This guideline is established by our company and its affiliates in accordance with paragraph (1) of the Addenda to the Code of Ethics (Amendment) for human rights management that respects the Guiding Principles On Business and Human Rights of UN.

Our company recognizes that all human beings have the right to be treated with dignity in respect of the Guiding Principles On Business and Human Rights of UN, including life and physical safety, freedom of thought, expression, freedom of religion, freedom of family life and privacy, freedom from food and water, torture, slavery or forced labor, and prohibition of discrimination.
Accordingly, our company takes appropriate measures to prevent infringement of the human rights of others and to prevent and resolve the negative effects on human rights arising from the company's management activities.

• 1. Our company complies with laws and internationally recognized global human rights standards that apply everywhere we engage in business activities.
• 2. In the face of conflicting regulations in the local country, it seeks ways to comply with global human rights standards.
• 3. Risks that can cause serious human rights violations are treated as important management issues for the company.

Our company's responsibility for respecting human rights includes the following scope.

• 1. The cause of the company's management activities negatively affecting human rights is prevented in advance, and the problem is appropriately dealt with if it occurs.
• 2. Even if the company has not directly caused a negative impact on human rights, efforts are made to prevent and mitigate human rights-related negative effects due to the management activities of the trading company.

The following policies and procedures shall be prepared to fulfill the responsibility for respecting human rights.

• 1. Policy will, such as the enactment of norms that contain the responsibility for respecting human rights of the company
• 2. Human rights inspection procedures for identifying, preventing, and mitigating negative impacts on human rights and inspecting and investigating the details of activities affecting human rights
• 3. Procedures to remedy the negative impact of human rights caused by the company

Executives and employees of our company shall identify, prevent, and mitigate the negative impact on human rights, and conduct due diligence on human rights if deemed necessary to fulfill their responsibilities for activities. This procedure involves identifying and evaluating practical and potential impacts on human rights, responding to problems found, recording response activities, and communicating with relevant stakeholders how the impacts were handled. Due diligence on human rights takes into account the following.

• 1. It includes negative effects related to human rights that may be directly or indirectly caused in the process of the company's management activities.
• 2. Various related matters are considered according to the location and size of the workplace, human rights-related risks, characteristics and contents of the project, and political and economic conditions and characteristics of the local country.
• 3. Recognizing that the risks to human rights gradually change as the company's activities and business operation environment change, it continues to implement them.

Our company will make efforts to identify and check the real and potential negative effects that not only major workplaces but also related companies of our company may have on human rights due to management activities according to the following process.

• 1. Where human rights-related risks are detected in major domestic and foreign workplaces, current status analysis and improvement measures are derived through human rights due diligence.
• 2. In principle, due diligence shall be conducted by internal experts, and if necessary, it may be conducted together with the support of external experts.
• 3. In some cases, practical interviews are conducted with groups and related stakeholders who may be potentially affected.
• 4. Potential and practical effects should be identified when conducting human rights due diligence on human rights. The potential impact should be taken to share the evaluation results at the enterprise level and to prevent and mitigate them by performing related procedures, and the actual impact that has already occurred should be subject to remedy and resolution.
• 5. Human rights due diligence is conducted using a checklist that diagnoses key elements related to human rights management.

Follow-up measures are taken by establishing a response system based on the facts found from human rights due diligence to prevent and alleviate negative effects that may affect human rights.

• 1. Establishment of an internal response system
  • - Clarify roles and responsibilities with related departments to solve problems found.
  • - Apply internal decision-making, budget allocation, and surveillance procedures to respond effectively to these effects.
  • - Apply internal decision-making, budget allocation, and surveillance procedures to respond effectively to these effects.
• 2. Follow-up and Remediation
  • - When there is a possibility or a negative impact on human rights, take necessary measures to prevent and alleviate objections.
  • - Even if the best policies and procedures are in place, efforts shall be made to improve the negative impact alone or in cooperation with other subjects if it causes an unexpected negative impact.
  • - If the negative impact is complexly related to the operation, production, and service of a company in relation to other entities (e.g., suppliers), there is no direct responsibility to prepare systematic improvement measures, but it plays a certain role.
  • - If the company has an influence to prevent or mitigate the negative impact on human rights, it shall be utilized, and if not, it may strengthen its influence in cooperation with the relevant entity.
  • - As an effective remedy, a grievance system is operated for stakeholders who may be potentially affected.

When stakeholders raise concerns about human rights impacts, the company gives a responsible explanation.

• 1. Communicate with stakeholders, including affected groups, individuals and investors, based on accountability and transparency, and consider various forms of communication, such as face-to-face meetings, publication of official reports (e.g., audit committee reports), and online channel utilization (e.g., the company's website).
• 2. When issuing an official report, it includes substantial and potential negative effects, and independent verification procedures are considered to increase the reliability of the report.
• 3. Provide information to help stakeholders assess whether the company is responding appropriately to specific human rights impacts.

It induces practical improvement in human rights management through internalization of organizational culture and institutional improvement activities of human rights due diligence results.

• 1. Activities to internalize human rights management into organizational culture, such as education on consensus building for all executives and employees, education on norms related to human rights management, and sharing success and failure cases.
• 2.The human rights management system is continuously improved by consulting experts, communicating with stakeholders, and discovering improvements through system implementation.

Our company operates a grievance system for negatively affected individuals and communities so that the issues raised can be discussed and resolved quickly.
The company shall endeavor to achieve a prompt and reasonable resolution by utilizing existing means such as an ethics counseling center, an unethical reporting center, etc. The grievance system performs the following important functions in relation to the company's responsibility for respecting human rights.

• 1. It makes it easy to grasp the negative impact on human rights and provides a path for directly affected stakeholders to raise problems.
• 2. It prevents the spread of human rights damage by dealing with grievance collection and victim relief at an early stage.
• 3. It identifies and improves problems with human rights policies and procedures through analysis of operational status.