Brogent Technologies Inc.
Operating Procedures for Prevention of Insider Trading
Article 1.

PurposeThe Operating Procedures are established to prevent the Company or its internal personnel fromunintentionally or intentionally violating related regulations on insider trading that may lead tolitigation or damage the reputation of the Company or its internal personnel. The Operating
Procedures are also adopted to prevent insider trading and protect the interests of investors and theCompany.
Article 2.

Applicable Scope

The regulations specified in these Operating Procedures shall be applicable to the Company’s
management procedures with regard to the prevention of insider trading except where otherwise
stipulated by the law.
Article 3.

DutiesI. The Finance Department of the Company shall be responsible for the formulation andmaintenance of the Operating Procedures.
II. The Company's spokesperson or acting spokesperson shall be responsible for announcing
critical company information to external parties.
Article 4.

Content of Operations

I. Definition of insider trading:According to the regulations stipulated in Article 157-1, Paragraph 1 of the Securities and ExchangeAct, upon actually acquiring knowledge of any information that has material impact on the shareprice of the Company, individuals subject to these Procedures on insider trading shall not, prior to
the public disclosure of such information or within 12 hours after its public disclosure, purchase or
sell any shares or equity-type securities of the Company listed on an exchanges or traded bysecurities firms. Violation of such regulation shall constitute insider trading.
II. Individuals subject to insider trading regulations:
The following individuals of the Company are prohibited from engaging in insider trading under theapplicable scope provided in Article 157-1, Paragraph 1 of the Securities and Exchange Act:
1. The Company's Directors, Supervisors, managerial officers, and natural persons assigned
to represent the Company and exercise duties in accordance with Article 27, Paragraph 1of the Company Act (according to Article 27, Paragraph 1 of the Company Act, where agovernment agency or a juristic person acts as a shareholder of a company, it may beelected as a director or supervisor of the company provided that it shall designate anatural person as its proxy to exercise, in its behalf, the duties of a shareholder).
2. Shareholders holding more than ten percent of Company shares.
3. Persons who acquire knowledge of the information by reason of occupational orcontrolling relationship.
4. Persons who, though no longer among those listed in the preceding three subparagraphs,
have only lost such status within the last six months.
5. Persons who acquire knowledge of the information from any of the persons specified in
the preceding four subparagraphs.
6. The Company's Directors, Supervisors, managerial officers and shareholders who hold1

more than 10% of Company shares as well as their spouses, minor children andindividuals holding the shares in the name of others according to Article 22-2 of theSecurities and Exchange Act.
III. The scope of information that has material impact on Company share price provided inArticle 157-1, Paragraph 4 of the Securities and Exchange Act includes:
1. Information relating to the finances or businesses of the company that will have a materialimpact on the price of the securities, or will have a material impact on the investment
decision of a reasonably prudent investor;

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2. Information relating to the supply and demand of the securities on the market that will
have a material impact on the price of the Company's securities, or will have a material
impact on the investment decision of a reasonably prudent investor.
IV. Information with material impact on share price and its means of disclosure:
According to regulations governing the scope of information with material impact and its method ofannouncement specified in Article 157-1, Paragraph 4 of the Securities and Exchange Act:
1. The method of announcement of information with material impact relating to the financesor businesses of the Company refers to the Company's announcement of such informationon MOPS;
2. The methods of announcement of information with material impact relating to the supply
and demand of market shares refer to the Company's announcements of such informationon MOPS, in a basic market status report, on non-local pages of at least two (2) daily
newspapers with national coverage, on national TV news channels, or in the electronic
newspaper reports of the aforementioned media.
V.

Operating procedures for material information:

1. The Company's processing and disclosure of internal material information shall be
conducted in accordance with related laws, orders, and regulations of the Taiwan Stock
Exchange or Taipei Exchange.
2. The Company's Directors, Supervisors, managerial officers, and employees shall fulfill
their duties with the attention and loyalty of a prudent administrator based on theprinciple of good faith and shall be required to sign a confidentiality agreement.
Directors, Supervisors, managerial officers, and employees who have learned of internal material
information of the Company may not leak such information to others.
The Company's Directors, Supervisors, managerial officers, and employees may not inquire thecompany's internal material information from others who have knowledge of such information, orcollect unpublished internal material information of the Company that are irrelevant to their jobduties. They are also prohibited from leaking the Company's unpublished internal material
information to others.
3. The transmission of the Company's internal material information files and documents inwritten form shall be adequately protected. Transmission through email or otherelectronic forms shall require appropriate processing by security technologies such as
encryption or electronic signatures. The Company's internal material information files anddocuments shall be backed up and stored in a secure location.
4. Individuals and entities outside the Company that are involved in the Company's mergers,
important memos, strategic alliances, other business collaboration plans, or signing ofimportant contracts shall be required to sign confidentiality agreements and may not leaksuch the Company's internal material information to others.
5. The Company's external disclosure of internal material information shall be conductedpursuant to the following principles:(1) Information disclosure shall be accurate, complete and prompt.
(2) Information disclosure shall have factual basis.
(3) Information shall be fairly disclosed.
6. Unless otherwise provided in laws or regulations, the disclosure of the Company's internalmaterial information shall be processed by the Company's spokesperson or acting
spokesperson and the sequence for the performance of acting duties shall be verified.
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Where necessary, the Company's person in charge shall be directly responsible for
conducting information disclosure.
The content disclosed by the Company's spokesperson or acting spokesperson shall be restricted tothe scope authorized by the Company. In addition, with the exception of the Company's person incharge, spokesperson or acting spokesperson, the Company's employees may not disclose internalmaterial information to external parties without authorization.

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7. The following records of information disclosed by the Company shall be retained:(1) The personnel disclosing the information, date, and time.
(2) The method of information disclosure.
(3) Content of disclosed information.
(4) Content of delivered written information.
(5) Other related information.
8. If the content of a media report is inconsistent with the content disclosed by the Company,
the Company shall immediately provide clarification on MOPS and request said media tomake corrections.
9. If a Director, Supervisor, managerial officer, or employee of the Company learns of a leakof internal material information, he/she shall immediately report to the responsible unit
and the internal auditing department.
The responsible unit shall formulate response strategies after receiving a report specified in thepreceding paragraph. Where necessary, it may invite the internal auditing department etc. to discuss
response measures and record the results for future reference. The internal auditing department shallalso conduct investigations in accordance with its duties.
10. In the event of the following occurrences, the Company shall hold the relevant personnel
responsible and take appropriate legal actions:(1) Disclosure of internal material information without authorization or violation of theOperating Procedures or other laws and regulations by Company personnel.
(2) The content of information disclosed by Company's spokesperson or acting spokesperson
exceeds the authorized scope or constitutes a violation of the Operating Procedures orother laws and regulations.
In the event that an individual outside the Company discloses internal material information of theCompany which results in damages to the Company's properties or interest, the Company shallpursue related legal remedies for the individual's legal liabilities.
Article 5.
The Company shall educate Directors, Supervisors, managerial officers, andemployees on the Operating Procedures or related laws and regulations. The Company shallprovide education for newly-appointed Directors, Supervisors, managerial officers, andemployees in a timely manner.
Article 6.
The Company shall establish and maintain files on the information of internal
personnel and report to the competent authority in accordance with the required time periodand methods.
Article 7.
These Operating Procedures shall be implemented after approval by the Board ofDirectors. The same shall apply to all subsequent amendments.
Article 8.

The Procedures were established on July 29, 2011.

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