Corporate Ethical Principles

• 01

  We comply with law and order.

  We try to become an exemplary and competitive company by complying with the regulations of all countries where we conduct a business at home and abroad, respecting the commercial transactions and customs of corresponding countries and developing fair and transparent business activities pursuant to the principles of the free and competitive market.​

• 02

  We respect superiors, colleagues and subordinates. ​

  We mutually respect superiors, colleagues and subordinates as an equal human being and do our best to form a fair and sound colleagueship based on smooth communication and trust.

• 03

  We respect customers, stockholders and partners.​​

  We build mutual trust by clearly understanding and obeying the ethical standards of customers and stockholders and pursue mutual development with partners through fair and transparent transactions.​

• 04

  We maintain the clean corporate culture.​

  We maintain the clean corporate culture by improving management transparency, actively protecting our assets and handling matters strictly separating private affairs from public affairs in all business activities.

Action Guide for Executives and Employees

• 01

  We comply with law and order.

  • We comply with all laws and regulations of all regions at home and abroad where we carry on business activities.

  • We abide by order in sound commercial transactions through fair competition between industries.

  • We act to keep personal and corporate dignity in a social and ethical.

• 02

  We respect superiors, colleagues and subordinates.

  • We fairly treat superiors, colleagues and subordinates without any unfair instructions, disturbance and discrimination between executives and employees.

  • We do not engage in violence/verbal abuse and sexual harassment between executives and employees.​

  • We do not engage in gambling, money transactions, giving gifts and private group activities between executives and employees.

• 03

  We respect customers, stockholders and partners.

  • We do not provide unfair requests, gifts and treats while complying with the ethical standards of customers and stockholders.

  • We do not receive any money and valuables, gifts, treats and convenience from partners.​

  • We respect employees in partners and do not make an unreasonable demand or do damage to partners.

• 04

  We maintain the clean corporate culture.

  • We transparently manage the company’s financial standing and management performance in accordance with accredited accounting standards.

  • We actively protect the company’s assets or information and do not privately use or acquire them.

  • We master the company’s ethical policies and actively practice them to maintain the clean corporate culture. ​

Principles

• 01

  In case of practical · potential conflict of interests between an individual and the company, report it to the company and act in preference to the company’s interests. The prohibition of conflict of interests is also applied to indirect transactions through family members or discretionary transactions.

• 02

  The prior approval is required for the use of the company’s assets and opportunities, competitive business and sidelines, self-dealing and transactions with a spouse, a lineal ascendant and descendant, the lineal ascendant and descendant of a spouse and a company that the above persons have a stake of over 50% or have a stake of 50% in total (hereinafter, “affiliate persons).

• 03

  The inside transactions and market disturbance are strictly prohibited in any cases. (The actions in the above 1.1 to 1.3 are collectively referred to as “conflict of interests”)

Prohibition of Inside Transactions and Market Order Disturbance

• 01

  For undisclosed critical information, it is also applied to market-related external information such as internal information, tender offer, mass acquisition / disposition, etc. of listed companies.

• 02

  Prohibit any transfer, establishment/acquisition of a security right and loan transaction of marketable securities including trading, stock exchange, etc. using undisclosed critical information

• 03

  ​ Do not give undisclosed critical information after expecting others’ trading or transaction or recommend them to engage in trading or transaction using that information

• 04

  ​ A person who produces or gets to know undisclosed critical information related to his/her duties is prohibited from transacting listed securities, etc. with that information.

Prohibition of Self-dealing and Transactions with Affiliate Persons

• 01

  The executives and employees are necessary to obtain prior approval from the company (for the representative director of the representative executive officer, the board of directors or the chairman of the board of directors) in any case where the conflict of interests could occur between them or their affiliate person and the company due to “self-dealing” such as a transaction with the company on their / the third party’s own account. ​

• 02

  The direct transactions and indirect transactions that the company stands joint surety for the debts of executives and employees are included.

• 03

  In case that the interests of executives and employees conflict with or could conflict with those of the company, fill in and submit a report in Appendix II

Prohibition of Using the Company’s Opportunities and Assets and Prohibition of Competitive Business and Sidelines

• 01

  The executives and employees are prohibited from using the company’s business opportunities (learned in performing their duties, using the company information and closely related to a business performed (to be performed) by the company) which could be beneficial to the company for their or the third party’s benefits.

• 02

  ​ The executives and employees are prohibited from engaging in transactions in the same business field as the company directly or indirectly through their family members, etc.

• 03

  ​ The executives and employees are prohibited from working as an executive or an employee in other company with the same business purpose or acquiring its stake without the approval of the board of directors or the chairman of the board of directors.

Principles

• 01

  Comply with the ethical standards of stockholders and customers in conducting a business

• 02

  ​ Not accept, promise or demand any economic profits including money and valuables, gifts, treats, convenience, etc. in relation to the duties of companies in a current or potential business relationship with the company (including, but not limited to partners and suppliers) and their stockholders and executives and employees (including retired executives and employees) (hereinafter, “stakeholders”)

• 03

  Thoroughly comply with all domestic and foreign anti-corruption laws (hereinafter, “the anti-corruption laws”) applied regardless of regions and countries where the company conducts a business including (i) Korea laws related to anti-corruption such as Criminal Law, Act On The Aggravated Punishment Of Specific Crimes, Improper Solicitation And Graft Act (hereinafter, “Anti-Solicitation Act”), Act On Combating Bribery Of Foreign Public Officials In International Business Transactions, etc. and (ii) FCPA and UK Bribery Act, etc. )

Action Guide​

• 01

  The executives and employees do not make any form of personal solicitation (solicitation for the provision of any tangible or intangible profits to meet personal needs or desires including providing convenience, discharging debts, giving a job opportunity, giving rights and interests, etc.) to the company’s stakeholders including partners, suppliers, etc.

• 02

  In case of receiving solicitation in breach of laws or against common practices of transaction or social norms in relation to duties from stakeholders, or solicitation which does not meet procedures and standards stipulated by the company or which could do damage to the company (hereinafter, “improper solicitation’) or an offer of economic benefits, the executives and employees refuse it and report it to the Compliance Department in case that such solicitation continues.

• 03

  In case that a request from a stakeholder could correspond to improper solicitation, respond through formal internal procedures including reporting it to the Compliance Department

• 04

  The executives and employees themselves and their family or the third party are prohibited from receiving economic benefits from stakeholders regarding the duties of the executives and employees.

• 05

  It is prohibited to make a solicitation through other department or executive or employee as well as directly accept solicitation from stakeholders.

• 06

  In principle, improper solicitation or provision of economic benefits for domestic and foreign public officials is prohibited. But, in case that it is necessary to provide economic benefits as an exception, the approval of the Compliance Department is required and the anti-corruption law is followed.

• 07

  The executives and employees request the Compliance Department to give advice in case that it is unclear whether the amount or scale of gifts, meals, treats or expenses for congratulations and condolences for public officials is beyond the standards permitted by the Anti-Corruption Act.

• 08

  Educate details on Anti-Corruption Act including Anti-Solicitation Act, etc. for executives and employees and Monitor whether they comply with them. For the main contents of Anti-Solicitation Act, refer to the Appendix

Principles

• 01

  All executives and employees comply with laws related to fair trade and respect the order of the market economy according to the principles of free competition to compete with competitors in good faith and make mutual efforts with other party to a transaction for the fair and free transaction environment.

• 02

  In case that it is determined that laws related to fair trade are applicable in relation to business performance, the executives and employees consult with or receive advice from the Compliance Department in advance and follow it.

• 03

  ​ In case of finding a violation or a possibility of a violation of laws related to fair trade in relation to business performance, the executives and employees immediately report it to the Compliance Department simultaneously with taking proper countermeasures.

• 04

  The executives and employees master and comply with customs laws related to other party to a transaction and countries that the company does business internationally, the Free Trade Agreement, the duty of export and import declaration/customs entry and foreign exchange declaration, Anti Money Laundering Laws, trade sanctions (including U.S. Economic Sanctions), etc.

Duty to Comply with Laws related to Fair Trade

All executives and employees are prohibited from engaging in the following activities or making other executives and
employees do the following activities regarding all businesses in which the company is involved. ​

• 01

  Unfair Common Action (Collusion): Action to agree on a price, transaction conditions, the production, market division, a bidding price, a successful bidder, etc. which unfairly limit competition jointly with other business operators including competitors, etc.

• 02

  Abuse of Market Dominance: Action which could significantly damage the interests of consumers or do business to (1) unfairly maintain or change a price, (2) unfairly adjust the production or sales, (3) unfairly disturb the business activities of other business operators or the participation of new competitors, or (4) unfairly exclude competitive competitors with the abuse of the company’s market dominance ​

• 03

  In case that a request from a stakeholder could correspond to improper solicitation, respond through formal internal procedures including reporting it to the Compliance Department

• 04

  The executives and employees themselves and their family or the third party are prohibited from receiving economic benefits from stakeholders regarding the duties of the executives and employees.

• 05

  It is prohibited to make a solicitation through other department or executive or employee as well as directly accept solicitation from stakeholders.

• 06

  In principle, improper solicitation or provision of economic benefits for domestic and foreign public officials is prohibited. But, in case that it is necessary to provide economic benefits as an exception, the approval of the Compliance Department is required and the anti-corruption law is followed.

• 07

  The executives and employees request the Compliance Department to give advice in case that it is unclear whether the amount or scale of gifts, meals, treats or expenses for congratulations and condolences for public officials is beyond the standards permitted by the Anti-Corruption Act.

• 08

  Educate details on Anti-Corruption Act including Anti-Solicitation Act, etc. for executives and employees and Monitor whether they comply with them. For the main contents of Anti-Solicitation Act, refer to the Appendix

Duty to Comply with Laws related to International Trade​

• 01

  The executives and employees shall accurately master and comply with all kinds of customs/dumping laws, requirements for the country of origin under FTA, the duty of export and import declaration/customs clearance, the duty of foreign exchange declaration, etc. related to the company’s international trade​

• 02

  The executives and employees shall accurately master and comply with Anti Money Laundering Laws and trade sanctions (including U.S. Economic Sanctions. Refer to the Appendix) in relation with international trade to be conducted by the company and in case of finding a country, a corporation, an agency, an organization or an individual subject to any sanctions or having any other concern or question, they shall make an inquiry to the Compliance Department in advance.

• 03

  The executives and employees shall make positive and full efforts to correctly understand the identity, personality, transaction structure and purpose, ownership structure, etc. of not only other party to an international transaction to be performed by the company, but also those who are directly or indirectly connected with a corresponding transaction and other party (customers, suppliers, agents, partners, consultants, investors, stockholders, funders, etc.) and figure out whether they could violate Anti Money Laundering Law and trade sanctions.