Ethics Pledge

• Yearly online ethics pledge signing is to remind all employees of Code of Ethics.

Ethical Consultation

• Window to ask trained counselors for ethic dilemma questions and get answers.
• Various methods such as visit, phone, mail, fax and e-mail are available.

Gift/Solicitation Voluntary Registration System

• When receiving inappropriate gift from the related parties, employees shall immediately return and register the details in the system.
• When receiving inappropriate solicitation from the related parties, employees shall express its refusal or inability of fulfillment to the related parties and register the details in the system.
• Applicability: Relating to the business, inappropriate gift or solicitation from the related parties with which We has business currently or prospectively.
• Details of registration are utilized for the anti-corruption prevention activities such as issue identification and management of vulnerabilities, etc.

Smart Auditor(Real Time Monitoring System)

• Monitor high-risk areas to prevent unethical and corrupt practices on an ongoing basis.
• Strengthen risk management through feedback on monitoring results.
• Implement the system in various scenarios in 8 areas including HR, finance, procurement, external suppliers, internal suppliers contract, security and general monitoring.
• Develop, test and transfer new scenarios for active monitoring by relevant teams.

Whistle-blower System

• The system is designed to set standards for reporting and processing unethical conducts and to protect and reward the 'whistle-blowers'.
• It is a base for recognizing and correcting problems and preventing ethical disasters in advance.
• eventually leading to a more mature internal reporting culture.

Ethics Reformation Committee

• Organized to support the existing ethical management monitoring system and implement comprehensive ethical practice reform to take proactive measures against unethical practices.
• Composed of 9 members representing various internal and external organizations and working independently.
• Process: Acknowledgement of reports on unethical/corruption and malpractice actions → Gathering information → When necessary to fact-check, request investigation to the relevant departments → Assessment on the investigation reports
• Operate as a corruption report channel separate from the Whistleblower System.
• Contacts : yully@hanwha.co.kr/ +82-2-2129-0283

Unethical Risk Map

• It defines types of possible unethical conducts of each organization and evaluates the likelihood and its impact.
• It is intended to increase management abilities of each organization handling unethical risks.

Internal Audit Performance Improvement Program

• In order to improve its competency, the departments in charge of internal audit, duty diagnosis, corruption and malpractice investigation support two (2) of its members per year to get a Corporate Internal Auditor Certification by Korea Listed Companies Association. The certification holders are already back to work and proceed their duties.
• Additionally, the internal education and training for Certified Internal Auditor (CIA) by the Institute of Internal Auditors is provided.

Sub-Contractor Sanction Policy

• Issue warning and suspend transactions with unethical or corrupt suppliers.
• Apply to all suppliers/partners of Our.

▶ Subject of Sanction

1. 1. Submitting false or misleading information in deliveries, specifications, services and documents which results in damage to Our reputation and credibility.
2. 2. Theft and embezzlement of assets and acquisition of unfair gains on consigned assets.
3. 3. Bribery (e.g. money (including facilitation payments, etc.), gifts, entertainment and convenience) to employees or officers
4. 4. Monetary transactions and joint investment with employees or officers who have a conflict of interest.
5. 5. Social activities such as golf and overseas travel with employees or officers who have a conflict of interest.
6. 6. Influence on the registration and transaction with suppliers.
7. 7. Damaging the reputation or false accusation on employees or officers and other suppliers.
8. 8. Disturb fair trade practices such as bid rigging, promotional advertising during bidding process, giving a bribe to client and related parties.
9. 9. Violations of the ethics-related policies and contract entered with.
10. 10. Other violations of Code of Ethics (and Guidelines).

▶ Types of Sanction

Suspension of transaction (permanent/ 5 years/ 3 years/ 1 year, etc.), Warning, Pledge of Prevention.

▶ Decision on Sanction

Decisions are made by the Sanction Deliberation Committee.

Voluntary Ethical Compliance Programs

• Promote an attitude and behavior change of individuals and organizations through voluntary audits on a regular basis
  (Through voluntary audit checklist)
• Prevent the ethical risks by identifying and improving a process vulnerable to unethical practices (ethical challenge tasks)
• Encourage enterprise-wide participation (all organizations, all directors and employees)
• Apply levels of participation to performance evaluations by individual and organization

Evaluation on Ethics Implementation

• Individual Evaluation: Performance results of the employees and officers apply in the MBO (Management By Objectives) evaluation
• Organizational Evaluation: Performance results of each organization apply in the MOU evaluation (evaluated by Department, Division, Unit)
• Special Evaluation

• HR Discipline: according to the principle with no leniency for corruptors, HR policy applies its discipline.

Ethics Index Survey

• Measure the level of work ethics of employees and partner employees
• Use the data for improving the enterprise-wide level of ethics and encourage voluntary improvement efforts by providing the feedback to each organization- Create a ripple effect for employees and partners in the process through the company's commitment and expectations to ethical management