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Code of Ethics Implementation Guidelines

A male and a female employees and two employees writing at the table

This guideline is intended to
provide examples of major types
of unethical behaviors and outline
allowed behaviors in order to
protect employees and stakeholders
against the risks from unethical
behavior.

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  • Prohibition of Receiving Money, Valuables, Entertainment, or Convenience

    Prohibition of Receiving Money, Valuables, Entertainment, or Convenience

    1. 1. Regardless of whether or not something was expected in return, requesting or receiving money, valuables, entertainment, or convenience from stakeholders for any reason is strictly prohibited.
    2. 2. Does not apply as the money, valuable, entertainment, or convenience prohibited in Article 3-1 under each of the following circumstances in which the provider’s sincerity, spontaneity, and affordability are recognized:
    3. 2-1. Marketing and promotional gifts; souvenirs with the stakeholder company's logo; and souvenirs generally provided by all participants of the events organized by stakeholders valued at less than ￦50,000.
    4. 2-2. Business-related meals and conveniences valued at less than ￦30,000.
    5. 3. If providing money, valuables, entertainment, or convenience to a stakeholder or a public servant for a business purpose, the employee must comply with the recipient’s code of ethics and Improper Solicitation and Graft Act
    6. 4. Acceptance by an employee’s family members, relatives or acquaintances will be regarded as acceptance by the said employee.
    7. 5. Should employee receive money, valuables, entertainment, or convenience as per Article 3-1 against their will, the employee must immediately return the item in question or provide monetary compensation equal in value, voluntarily register the matter on the portal, or report the matter to the Ethics department.
  • Restrictions on Golfing, Traveling Overseas, and Fraternizing with Partners

    Restrictions on Golfing, Traveling Overseas, and Fraternizing with Partners

    1. 1. Irrespective of at which party’s expense, employees must not play golf, travel overseas, or equivalent activities with a partner employee or a public servant as per the Improper Solicitation and Graft Act, unless at an official event organized by the company.
    2. 2. Should employee be required to play golf, travel overseas or equivalent activities with a partner employee or a public servant due to unavoidable circumstances, the employee must obtain the approval of the department manager and voluntarily register the matter on the portal beforehand.
  • Restrictions on Notification of Family Events

    Restrictions on Notification of Family Events

    1. 1. Employees may not inform an external stakeholder of family events. In particular, employees must not inform a partner of family events via mail, electronic mail, telephone (texting), or fax.
    2. 2. Employees may not accept excessive congratulatory or condolence money, gifts offering from stakeholders and must return any such offering that was received unavoidably.
    3. 3. If informing colleagues of family events via the portal, employees must use the Family Event bulletin board. Types of family events that may be notified are limited to immediate family members’ weddings and funerals.(*Immediate family member: employees or their spouses' grandparent, parent and child)
  • Prohibition of Financial Transactions

    Prohibition of Financial Transactions

    1. 1. Loans; loan guarantees; loan repayment; real estate leasing; joint purchase of real estate or membership; and the purchase at bargain price or disposal at high price of goods, real estate, marketable securities, memberships, business rights, etc. with stakeholders are prohibited.
    2. 2. Investment and acquisition of shares in stakeholders (including suppliers, partners, and client affiliates) are prohibited.
    3. 3. Investment or share acquisition by an employee’s family members, relatives or acquaintances will be regarded as investment or share acquisition by the said employee.
  • Prohibition of Influence Paddling and Inappropriate Favors

    Prohibition of Influence Paddling and Inappropriate Favors

    1. 1. Employees must not use their position for personal gain or the gain of a third party or request an inappropriate favor that severely obstructs fair and just execution of duty.
    2. 2. Employees must not seek a promotion or an assignment from the company via an acquaintance from either within or outside the company.
    3. 3. Employees must not request the company or a stakeholder to facilitate employment, assignment, or promotion of a family member or an acquaintance.
    4. 4. Employees must not request the company or a stakeholder to register as a vendor or trade with a business operated by a family member or an acquaintance.
  • Prohibition of Inappropriate Orders

    Prohibition of Inappropriate Orders

    1. 1. Superiors may not give orders to subordinates that go against the law, company regulations or fair work execution. Subordinates who receive such an order from their superiors may refuse to carry out the order by explaining the reason for the refusal.
    2. 2. If the same inappropriate order is repeated by a superior after refusing the carry it out as per paragraph 1, the individual is to immediately discuss the issue with the Ethics department.
  • Separation of Official and Personal Affairs

    Separation of Official and Personal Affairs

    1. 1. Employees must not use corporate credit cards, corporate funds or assets intended for operational needs and events, or the company’s information for personal purposes.
    2. 2. Employees shall refrain from false reporting or conduct that runs counter to the company’s interests for the purpose of embellishing their personal performance or their unit’s performance.
    3. 3. Employees may not concurrently be employed by another firm or perform for another firm without the company’s approval.
  • Prohibition of Political Involvement

    Prohibition of Political Involvement

    1. 1. Employees may express their political opinions but must make it clear that their opinions do not constitute the official view of the company.
    2. 2. Employees may not engage in any political activity within the company in whatsoever form or use the company, its personnel, or its assets for political purposes.
  • Fair Competition

    Fair Competition

    1. 1. Employees are required to compete with others in the industry based on good will and without infringing on a competitor’s interests by an inappropriate means.
    2. 2. The individual must respect domestic and international norms in business transactions and comply with all laws governing the company’s business activities in the particular country or region, including the Anti-graft law, the Act on Combating Bribery of Foreign Public Officials in International Business Transactions, and FCPA.
  • Restrictions on Transactions with Dishonorable Former Employees

    Restrictions on Transactions with Dishonorable Former Employees

    1. 1. Any business transactions with a former employee, who was dismissed or resigned as the result of their involvement in a corruptive or scandalous affair or a deliberate action against the company’s interests, or any firm in which such a former employee has significant managerial influence, are strictly prohibited.
      A firm in which such a former employee has significant managerial influence refers to a firm in which such a former employee or a member of their family is registered as the CEO, an executive, or a main shareholder thereof or is deemed a de facto owner or shareholder thereof.
    2. 1-1. The same applies to employees found to have been involved in a corruptive or scandalous affair or a deliberate action against the company’s interests after their resignation from the company.
    3. 2. Employees in charge of contract work are required to vet firms for such a fact before registering them as a vendor or entering a business contract with them.
    4. 3. The term of contract limitation as per paragraph 1 is ten years from the concerned employee’s dismissal or resignation.
  • Code Compliance and Violation

    Code Compliance and Violation

    1. 1. Employees are required to comply with the Code of Ethics and the Implementation Guidelines herein. Violators will be subject to disciplinary actions as per the company’s policies and/or civil/criminal prosecution.
    2. 2. Supervisors and managers are required to educate, train, and consult members of their unit to help them understand and uphold the Code of Ethics and the Implementation Guidelines measures to prevent violations thereof.
    3. 3. Should an employee be asked to act in violation of the Code of Ethics and the Implementation Guidelines or becomes aware of such behavior, said employee must immediately report the matter to the Ethics department or the Audit department.
    4. 4. The principle of zero tolerance will be implemented strictly on employees who commit any one of the three major ethical violations (receipt of money or valuables, embezzlement, and influence paddling/improper solicitation) regardless of having no history of prior offence. Such a violation, regardless of the sum of the monetary value involved, may result in termination of employment and corporate criminal proceedings if the employee is deemed to have been an active participant.
    5. 5. Matters concerning the Code of Ethics and the Implementation Guidelines that are not defined herein or are subject to debate shall be referred to the Ethics department and be subject to their interpretation.

[Terminology]

  1. 1. Stakeholder: An individual, juridical person or other organization whose rights or interests may be affected by the employee’s performance of their duty.
  2. 2. Partners: All contracted parties (individuals, juridical persons, and other organizations) in a business relationship with the company, including but not limited to internal and external partners, materials suppliers, general goods and services providers, and agents.
  3. 3. Money and Valuables: Items of monetary value such as cash, securities, gift certificates, and passes and physical goods such as gifts and souvenirs.
  4. 4. Entertainment: Dining, alcohol consumption, golfing, public performances, gambling, etc.
  5. 5. Convenience: Transportation, lodging, event support, tourism support, etc.
  6. 6. Principle of Zero Tolerance: Severely punish employees who violate any one of the three major unethical acts (receipt of money or valuables, embezzlement, and influence paddling/improper solicitation), regardless of their rank, position, or title and regardless of having no history of prior offence.
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Anti-Corruption 3 Principles

: These principles apply to all employees and board members

1. Zero Tolerance to Corrupt Practice

The company and its employees reject all types of corrupt behavior.

2. Engagement of Leaders in Anti-Corruption Campaign

All leaders should influence their subordinates' ethical behavior and create an ethical environment in their respective organizations.

3. No Leniency for Corruptors

The company will never tolerate an employee or a partner company who are engaged in corrupt practices.