and its subsidiaries have not donated to any political parties and interest parties. The company donated NT $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$127,712,879 to the "Small & Medium Business Credit Guarantee Fund" and NT$1,000,000 to the "Au Ho-nien Cultural Foundation". The subsidiary, SinoPac Life Insurance Agent has continuously participated in a platform of "Risk and Insurance Research Center, College of Commerce, NCCU" for six consecutive years. The total amount of the donation is NTD 0.6 million in total covering 2-year period.
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. Adopted "Guidelines for Corporate Governance", "Guidelines for Codes of Ethical Conduct", "Guidelines for Ethical Corporate Management", and "Guidelines for Corporate Social Responsibility." Established Ethical Management Committee and Sustainable Development Committee.
2. Reinforce the external auditors' independence and suitability assessment.
Future improvements:
1. Adopted "Rules of Evaluation of Board of Directors."
2. Adopted "Rules of Whistle Blowing Program."
3. Dividends are distributed within 30 days of the ex-dividend date.
No significant divergence