The purpose of these criteria is to determine details regarding the compensation and identity protection of the informant of corruption that occurs in task involving executives, staff members, partnerships, clients, and other parties involved in Namkwang Engineering Co., Ltd. (hereinafter referred to as ‘Company’).

Any case which violates the Code of Ethical Conduct, and Related Rules (hereinafter referred to as Ethics Management Rules).

• ① Those who have recognized an act of corruption, such as violation of Ethics Management Rules), by an executive or a staff member of the Company must report to the Corruption Prevention Secretariat (hereinafter referred to as ‘Secretariat’), under the Corruption Prevention Committee (hereinafter referred to as ‘Committee’) of the company. The most convenient method, among methods such as cyber complaint website, mail, phone call, fax, in person, etc., is to be chosen for report.
• ② In principle, the informant must specify the personal data of himself or herself and the violator and the content of violation and attach the evidence based on Attachment 1 ‘Corruption Report’ form to report. However, in cases requiring emergency, such as act of corruption in progress at the time of report, the informant may report only the relevant facts without evidence.

The standard for the compensation is as Attachment 2

• ① Case in which the content of the report is confirmed to be false or difficult to verify due to lack of evidence
• ② Report of corruption which is not related to the task with external party concerned. However, reports of corruption which causes direct damage to the company’s assets, such as misappropriation of company funds or theft of company assets, will be compensated
• ③ Matter which has already been reported or have been recognized by the Secretariat, other related departments, or external institution, and is under investigation, under disciplinary procedure, or have completed disciplinary procedure
• ④ Matters that were exposed by the press reports, etc
• ⑤ Case in which the informant is anonymous or used an alias, and thus the identity of the informant is unknown
• ⑥ Other cases in which the result of compensation review deems it inappropriate

In case which it is revealed that the informant is subject to exemption to compensation after the compensation has been made, it may be confiscated.

• ① The compliance administrator may request a compensation review while reporting on investigation results if deemed necessary for the following matters.
  • 1. Whether compensation should be made for report case in which bribery is unclear
  • 2. Whether compensation should be made for voluntary report
  • 3. In cases where the size or the nature of reported money or valuables, treatment, convenience, money for congratulation or condolence, event support, etc. is obscure; whether the reported matter infringes the Ethical Management Rules; and whether the informant is applicable as the subject of compensation
  • 4. Other cases requiring review due to uncertainty in applicability as the subject of compensation
• ② The compensation review is held within one week of request in principle; it is held with the compliance administrator as the chair and the secretary-general as the secretary, attended by the head of the auditing department, compliance manager, and subcommittee members of the relevant head office.
• ③ The compensation review is to draw a conclusion through discussion in principle. In cases where discussion is impossible, resolution may be made through majority vote. The result of the review is to be documented as minutes to be kept; if required, the result can be informed to the informant.

• ① The secretary-general of the Corruption Prevention Secretariat receives the compensation for the informant and provides it to the informant in a way which guarantees secrecy and which the informant wishes.
• ② Prohibition of identity leak or tracking of the informant
  • 1. Any executive or staff member who has recognized the identity of the informant, whether through duty or by chance, is prohibited from leaking the identity of the informant..
  • 2. The reported personnel and the executive or staff member of the reported personnel’s department or other related department are prohibited from performing any action which may expose the identity of the informant, such as inquiring the informant’s identity to the inspection team or the secretariat, or investigating the informant’s identity.
  • 3. In case which the secretariat receives inquiry applicable to Subparagraph 2 above, it must explain that such inquiry is a prohibited action based on this standard, and it is subject to penalty.
  • 4. Regarding the content of the report, the secretariat must not reveal or hint the identity of the informant or investigation cooperator without their consent. However, in case which the informant has voluntarily reported the bribery, the identity of the informant may be revealed with the informant’s consent, if required for investigation.
  • 5. Executives and staff members must not cause any disadvantage, in human resource and other affairs, to the informant in relation to the report.
  • 6. If the informant’s identity has been exposed due to an executive or staff member violating contents of Subparagraph 1 to 5 above, then the secretary general can investigate the channel of the exposure and request for disciplinary action to the related personnel.
  • 7. If it is deemed necessary due to the exposure of identity, the informant can inform such fact to the secretariat and request for protection.
  • 8. If the secretariat receives a request for protection from the informant, then the secretariat may request measures such as change in assignment if it deems that the informant may receive disadvantages in human resources or other affairs.

• ① If the informant receives retaliation from the reported or other related third party, then the informant must immediately inform the secretariat.
• ② The secretariat must immediately investigate the matters informed in Paragraph 1 and can request disciplinary action to the executive or staff member related to the retaliation; dismissal may be included among the disciplinary actions.

Any matters not determined specifically in this standard are determined through compensation review.

This standard is implemented as of July 20, 2006

1. Subject of compensation: personnel of the company, affiliated company, partner company; general external personnel

2. Standard of compensation

• A. Maximum amount of compensation: 50,000,000 KRW
• B. Standard of compensation: if reporting the following actions regarding the task of executives and staff members
  • (1) Report of bribery of others will be compensated for 10 times the amount of bribery

    The amount of bribery that is additionally revealed through the investigation of compliance administrator is exempted from the amount of compensation.

  • (2) Voluntary report of bribery: 5 times the amount of bribery

    Reporting within 5 days of recognizing the bribe will be compensated; however, for cases in which bribes were demanded first or which is deemed that it could sufficiently be refused, compensation will exempted.

  • (3) In the event where the company increases its revenue or reduces its loss due to the report, compensation will be provided in grade as the following, depending on the amount of increase or decrease

    Increase in revenue (decrease in loss)	Standard of compensation
    Less than 100 million KRW	10%
    100 million KRW – less than 500 million KRW	10 million KRW + 100 million KRW
    500 million KRW – less than 1 billion KRW	7% of the exceeding amount
    More than 1 billion KRW	30 million KRW + 500 million KRW
    	5% of the exceeding amount

Cyber complaint website

• Internet: Company home page (WWW.NAMKWANG.CO.KR) cyber complaint website
• Intranet: EKP – Namkwang Engineering Ethical Management – cyber complaint website

Telephone / Fax

• Corruption Prevention Secretariat: Tel. 02-3011-0511, Fax. 3011-0228

Zip code(135/100)

• 1139 Cheonho-daero, Gangdong-gu, Seoul, Korea (Gil-dong, Gamdong Green Tower), Namkwang Engineering Co., Ltd Recipient Corruption Prevention Secretary-genera