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Ethical Management

Ethical Code of Conduct

Chapter 1 Trust with Our Customers

1.1 Providing the Best Products and Services

1) Principle
We shall pursue the quality and service which our competitors can never imitate, and shall always make utmost efforts to this end. The quality and completeness of products and services to be used by customers shall be our most important value. Through our products and services, we shall build and maintain the trust that Lotte is reliable. This is our mission and the purpose of our existence; to create an affluent society.

2) Action Plan
① Make utmost efforts in order for our products and services to be customers’ first choice.
② Always pursue the highest level of satisfaction for a price that our competitors can never imitate.
③ Make customers trust and use the products and services only with the brand name of Lotte. To this end, strictly comply with all policies and procedures regarding safety, hygiene and quality at every moment.
④ Accurately identify the rapidly changing demands of customers, and be committed to meeting the expectation of customers by, for example, quickly responding to the reasonable complaints and requirements of customers.
⑤ Pursuing short-term profits or concealing products’ defects is an unconscientious act. Specifically, report and correct problems regarding the hygiene and safety or quality of products promptly.
⑥ Always check if products or components supplied by our partners comply with the standards and safety regulations of the company. Since even a minor component could largely affect the whole product, components or materials not meeting the standards or with defects shall be strictly excluded.
⑦ Domestic and foreign laws related to the safety of products are the minimum standards that we must basically comply with. In order to respond to safety problems which could occur later, establish and follow stricter in-house standards and safety criteria.

1.2 Honest Marketing

1) Principle
We shall provide only honest and truthful information in order to create the right customer values. We shall keep in mind that providing customers with false or exaggerated information for short-term sales growth or profits would in one moment, destroy customers’ trust which our colleagues have built with their best efforts. We shall actively disclose any information which may significantly affect our customers, even if it is disadvantageous to us.

2) Action Plan
① Those who are responsible for the marketing of products and services and communication with customers shall be well aware of in advance and comply with the related laws and company regulations.
② In the event of producing PR material, check if inaccurate information is included.
③ When using PR material produced by external agencies, thoroughly check if there are any factual errors or violations of intellectual property rights.
④ Refrain from the marketing plan indiscriminately criticizing competitors’ products based on information which is distorted and not obJecttive. Pay particular attention when mentioning competitors’ products in order not to violate the Fair-Trade Acts, etc.
⑤ Refrain from using vague or exaggerated wording when producing marketing material, and use words with clear meanings.
⑥ When the information about a product and service changes, inform the related division of such change to ensure that the product information is accurately reflected in the related material.

1.3 Protecting Customer Information Protection

1) Principle
>The damage done by the leakage of the company’s confidential information is to be borne by our company, but the damage caused by the leakage of customer information is directly passed on to our customers who are trusting us. Therefore, our company handles and manages customer information at the level beyond our company’s confidentiality. We shall set the internal standards regarding customer information protection above legal standards and shall collect and manage customer information in accordance with such standards.

2) Action Plan
① The principles of customer information protection are applied to all information which can identify individuals. Treat such information as the subject of first priority protection.
② Limit the access to customers’ personal information to ensure that only executives and employees involved in the applicable work are allowed to browse it.
③ The act of collecting customers’ personal information indiscriminately may be the subject of punishment. Do not collect any personal information, except that which is allowed to be collected by law.
④ Use personal information only for the business with which the customers agreed. Completely destroy the personal information of the customers which becomes no longer relevant or necessary to your business in order to ensure that such information is not recovered, according to the related regulation within the set period.
⑤ Be fully aware of the personal information-related laws of each country, since the level of regulations regarding personal information may vary depending on country.
⑥ The leakage of personal information does not only occur online. The personal information of customers may be leaked in unexpected places such as on photocopiers, desks or in the boxes collecting reusable paper. Manage such information strictly.
⑦ Treat the customer information received from our partners at the same level with our own information.
⑧ In the event of entrusting our customer information to a partner company, check if the partner company has physical, administrative and technical capabilities, enough to protect the customer information, and make sure whether it completely destroys such information after use.

1.4 Protecting Our Brand

1) Principle
Thinking that we are the face of Lotte, we shall first consider the position of our company and the profit of our customers before speaking about our company’s business through media such as TV, blogs, Twitter, Facebook and Internet Websites. We shall be committed to protecting the logo, mission, trademark and brand value of our company without damaging them via the media.

2) Action Plan
① Keep in mind that the behavior of each executive and employee is directly connected with the image of the company, and work to be careful in our words and actions to keep our dignity.
② Do not mention any confidential information regarding the company (financial, sales, customers, partners, employee information and intellectual property rights, etc.) and the policy, accidents and rumors which the company has not announced officially, or do not publish and distribute files containing photos, video and voice via the media without permission.
③ Do not slander our company and stakeholders through the media, and do not mention the accidents, complaints and slandering happening in the business process with the company and stakeholders.
④ Do not distribute false information, encourage illegal/unlawful acts, distribute pornography, make a personal insult, swear and cause sexual discrimination, etc. which all may damage the reputation of the company, stakeholders or others.
⑤ Consult with the related division, including a PR Officer, about the purpose and details of the interview in advance when having an interview with the media.
⑥ In the event of mentioning your personal opinion regarding the company, make clear that it is not the company’s opinion, but your own.

Chapter 2 Trust with Our Employees

2.1 Equal Opportunity and Fair Treatment

1) Principle
We, the members of Lotte, shall provide fair opportunities for all, treat all in a fair way and pursue the open organizational culture where anyone could grow as much as their ability and efforts. We did not enter the company and were not promoted through external pressure or improper solicitation, and we are responsible for handing down the clean organizational culture with no external pressure or improper solicitation over to our junior employees. We shall only reflect fair factors such as the characteristics of our business, capabilities and performance in the HR affairs. All HR-related decisions shall exclude discrimination based on personal characteristics, including gender, age, race, nationality and the region of origin, generation, religion and disability. In doing so, all executives and employees of Lotte could trust the company’s decision-making.

2) Action Plan
① Create a community where a specific person is not discriminated against due to personal characteristics.
② Eliminate from the organization the discrimination against individuals due to characteristics such as gender, age, race, nationality or the region of origin, generation, religion and disability, most of which cannot be personally changed. Do not discriminate against individuals due to their unique characteristics in the processes of recruitment, promotion, placement, salary, compensation, welfare benefits and education, etc.
③ Laws or policies regarding working conditions may vary depending on country. If this results in a difference between the HR regulation or policy of the local corporation and the policy of Lotte Group, stipulate such regulation and policy and reasonably explain its difference from the Group policy.
④ Be wary of anyone who claims that only those with a certain gender, age and background are able to conduct the job well.
⑤ Any improper solicitation regarding HR is prohibited, as it would deal a fatal blow to our community in the long term.
⑥ Evaluate everyone based only on their capability and performance and clearly explain our principle to those who solicit recruitment and promotion.

2.2 Mutual Respect among Our Members

1) Principle
Every one of Lotte’s executives and employees is valuable. We shall not allow any words and actions to undermine our respect and dignity. We shall reject any words or actions that undermine the dignity and class of our community and shall not create a working environment which is threatening, insulting, hostile or unpleasant.

2) Action Plan
① Always respect and care for your colleagues like your family.
② Do not judge others with your own values. Create the culture where various opinions and values of various people are recognized not as wrong, but as different and can also be understood.
③ The head of the department can only exist if there are members of the department. Since the members of the department are talents whom we entrusted to you to treat and foster with loving care, do your best to support them.
④ Employees shall do as they wish outside working hours. The director shall avoid making work orders outside working hours and ensure that the members strike the balance between work and family.
⑤ Avoid words and actions that express violence and sadism or show the sense of repulsion or incompatibility to others. Always be careful to ensure that your thoughtless words or actions do not hurt or cause misunderstanding to others.
⑥ In addition to words and actions, create a working environment devoid of bullying in the workplace by eradicating the acts of using improper wording or posting and sending improper content via communication systems such as telephone, messenger, social media, e-mail.
⑦ The above principles are applied not only to Lotte executives and employees, but also to relationships with our customers, partners and all stakeholders. Always speak and act carefully.

2.3 Gender Equality

1) Principle
The phrase ‘the members of Lotte’ includes the qualification and rights to be equally respected and treated. Lotte shall not discriminate against anyone due to gender and shall strictly ban words and actions expressing displeasure or hatred regarding gender.

2) Action Plan
① Childbirth and child-rearing are very important issues. Welcome and congratulate the maternity/paternity leave of your colleagues. Firmly eradicate any HR-related discrimination or inconvenience in connection with childbirth and child-rearing.
② The phrase ‘female employee’ is unnecessary, since it distinguishes employees by gender. In addition, female talents are not the subject of caring and compassion. Treat men and women equally without discrimination.
③ Ban any gender-related offensive conducts, sexual harassment and unwanted sexual contact and approach as well as any behaviors which create an uncomfortable working atmosphere due to the reason of refusing to go on a date.
④ Report to the in-house sexual harassment prevention team if you suffered or witnessed the above behaviors.
⑤ Anyone who commits sexual harassment will be strictly punished regardless of rank and the intention of their behaviors. Taking disadvantageous actions, including firing or placing the victim of sexual harassment to another department against their will shall also be subject to punishment.
⑥ The protection of victims shall be a top priority, when dealing with the sexual harassment cases. Do not push victims to reach a compromise with the abuser. Fulfil the confidentiality obligation in the disciplinary process.
⑦ The company shall strive to prevent sexual harassment by, for example, providing the education course once a year in order to prevent sexual harassment at work.

2.4 Safe Working Environment

1) Principle
We shall not only strictly comply with all laws regarding safety and hygiene, but also establish and follow even stricter in-house regulations to prevent any safety accidents. We shall be committed to providing a safe working environment not only for Lotte executives and employees, but also for our partners and all stakeholders, and actively spread the significance of safety to them. Lotte employees shall never neglect even any familiar jobs since we know that many accidents are caused by the mind of ‘it’ll never happen’ and ‘carelessness’ in our daily life, not by the lack of experience.

2) Action Plan
① Prioritize safety more than other values, and do not hesitate to address or correct safety-related problems due to costs, delivery date and practice, etc.
② Aggressively find out dangerous working conditions and problems threatening safety, and promptly consult with the director or safety manager to improve even minor ones.
③ Be well aware of safety-related regulations and measures in the place where you are working, and follow the user manual, safety regulations and emergency response procedure when using the equipment within the workplace.
④ Analyze the types of possible safety accidents and prepare the initial response manual for each accident. Establish elaborate management plans for the safety of human/material resources regarding the continuous operating of the company such as employees, facilities and IT assets, and conduct education and training for the executives and employees on a regular basis.
⑤ The executives and employees shall not allow unauthorized access to the workplace of the company, proactively inform partners and stakeholders of the significance of safety and hygiene and request them to follow the regulations.
⑥ Consult with management if you or your colleagues are having a hard time working normally due to health problems, psychological anxiety, etc.
⑦ Do not drink too much alcohol to interfere with your performance at work, and do not produce, use, sell, possess any illegal drugs or work after taking such drugs.
⑧ If a safety accident occurs, do not cover it up; check the facts through accurate investigation so as to make relevant people responsible, and then compensate the victim properly.

2.5 Protecting Our Assets

1) Principle
We shall be committed to protecting the company’s assets and use them for the intended purposes only. We shall actively protect not only tangible assets such as buildings, lands, communication equipment, funds, system, tickets for PR and vehicles, but also intangible assets such as information, technologies, working hours, especially trademarks and copyrighted works.

2) Action Plan
① The working hours of each employee also constitute the assets of the company. Avoid using private phone-calls, personal e-mail, social media and surfing the Web during working hours. It is the act of abusing the community’s assets to use private calls and e-mailing beyond the level of common sense.
② Protect property, data infrastructure, equipment and consumables from misuse, damage, theft or improper management.
③ The intentional damage, embezzlement and theft of the company assets are subject to the cancellation of the employment agreement and criminal punishment. The unauthorized transfer and leakage of information and false reporting about costs are also not allowed.
④ Do not conduct illegal actions such as stock trading, gambling and downloading pornographic material using the electronic equipment of the company.
⑤ Do not instruct or ask about private affairs, including financial work, buying a present and searching for information, other than the official business of the company to other executives and employees. The waste of employees’ working hours caused by your instructions is also the abuse of the company’s assets.
⑥ Do not use invitation cards, gift cards or giveaways for PR purposes for your private use.
⑦ The assets of our competitors are as important as ours. Protect the assets of our partners and competitors in a precious way.
⑧ Consult with and get an approval from the director when using the company’s assets for external use or for any purpose other than as intended.

2.6 Protecting Our Intellectual Property Rights

1) Principle
We shall always value and protect the intellectual property rights of the company. We shall not disclose the intellectual property and various information of the company to the outside without prior permission or due procedure. The range of intellectual property rights include not only trademarks, patent rights, copyright, design rights and utility model rights, but also the business and technical secrets of the company which are yet to be disclosed to the outside.

2) Action Plan
① All information related to the company business is the intellectual property of the company. Accurately record, report and systematically manage such information.
② Be well aware of which information must be protected, and comply with the in-house regulations on the intellectual property rights protection.
③ Pay particular attention not to violate the regulations on intellectual property rights protection when in contact with outsiders.
④ Clearly recognize that the unauthorized use, reproduction, distribution and alteration which infringes the intellectual property rights are subject to disciplinary actions or criminal punishment according to related regulations or laws.
⑤ Know-hows or technologies produced by the executives and employees at work shall not belong to individuals, but to the assets of the company. Manage even the intellectual property rights produced by individuals in accordance with the company regulations.
⑥ Check national differences and ensure that the intellectual property of the company is also protected overseas, since the laws on intellectual property rights may vary depending on country.
⑦ In the event of conducting business in cooperation with our partners, consult on and clarify who is the owner of the intellectual property rights in advance in order to avoid disputes over the intellectual property rights.
⑧ The intellectual property rights of our partners and all stakeholders shall be respected. Always check whether our new products or services infringe the intellectual property rights of others.
⑨ When we recruit manpower from our competitors and vice versa, verify and manage the entrance/resignation procedures of the company so as to check whether the intellectual property rights of others or our company are infringed.

2.7 Preventing Information Leakage

1) Principle
We shall properly use the communication equipment where needed at work, and ensure that information leakage does not occur by strictly following the company regulations on the information protection.

2) Action Plan
① All electronic equipment provided by the company is only for the company’s business. Check the acceptable standards if you wish to use them for purposes other than the company’s business.
② The company is obliged to check and record how the executives and employees use communication and services through electronic equipment in order to protect information.
③ Frequently check whether a personal computer is infected with a virus, and that the firewall is active and the security software is updated to the latest standards.
④ Use only authorized software within the company. Follow the company regulations and procedures when uploading and downloading all data.
⑤ Change your PIN(Personal Identification Number) more than once every three months and do not share it with others.
⑥ Delete the data related to the company business saved in your personal hard disk or electronic devices in the event of leaving the company or moving to another company. The director shall strictly manage the data to ensure that illegal data leakage does not occur when an employee leaves the company or moves to another company.
⑦ Manage your business through the company’s security system within the company. Get approval from the director if necessary since it is not allowable to leak the doocuments and information of the company via unauthorized storage media or e-mail to the outside without permission.
⑧ Always clearly designate a recipient and set a password for doocuments requiring confidentiality in order to prevent the leakage of the company’s important information via e-mail.
⑨ Pay particular attention not to leak the important information of the company in offline occasions such as meetings with the executives and employees of the company, our customers and partners.
⑩ Ensure that the personal social media does not become a channel to leak the information about the company.

Chapter 3 Trust with Our Partners

3.1 Compliance with the Fair Trade Act

1) Principle
We are taking the lead in complying with the Fair Trade Acts applicable to the subject regions around the world. The principles of equality, fairness and openness are the most important principles which have grown our society. We shall consider these principles as the very basic principles in our relationship with all partners around the world. We shall aggressively correct the existing practices of unfair trade, if any, to set the culture of fair trade, and shall pursue the beautiful culture of co-existence.

2) Action Plan
① Do not ask our partners to conduct unfair trade or practices by abusing your position. Fully understand the Fair Trade Act, and strictly reject any unfair actions that violate this Act.
② Select a partner publicly in accordance with the obJecttive criteria and specified procedures such as quality, prices and financial soundness.
③ Provide an opportunity for a company, which shares Lotte’s dedication to and effort in integrity, ethics and social responsibility, to be selected as our partner.
④ Consult with and gain approval from the director since there could occur information leakage, improper solicitation or situations violating the Fair Trade Act when conducting business with our partners where the executives and employees’ relatives or friends are working, or any stakeholders.
⑤ Frequently check and be well aware of the details to avoid the violation of the Fair Trade Act since the laws and policies regarding fair trade may vary depending on country and the details of the Fair Trade Act are changing as times and the world change.

3.2 Respect for Our Partners

1) Principle
We shall value our cooperation and relationships with all partners and treat them in an equal and fair way. All the principles of the code of conduct that we observe shall be applied to the relationships with our partners.

2) Action Plan
① Respect and treat the executives and employees of our partners equally and fairly like those of Lotte.
② Respect the management policy and the executives and employees’ working hours of our partners.
③ Explain the provisions regarding Lotte’s code of conduct and other policies to the partners, and request them to agree and comply to them.
④ Treat the partners in a fair way, regardless of their size.
⑤ Always pay particular attention to the protection of partners’ confidential information and intellectual property rights.
⑥ Actively provide partners with various growth opportunities, including HR development, quality improvement and technology development. The improvement of their competitiveness will be a driving force of our growth.

3.3 Fair Competition

1) Principle
We shall compete in a fair way based on the creativity of the company for the proper development of the national economy. We shall discourage the acts of undermining fair competition and shall take the lead in creating a fair and transparent world.

2) Action Plan
① It is prohibited to conduct any acts of disturbing the reasonable choice of customers through mutual agreement or connivance among companies and limiting the actual competition among companies. Do not conduct any prohibited act for immediate gains or results.
② Never even discuss with the competitors on anything against the Fair Trade Acts, including prices, the details of bidding, costs, profits, market share, sales region, the distribution of product family, business conditions, distribution method, the allocation of regions or markets, the boycott of a specific supplier and customer, provided products or services, and the class of customers or suppliers.
③ Do not participate in meetings with the competitors where the agenda is not clear. Even if participating in the meeting with a clear agenda, clearly show your intention to refuse the discussion when a dangerous subject begins to be discussed.
④ While an act, which is allowed in a certain country, may be illegal in another country, our competitors in a certain country may become our partners in another country. In order to prevent the violation of laws in such a case, be fully aware of competition-related laws of each country in advance.
⑤ Consider the possibility of violating the laws in advance, if the company runs the joint venture or cooperates with the competitor after finding it difficult to achieve its business goal alone.
⑥ An illegal act could significantly affect not only individuals, but also the company’s reputation. In addition to doing an illegal act itself, do not abet, condone and assist an illegal act.

3.4 Lawful Information Collection

1) Principle
We shall collect and secure information about our competitors in a legitimate and fair way. We shall not take away or misuse technologies belonging to our partners by using our status in the business process, and shall strive to enhance the win-win cooperation relationship with our partners.

2) Action Plan
① Do not collect the information of our competitors by using your personal relationships or through our customers and partners. Include and follow the provision of ‘Confidentiality’ in the agreements with the partners.
② Consult with the Compliance Officer in advance, especially since the direct collection/exchange of information with the competitors could be considered a violation of the Fair Trade Act.
③ Since it could be a problem to require the confidential information of the competitors when hiring an employee who has worked for our competitor, do not acquire the information of the competitors through such an employee.
④ In the event of acquiring the information of our competitors from anonymous sources, consult with the Compliance Officer in advance when viewing and processing such information.
⑤ You may be subject to punitive damages if caught taking away or misusing the technical materials of partners such as our subcontractors. Do not require our partners to provide their technologies and related materials without any fair reasons.

3.5 Prohibition of Corruption and Improper Solicitation

1) Principle
We shall conduct our business in a fair and transparent way. We shall not make any unfair personal profit, receive or provide improper money and valuables and entertainment treatment in our business relations. This principle is applied to all countries where we are conducting the business, and we shall respect and comply with any applicable domestic and foreign anti-corruption laws, including OECD Anti-Bribery Convention, Foreign Corrupt Practices Act (FCPA) and UK Bribery Act, in relation to our business activities in those regions.

2) Action Plan
① The executives and employees of the company shall not make improper solicitation for any public officials.
② The executives and employees of the company shall not provide money and valuables in relation to their duty for any stakeholders. Specifically, they shall not provide money and valuables above a certain amount for public officials, regardless of job relevance.
③ Money and valuables, prohibited to be provided, include all tangible/intangible financial gains such as gifts, meals, courteous and entertainment treatment, convenience, donations and sponsorship as well as cash.
④ Politely decline any money and valuables provided by stakeholders and then clearly explain the related company regulations and spirit of Lotte. ⑤ Comply with the company regulations regarding gifts, meals and courteous treatment and return any gifts that go against the regulations. If it is difficult to return the gifts, deal with it in accordance with the related regulations through consultation with the Compliance Officer or Ethical Management Officer.
⑥ Even if our partners such as stakeholders who are working with us receive any impermissible money and valuables, it may be seen as our fault. Explain our regulations to the stakeholders by, for example, specifying that the violation of the Anti-corruption Laws is the reason of contract cancellation, and then require them to follow the regulations.
⑦ Regulations or customs regarding gifts, meals and courteous treatment may vary depending on the country. Identify in advance and follow the related regulations or customs when taking a business trip or working at local offices overseas.
⑧ Receive advice and approval from the Compliance Officer of the company in advance for conducting business if it is unclear whether the domestic laws and code of conduct are being violated or whether the local laws and customs are different from this code of conduct or the company regulations while working in the foreign countries.

Chapter 4 Trust with Our Stockholders

4.1 Improving Stockholder Value

1) Principle
By establishing effective internal control systems, we shall work to monitor and constantly improve the performance of the company on behalf of the stockholders and to enhance stakeholder value in the long term. We shall build the relationship of mutual trust with stockholders and guarantee the equal rights of all stockholders.

2) Action Plan
① Be committed to enhancing the profit of our stockholders through efficient and reasonable decision-making and transparent and sound management activities.
② Modify the Internal Accounting Control regulations and systems, and actively cooperate for audits or investigations to ensure independent supervision.
③ Respect the due right of the stockholders as much as possible, and build a relationship of mutual trust with them.
④ Guarantee equal treatment for all stockholders, and actively guarantee the rights of minority stockholders.
⑤ It is Lotte’s stockholders who have affection to and interest in Lotte more than anyone. Carefully listen to the reasonable opinions of stockholders.

4.2 Preventing Conflicts of Interest

1) Principle
If there is a conflict of interest between individuals and the company, we shall work to meet the interest of the stakeholders such as the company and stockholders. If there is, or is feared to be, a conflict of interest, we shall report the situation to and get approval from the company to ensure that our personal interests do not confuse the reasonable decision-making.

2) Action Plan
① Do not act against the interests of the stakeholders such as the company and stockholders, including making personal gains through the position of Lotte executives and employees. It is also prohibited to acquire personal gains indirectly through family members, friends and agents of Lotte executives and employees.
② Get approval from the company in advance in the event that there may be a conflict of interest with the company, including self-dealing transactions or utilizing the business opportunity of the company.
③ Do not become the executive or employee of another company conducting the business in the same field or do not acquire the share of such company without the approval of the company.
④ Consult with the Compliance Officer in advance in the event that there could be a conflict of interest between the executives and employees and the company or that it is unclear whether there is a conflict of interest.

4.3 Improvement of Accounting Transparency

1) Principle
We shall accurately record any matters regarding the performance and financial position of the company in accordance with related laws, accounting standards and internal regulations. All accounting records shall be proven by appropriate accounting information. We shall record any matters regarding any performance and costs at the time of their occurrence in order to identify the accurate management situation. We shall not distort any data. Accurate accounting records are not an obligation simply limited to those who are responsible for accounting and finance, but the common obligation of all executives and employees.

2) Action Plan
① Prepare and manage the accounting records in accordance with the authorized accounting standards.
② Not only do international and national accounting standards differ, but they are also being frequently amended. Always check the latest standards.
③ Record the related data within the proper accounting period. Do not record any revenues or costs in advance or later in order to exaggerate the short-term performance or temporarily avoid a reprimand.
④ All costs incurred shall be proven by the uniform accounting data. Record time and expenses regarding the costs and submit it as a report.
⑤ In the event that a person in charge manipulates the accounting doocuments according to the instruction of his/her supervisor, both he/she and his/her supervisor shall have civil/criminal responsibilities. In the event that the supervisor instructs the manipulation of doocuments, the person in charge shall immediately consult with the compliance officer.
⑥ Consult on the problem with the director when your counterparty in the transaction is suspicious of manipulating the accounting doocuments or suspected as an individual, company or country having untransparent business practice, and reconsider such a transaction.
⑦ The director shall thoroughly check everything in accordance with principles in order to provide accurate and transparent information, and shall monitor the data on a regular basis in order to prevent the manipulation of accounting doocuments.

4.4 Prohibition of In-house Trading

1) Principle
We shall not make any unfair profit for ourselves, our family members or friends by utilizing undisclosed and insider information. We shall be committed to protecting the profit of our stockholders through efficient and reasonable decision-making and transparent and sound management activities.

2) Action Plan
① Always pay particular attention when providing any information regarding our business. Specifically, if it is insider information, providing such information to others and using it for personal use are all illegal. In addition, it may harm the due rights of the stockholders who have affection to and interest in Lotte the most.
② Insider information includes data regarding management performance, the transfers of executives, restructuring, mergers, acquisition, new product development, new patents, information regarding large-scale investments and the investment plans for a certain region. Manage the information in accordance with the same standards as insider information, if it is unclear whether the information that you are handling is insider information.
③ All trades such as transactions using the undisclosed important information and stock exchanges, the establishment/acquisition of the security right and securities lending transactions are strictly prohibited.
④ Do not provide the undisclosed important information in expectance of transactions by others or do not recommend anyone to be involved in the other transactions by using such information.
⑤ It is prohibited to conduct stock trading by using the insider information that you came to know at work even after leaving the company or moving to another company.
⑥ Protect the information in accordance with the same standards applied to our insider information, in the event of coming to know the insider information of your partners and competitors.
⑦ In principle, it is prohibited to own the stocks of our partners which have business relations with our company. The same applies to the case of acquiring the stocks of our partners in the name of your family members and relatives.
⑧ Consult with the Compliance Officer even if you have owned the stocks of our partners before entering our company, since there may be a conflict of interest, including providing unfair convenience in the business process.
⑨ It is prohibited to be involved in the trading of derivatives such as hedge trading and short stock selling for the stocks of our company and its affiliates and the related options and swaps.

Chapter 5 Trust with Society

5.1 Environmental Protection

1) Principle
We shall play a leading role in every type of business for environmental protection. We shall always think of the impact that our business could have on the environment and shall be committed to protecting the environment, starting from the small things. With the responsibility of environmental protection, we shall establish and strictly meet the standards beyond the level required by the environmental laws of each country, not only within our country, but also in every country where we are operating our business.

2) Action Plan
① Use natural resources only as much as needed in an efficient way and reduce the emission of environmental pollutants below the statuary level.
② Check first whether the development of new products or the change of any processes could have an adverse impact on the environment.
③ Establish the internal regulations to ensure that our activities meet the legal standards regarding the environment and regularly check if such regulations are complied with.
④ Actively seek the way of environmental protection through the change or innovation of our business, and encourage the executives and employees to do or make the related activities and efforts.
⑤ Require our partners and stakeholders to meet the same environmental protection standards as we do. Specify and sufficiently inform them that their contract with us may be cancelled if caught violating environment-related laws.
⑥ Frequently check if local environment-related laws change when working overseas, and take advance measures in response to such change.

5.2 Creation of Social Values and Social Contribution

1) Principle
We shall not only create social values and make the world affluent via our business, but also actively conduct social contribution activities with our capabilities and resources. As a member of the society, we shall participate in the problem-solving activities in the local community and take the lead in developing the local community. We shall actively encourage the social service activities of each executive and employee and be committed to contributing to society by, for example, participating in social service and disaster relief activities at the company level.

2) Action Plan
① The members of Lotte are accompanied with a higher level of social responsibility than others. Each executive and employee of Lotte shall be committed in fulfilling his/her responsibility and duty as a member of the local community to enhance the trust for the company.
② Respect the culture and values of the local community and contribute to improving the quality of life in the local community.
③ Provide a positive impact on social development by actively supporting activities for public interests, including academics, art, culture and sports, which psychologically enrich humanity.
④ Active participation in social service activities as individuals or on behalf of the company is the duty and responsible action of Lotte members. Actively participate in social service activities such as volunteer work and disaster relief.
⑤ Seek the plans with which our business activities can create social values and fulfill our social responsibility, and work to act on such plans.

5.3 Respect for Human Rights

1) Principle
Human rights are the basic rights and freedoms to be granted to everyone. The members of Lotte shall support and respect the “United Nations Guiding Principles on Business and Human Rights” declared internationally and guarantee human rights in places where we are conducting our business.

2) Action Plan
① Regarding our business, we shall respect human rights anywhere at any time.
② We shall follow our values and standards regarding respect for human rights and spread them to our partners.
③ We shall work to prevent a negative impact on human rights, which may be caused by our business.
④ We shall guarantee and support human rights in the local community which we belong to.
⑤ We shall be well aware of and comply with local laws regarding labor.
⑥ We shall not allow child labor in the workplace of our company and partners and shall follow the local laws and international standards regarding the minimum working age.
⑦ Consult with the Compliance Officer and check the requirements of the minimum working age in accordance with the related laws, when an employee below 18 is required to be employed.
⑧ Coercion, confinement or other forced labor, etc. shall not be allowed.

5.4 Respect for Cultural Diversity

1) Principle
We shall accept the values and customs of each country as much as possible, to live up to the reputation of Global Lotte, and shall embrace various cultures and opinions of people around the world with an open mind. We shall be obliged to preciously protect and develop the resources and human resources of the countries where we are conducting our business, since we borrowed these resources from those countries.

2) Action Plan
① Do not discriminate against the local executives and employees due to different culture and values.
② Open communication is very important anywhere. Create various opportunities and channels to ensure that the opinions of the locals can be heard carefully.
③ Do not force the locals to follow our values and customs, and do learn from them first.
④ There are different laws, customs and manners depending on countries and regions. Pay particular attention when working overseas or on a business trip, since a behavior that is not a problem at home may cause trouble in foreign countries.
⑤ The principle of ‘trust’ is applied all around the world. Always check things that the locals value and value them as well so that the locals can trust us.

5.5 Compliance with the Laws of Each Country

1) Principle
The members of Lotte are working to respect the laws all around the world. We shall be fully aware of and understand the related laws and company regulations applicable in our business process and shall regularly check whether the related regulations are complied with in our daily work. Especially, we shall firmly exclude the act of being involved in corruption or criminal activities for profit.

2) Action Plan
① Understand the laws applicable in the business process and conduct the business in accordance with such laws.
② If dispatched to an overseas workplace, fully understand the related laws of other countries which could affect your business as well as the country where you are dispatched.
③ Thoroughly check and follow the trade laws regarding import and export, including the licensing or approval of each government, in the event of importing and exporting commodities or products.
④ It is prohibited to do businesses with countries or organizations and individuals against which trade sanctions have been imposed.
⑤ Consult with the Compliance Officer in advance in the event of international trade negotiations or transactions and trade with foreign governments/organizations.
⑥ Report the cases to the applicable department such as “Sinmungo” of the Group or each company in the event that there is suspicion of money laundering such as purchasing a large number of vouchers unnecessarily and turning them into cash.

5.6 Separation of Politics and Economy

1) Principle
Politics is the process of democracy that makes the world better by gathering various opinions based on the principle of one-man one-vote for all members of the nation. We believe that the world could develop further through such processes. If a company is involved in such a fair process in an unfair way, it would become an obstacle in making a better world. We shall not restrict our employees from expressing their personal opinions regarding politics. Even if a certain politician or political organization has a favorable opinion or claim to our business, however, we shall not support or join them in an unfair way at the level of the Group, affiliates and organizations.

2) Action Plan
① The name of Lotte shall not be used for political activities or for the interests of political parties or their candidates.
② Do not do any acts which support or appear to support a certain politician or organization by using the resources and costs of the company.
③ Do not expose your title or position in the company to ensure that you don’t look like you are supporting them at the company level, when personally attending the meetings of certain politicians or political parties. Keep in mind that our title or position may be utilized by others, regardless of our intentions.
④ Consult with the PR Officer of the company when you are likely to be exposed to the media such as newspapers or broadcasting.
⑤ Always pay particular attention when uploading a post or writing a comment via social media to ensure that your wording is not misunderstood in a political way.
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