1. Purpose

The purpose of this Guideline is to define the Behavior Guideline for officers and employees to comply with and matters required for practicing the Code of Ethics.

2. Definitions of Terminologies

• 1) Officers and employees : It means all officers and employees receiving the wages in consideration of providing labor to the Company, and officers and employees of agency that works on all or part of company works, consultant, and contract position may be considered as officers and employees in accordance with the pertinent matters.
• 2) Family members : It means the spouse of applicable officers and employees, direct relative of applicable person and spouse, and relative within 4th degree of lineage.
• 3) Interested parties : It means all natural persons, corporate entities, and other organizations in and out of the Company influenced for rights and interests from the act of officers and employees and decision making related to this work and it shall be classified as follows.
  • ① Vendor : A subject body of conduct to provide the goods or service to affiliated company of Sinokor Group
  • ② Other Interested Party : Any interested party besides vendor
• 4) Informer and reporting person
  • ① Informer : Any person informing or testifying any unethical conduct of an officer or employee
  • ② Reporting person : Any person recognizing the fact that an officer or employee engaged directly in unethical conduct and report the same
• 5) Act of applicable party : In the event that this Guideline is violated through the act of applicable person as well as act through its family members, it shall be considered as the act of the applicable person.
• 6) Conflict of interest : It means the situation that may seem to influence on the work decision with the personal interests of officers and employees.
• 7) Inevitable situations : ‘Inevitable situation’ means the case where it is determined to accept if refusal of it would be considered as rude for the favorable treatment or the case of receiving through family member, relative or a third party or the applicable party is unable to recognize the fact.
• 8) Superior : ‘Superior' means the authority or capability to place the other party in superior or adverse position under such a relative concept and, such ‘superior position‘ means to use the superiority to take better position than the other party in the transaction relationship that it is realized by the asymmetric decision making position.
• 9) Ordinary level
  • It means the level to understand when considering with the common knowledge by other officers and employees or non-beneficiary.
  • ① A level that is recognized with the justification when disclosed to an ordinary person
  • ② An act to dispose the work in fair position without forcing the beneficiary with any burden

3. Applicable Category of the Ethics Guideline

When carrying out the work, the types of regulation subjected to the unethical behavior are showing as follows.

• 1) Transparent and fair transaction with Vendor
  • (1) Conflict of interest with Vendor: Work stipulation and transparent transaction
  • (2) Providing unfair opportunity: Rejection of transaction, restriction of participation and discrimination
  • (3) Unfair transaction: Illegal transaction, illegal support, business interference
  • (4) Disclosure of supplier Information
• 2) Integrity in Work Performance
  • (1) Reception of Money and/or goods : Money, gift, congratulatory and condolence payment
  • (2) Accommodation and reception : Meal, illegitimate business premises, speculative recreation, high-cost sports
  • (3) Providing convenience : business trip support, personal leave support, office fixture, sponsorship/endorsement
  • (4) Monetary transaction : Borrowings, low-price purchase, high-price selling, debt repayment, guarantee of loans, monetary lending, joint investment
  • (5) Guarantee on future : Brokering of Employment and promise to enter into a contract
  • (6) Act of providing entertainment to interested party : Meal, gift, congratulatory and condolence payment, lecture fee of interested party, illegitimate business premises, speculative recreation, high-cost sports
• 3) Justifiable use of company assets
  • (1) Use of tangible assets and intangible assets for other purpose: Embezzlement and misuse of tangible assets and misuse of intangible assets
  • (2) Embezzlement and misuse of fund
  • (3) Misuse of job information : Information discharge, customer information discharge, and company personnel discharge
• 4) Preparation and management of important information
  • forgery, alteration, and false report of documents
• 5) Practice of Ethics for officers and employees
  • (1) Behavior Guideline on work: No distinction of work, neglect of duty, neglect of management and supervision, overreaching conduct, unreasonable work disposition
  • (2) Behavior Guideline to maintain sound organizational culture: Faction based on blood, regional and academic ties, sexual harassment, interference with the organization atmosphere, loss of dignity, delivery of bribery, demand for money and entertainment to subordinates, monetary transaction between employees, concurrent business and sideline, favor for personnel, other interference with work discipline

1. Basic Principle

• 1) “Vendor” in this principle represents vendors that provide services, and so on, to the Sinokor Group in a superior position, so the “Vendor” excludes government entities or monopolistic enterprises in this principle; also, in transaction with the vendor, officers and employees shall strictly comply with the pertinent laws and regulations of the “Act on Monopoly Regulation and Fair Transaction“ and others.
• 2) Suppliers in the transaction shall select the optimal supplier based on fair and transparent principle. This principle shall be complied with in all transactions including the simple service contracts as well as mass purchase contracts.
• 3) In the event that there is a need for restriction or adjustment on the transaction condition with the vendor, it shall be processed by clear and reasonable cause and transparent procedure.
• 4) There shall be no inequality, illegal treatment or unkind transaction act by using the superior position.
• 5) For transaction with vendor, interests of the Company shall be considered with the priority and no personal gain related to the individual profit shall be taken.
• 6) With respect to any vendor with personal interests, officers and employees shall not exercise any influence when making the transaction by reporting to the applicable officer or employee in advance.
• 7) Subject to practice the fair transaction related Ethics Guideline
  • - Constituents of purchase/service work related purchase department
  • - All officers and employees related directly or indirectly to other pertinent works

2. Conflict of Interest with Vendor

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Work stipulation	• Work stipulation with vendor	Place limited	Report in other than designated place
  Transparent transaction	• Pursuit of personal gain from vendor • Demand for employment guarantee, employment brokerage and transaction guarantee • Acquisition of equity and joint investment of vendor	Prohibited	Report upon reception

• 2) Work stipulation with vendor
  • (1) Meeting for work cooperation with the approval by the authorized person shall be interviewed in the company in principle.
  • (2) In the event that a meeting is needed at outside location for flawless work cooperation and standard under the inevitable situation, it shall be an exception for setting the place of meeting at a coffee shop or nonalcoholic beverage offering shop.
  • (3) Notwithstanding the above Paragraph (2), when the work standard at the place other than designated location is turned into entertainment and reception, it shall be aggressively opposed or avoided.
  • (4) For the flawless work cooperation and standard under inevitable situation, it shall be an exception to provide meal service to vendor when stipulating the work in the Company.
  • (5) Notwithstanding the above Paragraph, in the event that the entertainment or reception is received or provided from the vendor, it shall be reported to Department in Charge of Ethical Management.
• 3) Transparent transaction with Vendor
  • (1) In relation to the performance of duty, the officers and employees shall be barred from seeking of personal gain directly or indirectly from the vendor and its officers and employees.
  • (2) All officers and employees shall be refrained from demanding for Guideline of employment after resignation, brokerage of employment, transaction stipulation and others to vendor or accept any proposal thereof.
  • (3) No officers and employees may engage in any conduct for joint profit, such as, investing jointly with vendor or acquiring the equity of vendor, and it shall not engage in concurrent position as an officer or employee of vendor.
  • (4) Vendor shall take the Oath to comply after fully recognize the policies and regulations of the Ethical Management of the Company.
  • (5) An officer or employee shall take following measure for the settlement of the transparent transaction.
    • ① In the event that any officer or employee receives the proposal of the above Paragraph (2) or (3) from vendor, it shall be reported to Department in Charge of Ethical Management.
    • ② In the event that an officer or employee is engaged in illegal activity in relation to the above Paragraph (2) or (3)without the approval of the Company, the transaction with the relevant vendor shall be suspended for 2 years from the date of confirming such act as true and it shall be applied consistently even for the case of the officer or employee of applicable vendor is retired. (However, the transaction suspension period may be adjusted through the resolution of the Ethics Committee.)
    • ③ In the event that there is any illegal act of the above Paragraph (2) or (3) without obtaining the approval of the Company, applicable officers and employees shall be subject of disciplinary action.

3. Providing Unfair Opportunity

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Refusal of transaction	• Refusal for unilateral transaction without justifiable cause • Exclusion of transaction participation • Taking away of opportunity	Prohibited	Report when acted on
  Restriction of participation	• Establishment of exclusive transaction condition • Establishment of transaction territory without basis • Limited to the other party of transaction	Prohibited	Report when acted on
  Discrimination	• Granting benefit only for specific company • Difference in purchase price of same product • Discrimination on order frequency of same product • Discrimination in proceeds payment term	Prohibited	Report when acted on

• 2) Behavior Guideline
  • (1) The officers and employees of the Company shall not engage in any of the followings intentionally for specific vendor.
    • ① Refusal of transaction : In the event that the transaction is rejected without detailed cause even though there is no special disqualification cause of the Company regulation regarding the participating qualification or having legal problem
    • ② Restriction of participation : For selecting specific vendor or excluding avoided vendor
      • - In the event that the condition is exclusively set
      • - In the event that the party to the transaction is limited due to unclear cause
    • ③ Discrimination : For rendering adverse benefit to avoiding vendor or giving incentive to preferred vendor
      • - In the event that the transaction conditions are applied discriminatorily
      • - In the event that there is no contribution to the enhancement of competitiveness of the Company but to protect existing vendor, prefer vendor of retirement or prefer the vendor of blood, regional and academic ties relationship
  • (2) If there is any cause to restrict the transaction with the vendor inevitably, the cause shall be reported to the authorized person and obtain the approval in accordance with the procedure defined by the Company.

4. Unfair Transaction

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Illegal transaction	• Unilateral volume control, illegal low-price purchase, unilateral change of contract conditions, intentional delay of proceeds payment, unilateral transaction cut off due to illegal cause	Prohibited	Report when acted on
  Illegal support	• Illegal funding, personnel and asset support	Prohibited	Report when acted on
  Business interference	• Illegal hiring by vendor personnel, transaction interference with competitor, other interference with business activities	Prohibited	Report when acted on

• 2) Behavior Guideline
  • (1) The vendor shall be granted with fair opportunity and condition in accordance with the principle and procedure defined by the Company and it shall not apply the following act intentionally.
    • ① Unjust transaction : Any act of adjusting the transaction condition unilaterally without advance stipulation when there is any cause to change the contract condition within the contract period
    • ② Unjust support : Any act to support illegally for the purpose to secure the competitiveness with the purpose to secure the competitiveness edge of specific vendor
    • ③ Business interference : Any act of interference on business intentionally or without advanced stipulation with vendor
  • (2) In the event that there is an inevitable cause to modify the transaction condition with the vendor, the cause shall be reported to the authorized person under the procedure defined by the Company to obtain the approval, and if necessary by the foregoing, it shall be stipulated with the vendor.

5. Disclosure of Supplier Information

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Information discharge	• Disclosure of pertinent information acquired from vendor to outside	Prohibited	Report when acted on

• 2) Behavior Guideline
  • (1) All information of vendor provided for transaction relationship shall not be discharged to outside without the approval by the authorized person.

1. Basic Principle

• 1) If the interested party provides goods, entertainment and reception, convenience, monetary transaction, guarantee on future or others, it shall influence on normal decision making that such provision shall first be refused cordially.
• 2) Notwithstanding the above Paragraph 1), in the event that such has been provided by the interested party, no punishment shall be rendered in the event that the self report and post disposition have been made in accordance with the procedure set forth under the following Paragraph. However, for the prohibited act excluding the conduct provided under the inevitable situation, reporting and post disposition alone would not exempt from the punishment
• 3) In the event that officers and employees recognizes that a colleague has received money, entertainment and reception, convenience, monetary transaction or guarantee on future but failed to report and take post disposition following the regulation, they shall report to the Company in accordance with the subject Guideline.
• 4) Family members of officers and employees shall not receive or demand any treatment considered as provided in relation to the work from any interested party.

2. Type of Money and Goods and Ethics Guideline

• 1) Direct reception
  • (1) In the event that the applicable party received the money/goods from the interested party
  • (2) In the event that family member, relative or friend received money/goods from the interested party and delivered it to the applicable party
• 2) Indirect reception
  • (1) In the event that the superior received money/goods from the interested party and delivered it to the lower ranking party
  • (2) In the event that the lower ranking party received money/goods from the interested party and delivered it to the high ranking party
  • (3) In the event that money/goods are received from the interested party to exchange with the same ranking party
• 3) Violation of the Ethics Guideline
  • In the event that goods or money is received directly and indirectly from the interested party, all shall be considered as the violation of the Ethics Guideline in principle.

3. Reception of Money and/or Goods

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Money	Cash or cash equivalent goods, including cash, check, marketable securities	Prohibited	Report and entrust
  Gift	Including gift, gift certificate, tickets, golf practice, health club access, and other sales promotion and discount benefit	Prohibited	Report and entrust (However, report and entrust when receiving beyond limit for gift following the social norm)
  Congratulatory and condolence payment	congratulatory and condolence payment and goods (anniversary ring and etc.)	Prohibited for intentional notice	Report and entrust when receiving beyond limit

• 2) Exception
  • (1) Souvenir distributed by the interested party for publicity purpose or souvenir ordinarily provided to attendees in events managed by the interested party
  • (2) Goods provided openly for helping out officers and employees under difficult situation from disease, disaster and so forth
  • (3) Goods provided openly to officers and employees from employee cooperative and etc.
  • (4) Other goods permitted in accordance with laws, regulations or social norm

• 3) Behavior Guideline when receiving money
  • (1) In the event that any money is received from the interested party, it shall not be received regardless of any reason, and it shall be refused or returned cordially.
  • (2) In the event that any money is received from the interested party, it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience" and the money provided shall be entrusted to Department in Charge of Ethical Management.

• 4) Behavior Guideline when receiving present
  • (1) In the event that any gift is received with possible conflict of interest from the interested party, it shall be rejected or returned cordially.
  • (2) For the case of sales promotion or discount benefit, it may be received only for the case permitted to everyone, but it shall be considered as gift for the case of falsified sales promotion materials attaching only the logo on the high-priced gift under the social perception.
  • (3) In the event that there is any proposal from interested party on providing the gift, the Ethical Management policy of the Company shall be explained and reject it resolutely and cordially to cut off the gift providing conduct.
  • (4) In the event that the gift is provided from a vendor, it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience" and the gift provided shall be entrusted to Department in Charge of Ethical Management.
  • (5) In the event that the applicable party does not know the fact of gift provided by the other interested party and in the event that it is the gift provided by the official event of the Company, they shall be disposed as follows.
    • ① In the event that the gift is received within the decision standard limit following the social norm, the personal ownership is possible after reporting to the authorized person.
    • ② In the event that the gift beyond the decision standard limit following the norm or gift at the ordinary time is received, it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience" and the gift beyond the decision standard limit shall be entrusted to Department in Charge of Ethical Management.
    • ③ In the event that it is difficult to entrust the gift provided to Department in Charge of Ethical Management, it shall be disposed in accordance with the disposition procedure of Department in Charge of Ethical Management.

• 5) Behavior Guideline to dispose congratulatory and condolence payment
  • (1) No officers and employees may receive any flower, orchid, or other flower base from the a vendor, and in the event that congratulatory and condolence payment or others is provided, it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience" and the money or goods beyond the decision standard limit shall be entrusted to Department in Charge of Ethical Management.
  • (2) All officers and employees shall not notify the fact of personal events to the interested party in advance. (However, information on the Company for employees may be posted or forwarded via company mail or bulletin board.)
    • ① Any act of delivering or forwarding the invitation to the interested party.
    • ② Any act to post on bulletin board where outside interested party may observe
    • ③ Any act to publicly informing the contents of congratulatory and condolence payment
  • (3) In the event that there are goods, such as, congratulatory and condolence payment or gift, flower or the like beyond the limit of decision standard from the other interested party is provided, it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience" and the money or goods beyond the decision standard limit shall be entrusted to Department in Charge of Ethical Management.
  • (4) In the event that any flower, orchid, or other flower base is provided to congratulate for the interested party of promotion, it shall be disposed in accordance with the Behavior Guideline when receiving the gift.

4. Accommodation and Reception

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Meal	Excessive meal in high-class Japanese restaurants, Korean restaurants, hotels and others	Prohibit excessive meal	Report upon receiving in excess of limit
  Illegitimate business premises	Room salon, drinking hole, night club, massage parlor, high class barber shop, high class sauna, other luxury entertainment sites	Prohibited	Report upon receiving
  Speculative recreation	Go-Stop, casino, gambling	Prohibited	Report upon receiving
  Sports	High-cost sports of golf, ski, shooting, yacht and so forth	Prohibited	Report upon receiving other than official meeting approved by the Company

• 2) Behavior Guideline for entertainment and reception
  • (1) No officer or employee shall receive entertainment or reception from the vendor, and in the event that such entertainment or reception is received, it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience"
  • (2) Any officer or employee may receive customary business treatment for meal or the like for the flawless work cooperation with the approval by the authorized person from other interested party, but the amount shall be reasonable within the decision standard limit and it is acknowledged only for the case of not prohibited under law or work customs.
  • (3) In the event that it is the category prohibited or beyond the limit of entertainment or reception even for the meal for flawless work cooperation under Paragraph (2), it shall be avoided or sanctioned.
  • (4) The decision standard limit means the total amount of first and second in sum of meal, beverage, confectionary, gift and the like, and in the event that it participates in the event that included the reception in excess of the decision standard limit, the approval by the authorized person shall be obtained.
  • (5) No entertainment or reception shall be received through sports unable to obtain the approval and the speculative recreation for using illegitimate business premises for the subject conduct other than the sports obtained with the approval by the authorized person for official meeting.
  • (6) In the event that any officer or employee receives entertainment or reception prohibited under the Behavior Guideline and meal beyond the decision standard limit from other interested party, it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience"

5. Providing Convenience

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Business trip support	Transportation convenience (railway/airway/bus ticket, vehicle support), accommodation convenience (accommodation, meal support and etc.)	Prohibited	Pay the actual expenses and report upon receiving
  Personal leave support	Provision of transportation and accommodation of personal leave and tourism information	Prohibited	Pay the actual expenses and report upon receiving
  Office fixture	Support of transfer expense and office fixture (wall clock, mirror, paper and etc.)	Prohibited	Report and entrust upon receiving
  Sponsorship/ endorsement	Invitational event (domestic and overseas seminar and etc.) of interested party other than sponsorship of inter-department event (money, goods, transportation)	Prohibited	Report and entrust upon receiving sponsored goods Report when participating in event of interested party yet to approve by the Company

  Note) It shall be an exception in the event that the same facilities, meal and traffic convenience are provided for trainees with the participating in programs of official education, event and so forth as hosted by the interested party.

• 2) Behavior Guideline for business trip and personal leave support
  • (1) Regardless of purpose, officers and employees shall not demand for provision of convenience from the interested party or accept any convenience.
  • (2) In the event that the justifiable consideration is not paid even with the provision of convenience for transportation/accommodation, it shall be remitted to the representative of provider with the attachment of the deposit slip copy and report the same to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience"

• 3) Behavior Guideline for office fixture and supplies
  • (1) For moving the office, transfer of department or the like, no endorsement (cash or goods) shall be received from the interested party.
  • (2) When notifying the interested party for the fact of office moving or department moving in accordance with the need for work, the contents of refusal of goods or money shall be stated on the invitation with careful consideration not to have the interested party to feel burdens.
  • (3) In the event that there is an inevitable cause to accept the office supplies, it shall be disposed in accordance with the Behavior Guideline for accepting the gift.

• 4) Behavior Guideline for sponsorship/support
  • (1) When there is any company event, such as, picnic, sport competition, workshop or the like, no sponsorship of cash, goods, transportation or the like shall be provided by the interested party.
  • (2) Any act of notifying the contents of event with the following method in advance shall be considered as an intended act to obtain the sponsorship.
    • ① Any act of posting on the company’s bulletin board for interested party to see or placing burden by publicly talking on event related matters to interested party
    • ② Any act of delivering the event invitation to interested party without the approval of the fully authorized person.
  • (3) In the event that there is a need to invite interested parties for any event, the approval by the authorized person shall be obtained in advance, but the interested parties shall be informed that no contribution (money or goods) would be accepted when inviting that there should be no burden in attending the event.
  • (4) In the event that any interested party brings cash or contribution in goods, it shall be returned, and in the event that it shall be received inevitably, it shall be reported to Department in Charge of Ethical Management and entrust the money or goods to Department in Charge of Ethical Management.
  • (5) In the event that it is the event hosted by the interested party, it must be work purpose, and the participation is available only after obtain the approval by the authorized person in advance. However, in the event that it deviates the work purpose of considers to be modified for providing convenience or entertainment, it shall be avoided, and in the event that there is any entertainment or reception inevitably, it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience"

• 5) Prohibition to pay expenses
  • (1) No interested party shall be brought to pay for the expenses for entertainment of another customer or department get-together or receive money after handing over the receipt.
  • (2) In the event that the interested party paid the expenses first after incidentally met with the interested party in a place of department get-together or the like, it shall be reported to the superior and reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience"

6. Monetary Transaction

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Borrowings/ low-price purchase and high-price selling	• Lease, security set, free reception, low-price purchase and etc. for assets of interested party, such as, real and personal properties • High price selling of personally owned assets for officers and employees	Prohibited	Report upon receiving
  Debt repayment	Payment or vicarious repayment of personal debt for credit card proceeds, proceeds on credit, loan amount.	Prohibited	Report upon receiving
  Guarantee of loans	Demand of guarantee or proposal of guarantee on loans	Prohibited	Report upon receiving
  Monetary lending	Any act of borrowing or lending the money of interested party, and payment or collection of interest thereof	Prohibited	Report upon receiving
  Joint investment	Joint investment and joint property acquisition on the equity with interested party for personal and real property, condo/ golf/ health club membership and etc.	Prohibited	Report upon receiving

• 2) Behavior Guideline for borrowings/purchase at low price/purchase at high price
  • (1) For the convenience or profit of officers and employees and family members, no interested party shall be required to lease its property or engage in any act of provided with collateral.
  • (2) Any act of gaining practical profit by receiving any real or personal property for free or purchasing at a price lower than normal price and all such acts shall be considered as receiving money.
  • (3) Any act of gaining practical profit by selling any real and personal property owned by officers and employees at a higher price than normal to the interested party shall be considered as accepting money to be strictly prohibited.
• 3) Behavior Guideline for debt repayment and guarantee of loans
  • (1) Vicarious payment: Any act of accepting payment, repayment, or guarantee as proposed by the interested party or request to interested party for payment, repayment, or guarantee on debts (card payment, payable on credit, loan amount etc.) of the applicable party, family and employees shall be strictly prohibited.
  • (2) Loan guarantee: When taking out any loan for applicable party, its family, and employees (regardless of lending institution to be financial institution or any other type), the interested party shall not be requested for guarantee or act to accept the proposal of guarantee by the interested party.
  • (3) Any act of vicarious payment or guarantee of loan shall be strictly prohibited as it is considered as receiving money.
• 4) Behavior Guideline for loan
  • (1) Any act of borrowing or loaning money by officer or employee or its family member with the interested party shall be prohibited.
  • (2) Payment or collection of interest and the monetary loan shall be considered as monetary acceptance regardless of cause.
• 5) Behavior Guideline for Joint Investment
  • (1) In the event that any officer or employee or its member gains personal and real property with the joint investment of fund with the interested party (regardless of its purpose), it shall be considered as receiving the amount equivalent to the equity from the interested party.
  • (2) Assets under the joint name, such as, condo/golf /health club membership, real estate and others and the assets under the practical equity ownership relationship even if they are under the name of others shall be applicable as well.
  • (3) In the event that the joint investment has been processed under the personal and real property before transacting with the Company, the pertinent fact shall be reported to Department in Charge of Ethical Management and clear up the personal equity thereof.
  • (4) Any act of practically owning a cooperative company having the transaction relationship with the Company through the joint investment with the interested party under the name of officer or employee or its family members shall be strictly prohibited.

7. Guarantee on Future (Promise on Employment, Entering into a Contract and Etc.)

• 1) Subject behavior and standard of determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Brokering of employment	Act to receive promise for hiring after resignation, employment brokerage and others from interested party	Prohibited	Report upon receiving
  Promise to enter into a contract	Enter into the promise to transact after resignation and etc.	Prohibited	Report upon receiving

• 2) Behavior Guideline
  • (1) Promise for employment and hiring after resignation: No demand for promising any type of employment or applicable thereof to the interested party or accept any proposal from the interested party.
  • (2) Promise on entering into the transaction contract: No demand shall be made to promise to guarantee any benefit, such as, entering into transaction after the resignation to the interested party or accept any such proposal from the interested party.
  • (3) In the event that the employment or promise for transaction has been proposed by the interested party, it shall be reported to the superior immediately and then report the same to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience"

8. Provision of Entertainment

• 1) Basic Principle
  • (1) In the event that the reception (meal, gift, congratulatory and condolence payment, external lecture fee or etc.) to any interested party, such as, government employee, at the expense of the Company or individual, it shall be processed by complying with the provisions of the other party or laws and regulations.
  • (2) The regulation on entertainment expense of the interested party and contents of laws and regulations shall be fully known and complied with.
• 2) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Meal	Excessive meal in high class restaurant in Japanese restaurant, Korean-court restaurant, hotel and others	Confirmation of regulations of interested party	Report when providing beyond the limit without acquiring the approval of the authorized person
  Gift	Payment of golf practice site, service right, health club service right, gift certificate, admission right, goods and etc.
  congratulatory and condolence payment	Payment of congratulatory and condolence payment, flowers and birthday ring and etc.
  Lecture fees	Fees for the external lecture of interested party		Report when providing without acquiring the approval of the authorized person
  Illegitimate business premises	Room salon, drinking hole, night club, massage parlor, high class barber shop, high class sauna, other luxury entertainment sites
  Speculative recreation	Go-Stop, casino, gambling
  Sports	High-cost sports of golf, ski, shooting, yacht and so forth

• 3) Entertainment
  • (1) In the event that there is a need of entertainment for the interested party, the approval by the authorized person shall be obtained based on the expected expense in accordance with the delegated full payment provision.
  • (2) In the event that the meal is provided to a vendor (excluding the case of provided by the Company for the flawless work cooperation and stipulation in inevitable cause), it shall be reported to Department in Charge of Ethical Management pursuant to the "Report of Receiving/Providing Money/Goods/Convenience"
  • (3) In the event that there is a need for entertainment to customer company, public employee or other interested party, the regulation of the other party or laws and regulations shall be complied with to process.
  • (4) In the event that the regulations of the other interested party or laws and regulations are not complied with when providing reception to other interested parties, or in the event that the decision standard limit of meal, gift or congratulatory and condolence payment as subject act is exceeded without acquiring the approval of the authorized person, or in the event that lecture of other interested party, illegitimate business premises, recreation, or sport not acquired of the approval by the authorized person is provided, it shall be reported to Department in Charge of Ethical Management.

1. Basic Principle

• 1) Those tangible assets and intangible assets of the Company and confidential information are important assets of the Company that these assets shall be used only for the business activities and approved purpose of the Company, and officers and employees shall have the responsibility to be prepared for loss, misuse and theft of the assets.
• 2) The expenses of the Company shall be constituted as the public fund and used for the sound corporate activities. Therefore, it shall be used only for the pre-determined purpose and the provisions of the Company shall be complied with.

2. Use of tangible assets and intangible assets for Other Purpose

• 1) Subject behavior and standard for determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Embezzlement/misuse of tangible assets	• Private use of common goods of company vehicle, fixture, supplies, expandable goods • Unauthorized take out of company assets • Unauthorized use other than the work purpose of machine, facility, equipment and etc. • Use of individual profit-oriented purpose of corporate card • Use other than the purpose of expense account	Prohibited	Report when acted on
  Misuse of intangible assets	• Disclosure or private use of duty invention • Unauthorized lease or private use of intellectual property rights of the Company, such as, trademark, patent right and etc. • Use for personal gain, provision to competitor through the design drawing discharge/business secret discharge/ information system discharge and etc.	Prohibited	Report when acted on

• 2) Behavior Guideline
  • (1) All assets of the Company shall be used only for the purpose approved by the authorized person or business activities.
  • (2) In particular, assets of various goods, including corporate cards, vehicle or PC, shall be facilitated only for the work activities and not for the individual purposes. In the event that it is utilized for private use for inevitable cause, the contents of use shall be reported to the superior manager and applicable officer immediately, and any expense generated in accordance with the utility of the applicable asset shall be converted and settled in accordance with the corporate accounting regulation to the Company.
  • (3) The information communication system shall be used only for the permitted purpose or business performance and the confidential information shall not be disclosed to outside by using the Company system or abuse for the illegitimate and commercial purpose.
  • (4) Any information acquired by using position or duty shall not be used in engaging in personal profit-oriented business or act to engage in works of others.
  • (5) Any business secret or information that requires security of the Company shall not be disclosed to outside unauthorized, and any information acquired while working shall not be disclosed without the advance permission or approval.

3. Embezzlement and Misuse of Fund

• 1) Subject behavior and standard of determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Embezzlement and misuse of fund	• Personal taking and bequeath to interested party through unauthorized withdrawal of the Company fund, private application and manipulation of accounting books • Private use of profit • Illegal use (card discount) and loan to others of corporate card • Private use of marketable securities of the Company • Expense disposition through falsified receipts (receipt for personal use and etc.) • Abuse of non-verifying expense system • Manipulation of accounting books: Combined disposition as the expense for other account for personal amusement or entertainment expenses difficult to dispose for accounting • Unauthorized use by providing the corporate card of the Company to family/relative • Other private execution against the expense discrimination standard of the Company	Prohibited	Report when acted on

• 2) Behavior Guideline
  • (1) Private use of the Company’s fund, such as, profit proceeds and others, shall be prohibited regardless of cause and excessively small amount or the like.
  • (2) Act to embezzle the fund, act to spend the fund for private purpose or the like shall never be permitted.
  • (3) With respect to the expenses actually not generated, withdrawal of the Company fund by submitting false statement shall never be permitted.
  • (4) The fund management of the Company, such as, income and so forth, shall be managed with the account under the company name, and it shall not be used by seeking or abusing the interest gain by using the deposit through the personal account or delayed deposit for income or account payable on credit.

4. Misuse of Job Information

• 1) Subject behavior and standard of determination

• Subject behavior and standard for determination

  Classification	Example category	Principle of behavior	Standard of determination
  Information discharge	• Any act of disclosing management information, sales information and other internal information to outside of the Company. • Any act of distributing accusation, false fact and libel related to the Company in and out of the Company • Any act of violation of conserving data, document, and security provision, external disclosure of copy, core matter and others • Any act of distributing the information on previous work, confidential information and others in and out of the Company	Prohibited	Report when acted on
  Customer information discharge	• Customer information acquired on the job • Information of price and quality submitted by vendor	Prohibited	Report when acted on
  Company personnel discharge	• Disclosure of personal information or contact	Prohibited	Report when acted on

  • • Management information: Major corporate policy, decision making, management plan, performance, finance/accounting data and etc.
  • • Sales information: Sales record information, service and vendor information and etc.

• 2) Behavior Guideline
  • (1) Information discharge
    • ① The act of discharging management information, sales information and other corporate information to outside shall not be engaged, and no act to damage the corporate image, disrupting or interfering with the organization atmosphere, such as, distributing false fact or groundless rumor, shall be committed.
    • ② In addition, any act of disclosing the Company information to a third party or selling the information for private gain after the resignation shall be committed.
    • ③ No trading of interest on marketable securities or other assets, including the stock transactions, by using undisclosed information acquired during the period of employment shall be allowed and no act of advising or influencing thereof shall be engaged.
  • (2) Disclosure of customer information : No customer information shall be disclosed or used for any other purpose without the consent of the customer in advance and any information on customer or vendor shall not be disclosed to any unauthorized person authorized within the Company.
  • (3) Discharge of the corporate personnel : The act of aiding or abetting to discharge personal information or contact of core technical personnel that the Company specially manages to outside or introducing to head hunter or the like shall not be engaged.

1. Basic Principle

• 1) Records and reports of all information shall be accurately and honestly made in accordance with applicable laws.
• 2) Any document that is different from the fact from intentional or negligent act may cause difficulty of discrimination or determination of superior or relevant department to greatly harm the interest of the Company with erroneous decision that it shall be recognized that it is expressly illegal act.
  • ※ Types of standard
    • - Domestic & international laws, regulations & contracts
    • - Corporate policy/regulations (procedure and manual)
    • - Executive instructions and work guidelines
    • - Internal stipulation and other standard or basis

2. Behavior Guideline

• 1) Forgery and alteration of document
  • (1) All documents of certain kinds that officers and employees recorded and submitted to the Company shall be accurately and honestly prepared.
  • (2) Instruction by the superior to manipulate the document or accepting such practice by the subordinate to follow such instruction knowing that it is an expressly illegal act shall be subject to punishment as the same illegal act.

• 2) False report
  • (1) Making false report to the top management of the Company, management examining organization or external organization of the Company shall be constituted as an illegal act that must be strictly prohibited.
  • (2) False explanation for the case of providing the service to customer shall be considered as the illegal act.
  • (3) Manipulating information for the purpose of causing misunderstanding by the information recipient other than the direct false report shall be included in the same illegal act.

1. Basic Principle

• 1) All officers and employees shall fulfill respective due care with the fiduciary duty on required affairs for position, and they shall not engage in any act to inflict loss or damage to the honor of the Company.
• 2) All officers and employees shall keep the honor of the Company by placing best effort on language and behavior displayed as people of Sinokor and the basic types that deviate from the Ethics Guideline are shown as follows.
  • (1) Behavior Guideline on work
    • - Non distinction of work
    • - Neglect of duty
    • - Neglect of management and supervision
    • - Over-reaching conduct
    • - Unreasonable work disposition
  • (2) Behavior Guideline to maintain sound organizational culture
    • - Formation of faction based on blood, regional and academic ties
    • - Sexual harassment
    • - Interference with organization atmosphere
    • - Loss of dignity
    • - Delivery of bribery
    • - Demand for money and entertainment to subordinates
    • - Monetary transaction between employees
    • - Concurrent business and sideline
    • - Favor for personnel
    • - Other interference with work discipline

2. Behavior Guideline on Duty

• 1) No distinction of work
  • Matters shall be clearly classified and the personal position shall not be used to seek for personal gain.
  • (1) Private emotion and interests shall be excluded to work on matters fairly and squarely.
  • (2) When carrying out the work, interest of the Company shall be contemplated and acted on with the utmost priority.
• 2) Neglect on duty
• One shall not fail to perform the works specified under the work provision for its position or duty (or assigned with the work instruction with responsibility) to inflict loss to the Company or causing damage to its honor
• • (1) All officers and employees shall have the sense of mission on works granted to each party in accordance with the Company’s policy to duly carry out.
  • (2) All officers and employees shall understand the regulations and systems of the Company related to the works and complied with them.
  • (3) All officers and employees shall share the information by superior, colleague and department to complete the work with positive cooperation.
  • (4) In the event that the superior officer is involved in neglect of his duties or illegal or illegitimate act, or in the event that he may cause material influence to the Company, it shall be reported to Department in Charge of Ethical Management.
• 3) Neglect on management and supervision
  • As a good faith manager responsible for the work performance, it shall not inflict any loss or damage the honor of the Company by not fulfilling the due obligations
  • (1) All officers and employees shall be able to take responsibility of the duty performance result give for each position and title.
  • (2) All officers and employees shall forecast the risks possible from the work performance with due care from time to time and shall have the sense of responsibility for problems occurred.
  • (3) In particular, for any manager, it shall fulfill its obligation of management and supervision on subordinate.
• 4) Over-reaching act
  • All officers and employees shall be refrained from the things not to be abusing its position to inflict loss or damage the honor of the Company.
  • (1) Superior shall not render illegal work instruction irrelevant to the work purpose of the Company to its subordinate.
  • (2) No officer or employee shall deviate its work authority and scope of responsibility or otherwise against the regulations of the Company to make the decision making or officially deliver any promise not available to keep.
• 5) Unreasonable work disposition
  • All officers and employees shall be refrained from rendering unreasonable work instruction or engage in any act for the purpose of rendering adverse influence on specific interested party or others against the work purpose.
  • (1) No act shall be engaged for doing something not supposed to do or not doing something supposed to do for the purpose of rendering advantage or disadvantage to specific interested party.
  • (2) No act shall be made to delay the work or committing interference or instigating interference for the purpose of rendering advantage or disadvantage to any specific interested party.

3. Behavior Guideline to Maintain Sound Organizational Culture

• 1) Factions based on blood, regional and academic ties
  • (1) No faction based on the blood, regional and academic ties or private organization shall be organized.
  • (2) No discriminatory treatment shall be rendered following blood, regional and academic ties, gender, religion, age, disability, marital status, nationality, race or the like between officers and employees.
• 2) Sexual harassment
  • (1) By recognizing that sexual harassment may harm the work atmosphere at the workplace and interfered with individual human right as well as causing loss of corporate image and legal issues, act shall be done not to cause such issues.
  • (2) No act of sexual harassment with physical, linguistic and visual act that may instigate the sexual humiliation shall be engaged.
    • ① Any act to feel sexual humiliation or abhorrence, or pressure during the work
    • ② Any act of unnecessary physical contact
    • ③ Any act of coercing dance, singing or assistance in alcohol consumption while having the team’s get-together
    • ④ Sexually discriminatory language or conduct
• 3) Interference with organization atmosphere
  • (1) No verbal use or act that may interfere with sound peer relationship, such as, use of disruption of social norm, violence, act to inflict personal abhorrence, unpleasant or damaging act to other employee at the job or the like shall be rendered.
  • (2) No act of interfering with maintaining and succeeding activities for clean organizational culture and damaging the corporate value and the Company image shall be engaged.
  • (3) Make sure to remember that behavior of each officer or employee is directly related to the company’s image and make effort to keep the honor of the Company through clean cut attire, courteous manner and graceful language use.
  • (4) Any meal not to interfere with the job performances that satisfy the following standard shall be recognized for the work cooperation with the approval by the authorized person.
    • ① All official get-together and meetings shall be finished for initial meeting if possible.
    • ② Do not engage in any act of recommending excessive alcohol beyond the personal capacity of alcohol consumption.
• 4) Disgraceful conduct
  • (1) All officers and employees shall keep the external grace and honor on the basis of ethical and diligent representation as a man/woman of Sinokor and not to engage in any act against it with the posture to represent the Company.
  • (2) No officers and employees shall influence the work performance or dishonor the Company due to lewd personal life.
  • (3) All officers and employees shall comply with laws and company regulations and no officer or employee shall disgrace the Company with the personal unfair conduct not customarily acceptable in the community.
• 5) Bribery
  • (1) Providing any money or goods to a superior personally may seem like asking a favor for promotion, personnel record, salary or the like that it shall be prohibited.
  • (2) In the event that a subordinate provides goods, entertainment, convenience or the like personally, the higher ranking officer shall firmly reject it and take measure to warn for the applicable employee.
• 6) Demand of money, goods, entertainment or the like to subordinate officer
  • (1) Demanding subordinate for money, goods, entertainment and the like by using its position shall be strictly prohibited as the violation of the Ethics Guideline.
  • (2) No act of compulsorily mobilizing subordinate on demanding goods in exchange of salary, work record or the like shall be committed.
  • (3) In addition, receiving special benefit on promotion, wage or work record from superior and providing money or goods shall be applicable to violating act of the Ethics Guideline.
• 7) Monetary transactions between employees
  • (1) All monetary transactions between the peers at the job may worsen the peer relationship, harmful to work atmosphere or interfere with the Company’s work if there is any problem of default or the like that it shall be prohibited and, if the monetary transaction is caught, it shall be subject for severe punishment.
  • (2) All behavior to damage the peer relationship and customary gambling shall be strictly prohibited and effort shall be made for sound leisure undertaking.
• 8) Concurrent work and sideline
  • (1) Concurrent work and sideline
    • While in employment, concurrent position, concurrent business, or sideline (including the use of someone else’s name) shall be prohibited in principle.
  • (2) External lecture
    • Any activity of outside lecture, consulting and etc. with the purpose of personal gain shall be prohibited.
  • (3) Leasing of license or the like
    • Any intellectual property or work knowledge acquired on the job shall not be provided to other company and no leasing license or certificate to another company shall be allowed.
• 9) Unjust request for personnel affairs
  • (1) No officer or employee shall have another person to ask favor to party in charge of personnel in order to have adverse influence on personnel of its own appointment, promotion, transfer or the like.
  • (2) Any officer or employee shall not use the position to unjustly intervene in personal matters of appointing, promoting or transferring of other officers and employees.
• 10) Other acts to interfere with work discipline
  • (1) Any officer or employee shall not use inappropriate internet for indiscrete chatting, lewd site, access, online stock transaction and others during the work hours and it shall not engage in any private business act through the internet.
  • (2) In relation to the SNS use, customers, shareholders, competitors or colleagues shall not be criticized, and it shall not dispute with SNS user or mentioning of all confidential information, case related to the Company yet to be announced, information and rumors.
  • (3) No disruptive act shall be engaged for maintaining illegitimate gender relationship by using the work relationship or abusing the position in the Company.
  • (4) During the work hours, no facilities of sauna, golf course and others irrelevant to the work shall be used, and in the event that it is inevitable, make sure to obtain the approval by the authorized person.
  • (5) In the event that one recognized any matter or condition that may inflict damages to the Company, it shall be reported to the authorized person immediately, and in the event that there is any damage for not informing the same, it shall not be exempted from liability.
  • (6) No act that may cause the damage to the Company by the method of illegality, falsity or any other method shall be committed or done.

1. Behavior Guideline

• 1) In the event that any officer or employee violates the Ethics Guideline inevitably, or in the event that the officer or employee witnesses or perceived any act in violation of the Ethics Guideline by another officer or employee, or in the event that it receives the proposal to be related to the violation matter, the reporting party or informer shall report (inform) the fact immediately.
• 2) In the event that any officer or employee receives money or goods, convenience, or guarantee on future, it shall prepare the "Report of Receiving/Providing Money/Goods/Convenience", and in the event that there is any entertainment and reception received, the "Report of Receiving/Providing Money/Goods/Convenience" shall be prepared to r to the superior officer and report the same to Department in Charge of Ethical Management within one week after the occurrence and the money and goods provided shall be entrusted to Department in Charge of Ethical Management. However, in the event that there is a delay of report due to any special cause, it shall be reported to Department in Charge of Ethical Management by attaching the cause of delay for report within 30 days from the occurrence date.
• 3) In the event that the head of department is reported or learned of the violation of the Code of Ethics and Ethics Guideline by any employee in the department through any certain route, the disposition plan shall be instructed and the disposition result shall be forwarded to Department in Charge of Ethical Management immediately.
• 4) In the event that any officer or employee reports (informs) any act subject of report or inform, it shall be considered as the purpose of concealing to lose the opportunity for appropriate protection or become a subject of disciplinary action.

2. Conduct subject for Report and Information

For not permitting, or inappropriate to ordinary common sense in accordance with laws, regulations, standard or social norm for interested party:

• 1) When receiving money
• 2) When receiving gift, and when receiving the gift in excess of limit following the social norm
• 3) When receiving congratulatory and condolence payment or goods in excess to the limit
• 4) When receiving entertainment and reception in excess to the limit (prohibited for vendor)
• 5) In the event that the justifiable consideration is not paid after receiving convenience of transportation, accommodation and etc.
• 6) In the event that the office fixture is received
• 7) In the event that the proposal for employment guarantee or promise for transaction
• 8) Other case of violating the Code of Ethics and Ethics Guideline
  • * The foregoing amount limit for each category is separately provided

3. Information on Violation of Ethics Guideline by Vendor

• 1) In the event that there is any demand or request for favor in violation of contents of this Ethics Guideline from any officer or employee, the vendor shall inform the same to Department in Charge of Ethical Management to prevent recurrence.
• 2) Any vendor that violated this Ethics Guideline shall be subject of adverse interest in accordance with the gravity of the contents of violation, such as, earning, transaction suspension or the like.

4. Protection of Informer and Etc.

• 1) Exposure of identity or content of reporting party, informer and opinion stating party regarding the violation of the Ethical Management (hereinafter referred to as the “reporting party”) shall be prohibited in principle and no justifiable adverse interest shall be imposed on the reporting party.
• 2) Any officer or employee recognized the identity of the reporting party shall guarantee the secrecy of identity and it shall not engage in any act to expose the identity. However, when recognized as required for the investigative purpose by the department in charge of the audit, the identity may be disclosed after obtaining the consent of the reporting party.
• 3) The reported party (informed party) or employee of pertinent department shall not be engaged in any attempt or act enabling the exposure of identity for inquiry of content or identity of the reporting party or search to find out the same.
• 4) The reporting party that has its identity exposed, discriminatorily treated and other adversely impacted may apply Department in Charge of Ethical Management for protective measure or relief and Department in Charge of Ethical Management shall take appropriate action determined as required for the reporting party.
• 5) In the event that the identity of the reporting party is exposed, Department in Charge of Ethical Management may investigate how the identity is exposed and any officer or employee exposing the identity of the reporting party intentionally or negligently shall be subject to the disciplinary action.
• 6) In the event that the reporting party is retaliated from the reported party (informed party), the fact shall be notified to Department in Charge of Ethical Management immediately and Department in Charge of Ethical Management may demand the employee related to the retaliatory act may demand for disciplinary action pursuant to the pertinent regulation.

5. Report of Interested Relationship

• 1) In the event that there is conflict of interest with the Company or concerned to occur in relation to the work performance, an officer or employee shall report the applicable fact to Department in Charge of Ethical Management.
• 2) In the event that there is any following cause arising to the applicable party or its family members and has the conflict of interest with the Company occurred or possible to occur, any officer or employee shall report the same to Department in Charge of Ethical Management.
  • (1) In the event that officers and employees or any family member owns directly or indirectly for all or part of equity of the company with the transaction relationship (However, it excludes the case of ownership for the purpose of simple investment for equity in listed company)
  • (2) In the event that a family member of officers and employees is hired for managerial level or higher to a company transacting with the Company
  • (3) In the event that a company where a family member of officers and employees is working as an officer is expected to have the transaction relationship with the Company in near future
  • (4) In the event that it is possible to generate the conflict of interest even if it is not the subject of the above report
• 3) The report of the interest relationship shall be implemented regularly and from time to time and the officer or employee that reported the interest relationship may not participate in the decision making related to the applicable interest relationship in accordance with the intent of the applicable person.
• 4) Notwithstanding the occurrence of conflict of interest, in the event that the applicable fact is not reported, it may be subject of disciplinary action.

6. Processing of Department in Charge of Ethical Management

• 1) Department in Charge of Ethical Management may have the factual confirmation when necessary for the matters received and the related officers and employees shall make active cooperation.
• 2) In the event that there is any report (informing), Department in Charge of Ethical Management shall forward a letter to request for prevention of recurrence to request for cooperation together with the meaning of appreciation to the applicable interested party and representative of the Company.
• 3) Department in Charge of Ethical Management shall present for deliberation to the Ethics Committee in the event that it is required for resolution and finalization of the disciplinary action in accordance with the confirmed fact.

7. Ethics Committee

• 1) In relation to the operation of the Ethics Guideline, the Ethics Committee shall be established and the Ethics Committee shall be consisted with the following members.
  • - Commissioner: CEO or an officer designated by CEO
  • - Member: Auditor and each Director of Division
  • - Coordinator: Team Manager of Department in Charge of Ethical Management
• 2) Duties of the Ethics Committee are shown as follow.
  • (1) Interpretation of the Code of Ethics and Ethics Guideline
  • (2) Maintenance and improvement of the Code of Ethics and Ethics Guideline
  • (3) Deliberation and finalization on subject person of disciplinary action

8. Deliberation on Person Violated the Ethics Guideline

• 1) The coordinator of the Ethics Committee shall report to the Commissioner by reviewing the need for deliberation of the Ethics Committee.
• 2) Convening of the Ethics Committee: The coordinator of the Ethics Committee shall notify the matters required for the cause of deliberation, date and time, place and the like of the Ethics Committee to the subject parties of deliberation and members of the Committee at least 7 days prior to hold the Ethics Committee.
• 3) Attendance of person subject for deliberation
  • (1) Subject person for deliberation shall respond to the inquiry of the Ethics Committee by attending to the Ethics Committee and may clarify for the cause of its deliberation.
  • (2) Subject person for deliberation may submit written statement in the event that it is difficult to attend in the Ethics Committee for personal reason or other cause.
  • (3) In the event that the subject person for deliberation with the notice to attend in the Ethics Committee is unable to attend, it may deliberate with its absence.
• 4) Resolution and finalization of the disciplinary action
  • (1) As a result of deliberating the violation of the Ethics Guideline on any violating party to the Ethics Guideline, it shall finalize the contents of the violation and the criteria of disciplinary action on the violating party to turn into the disciplinary action committee.
• 5) Review on deliberation
  • (1) From the matters resolved by the Ethics Committee, it shall be reviewed when there is a detection of clear error at the time of requesting for review or thereafter for the party disciplined against.
  • (2) The Deliberation Committee for Review shall be convened within 10 days from the date of receiving the request for review in principle, but it may be extended for once in the event that the holding of Committee meeting is difficult.
  • (3) With respect to the disciplinary action agenda presented for the review, it shall not place for the disciplinary action with greater disposition than the original disciplinary action but it shall be an exemption in the event that the new illegal fact is discovered other than the original disciplinary action cause.

9. Criteria for disciplinary action

When violating the Code of Ethics and Ethics Guideline, the criteria of the disciplinary action shall be made for the personnel disciplinary action instruction in principle, and anything not defined under the personnel disciplinary action instruction may be set forth separately from the Ethics Committee.

10. Reward and disciplinary action

• 1) The Company may pay the appropriate level of compensation or reward in accordance with the pertinent regulations to officers and employees that provided meritorious service to accomplish the goal of the Ethics Guideline.
• 2) The Company may discipline or take measure for civil or criminal action in accordance with the pertinent regulation on officers and employees violating the Ethics Guideline.

11. Interpretation

In the event that there is any inquiry on the part not set forth under detailed rules of the Code of Ethics and Ethics Guideline, it shall be inquired to Department in Charge of Ethical Management to follow its interpretation.

12. Statement of Oath to Practice the Code of Ethics

The Statement of Oath to Practice shall be prepared as indicating the full awareness of the contents of the Code of Ethics and Ethics Guideline and actively participate in the Ethical Management that strives for the Company to practice.

1. Time of Implementation

This Ethics Guideline shall be implemented from January 1, 2018.

2. Application

This Ethics Guideline shall be applied to all officers and employees, including regular position, temporary position, contract position, advisors, agents and others.

3. Relationship with Other Provisions of the Company

This Ethics Guideline shall have the priority over other provisions in the Company other than the Code of Ethics.

4. Department in charge of ethical management

Under this Guideline, the department in charge of ethical management means the Audit Office.