Anti-bribery Statement

GigaDevice Semiconductor Inc.

Anti-commercial Bribery Compliance Policy

GigaDevice Semiconductor Inc. (collectively, "GigaDevice" or the "Company") always adheres to the principles of fairness, integrity, and compliance in conducting businesses globally, dedicated to complying with all applicable anti-corruption and anti-bribery laws and regulations in all jurisdictions where GigaDevice does business, and upholding a "zero-tolerance" attitude towards any form of corruption and bribery, in order to regulate the Company's business activities, continuously enhance GigaDevice's competitiveness in the international market, and ensure compliance operations. To provide a long-term and effective guarantee for the Company's compliance development, GigaDevice has formulated this Policy based on actual situations.

This Policy applies to all employees (including all directors, supervisors, managers, ordinary employees, and labor dispatch personnel) and cooperative partners of the Company and its affiliates, subsidiaries, and branches at all levels, requiring them to comply with it and the requirements and guidelines of anti-bribery compliance management in various fields in their business practices, and adhere to high standards of integrity and compliance. Specifically:

GigaDevice requires all employees or entities or individuals who conduct business activities on behalf of GigaDevice to comply with GigaDevice's Administrative Measures for Anti-Commercial Bribery, requirements of anti-bribery compliance management in various fields, and relevant specific guidelines. GigaDevice requires them not to offer, promise, give, solicit or accept any bribery (including, without limitation, cash, commissions, kickbacks, securities, or valuables) directly or indirectly to/from any public officials or other entities and individuals for improperly influencing the legitimate duties or actions of the recipient, obtaining business opportunities or other improper benefits; prohibits them from participating in any reception and entertainment activities organized by organizations having business connections with the Company or their affiliates which may affect the business fairness or result in acquisition of improper benefits; if any suppliers, agents, consultants, and other cooperative partners make the above actions for the same purpose towards GigaDevice's employees, the employees must refuse and report to the Company.

GigaDevice requires all cooperative partners to comply with all applicable anti-corruption and anti-bribery laws and regulations, and will take effective measures to ensure that its cooperative partners and third parties are aware that they are required to adhere to the highest standards of integrity and relevant anti-corruption and anti-bribery compliance requirements in conducting any behavior or business on behalf of GigaDevice.

To ensure the effective implementation of GigaDevice's compliance system, in the aspect of organizational structure, GigaDevice has set up a comprehensive and multi-level anti-commercial bribery management organizational structure, which is led by the Board of Directors, supervised by the Board of Supervisors, managed and supported by the General Manager's Office, and implemented by the Company's Compliance Committee, Anti-commercial Bribery Management Department, Anti-commercial Bribery Supervision Department, and other departments. The Company's business departments, Anti-commercial Bribery Management Department, and Anti-commercial Bribery Supervision Department jointly build three lines of defense for anti-commercial bribery management, jointly identifying, preventing, and responding to any potential commercial bribery compliance risks. GigaDevice will conduct anti-commercial bribery compliance training as compulsory training program for employees. Such training will promote employees’ compliance awareness and help them understand the Company's every anti-commercial bribery compliance requirement.

GigaDevice encourages all employees and cooperative partners to report any suspicious behavior. If you find anyone obtaining personal interests, making unreasonable requests, or other aforementioned behaviors, please report or tip off anonymously to the Company's Internal Audit Department immediately via the following channels. The Company will seriously and thoroughly investigate and deal with any suspicious issues involving corruption, bribery, and unfair competition, and will never allow any behavior that damages the Company's reputation or harms its interests, and will never allow anyone to touch the red line of legal compliance.

Report hot-line: (86) 10 82881666-1166

E-mail: woodpecker@gigadevice.com

GigaDevice Semiconductor Inc.