Corporate Governance

This Policy sets forth the Rules and Procedures for Reporting Complaints
Regarding Accounting, Internal Controls, Financial Reporting or Auditing Matters
and Company Business Transactions and Establishes Protections Prohibiting
Retaliation against Reporting Employees

The Company is committed to promoting compliance with the laws, rules, and regulations that govern its business operations and to encouraging its employees to report unlawful conduct or conduct that violates the Company's policies or standards for business practices. This Policy Statement sets forth the basic procedures by which complaints or reports of misconduct regarding the Company's accounting, internal controls, financial reporting or auditing matters and business transactions ("Reportable Matters") may be brought to the Company's Compliance Officer or its Audit Committee, as well as the Company's policy protecting reporting employees by prohibiting unlawful retaliation or discrimination against employees who submit such complaints. This Policy Statement applies equally to Asia Pacific Wire & Cable Corporation Ltd. and each of its subsidiaries and controlled affiliates (together called the "Company").

1.0  This policy addresses complaints regarding misconduct relating to any of the following matters:
1.1  fraud, deliberate error or gross negligence in the preparation, evaluation, review or audit of any financial statement of the Company;
1.2 fraud, deliberate error or gross negligence in the recording and maintaining of any accounting or financial records of the Company;
1.3 fraud, deliberate error or gross negligence in conducting or documenting any business transaction for or on behalf of the Company;
1.4 fraud, deliberate error or gross negligence in failing to file and report in a timely, complete and accurate manner any required governmental or administrative notices, reports, returns or other filings;
1.5 theft or misappropriation of Company property or assets, or diverting any Company property or assets to a party or for a purpose other than that intended, including without limitation any self-dealing or disproportionately favorable treatment of any third party without full disclosure to senior management and a legitimate business purpose;
1.6 material deficiencies in or material noncompliance with the Company's internal controls on financial reporting;
1.7 misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports of the Company;
1.8 deviation from full and fair reporting of the Company's financial condition; or
1.9 violations of the Company's Code of Ethics.
In this Policy Statement, the term "gross negligence" means disregard for, or recklessness or indifference in complying with, the Company's standards for good business practices, including compliance with all relevant internal procedures.

Complaints regarding Reportable Matters may be submitted to the Company's Compliance Officer. Submissions by employees of concerns may be made on a confidential or an anonymous basis. Complaints should be transmitted as follows:
By mail:
Asia Pacific Wire & Cable Corporation Ltd.
Room B, 15th Floor, No. 77, Sec. 2, Dunhua South Road,
Taipei, 106, Taiwan
Attn: Compliance Officer
By e-mail:
By voicemail at: 0800-077-558
Or by intranet at:
If the complaint or report of misconduct is related to the Compliance Officer, or if there are other extraordinary reasons why you are not comfortable sending your report to the Compliance Officer, then the complaint may be sent directly to the Audit Committee of the Board of Directors. In such a case, the following forwarding service, maintained outside the Company, may be used:
P.O. BOX 96-458 Taipei
Taipei City 10699
Taiwan (R.O.C)
Attn: Audit Committee of APWC
All correspondence received at this address will be forwarded directly to a member of the Audit Committee.

When submitting a complaint, you are asked to provide as much detailed information as possible. Providing detailed, rather than general, information will greatly assist us in effectively investigating complaints. This is particularly important when an employee submits a complaint on an anonymous basis, as we may be unable to contact the reporting employee with requests for additional information or clarification. However, employees who submit anonymous complaints should do so in a manner that does not inadvertently suggest their identity (for example, do not state "I know this because it is my job to approve accounts payable checks").

The Company is providing these anonymous reporting procedures so that the Company's employees may disclose genuine concerns without feeling threatened. As detailed below, the Company prohibits retaliation or retribution against any person who in good faith submits a report under this policy. Employees who choose to identify themselves when submitting a report may be contacted in order to gain additional information. To the extent practicable, the Company will keep confidential the identities of employees who choose to identify themselves when submitting a report.

All conversations, calls, and reports made under this policy in good faith will be taken seriously. However, employees who file reports or provide evidence that they know to be false or without a reasonable belief in the truth and accuracy of such information will not be protected by this policy and may be subject to corrective action up to and including immediate termination.

The Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to good faith reporting of complaints regarding Reportable Matters under US law, Taiwanese law, or the laws of any jurisdiction where the Company has operating activities, regardless of the final outcome of any investigation.

Upon receipt of a complaint, the Compliance Officer or Audit Committee, as the case may be, will (1) determine whether the complaint actually pertains to Reportable Matters and (2) when possible, acknowledge receipt of the complaint to the sender.

Complaints relating to Reportable Matters will be reviewed under Audit Committee direction and oversight by the Compliance Officer or such other persons as the Audit Committee determines to be appropriate. The review may include a discussion of the complaint or concern with the reporting person, and any other investigation deemed appropriate and including other persons, management, or the Company's independent advisors. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review.

Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee.

The Compliance Officer will maintain a log of all complaints, tracking their receipt, investigation and resolution and shall prepare a periodic summary report thereof for the Audit Committee. Copies of complaints and such log will be maintained in accordance with the Company's document retention policy.