The purpose of this guideline is to stipulate a detailed standard of judgment and conduct guideline for the Code of Ethical Conduct.

The definitions of the terms used in this guideline are as the following.

• ① Money and valuables: economic profit, such as money (cash, gift certificate, marketable securities) and goods
• ② Treatment: Benefits including meals, feasts, golf, performances, and entertainment
• ③ Convenience: Money and valuables, such as transportation, accommodation, tourist, event support, or any other support besides treatment
• ④ Party concerned: Persons such as executives and staff members, corporate bodies, and other organizations that are directly affected in rights or profit by task performed by the relevant executive or staff member.
• ⑤ Violation of this guideline by the family, relatives, and acquaintances of the executive or the staff member will be considered as an action by the said executive or staff member.
• ⑥ Corruption Prevention Secretariat: Department in charge of ethical management under the committee, established by Corruption Prevention Management Committee’s detailed management regulations (revised on July 19, 2006); the head of the planning department serves as the secretary-general (hereinafter referred to as ‘secretariat’).

• ① Prohibition of bribery
  • 1. Standard of judgment
    • - Accepting gift certificates, shoe tickets, etc. from party concerned applies to bribery regardless of the amount and the reason; thus, it is a violation of Code of Ethical Conduct
    • - If the money received for congratulations or condolences exceeds the socially accepted range, or the event of congratulation or condolence has been notified beforehand to a contractor and causes pressure, it is considered a violation of Code of Ethical Conduct
    • - If the money supported by person or team for an event of congratulation or condolence of an executive or staff member of the company exceeds 50,000 KRW, it is considered a violation of Code of Ethical Conduct
  • 2. Conduct guideline
    • - The recipient must politely refuse even if the party concerned provides money or valuables as a token of gratitude. If the money or valuable has been received regardless of will in cases such as mail or leaving the goods during absence, it must be immediately returned. If the money or valuable must be received due to unknown sender, it must be reported by attached ‘Acquisition Report of Money, Valuable, etc.’ form to subcommittee member for relevant head office
    • -Once the subcommittee member receives the said report, he or she must immediately report to the compliance manager for relevant head office. If the money or valuable is difficult to return, then it must be used for donations, etc. and the result of the measure must be notified to the secretariat
    • - Among the events of congratulations and condolences of executives and staff members, if the family member suffers a particular deprivation (requiring a large amount for operation charges), or for cases determined by collective agreement, the money or valuable may exceed 50,000 KRW
    • ② Prohibition of receiving treatment
      • 1. Standard of judgment
        • - Receiving a provision of meal or being entertained in liquor or golf from party concerned is a violation of Code of Ethical Conduct; suggesting, notifying, or demanding such treatment to the party concerned is also a violation of Code of Ethical Conduct
        • - Playing golf with party concerned in private and burdening the cost to the party concerned, playing golf without the approval by the company during office hours, or using golf membership held by the party concerned for private use are all violation of Code of Ethical Conduct
      • 2. Conduct guideline
        • - In the event where a meal with the party concerned out of necessity takes place, the cost is burdened by the company in principle; even if the party concerned is participating due to unavoidable reason, the cost must be processed by company’s expense (reasoning lack of budget for burdening the party concerned will not be tolerated)
        • - A small sum of meal expense can be made by the party concerned in consideration of social acceptance, but it must not be frequent. Any suggestions for a second round must be politely declined.
        • - In the event of playing golf during office hours in relation to task, it must be reported to the subcommittee member of the relevant head office in the process conforming to bribery.
        • ③ Prohibition of receiving convenience
          • 1. Standard of judgment
            • - In the event of company events, such as outing or athletic competition, or an individual business trip, receiving sponsorship or suggesting such for transportation, accommodation, tourist information, event support, etc. is a violation of Code of Ethical Conduct
          • 2. Conduct guideline
            • - In the event where accommodation or transportation is officially provided for attending at seminars, etc. hosted by the party concerned, it must be reported to the subcommittee member of the relevant head office in the process conforming to bribery; the relevant sum cannot be claimed when calculating the business travel expenses
            • - Attendance of party concerned for events other than official event of the company and held at department level, club events, etc. is prohibited
            • ④ Prohibition of private use of company assets
              • 1. Standard of judgment
                • - Unauthorized transfer or arbitrary usage for private purposes of company assets are violation of Code of Ethical Conduct
                • - Using information obtained during work from company to accumulate private property through methods such as stock exchange is an activity that damages the public image of the company and a violation of the Code of Ethical Conduct (short term investment of less than 6 months in the form states above is subject to fine by the Financial Supervisory Service)
              • 2. Conduct guideline
                • - Company assets must be used for official purposes; in the event where private usage is required due to necessity, it must be reported to the subcommittee member of the relevant head office in the process conforming to bribery
                • - The company holds the ownership of information obtained while on duty; private use of even the minor information is prohibited.
                • ⑤ Prohibition of infringing personnel relations
                  • 1. Standard of judgment
                    • - Remaining idle or concealing dereliction of duty by one’s superior while knowing about it, and following an unjust order, is a violation of Code of Ethical Conduct
                    • - A personnel’s superior is prohibited from exercising pressure on bidding, contract, etc. through actions such as recommending a subcontractor
                    • - A personnel’s superior may present a designated gift for the said personnel for encouragement; subordinate personnel is prohibited from presenting any money or valuables to his or her boss
                    • - Pressuring a sexual contact or date using one’s position at work is sexual harassment; speaking, acting, or describing in an obscene way to any executive or staff related to work and sexually humiliating them or shaming them are also sexual harassment. Any sexual harassment is prohibited.
                  • 2. Conduct guideline
                    • - If a personnel is aware of the dereliction of duty by his or her superior, he or she must report to the secretariat or inspection team in person
                    • - If an order from one’s superior goes against the Code of Ethical Conduct, is related to corruption, or can cause a grave damage to the company, the said personnel must report to the secretariat or inspection team. In the event of an unjust order in general business process, the personnel must first address the injustice of the order; if this is not accepted or the said personnel suffers a disadvantage, then it must be reported to the secretariat or the inspection team
                    • - Victim of sexual harassment must take an initial measure such as expressing refusal, caution, or warning to the assailant; then, the victim must consult his or her superior or the secretariat for a swift resolution and report to the inspection team

In the event where the Code of Ethical Conduct or similar guidelines for the executive and staff members is violated, it is penalized according to related regulations of the company.

This guideline is implemented as of July 20, 2006.