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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.

  • Ban on giving and accepting gifts, entertainment or favors

    1. 1. Regardless of whether or not something was expected in return, giving, demanding or accepting gifts, entertainment or favors from stakeholders for any reason is prohibited. However, exceptions are made if the amount is within a generally acceptable level (below KRW50,000) and it is acknowledged that the offering party is acting voluntarily with pure intentions and the gift, entertainment or favor creates no obligation.
    2. 2. Acceptance by an employee’s family members, relatives or acquaintances will be regarded as acceptance by the said employee
    3. 3. If an employee inevitably receives a gift, entertainment or favor against his/her will, he/she shall immediately return the said gift, entertainment or favor or the monetary equivalent thereof and notify the Ethics Team
  • Restrictions on socializing with stakeholders

    1. 1. Regardless of how the cost was shared, engaging in activities such as golfing and taking overseas trips with stakeholders who have a practical and direct connection to one’s work is prohibited. If an employee engages in such an activity due to unavoidable circumstances, he/she shall give prior notice to his/her superior. If prior notice is not possible, notice shall be given immediately after the activity ends.
  • Restrictions on notice of major family events

    1. 1. Employees shall refrain from indiscriminately and actively informing stakeholders of major family events, whether they are personal or pertain to colleagues.
    2. 2. Employees may not accept excessive condolence or congratulatory gifts from stakeholders. Even if a gift is accepted due to inevitable circumstances, it must be returned to the provider.
  • 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, partner companies, and affiliates of clients) 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.
    4. 4. Any incidence of above-mentioned transactions with stakeholders shall be reported to the Ethics Team.
  • Prohibition of unfair intervention and solicitation

    1. 1. Employees may not exploit their position for wrongful gains or for causing others to reap wrongful gains.
    2. 2. Employees may not make solicitations for their promotion, assignment or other HR related matters through acquaintances within or outside the company.
    3. 3. Employees may not make solicitations for hiring, promotion, assignment or other HR related matters of family members, relatives or acquaintances to the company or stakeholders.
    4. 4. Employees may not make solicitations for supplier registration or business transactions involving companies run by family members, relatives or acquaintances to the company or stakeholders.
  • Handling wrongful 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 an order that is not carried out in accordance with Paragraph 1 is given again, the pertinent subordinate shall immediately notify and consult with the Ethics Team.
  • Separation of company and personal affairs

    1. 1. Employees may not use the company’s budgets, assets and information for personal gain.
    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 carry out work activities for another firm without the company’s consent.
  • Prohibition of political activities

    1. 1. Employees may express their personal political views. However, they must clearly convey that such views are personal views and do not represent the company’s official position.
    2. 2. Employees may not engage in any form of political activity within the company, and may not utilize the company’s organizational units, personnel or property for political purposes.
  • Fair competition

    1. 1. The company shall compete in good faith against competing firms and refrain from wrongful violation of competing firms’ interests.
    2. 2. The company shall comply with the laws and regulations of countries in which it operates including anti-bribery rules involving public officials.
  • Compliance with regulations

    1. 1. The company shall comply with the laws and regulations of countries in which it operates including anti-bribery rules involving public officials.
    2. 2. Organizational unit leaders shall carry out training, consulting and preventive measures to ensure that employees in their respective units understand and abide by the Code of Ethics and the Implementation Guidelines.
    3. 3. Employees shall notify the Ethics Team if they are forced to take action that violates the Code of Ethics and the Implementation Guidelines or become aware of any such violation.
    4. 4. The Ethics Team will faithfully investigate all reported cases and protect the informants’ identity and confidentiality. The Ethics Team will take all steps necessary to ensure that informants do not receive unjust treatment or disadvantages for reporting a case. Employees who become aware of an informant’s identity by chance or during the course of carrying out their duties shall not reveal the informant’s identity.
    5. 5. Employees shall direct questions on matters not explicitly stated in the Code of Ethics and the Implementation Guidelines to the Ethics Team and comply with the Ethics Team’s interpretation.
  • Restriction on transactions with a corruptive retiree or resignee

    1. 1. Any transactions with (i) a retiree or resignee who was retired or resigned due to his/her corruptive acts or intentionally committed acts subject to dismissal during his/her employment, or (ii) any entity, the management of which such retiree or resignee is participated or involved in, are strictly prohibited. The entity referred in (ii) above includes the entity that the retiree or resignee subject to (i) above is a president, director, or officer thereof, or an owner or major stakeholder, whether directly or indirectly, thereof.
    2. 1.1 The restriction or prohibition as set forth herein shall also apply for a retiree or resignee who is found, after his/her retirement or resignation, to be corrupted or to have intentionally committed acts subject to dismissal during his/her employment
    3. 2. Prior to execution of contracts or registration of contracting entity, Company (or the team in charge of contract execution in Company) shall scrutinize the possibility of the transactions as referred in paragraph 1 above.
    4. 3. The restriction with the retiree or resignee as referred in paragraph 1 shall apply for a period of ten (10) years of his/her retirement or resignation.

[Definition of terms]

  1. 1. Stakeholders: Suppliers, partner companies, clients, groups and individuals whose rights and interests are affected by one's business activities.
  2. 2. Money and goods: Monetary gifts (cash, marketable securities, gift certificates, coupons, etc.) and goods (presents, souvenir, etc.)
  3. 3. Entertainment: Meals, drinks, golf, performances, gambling, etc.
  4. 4. Favors: Favors: Transportation, accommodation, sponsorship of special events, sightseeing, etc.
  5. 5. Acceptable gifts: A gift accepted, judging by sound common sense, that allows work to be handled in a fair manner without posing a burden on either party.
  6. 6. Inevitable circumstances: Unable to refuse due to the absence of the recipient, or when it is deemed to be rude to make strong refusal.