01 Performing our duties fairly

• We neither accept nor offer improper solicitations, money, goods, entertainment or favours to or from stakeholders.
• We do not lend or borrow money between colleagues, nor engage in drinking, gambling or anything else that harms order or morale at work.
• We do not collect money for gifts, or give personal gifts, on promotions, holidays or other special occasions.

02 Building a healthy corporate culture

• We do not leave work unnecessarily, shop online or trade shares during working hours.
• Apart from clubs and volunteer groups, we do not join informal circles based on school or regional ties, as they create factions and friction.
• We treat one another with trust and respect as individuals, and do not insult, discriminate against or otherwise act unethically towards colleagues.
• We protect pregnant employees and minors in accordance with the law.
• We do not make lewd jokes or sexual references, or circulate pornographic sites or images.
• We refrain from sexual jokes or offensive remarks about anyone’s appearance.
• At dinners and outings we do not make anyone pour drinks, nor do we make unnecessary physical contact.

03 Non-discrimination

• We do not discriminate in hiring, promotion, pay or training on the grounds of race, sex, origin, political opinion, social status or disability.
• We give fair opportunity on the basis of ability and achievement, appraise against fair criteria and reward accordingly.

04 Protecting company assets and information

• Company assets means everything we use — money, information, equipment, land and buildings.
• Using company assets for private purposes breaches this code.
• Company property and equipment must not be used or removed without authorisation.
• Paying for golf or entertainment unrelated to work with a corporate card is embezzlement.
• Taking office supplies home, or excessive personal calls and internet use, also breaches this code.
• Company money such as sales proceeds or fees must never be received in cash or into a personal account.
• Falsifying documents to cover an overspend on events or dinners is illegal.
• Group funds and team prize money must be held in a shared account and managed transparently.
• Company noticeboards and internal e-mail must not be used to promote the business of family or friends.
• Important information obtained during a project must not be disclosed or leaked.
• We do not comply with requests from former colleagues or acquaintances for organisational, personnel or management information.
• Even where a public body asks for management or personal information, it must not be released without prior approval.

05 Protecting whistle-blowers

• No one who makes a legitimate report — from outside or inside the company — or who gives evidence, submits materials or otherwise cooperates with an investigation, shall suffer retaliation such as loss of status or discrimination in their working conditions.

06 Protection of personal data

• Personal data of employees, customers and partners obtained in the course of work is protected securely in accordance with the law.

01 Spreading the code · family occasions

• We should make this code known to our partners’ employees too, and encourage them to follow it.
• Sending notices of family occasions to partners in order to receive gift money is strictly forbidden.
• Gift money received from a supplier may affect our impartiality and must be returned at once.
• Telling partners about a manager’s family occasion breaches this code.

02 Gifts and money

• We decline money or goods offered by partners or customers as thanks, since it can be abused.
• Money or vouchers from a partner handed out by a manager are still gifts received, and breach this code.
• We must not gamble with partners, directly or indirectly, for money or goods.
• We decline travel vouchers from a partner’s staff, and invitations to travel together.
• Receiving money or entertainment in return for awarding work or a contract is bribery.
• If a partner asks for an employee’s home address or phone number, we politely decline.
• We do not accept expensive souvenirs or promotional items from partners beyond what is customary.
• We neither give nor receive holiday gifts such as fruit or farm produce to or from partners and customers.
• When visiting a partner we accept no money or expenses of any kind, including travel costs.

03 Entertainment and sponsorship

• Business meals with partners require prior approval and stay within the customary limit (KRW 30,000 or less).
• As a rule, the company bears business costs incurred with partners.
• A partner’s staff are business stakeholders, so we avoid private gatherings with them.
• If a partner’s staff steer us towards an upmarket bar or entertainment venue, we politely decline and do not go.
• We accept no golf hospitality from partners; golf trips at home or abroad also breach this code.
• We accept no sponsorship from partners for sports days, hikes or any other event.

04 Choosing partners · fair dealing

• Private contracts invite accusations of favouritism, so we use competitive tendering.
• Where a partner has committed bribery or another offence, we discuss suspension of trade fully.
• We avoid dealing with firms run by relatives or acquaintances.
• Asking an existing supplier to match a cheaper supplier’s price reveals that supplier’s information and is unethical; the proper course is to change supplier through the normal process.
• Holding a concurrent post at a partner breaches fair dealing and must be firmly refused.
• A manager pressing us to trade with a relative’s firm breaches this code.

05 Shareholdings and investment

• Taking a stake in an unlisted partner or a spun-off company risks compromising fairness and is prohibited.
• We avoid investing in the shares of listed partners we trade with, as it may raise ethical concerns.
• We do not buy shares on the strength of advance knowledge of a partner’s listing.
• We make no joint purchases of property, memberships or the like with a partner’s staff.

06 Money lending

• We must not lend or borrow money with anyone at a partner or customer.
• We must not borrow money from a partner’s staff or offer property as security to them.
• We neither give nor receive loan guarantees to or from partners and customers.

01 Requests to speak externally

• We obtain company approval before accepting an outside speaking engagement.
• We must not speak at another company on our investment, technology development or future plans.
• Registering as a lecturer with an organisation and being paid to speak counts as external activity, and requires prior company approval.

02 Ethics towards stakeholders

• No money, vouchers or gifts of any amount may be given to or received from public officials.
• Nor may we make requests of stakeholders while promising later reward.

03 Matters not covered by these guidelines

• Where these guidelines are silent, ask the company first and then decide.

• Every employee must follow these guidelines faithfully. Anyone who breaches them is accountable for their conduct, and the company may take disciplinary action under the employment rules.
• Where a breach occurs, the company will establish the cause thoroughly and prevent recurrence through training.