Whistle-blowing System | Hanwha Ocean

Whistle-blower System

A ship and three people with their hands together in the middle of the circle

The purpose of this system is to
clearly articulate and effectuate an
internal reporting process of any
inappropriate activities
(unlawful/unethical/corrupt activities)
that can occur inside and outside of the
company in the ordinary course of
business.

Reporting Process
1. 1. Applicable Activities
  1. 1.1 Accepting inappropriate bribes, entertainment, or favors from stakeholders
  2. 1.2 Taking advantage of his/her job position to gain profit or causing damage to the company
  3. 1.3 Interfering with other employee's work to benefit oneself or others
  4. 1.4 Disclosing company's confidential information and customer information without permission
  5. 1.5 Collusion among stakeholders such as bid rigging to close a deal
  6. 1.6 Spreading malicious rumors and lies and damaging the company image or reputation of certain employees
  7. 1.7 Retaliation against whistle-blowers by exposing the identity or unfair treatments
  8. 1.8 Other activities in violation of code of ethics, employee code of conduct, and laws
2. 2. How to File a Report
  1. 2.1 A report may be made using the real name or anonymously. However, in case of an anonymous report, there may be a difficulty in the investigation and the payment of compensation, so it is recommended to make a report using the real name.
  2. 2.2 Include the name of reporter (if reporting with real name) and the information of the person involved in the alleged misconduct in detail and provide the supporting documents if there is any.
  3. 2.3 Where to File
    1. (1) Online Report Channel: Company Website or Company Portal
    2. (2) Visit the Duty Diagnosis Department 2 or Call: Phone) 055-735-4400, Fax) 055-735-9102
    3. (3) Report by mail: Duty Diagnosis Department 2, 3370, Geoje-daero, Geoje-si, Gyeongsangnam-do, 53302 Korea
    4. (4) Reports can also be filed at different locations by different methods upon request.
3. 3. Duty of a Whistle blower
  1. A person who reports must not intentionally make a false accusation to defame or slander others.
4. 4. Follow-up Procedures
  1. 4.1 Duty Diagnosis Department 2 clarifies the submitted information as soon as possible.
  2. 4.2 Reports the information to the Head of Duty Diagnosis Division and conducts an investigation. However, if after reviewing the submitted information, the alleged violation is determined to be not applicable or its obscurity makes it impossible to verify the report, or it is a minor violation having no significance in relation to duty diagnosis, the Office can close the case at its sole discretion.
  3. 4.3 When the report turns out to be a false accusation, the applicable department can request disciplinary action against reporter to degree of damage.
  4. 4.4 Once the approval by the manager who has the authority is obtained, duty diagnosis results, along with any disciplinary or corrective action necessary, will be notified to the pertinent department.
Whistleblower Rewards
1. 1. Applicable Activities
  1. 1.1 Reporting of employee’s acceptance of bribes, entertainment, or favors
  2. 1.2 When the report of the violation resulted in increasing profit or reducing loss to the company.
2. 2. Basis of Reward
  1. 2.1 Reward Amount Limit
    1. (1) A report of employee’s acceptance of a bribe, entertainment, or favors: KRW 30 million
    2. (2) When reporting the violation resulted in increasing profit and reducing loss to the company: KRW 100 million
  2. 2.2 When more than two grounds for the reward exist for a same case, whichever is larger will be applied.
  3. 2.3 The bribery amount or the effect of increased profit or reduced loss that turned out to be irrelevant to the submitted report the inspection is excluded.
3. 3. Calculation of the Reward
  1. 3.1 Reporting an employee's acceptance of bribes, entertainment, or favors: Five times the received amount
  2. 3.2 When reporting the violation resulted in increasing profit and reducing losses to the company: in proportion to the amount contributed
  3. 3.3 If the amount of the reward is small, the ₩300,000 minimum reward shall apply. For individuals who are not eligible to receive a reward as per these regulations but nevertheless provide a report of material contribution to the elimination of ethical violations from the business sites of this organization (e.g., Fabricated payment request by an employee of a partner), a gift certificate no greater than ₩200,000 in value may be presented.
4. 4. Exclusion to the Reward
  1. 4.1 When the submitted report turns to be false or impossible to prove due to lack of evidence
  2. 4.2 When the report is released to the media or reported to company already
  3. 4.3 When the report is submitted anonymously, and it is not possible to identify reporter
  4. 4.4 When the report is submitted by a member of Duty Diagnosis Division
  5. 4.5 Other cases deemed to be inappropriate for reward
5. 5. Leniency Program for Self-reported Misconduct
  1. 5.1 If you report yourself for receipt or acceptance of money, convenience or entertainment to the Head of Duty Diagnosis Division (Whistleblowing Center), Legal planning Department (Portal>Ethical Compliance>Ethical Management>Gift>Self-Report on Graft) within 7 working days from the date of recognizing such incidents, you will be exempted from responsibility.
  2. 5.2 When an employee self-reports his/her intentional act or mistake which caused damage to the company immediately after the recognition, the disciplinary action will be mitigated.
  3. 5.3 Exception
    1. (1) When Duty Diagnosis Division had already started an investigation of the pertinent case at the time of self-reporting
    2. (2) When the self-reporting employee refuses to return the inappropriately accepted benefits or compensate the company for the damage caused
  4. 5.4 When the employee whose disciplinary actions were exempted or mitigated under the leniency program makes a second offense for the same or similar activity is subject to aggravating circumstance.
6. 6. How the Reward is Paid
  1. Reward payment is to be processed by a minimum number of personnel in order to protect the identity of the reporter.
  1. 6.1 Duty Diagnosis Division is to fill out the reward recipient’s information (name, copy of bankbook in the recipient’s name, reward amount, and payment details: duty diagnosis aid) and deliver it in person to Tax and Accounting Division.
  2. 6.2 Tax and Accounting Division is then to transfer the reward (having deducted the applicable withholdings tax) and deliver a transfer statement, along with an NDA signed by all individuals involved, to Duty Diagnosis Division.
  3. 6.3 Duty Diagnosis Division is to then inform the recipient about his or her tax liabilities (general income tax report, etc.).
Protection of the
Whistleblower
1. 1. Prohibition of Exposing Identity or Tracking Down
  1. 1.1 Any employee who accidently or in his/her course of business comes across the identity of a reporter or the submitted claim shall not disclose the pertinent information to anybody.
  2. 1.2 The person involved in the alleged misconduct or anyone from his/her department shall not make any attempts to find out the identity of reporter by asking Duty Diagnosis Division or questioning other employees.
  3. 1.3 Anybody who violates any one of the above articles is subject to disciplinary action.
2. 2. Managing the Exposed Whistle blowers and Prohibition of Unfair Treatment against the Whistle blower
  1. 2.1 When a reporter's identity is exposed, he/she shall report the incident to Duty Diagnosis Division, who will then track down the route and request disciplinary action.
  2. 2.2 Any discrimination or unfair treatment against reporter is prohibited, and any violator is subject to disciplinary action.
  3. 2.3 When a reporter believes he/she was discriminated or received unfair treatment or such actions are expected, he/she will request Duty Diagnosis Division for protection measures, such as a change of position. Duty Diagnosis Division shall make their best efforts to solve the situation without detriment to reporter after conducting through research.

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Hanwha Ocean

Whistle-blower System

Online Whistle-blowing

Anti-Corruption 3 Principles

1. Zero Tolerance to Corrupt Practice

2. Engagement of Leaders in Anti-Corruption Campaign

3. No Leniency for Corruptors

Hanwha Ocean