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ESG

G(Governance)

Anti-Corruption Management Policy

Chapter 1: General Provisions

Article 1 Purpose

The purpose of our anti-corruption management policy is to ensure that not only our executives and employees, but also our agents and counterparties, abide by global laws and standards related to anti-corruption.

Chapter 2 Business Procedures

Article 2 Global Anti-Corruption Compliance

Employees of our company are responsible for complying with all global laws and standards related to anti-corruption.

Employees of our company must comply with local anti-corruption laws and regulations, as well as global anti-corruption laws and standards. In Korea, there are 'Criminal Act', 'Act on Aggravated Punishment, etc. of Specific Crimes', 'Act on Aggravated Punishment, Etc. of Specific Economic Crimes', and 'Improper Solicitation and Graft Act'.

Even if the act was conducted by social or business practices, immunity cannot be granted if it violates global anti-corruption laws, standards or local laws.

On the other hand, if there is a conflict between global anti-corruption laws, standards, local laws and our company's anti-corruption compliance guidelines, we follow the strictest standards.

Article 3 Entertainment and Convenience
3.1 General principles

Employees of our company cannot give or receive money or anything of value in relation to entertainment and convenience to all stakeholders, including domestic and foreign public officials and transaction partners, with dishonest intentions for business interests. An example of ‘valuables’ is as follows.

  • - Securities, real estate, meals, gifts, golf
  • - Expenses such as transportation and lodging
  • - Licenses and discounts on products and services
  • - Political Contribution
  • - Other tangible and intangible economic benefits such as taking over or waiving debt, providing employment, granting interests, etc.

However, entertainment and convenience necessary for business purposes, such as product promotion, contract conclusion, and promotion of business-related mutual understanding, can be given and received at a normal level, and the following must be observed.

  • - The level of business entertainment and convenience must be reasonable.
  • - Business entertainment and convenience should not be provided frequently to stakeholders for a certain period of time.
  • - The details of related expenditures must be accurately reflected in the company's books, etc.
3.2 Meals, gifts, etc.

When employees of our company provide meals, gifts, etc. to stakeholders as a sign of goodwill or courtesy or to promote friendship, the following must be observed.

  • - Meals, gifts, etc. should be small compared to the other party's salary level.
  • - Meals, gifts, etc. can be provided only when necessary for a clear cause, and must not be provided frequently for a certain period of time.
  • - Entertainment such as meals cannot exceed the limit of 100,000 won, and gifts of 50,000 won [100,000 won for agricultural and marine products and processed products (including flowers)]. However, if you need to exchange meals or gifts that exceed the limit, you must obtain approval from the head of the department in advance. When dealing with public officials under the ‘Improper Solicitation and Graft Act’, the relevant laws and the internal code of ethics shall be followed.
3.3 Providing convenience

Employees of our company must observe the following in relation to providing convenience to stakeholders.

  • - Conveniences such as transportation and accommodations that exceed the usual level shall not be exchanged. However, convenience generally provided to all attendees at events, etc., is excluded
  • - It is directly or indirectly related to the promotion, demonstration or explanation of products or services, conclusion of a contract or its implementation, and must be at a reasonable level.
  • - Conveniences are not provided to family members other than those concerned.
  • - Expenses incurred from providing convenience should not be paid to stakeholders, but must be paid directly to the place where the convenience is used, such as airlines and hotels.
Article 4 Facilitation

Employees of our company cannot provide any facilitation payments to domestic and foreign public officials. Facilitation payments are the provision or intention to provide a small amount of money to public officials engaged in routine or repetitive duties for the purpose of facilitating the legitimate performance of their duties, and typical applicable duties are as follows:

  • - Receipt and processing of administrative documents such as visa issuance
  • - Customs clearance, loading and unloading related to product transportation
  • - Telephone opening, electricity and water supply
Article 5 Customers, etc.

The same anti-corruption compliance guidelines applied to agents can also be applied to counterparties, such as suppliers and customers, through mutual understanding.

Article 6 Accounting Records and Management

Global anti-corruption laws and standards strictly stipulate that transactions occurring in all business processes be recorded and managed according to the internal accounting management system.

Therefore, our company's executives and employees must keep and properly account for invoices, receipts and other related evidence arising from business, and the possession of expenses or assets not recorded in the books is strictly prohibited.

In addition, all business as well as the maintenance of books and records must be conducted in accordance with appropriate procedures through the company's internal accounting management system as follows.

The expenses of all transactions must be executed according to the approval of the appropriate decision-making authority.

All transactions must be prepared in accordance with accounting standards and approved by the appropriate approval authority.

Assets must be used according to the approval of the appropriate decision-making authority.

Periodically inspect assets.

Article 7 Anti-corruption Compliance Training

Employees of our company must conduct and complete anti-corruption compliance training according to the guidance of the Management Support Office, and submit relevant evidence to the Management Support Office.

Article 8 Declaration and Whistleblower Protection

Employees of our company must declaration to the Management Support Office when they become aware of violations of global anti-corruption laws, standards, and our company's anti-corruption compliance guidelines, or when they are aware of suspected violations.

The company strictly protects the prosecutor, strictly prohibits disclosure of the identity of the prosecutor, retaliation and search for the prosecutor, and does not give the prosecutor any disadvantages such as employment relations.

Article 9 Rewards and Punishments

The company may reward executives and employees who have contributed to achieving the objectives of our company's anti-corruption compliance guidelines in accordance with the relevant provisions of the reward and punishment guidelines.

In addition, the company punishes executives and employees who violate global anti-corruption laws, standards, and our company's anti-corruption compliance guidelines in accordance with the relevant regulations of the employment rules and reward and punishment guidelines.

Disciplinary measures (dismissal, suspension, salary reduction, reprimand, etc.) may be taken. On the other hand, if our executives and employees are fined as a civil or criminal punishment for violating global anti-corruption laws and standards, the company does not have any preservative responsibility.

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