Article 1 (Purpose)

The purpose of this Code of Conduct is to promote ethical management activities by setting the criteria and relevant procedures for proper behavior and value judgement to be held by the Company’s employees.

Article 2 (Scope of Application)

These Action Rules shall apply to all employees (including directors) including those dispatched from subcontractors, etc. to carry out the Company’s business.

Article 3 (Definitions)

As used herein, the following terms shall have the meanings stated as follows:

(1) “Money or articles of value” refers to cash, marketable securities, goods, or other economic benefit.

(2) “Entertainment” refers to meals, liquor, sports, amusement, etc. provided in expectation of something in return.

(3) “Convenience” lodging, transportation, tours, event-related support, etc. provided in expectation of something in return.

(4) “General social customs” refers to an act done voluntarily and with pure intention, with neither the beneficiary nor the benefactor feeling any sort of burden. A gift worth more than 50,000 won presented on a single occasion or a total of 500.000 won in a year shall be deemed unacceptable under general social customs.

(5) “Stakeholders” refers to individuals or a group of individuals within/outside the Company affected by an act or decision made by the Company or the Company’s employees.

(6) A “whistleblower” refers to an employee or stakeholder who is obligated to report information on an unethical act perpetrated by a Company employee.

(7) A “subcontractor” refers to an individual or corporation doing business with the Company.

(8) An “informer” refers to an employee of the Company or a subcontractor or a customer who reports an act of receiving what is stated in the foregoing items (1) through (3) to the Company.

(9) An “unethical actor” refers to a person engaging in an act that is in contradiction of the Company’s Code of Ethics and this Ethical Code of Conduct.

Article 4 (Customer Value Creation; Customer Service)

(1) Employees shall engage in acts and make judgements putting the priority on customers, keeping in mind that they are the Company’s reason for being.
(2) Employees shall strive to provide high-quality goods and services to fully satisfy customers.
(3) Employees shall strive for quality management for the satisfaction and safety of customers.
(4) Employees shall strive to provide good-quality goods at reasonable prices, keeping in mind that this is the basis for the best customer service.

Article 5 (Respecting Customers’ Opinions; Keeping Promises to Customers)

(1) Customers’ reasonable requests shall be handled promptly and faithfully.
(2) Honest and truthful information shall always be provided to customers.
(3) Efforts shall be made to improve the channel through which customers’ complaints or suggestions are received. Said complaints or suggestions shall be dealt with by the department in charge promptly and accurately.
(4) Promises to customers shall be kept under all circumstances.

Article 6 (Receiving Customers)

(1) Customers shall be received politely and faithfully, with attention paid to their requests.
(2) All customers shall be treated equally.
(3) While customers are around, employees shall not engage in private conversation, talk about the Company’s secrets, or speak ill of another employees.
(4) Employees shall ensure that customers have a good impression of the Company using good manners.

Article 7 (Protection of Customer Information)

(1) Employees shall not use information on the Company’s stakeholders for any unauthorized purpose.
(2) Customer information shall not be disclosed to a third party without authorization.
(3) Customers’ property shall be handled with care as if it is the Company’s property, and shall not be used without authorization.

Article 8 (Sincere Management; Maximized Market Value of Stock)

(1) Employees shall do what they can to enhance the market value of the Company’s stock by improving business performance from a long-term perspective.
(2) Employees shall engage in innovation/improvement activities based on creative thinking, cope positively with changes in the market situation, and be prepared against an uncertain future.

Article 9 (Compliance with Laws; Maintaining Transparency)

(1) All business operations shall be carried out in accordance with legitimate principles and procedures.
(2) All business operation-related records shall be drawn up and managed rationally and transparently.

Article 10 (Listening to Minority Shareholders’ Opinions)

The Company shall do its best to listen to the justified opinions of minority shareholders and have them reflected in the Company’s overall management.

Article 11 (Basic Workplace Ethics)

(1) Employees shall have a firm sense of mission regarding their assignments and shall strive to complete them perfectly.
They shall ensure that loss or damages do not occur due to errors in conducting the Company's business.
(2) Employees shall comply with the Company’s regulations and strive to create higher value for the Company.
(3) Employees shall not inflict loss on or tarnish the image of the Company through neglect of duty, careless management/supervision, or by overstepping their authority.
(4) Employees shall not tarnish the image of the Company or impair their dignity by use of bad language or by insulting others.
(5) Employees shall observe the law, always strive to protect the prestige of the Company, and maintain their dignity, and shall not engage in any act which may be denounced by others socially or ethically.
(6) Employees shall keep basic order within the Company, strive to win respect from their colleagues and people from the businesses doing business with the Company, and make the Company a pleasant workplace.
(7) Employees shall not reproduce or use illegal software.

Article 12 (Challenge/Innovation; Cooperation and Harmony)

(1) Employees shall keep an ambitious attitude toward new sectors unexplored thus far.
(2) Employees shall strive with an ambitious attitude to innovate and improve the way that the company's business is done.
(3) In pushing ahead with a new business, employees shall cooperate with those from other departments so that the power of the organization can be maximized.
(4) Employees shall solve existing problems with creative thinking in an effort to support the Company’s development.

Article 13 (Fair Treatment)

(1) Employees shall expect to be treated fairly purely based on their abilities and performance results, regardless of regional faction, alumni affinity, gender, etc.
(2) The Company shall evaluate employees obJecttively and fairly, purely based on their abilities and performance results, and shall do its best for reasonable compensation of employees.

Article 14 (Protection of Company Property and Information)

(1) Employees shall not use the Company’s Property without authorization for any purpose not related to company business.
(2) Employees shall not use Company funds dishonestly or without authorization.
(3) Employees shall not use Company-provided computers to engage in online gaming, chatting, video viewing, private stock transactions, or visiting pornographic websites.
(4) Employees shall not cause harm to Company property.
(5) Employees shall not disclose Company-related information to an outsider and shall follow the Company’s Information Security Management Regulations.

Article 15 (No Unethical Acts)

(1) Employees shall not present gifts to each other unless in one of the following cases:
(2) Prohibition of receiving work-related money or profit
Employees shall not receive money or articles of value provided in expectation of something in return in connection with company business. If they receive such a gift unavoidably, they shall report it to the Company unless the gift is provided without expectation of something in return in connection with company business and is something small under general social customs.
② Employees shall not ask for money or articles of value in connection with company business or overlook such an act perpetrated by those under their authority.
③ Employees shall not be provided with convenience from a stakeholder in connection with company business unless the gesture is something small under general social customs.

(3) Prohibition of money lending or loaning and standing joint surety
① Employees shall not borrow or lend money from/to each other unless such action is permitted by their supervisors in advance.
② Employees shall not offer payment guarantee (including joint assurance) to each other. The foregoing sentence shall not apply in case of a guarantee offered concerning an in-house loan provided for employees’ welfare under the relevant supervisor’s approval.

(4) Accepting/Receiving congratulatory or condolatory money
① Congratulatory/condolatory money offered between employees shall be voluntary and follow general social customs.
② Employees shall not make subcontractors or others parties feel burdened by carelessly informing them of a congratulatory or condolatory occasion.

(5) Prohibition of giving fees for expedited process
① The Company shall not pay a bribe to any public official to more speedily process a regular official task. ② The Company may pay money for expedited service in the following exceptional cases.
(6) Prohibition of Sexual Harassment
① The Company shall carry out education sessions for employees at least once a year to prevent sexual harassment in the workplace. Employees shall not engage in speech or behavior that may make others feel ashamed sexually (such as obscene jokes, being made to serve superiors at a table or dance, unnecessary bodily contact, sexual remarks regarding the body of an employee). Directors and manager-level employees shall strive to prevent sexual harassment and check on the situation from time to time.
② Fact-finding efforts shall be made thoroughly concerning even a case of sexual harassment reported anonymously.
③ In the event of occurrence of a case of sexual harassment, efforts shall be made to find facts obJecttively, not to let the victim suffer, and to have the perpetrator punished according to internal regulations and procedures.

(7) Employees shall not engage in any act that is deemed to be obJecttively unethical.

Article 16 (Directors’ Social Responsibility; Need to Observe International Norms)

(1) Directors shall play a leading role in coping with crises and handle opportunities for the Company, keeping in mind their social responsibilities, and shall always carry out activities in accordance with international standards.
(2) Directors shall do what they can to detect risk factors in advance from a long-term perspective and based on strategic thinking in carrying out overall operations.
(3) Directors shall do their best to make reasonable decisions, using all available knowledge and information and shall be responsible for decisions made by them.

Article 17 (Establishment of Good Labor-Management Relationship)

(1) Employees and management shall strive for mutual development by building trust and harmony between them.
(2) Management and the labor union shall consult with each other where necessary to amend the existing collective Agreement including the Company’s Code of Ethics and this Ethical Code of Conduct.

Article 18 (No Conflicts of Interest between Employees and the Company)

Where there are conflicts of Interest between employees and the Company in carrying out this Ethical Code of Conduct, the Company’s overall interests shall be given priority consideration.

Article 19 (Self-Development)

(1) Employees shall always strive to enhance their quality and abilities as employees.
(2) The Company shall strive to help employees to enhance their abilities under a training plan by gaining an understanding of their core competencies.

Article 20 (Proper Performance of Duties)

(1) Employees shall not engage in any act that they must not do, and shall not avoid carrying out an act they must do to give an advantage or disadvantage to specific stakeholders. Employees shall not engage in any act that may delay or obstruct company business.
(2) Employees shall not engage in any act that may mislead their supervisors’ or relevant departments’ decisions by forging or manipulating a doocument or numbers in a doocument.

Article 21 (Equal Opportunities for Subcontractors)

(1) The Company shall provide all subcontractors with transparent and fair transaction opportunities.
(2) The Company shall equally provide all subcontractors with the information needed for their transactions with the Company.
(3) Employees shall not exercise their influence to have a business run by a relative or acquaintance selected as a supplier.

Article 22 (Fair Transactions)

(1) All transactions involving the Company shall be carried out fairly and transparently under the law.
(2) Good-quality goods and reasonable prices shall be the basis of all transactions involving the Company.
(3) All transactions involving the Company shall be carried out under fair procedures and in accordance with the contracts signed. Where there is a transaction carried out not in accordance with a contract signed, the relevant employees shall consult with their supervisors regarding it and decide what to do.

Article 23 (No Unethical Acts toward Subcontractors)

(1) Employees shall not accept money or articles of value, entertainment, or conveniences offered by a subcontractor in connection with company business. The foregoing sentence shall not apply to a case of something not large under general social customs. Where it is judged that such a thing offered by a subcontractor is in expectation of something in return or goes beyond the level accepted under general social customs, the relevant employee and his/her department manager shall report it to the Office of Ethics (Ref. Appendix 2 hereto).
(2) Where an employee has accepted what is stated in the first sentence of the foregoing (1), he/she shall handle it per Appendix 1 hereto.
(3) Prohibition of other unethical behaviors

Article 24 (Encouraging Subcontractors’ Compliance)

Employees shall encourage subcontractors to comply with the Company’s Code of Ethics and this Ethical Code of Conduct.

Article 25 (Law Compliance; Sound Business Activities)

The Company shall respect values traditionally kept by the country and society, observe the law, engage in healthy business activities, create wealth for society, and strive to improve the quality of the lives of people.

Article 26 (No Involvement in Politics)

The Company shall not be involved in politics.

Article 27 (Protection of Environment and Resources)

(1) The Company shall do its best to keep the environment clean, keeping in mind the importance of protection of the environment and resources.
(2) The Company shall use environmentally-friendly containers and packing materials wherever possible.
(3) The Company shall recycle waste materials and refrain from producing pollutants wherever possible.

Article 28 (Safety Management)

(1) The Company shall strive to prevent fire/gas-related accidents through systematic and continued training and inspections.
(2) In the event of an accident stated in the foregoing (1), the Company shall take prompt measures to deal with it, placing top priority on the safety of local residents and customers.
(3) The Company shall carry out periodic checks of facilities to ensure the safety of customers.
(4) The Company shall prevent disasters and accidents to improve the conditions of workplaces.
(5) The Company shall carry out education and training for safe operation of vehicles to ensure the safety of employees, customers, and local residents.

Article 29 (Operation of Ethics Committee)

The Company shall have the Ethics Committee and Office of Ethics for more efficient operation of the Code of Ethics and Ethical Code of Conduct. Matters pertaining to the composition and functions of these organizations shall follow the Ethics Committee Operational Regulations.

Article 30 (Protection of Whistleblower)

The Company shall operate the whistleblowing system and criteria for protection of informers and whistleblowers.

Article 31 (Rewards and Disciplinary Action)

(1) Rewards

The Company may reward employees who have contributed to the Company through distinguished service in ethical management pending a decision by the Ethics Committee, and the level and procedure of the reward shall follow the Personnel Management Regulations.

(2) Disciplinary Action

The Company may discipline an employee who has acted contrary to the Code of Ethics and this Ethical Code of Conduct pending a decision by the Ethics Committee. Details of disciplinary actions shall follow the Personnel Management Regulations.

Article 32 (Additional Rules)

(1) This Ethical Code of Conduct shall be in effect as of January 1, 2001.
(2) This Ethical Code of Conduct shall not apply to unethical acts perpetrated before the date stated in the foregoing item (1).
(3) This Ethical Code of Conduct shall have priority over other regulations except for the Articles of Incorporation and the Code of Ethics in application. This Ethical Code of Conduct may be amended or abolished via a decision by the Board of Directors.
(4) Should there arise a dispute due to ambiguity of interpretation of a clause of these Action Rules or a conflict of interest, it shall be settled through an authoritative interpretation by the Ethics Committee.

1. How to handle money offered to an employee

(1) Money offered to an employee as a gift shall be returned to the relevant business (or the individual as the case may be).
(2) The written explanation of the return and a request for prevention of repetition of a similar case, together with a deposit slip without a bankbook, shall be sent to the representative of the relevant business (or the individual as the case may be) in the name of the chief of the relevant division.
(3) The relevant informer shall submit the result of handling said case, together with the report and copies of the letter sent and a deposit slip without a bankbook, to the Office of Ethics.

2. How to handle a gift offered to an employee

(1) With regard to a gift delivered without the relevant employee’s knowledge or a case in which refusal to receive is feared to be regarded as impolite, the employee shall report it to his/her immediate superior and handle it as follows:
(2) A gift whose content is feared to deteriorate within a short period and thus is thought that returning it does not appear to be a good option shall be donated to a social welfare facility in the name of the representative of the sender’s company. Then, the details of the gift and the receipt issued by the said facility shall be sent to the sender’s company following the method stated in the foregoing 1(2), and the report of the result shall be submitted in accordance with the foregoing 1(3).
(3) A gift that does not fall under the category stated in the foregoing (2) shall be returned to the representative of the sender’s company, after which the procedures stated in the foregoing 1(2) and 1(3) shall be followed.
(4) In the case of a gift that does not fall under the category stated in the foregoing (2), but whose return is not proper due to damage to the content, the employee shall report it to the Office of Ethics. The Office of Ethics shall then decide how to handle it (e.g. public disposal or donation to a social welfare facility), after which the procedures stated in the foregoing 1(2) and 1(3) shall be followed.