The relevant regulations are to be performed relating to "Establishing Internal Control System Implement Regulation for Public Companies" of the Securities Management Committee.

The Internal audit system appoints the supervisor of audit dept to be engaged in the audit related task management of the professional territory, so as to comply with the requirements of the external supervisory parties.

Personal "conflicts of interest" exist any time employees or directors face a choice between their personal interests (financial or otherwise) and the interests of SPIL. Conflicts of interest may call into question SPIL's integrity. It is therefore crucial that service to the company not be subordinated to personal gain and advantage and that all employees and directors be accountable for acting in the SPIL's best interest and for avoiding even the appearance of a conflict.

Any individual in a position where his or her objectivity may be questioned because of an individual interest or family or personal relationship (including if a member of an individual's immediate family or household works for a company which is itself in direct competition with SPIL.) should notify his or her immediate supervisor, or SPIL's audit unit. Similarly, any individual aware of a material transaction or relationship that could reasonably be expected to give rise to a personal conflict of interest should discuss the matter promptly with SPIL's audit unit.

Potential conflicts of interest involving an executive officer or a director will be reviewed directly by SPIL's board of directors. Potential conflicts involving an employee of SPIL, other than an executive officer, will be reviewed in accordance with SPIL's regulations.

In certain limited cases, activities giving rise to potential conflicts of interest may be permitted if they are determined not to be harmful to SPIL. Any such determination will be made by the board in the case of executive officers or directors, and in accordance with the company's employee handbook in the case of other employees.

Furthermore, it is critically important that financial statements and related disclosures be free of material errors. Employees and directors are prohibited from knowingly making or causing others to make a materially misleading, incomplete or false statement to an accountant or an attorney in connection with an audit or any filing with any governmental or regulatory entity (such as the ROC SFC, The NASDAQ Stock Market, Inc. or the U.S. SEC). In that connection, no individual, or any person acting under his or her direction, shall directly or indirectly take any action to coerce, manipulate, mislead or fraudulently influence any of SPIL's auditors if he or she knows (or should know) that his or her actions, if successful, could result in rendering SPIL's financial statements materially misleading.

SPIL has established procedures for submitting concerns regarding accounting, internal accounting controls or auditing matters to the Board (and for submitting other concerns to the non-management directors of SPIL) prior to the establishment of the Audit Committee and to the Audit Committee after it has been established.

No individual will be subject to retaliation of any kind (or threat of retaliation) for reporting in good faith any ethical concerns, suspected securities law violations or other suspected misconduct. Any individual who believes that he or she has been retaliated against (or threatened or harassed) in violation of this policy should immediately report the matter to his or her immediate supervisor, or SPIL's audit unit.

This Code of Ethics sets forth the fundamental principles and policies that govern the employees and directors with respect to their conduct of SPIL's affairs. It is not intended to, and does not, create any rights in any employee, customer, supplier, competitor, shareholder or any other person or entity. This Code of Ethics is intended solely for the internal use by SPIL and does not in any way constitute an admission, by or on behalf of SPIL, as to any fact, circumstance or legal conclusion.