Code of Ethics < Ethical Management

1. Purpose

The purpose of this Code of Ethics is to present the standard for ethical decisions and conducts to practice and correct decision making for officers and employees in the process of practicing the Ethical Management of Sinokor Group (hereinafter referred to as the ‘Group’).

2. Obligation of Compliance

All officers and employees of the Group have to comply with the Code of Ethics for developing into excellent global logistics enterprise and building up the corporate culture striven for the Ethical Management.

3. Scope of Application

1) This Code of Ethics shall be applied to all officers and employees of holding company, subsidiary company and grand-subsidiary companies of the Group.
2) Subsidiary companies and sub-subsidiary companies may operate separate Ethics Guideline within the scope not to interfere with the vision and policy of this Code of Ethics and the Ethical Management of the Group.

1. Customer Satisfaction

1) Provide the best service to customers at all times and work hard to grow with customers.
2) Always listen to the opinions and proposals of customers and humbly accommodate their needs.
3) Regarding the customer complaints, it shall be disposed as promptly and fairly as possible and make sure to respond to customer for its result.

2. Customer Protection

1) Provide accurate and fair information in due time to customers at all times.
2) The information of customers has to be securely managed, and in the event that it is required under laws and regulations, it shall not disclose pertinent information or use the same for any other use without the consent of customer.

3. Customer Respect

The customers are the highest standard for all decisions and conducts by thinking in the position of customers with the kind attitude and genuine mind under the conception that the customers are the reason for the Company’s existence.

4. Generating Customer Value

Under the recognition that the customer advancement would be our advancement, place the effort to generate the added-value required for customers at all times.

1. Structuring Fair Transaction Procedure

1) All vendors equipped with certain qualification shall be provided with the equal opportunity to participate in transactions.
2) Evaluation on any vendor shall follow objective and fair deliberation standard.
3) Evaluation on any vendor shall be shared with the vendor and mutual cooperation shall be made for improving the transactions.

2. Striving for Mutual Development with Vendor

1) All vendors may have free opinion in relation to the transactions and in the event that the contents are reasonable, they shall be actively reflected in transactions.
2) In the event that any information and know how are acquired to be helpful for the vendors in the product or service use process, it shall be provided to the vendors.

3. Structuring of the Ethical Management system

1) All transactions with vendor shall be maintained in transparent and fair manner and cooperation shall be made to enable win-win for both.
2) Place efforts in various methods for establishing sympathy with vendor for the Ethical Management.
3) In the event that there is any material violation related to the Ethical Management, such as, causing environment pollution, exploitation of labor or the like in the product manufacturing and distribution process of vendor, an action may be undertaken for reduction of transaction, suspension or the like.

1. Compliance with fair transaction

1) In all business activities in Korea and overseas, the fair transaction order shall be followed.
2) Various laws (for the case of Korea, "the Act on Monopoly Regulation and Fair Transaction", the "Anti-Corruption Act" and others) shall be complied with for various international contracts and fair transactions of each country.

2. Fair and Free Competition

1) The principle of free competition shall be complied with and the order of market economy shall be respective anywhere in the world.
2) Through the fair method, good faith competition with the competitors would be striven for and it shall not use the weakness of competitor unjustly.

1. Basic Ethics for officers and employees

1) With high ethical value point, the management vision and motto of the Company shall be shared and practiced.
2) Dignity of individual officer or employee and honor of the Company shall be honored and officer or employee shall place the best effort in the works with the sense of pride as an officer or employee of the organization.
3) All officers and employees shall place effort to conform to the human resource image sought by the Company and place the best effort for self-advancement to have the competitiveness in the global market under the globalization era.

2. Avoidance of Conflict of Interest with the Company

1) During the work performance, one shall not accept any type of goods or entertainment from the interested party or provide any of the same.
2) In the event that the understanding of the Company and understanding of each officer or employee are in conflicting while carrying out the duty, the interest of the Company shall be considered with the priority.

3. Fair performance of duty for Vendor

1) One shall carry out the duties with the legitimate and ethical method in accordance with pertinent laws and regulations and regulations of the Company.
2) One shall clearly recognize the rights and responsibilities given in accordance with the corporate policy and intention and one shall be liable for the result.

4. Protection of the Company’s Assets and Maintenance of security

1) All officers and employees shall use the Company assets appropriate to the work purpose and it shall be responsible for loss, erroneous use and theft of assets.
2) Any expense of the Company shall be public fund that shall be used for the sound corporate activities.
3) All tangible assets and intangible assets of the Company shall not be abused or displayed to any third party at will and such shall be maintained as secret perpetually even after the withdrawal from the Company.

5. Accurate • Honest report

1) Do not mislead the decision making of the superior or pertinent department by manipulating the document and coefficient or making false report that is different from the fact.
2) Any report required for the work performance shall be reported accurately and honestly in due time.

6. Practice of ethics Mutually for officers and employees

1) All officers and employees shall place effort for building up the sound organizational culture with the attitude to respect and considerate without preconception, bias, or preference on the basis of good manner.
2) Instruction of superior on work shall have the best effort to carry out with the exception of illegal or unjust case for its contents.
3) No criticism of others or no physical and verbal act to cause violence, disruption of social norm, sexual harassment or the like against others shall be undertaken.
4) No faction for blood, regional and academic ties shall be established or formulate private organization and so forth within the workplace.
5) While in employment, an employee shall not be engaged in outside concurrent position, sideline, or additional work.
6) Any act of receiving favors, brokerage, monetary transaction and acceptance of goods between officers and employees shall be prohibited.
7) It shall have the responsibility to supervise with the help for officers and employees to comply with pertinent laws and regulations and ethical provisions.

7. Mutual Respect and No Discrimination between Group Companies

All officers and employees shall have mutual respect for group companies, maintain the organic cooperation to maximize the group synergy and it shall not have any discrimination following the position in the group.

1. Respect and Fair Treatment for Individual officers and employees

1) Basic human rights of officers and employees for each individual shall be respected and effort is placed for building up the work environment where all officers and employees feel the pride and joy on the respective job.
2) Equal opportunity shall be granted to officers and employees and it shall be evaluated and compensated with the fair standard in accordance with the accomplishment and outcome.

2. Development of Human Resources

The system required for officers and employees to grow into autonomic and creative personal talent shall be equipped with and implemented.

3. Guarantee of Self-Regulated Expression of Intent

The autonomic intent is guaranteed by having the system required for indicating any problems and make proposal freely for all officers and employees.

4. Health and Safety of officers and employees

1) The work environment for officers and employees to pleasantly and safely work shall be established.
2) For the health promotion of officers and employees, the effort shall be made to deploy the regular examination, disease prevention activities and others.

5. Obligation to Protest whistle blower

1) Any personal information of officers and employees that reported the fact of act against the Code of Ethics or seeking for illegal profit as well as contents of such report shall be guaranteed with thorough secrecy.
2) Any officer or employee of the report shall be protected from adverse interest on the personnel from its reporting.

1. Maximization of Corporate Value

1) New value of company shall be generated through the continuous management innovation and sound financial structure.
2) The maximization of justifiable interest shall be striven for with the reasonable and efficient management.
3) The competitiveness of existing business shall be strengthened and the sustainable industry shall be promoted.

2. Transparent Management

1) The accounting data shall be accurately and clearly recorded and managed in accordance with the pertinent laws and regulations and accounting principle.
2) The corporate contents shall be transparently notified in accordance with legitimate procedure to make reasonable investment decision for shareholders and investors.
3) The system to enhance the transparency of management shall be equipped with and implemented.

3. Protection of Rights of shareholders and investors

The Company shall place effort to protect the interest and right of shareholders and investors and enhance the investment profit.

1. National Economic Development

The Company shall contribute to the national economic development through continuous employment generation and diligent tax payment.

2. Social Contribution Activities

1) The officers and employees are guaranteed with the participation in social service activities, such as, volunteer service, disaster relief and the like, and actively supported, and contribute the advancement of local community as a constituent.
2) Culture, art and sport activities are supported and make effort to conserve the traditional culture.

3. Environment-friendly Management

1) Preventive environment protection activities are deployed for resource savings, use of environment-friendly product, environment-friendly technology development and so forth.
2) International standard, pertinent laws and regulations and internal regulations related to the environment protection shall be complied with.

4. Political Neutrality

1) The Company shall not involve in the politics of applicable country and the political neutrality shall be the basis in principle.
2) The Company shall respect the individual right to vote of officers and employees but the political activities or meetings of officers and employees shall be prohibited.

5. Performance of obligations for Corporate Citizens

1) The corporate value increase and profit generation shall be made through continuous growth, and make contribution to the social development with the employment and diligent tax payments.
2) All officers and employees shall comply with pertinent laws and regulations of the applicable region regardless of home or abroad to fulfill its social responsibilities as the corporate citizens.
3) No officers and employees shall receive or provide any bribery in illegal goods or entertainment and avoid any corruptive act of any other types.

1. Ethical Management and Etc.

1) In the event that any officer or employee violates the Code of Ethics, Department in Charge of Ethical Management shall investigate it to report to Ethics Committee.
2) In carrying out the duties by Department in Charge of Ethical Management, officers and employees shall duly comply with it in the event that data or information is required to submit.
3) Each division of the Company shall have a person in charge of the Ethical Management works (hereinafter referred to as the ‘responsible person of ethics’).
4) Department in Charge of Ethical Management shall establish and revise the Code of Ethics for officers and employees to comply with and practice of the Code of Ethics and it shall be in charge of education and publicity of the Code of Ethics with the responsible person of ethics.

2. Obligation to Report

1) In the event that there is a need of consulting in relation to the application and compliance with the Code of Ethics, officers and employees may consult with the responsible person of ethics and Department in Charge of Ethical Management at anytime.
2) In the event that there is any coercion or recognition of any act in violation of the Code of Ethics, officers and employees shall be able to report the same to the responsible person of ethics or Department in Charge of Ethical Management and the report shall be based on the objective fact.

3. Reward and Disciplinary Action

1) The Company may reward in accordance with the provisions related to officers and employees that have merits in accomplishing the purpose of the Ethical Management.
2) Any officer or employee in violation of the Code of Ethics shall be subject for corresponding disciplinary action in accordance with the company regulations pertinent to personnel of the Company.

1. Date of Implementation

This Code of Ethics shall be implemented from January 1, 2018.

2. Interpretation of the Code of Ethics

In the event that it is not defined on the Code of Ethics or in the event that there is different opinion to construe each provision in relation to the activities of the Ethical Management of officers and employees, the interpretation and decision of the Ethics Committee shall be followed.