A、Establishment of ethical corporate management policies and programs

1. Does the company have an ethical corporate management policy approved by its Board of Directors, and bylaws and publicly available documents addressing its corporate conduct and ethics policy and measures, and commitment regarding implementation of such policy from the Board of Directors and the top management team?

V

The Company’s Board of Directors approved the establishment of the “Code of Integrity Management,” “Operating Procedures and Behavioral Guidelines for Integrity Management,” and the “Code of Ethical Conduct” on May 9, 2023. These documents clearly stipulate that the Company's directors, managers, employees, or those with substantial control over the company must not directly or indirectly offer, promise, request, or accept any improper benefits, nor engage in other dishonest acts such as illegal activities or violations of fiduciary duties that may harm the company’s interests and reputation. The Company aims to establish and actively implement a corporate culture of integrity management.

The Company's Code of Integrity Management and related policies have been disclosed on the company website and the Market Observation Post System.

No significant deviation.

2. Whether the company has established an assessment mechanism for the risk of unethical conduct; regularly analyzes and evaluates, within a business context, the business activities with a higher risk of unethical conduct; has formulated a program to prevent unethical conduct with a scope no less than the activities prescribed in Article 7, paragraph 2 of the Ethical Corporate Management Best Practice Principles for TWSE/TPE Listed Companies?

V

In accordance with the regulations established by the Board of Directors in the “Code of Ethical Management” and the “Operating Procedures and Behavioral Guidelines for Ethical Management,” the Company has created a risk assessment mechanism for dishonest behavior. The Company regularly analyzes and evaluates business activities within its operational scope that carry a higher risk of dishonest behavior. This includes preventive measures for behaviors outlined in Article 7, Paragraph 2, of the “Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies” and is used to formulate plans to prevent dishonest behavior.

The Company has designated the Finance and Administration Department as the responsible unit to assess and review whether the current rules and regulations effectively reduce the risk of dishonest behavior. The risk assessment for dishonest behavior in 2025 was deemed to be of low risk.

No significant deviation.

3. Does the company clearly set out the operating procedures, behavior guidelines, and punishment and appeal system for violations in the unethical conduct prevention program, implement it, and regularly review and revise the plan?

V

The Company has clearly outlined relevant operating procedures and behavioral guidelines in the “Operating Procedures and Behavioral Guidelines for Ethical Management” to prevent dishonest behavior. Additionally, Article 23 of the “Operating Procedures and Behavioral Guidelines for Ethical Management” and the Company's “Reward and Punishment Management Regulations” establish related disciplinary and grievance mechanisms.

The Company has a zero-tolerance policy for corruption and does not allow any bribery, fraud, abuse of company assets, or actions that sacrifice the Company’s interests for personal gain. To strengthen and implement integrity management, the company has designated the “Finance and Administration Department” as the dedicated unit for integrity management. This unit is responsible for timely establishing or revising various codes and operating procedures related to corporate governance and integrity management, as well as regularly conducting risk assessments and revisions of prevention plans for dishonest behavior. The unit also regularly reports the progress to the Board of Directors.

In 2025, there were zero cases of dishonest behavior discipline or grievance proceedings.

No significant deviation.

B、Ethical Management Practice

1. Does the company assess the ethics records of those it has business relationships with and include ethical conduct related clauses in the business contracts?

V

The Company conducts its business activities in compliance with fair ethics and adheres to relevant laws, regulations, and contractual terms. In addition, the company follows the “Code of Ethical Conduct” and the “Supplier Management Procedures” to assess the integrity records of business partners. Contracts signed with trading counterparts clearly specify integrity behaviors and prohibit any improper business practices such as bribery, corruption, or extortion, ensuring compliance with anti-corruption regulations.

No significant deviation.

2. Has the Company set up a dedicated unit to promote ethical corporate management under the board of directors, and does it regularly (at least once a year) report to the board of directors on its ethical corporate management policy and program to prevent unethical conduct and monitor their implementation?

V

The Company has currently designated the “Finance and Administration Department” as the dedicated unit for promoting corporate integrity management. This unit reports on the implementation of integrity management to the Board of Directors at least once a year. Future adjustments will be made based on the development of the organization.

On November 10, 2025, the implementation status of ethical management has been reported to the Board of Directors.

No significant deviation.

3. Has the company established policies to prevent conflict of interests, provided appropriate communication and complaint channels, and properly implemented such policies?

V

The Company has established conflict-of-interest provisions in both the “Code of Ethical Management” and the “Corporate Governance Best Practice Principles,” requiring directors, managers, and all employees to avoid conflicts of interest. They are prohibited from using their position or influence within the Company to obtain improper benefits for themselves or others.

The Company has also implemented a robust internal control system and operational regulations. All employees receive training based on their job scope to ensure the proper execution of functional duties and prevent internal conflicts of interest. If any violations of integrity regulations are discovered, employees can file complaints or reports through publicly available whistleblowing channels, a fair and impartial investigation mechanism, and a system for individuals to present their statements. This further reduces the likelihood and impact of conflicts of interest.

No significant deviation.

4. Does the company have effective accounting and internal control systems in place to enforce ethical corporate management? Does the internal audit unit follow the results of unethical conduct risk assessments and devise audit plans to audit compliance with the systems to prevent unethical conduct or hire outside accountants to perform the audits?

V

The Company follows the Financial Reporting Standards for Securities Issuers, International Financial Reporting Standards (IFRS), International Accounting Standards, Interpretations, and Announcements (IFRSs) to establish its accounting system and prepare financial reports. The Company has entrusted PricewaterhouseCoopers Taiwan to audit and certify the financial reports.

The Company has established internal control systems related to integrity management, and the internal audit unit formulates audit plans based on the risk assessment results of dishonest behavior. These plans include the audit subjects, scope, items, frequency, and other details. The audit results are compiled into audit reports and submitted to the Audit Committee and the Board of Directors, allowing management to understand the execution of the Company’s internal controls to achieve effective management.

No significant deviation.

5. Does the company provide internal and external ethical corporate management training programs on a regular basis?

V

The Company regularly promotes the importance of integrity management to employees through meetings, training sessions, and occasional awareness campaigns. The content includes ethical standards, confidentiality agreements, rules and regulations, and grievance and whistleblowing mechanisms.

No significant deviation.

C、Implementation of Complaint Procedures

1. Has the company established specific whistle-blowing and reward procedures, set up conveniently accessible whistle-blowing channels, and appointed appropriate personnel specifically responsible for handling complaints received from whistle- blowers?

V

The Company supports a culture of integrity and transparency, encouraging both internal employees and external parties to report any actions that violate laws or the Company's policies through relevant reporting channels, with the option to report anonymously. The “Code of Ethical Management” and the “Operating Procedures and Behavioral Guidelines for Integrity Management” establish a reporting system, detailing specific reporting channels, reward systems, and the responsible handling units as follows:

1. Reporting Channels:

   • Whistleblowing and Complaint Hotline:

     04-24912385

   • Whistleblowing and Complaint Email:

     ir@bonraybio.com

2. Responsible Handling Unit:

The Company has designated the Finance and Administration Department to collect and handle reports, which will be submitted for the General Manager’s approval before closure.

No significant deviation.

2. Has the company established standard operation procedures for investigating the complaints received, follow-up measures taken after investigation, and mechanisms ensuring such complaints are handled in a confidential manner?

V

The Company's “Operating Procedures and Behavioral Guidelines for Integrity Management” establish standard operating procedures for handling reported issues, the follow-up actions to be taken after an investigation is completed, and related confidentiality declarations. All personnel with knowledge of the case details must strictly adhere to confidentiality principles. Any leaks or breaches of confidentiality will result in severe disciplinary action in accordance with the company's disciplinary regulations, to prevent retaliation or improper treatment of the whistleblower.

No significant deviation.

3. Has the Company adopted proper measures to protect whistle- blowers from retaliation for filing complaints?

V

The Company's “Operating Procedures and Behavioral Guidelines for Integrity Management” have established confidentiality mechanisms for the reporting process, prohibiting retaliation or improper treatment of whistleblowers acting in good faith.

No significant deviation.

D、Strengthening Information Disclosure

Does the company disclose its ethical corporate management policies

and the results of their implementation on its website and the Market Observation Post System (MOPS)?

V

The Company has disclosed the “Code of Ethical Management” and its implementation status on the Company’s official website.

No significant deviation.

E、If the Company has adopted its own ethical corporate management best practice principles based on the Ethical Corporate Management Best Practice Principles for TWSE/TPEx Listed Companies, please describe any deviations between the principles and their implementation: No such deviation.

F、Other important information that helps understand the Company's ethical management operations: Ethical management is the core value and foundation of the Company’s operations. The Company’s Board of Directors has approved the establishment of the “Code of Ethical Conduct,” “Ethical Corporate Management Best Practice Principles,” “Procedures for Ethical Management and Guidelines for Conduct,” “Procedures for the Prevention of Insider Trading,” and “Rules Governing Financial and Business Matters Between the Company and its Related Parties” as the guidelines for all directors, employees, and business partners to follow.

Responsibilities of the Ethical Corporate Management Unit:

1. Plan and implement the company’s ethical corporate management policies, and continuously review and revise relevant systems, such as the “Ethical Corporate Management Best Practice Principles", "Procedures for Ethical Management and Guidelines for Conduct,” and the “Codes of Ethical Conduct.”

2. Establish and regularly implement a risk assessment mechanism for unethical conduct to identify potential risks of unethical behavior in operational activities and develop preventive measures.

3. Promote training and awareness campaigns related to ethical management to enhance compliance and ethical awareness among directors, managers, and employees.

4. Establish a whistleblowing and grievance mechanism to handle internal and external reports, and conduct investigations, handle cases, and ensure confidentiality in accordance with regulations.

5. Coordinate with all departments to implement internal control systems related to ethical management, and cooperate with the internal audit unit to review the implementation of these systems.

6. Regularly compile the results of ethical management initiatives and report on their implementation to the Board of Directors at least once a year.

Annual Work Plan of the Ethical Corporate Management Unit:

1. Regularly review and update regulations, systems, and operational procedures related to ethical management.

2. Conduct annual training and awareness programs on ethical management and compliance.

3. Conduct risk assessments for unethical behavior and develop prevention plans.

4. Maintain whistleblowing and grievance channels to ensure the effectiveness of case intake, investigation, and confidentiality mechanisms.

5. Collaborate with internal audit and internal control systems to review the implementation of the ethical management framework.

6. Compile annual implementation outcomes and report to the Board of Directors to strengthen corporate governance and an ethical culture.

The implementation status of the Ethical Corporate Management Unit is as follows:

1. Board of Directors

• Annual regular briefings are provided to all directors on insider trading prevention, ethical management, and ethical conduct.

• In September 2025, all directors (9 in total) were briefed on measures to prevent insider trading, the blackout periods for insider trading, and the legal liabilities for violations of insider trading regulations.

• Directors shall complete the required continuing education hours each year as prescribed by law, with course content including, but not limited to, the prevention of insider trading and corporate governance.

2. Employees

• Upon joining the Company, all new employees shall receive training on the Code of Ethical Conduct and the Ethical Management outlined in their employment contract and shall sign to acknowledge their responsibility.

• During regular meetings, the importance of ethical management shall be emphasized to all employees, including the prohibition of improper banquets, kickbacks, bribes, or hospitality, and the procedures for filing complaints and making reports.

• All employees have a responsibility to report unethical or improper conduct to the Company through appropriate channels. Reporting and complaint channels include: internal suggestion boxes, a dedicated whistleblowing and grievance hotline, and submitting feedback via email or the website.

• The Company's “Procedures for Ethical Management and Guidelines for Conduct” clearly stipulate that employees are protected from unfair retaliation or treatment when reporting misconduct or participating in investigations.

• In 2025, there were zero complaints or reports (including anonymous reports) related to ethical management.

3. Business Partners:

• Prior to establishing a business relationship with distributors, suppliers, or other business partners, the Company must first assess the legality and reasonableness of their business conduct and evaluate whether they have any history of violating ethical management. During business processes, the Company explicitly refuses to directly or indirectly offer, promise, request, or accept any form or type of improper benefit. Once any unethical conduct is discovered, the Company will immediately cease all business dealings.

• The Company's website provides a dedicated hotline and email address for whistleblowing and grievances, allowing business partners to submit reports and complaints, which are handled by designated personnel. Case investigators conduct inquiries in accordance with confidentiality principles to protect whistleblowers and complainants; disclosure of case details to unauthorized personnel is strictly prohibited. When conducting investigations with relevant personnel, discussions are limited to matters directly related to the case to ensure the rights of whistleblowers are safeguarded. In 2025, there were zero related complaints and reports (including anonymous reports).

4. Board of Directors' Oversight Actions

• The Board of Directors has adopted the “Code of Ethical Conduct,” “Code of Ethical Management,” “Procedures for Ethical Management and Guidelines for Conduct,” “Procedures for the Prevention of Insider Trading,” and “Rules Governing Financial and Business Matters Between the Company and its Related Parties” to demonstrate its commitment to upholding ethical management and ethical values.

• The Company's dedicated ethical management unit regularly reports to the Board of Directors and reports immediately upon the discovery of any non-compliance, assisting the Board in understanding the implementation status of the Company's ethical management and the upholding of ethical values.

• The planned reporting to the Board of Directors regarding the implementation of ethical management and ethical values for 2026 is as follows:

  • New hires and all employees have signed provisions related to ethical management and ethical values in their employment contracts.

  • A suggestion box has been placed in the pantry. As of the publication date of the 2025 annual report, there have been zero reports of violations related to ethical management.

  • Disclosure of the implementation status of ethical management and ethical values on the website, in the annual report, and in public statements.

  • Internal control self-assessments for all departments were completed in December 2025, with no significant deficiencies or irregularities identified.

  • A letter promoting the prevention of insider trading was issued to all directors. The actual promotion month was September 2025.

  • An educational and awareness letter on “Ethical Management, Prevention of Insider Trading, and Handling of Material Information” was issued to all employees and managers. The content included: the importance of ethical management; the scope and elements of insider trading; legal liabilities for violations; regulations regarding material internal information; and illustrative examples. The actual promotion months were September and October 2025.