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Corporation Ethical Management Code of Ethics

Code of Ethics

Code of Ethics for Employees

Statement of the criteria for employees’ conduct and value judgment

  • Client We gain trust from our clients through client satisfaction management and grow together with them.
  • Shareholders To create shareholder value, we increase corporate value by reinforcing transparency and efficient management.
  • Employees All SKC employees fulfill their duties dutifully with accountability.
  • Society We become a trusted firm by observing the social norm and make a contribution to a society through social and cultural activities.
All SKC employees take the SKMS as the basis of corporate governance and create values for the related parties such as clients, employees and shareholders to play key roles for the betterment of society and economic development and make a contribution to the happiness of humankind.
For fair and transparent business management, we enact the code of conduct and practice guide as the criteria for business management behavior and value judgment.
1. Client
『We gain trust from our clients through client satisfaction management and grow together with them.』
- We respect our clients’ diverse opinions and have them reflected on our business management.
- We keep working hard to provide the best products and services that our clients want.
- Our clients’ properties and information are protected as safely and securely as our assets.
2. Shareholders
『To create shareholder value, we increase corporate value by reinforcing transparency and efficient management.』
- We increase corporate values through transparent decision making process and efficient management activities.
- We respect our shareholders’ requests and proposals and share our management results with them.
- We prepare all management documents in accordance with the related laws and accounting standards and protect our shareholders’ interests by dutifully disclosing the information.
3. Employees
『All SKC employees fulfill their duties dutifully with accountability.』
- We dutifully observe all related laws and regulations that you have to comply with as the SKC employees.
- We create corporate culture that intensifies mutual respect and encourages us to work with enthusiasm and initiative.
- We enhance our competitiveness and maintain our fame and dignity.
4. Society
『We become a trusted firm by observing the social norm and make a contribution to a society through social and cultural activities.』
- We observe the local laws and respect the culture and tradition of the communities.
- We perform environment-friendly management and actively participate in environmental protection.
- We make a contribution to social development by actively participating on CSR activities.
- We pursue co-prosperity with our partners and compete with our rivals in a fair manner.
【Addenda】
A. The Code of Ethics comes into effect on March 1, 2006.
B. The Code of Ethics applies to the Company and all employees, and all employees are liable to observe it dutifully. Any violation shall be punished according to bylaws.
C. We provide ‘Code of Ethics Guide’ to help our employees interpret and observe the Code of Ethics correctly.

Code of Ethics Guide

Specific regulations for the implementation of the Code of Ethics

  • Employees’ basic duties Observance of basic ethics for employees, prohibition of acts under conflict of interests, ban on bribery and corrupt practices
  • Protection of company’s properties Physical property, intellectual property
  • Observance of laws Observation of domestic and international laws and regulations (fair trade, accounting management, quality/safety/environment management)
  • Work handling procedures Organization in charge, protection of whistle blowers, consultation / reporting procedures
1. Objectives
The purpose of the Code of Ethics Guide is to stipulate specific provisions needed to implement the purport of the Code of Ethics for SKC employees.
2. Target
All employees of SKC and the firms under the control of the SKC shall understand and observe the Code of Ethics and Code of Ethics Guide.
For any inquiry about the Code of Ethics and Code of Ethics Guide, contact the leader of the organization or Ethical Management Department.
3. Employees’ basic obligations
3.1. Basic ethics for employees
All SKC employees shall fulfill their duties and take responsibility for the results based on the principle of good faith.
All SKC employees clearly understand their roles and understand and observe the Code of Ethics and related regulations.
If any of the employees violates the Code of Ethics, sees the other person violating it, or is forced to violate it, such incident shall be reported to the Company immediately.

3.2. Ban on practices under conflict of interests
In the event of conflict of interests when fulfilling of their duties, employees shall take the Company’s interest prior to others.
All employees shall make their best efforts to avoid any conflict of interests with the Company. If the conflict occurs, it shall be reported to the Company.
Examples of the conflict of interests
A) Employees enter into an agreement or engage in business with the Company directly or through a third party;
B) Any financial conflict of interest or involvement of rights/obligations with the Company’s rival or contractual party directly or indirectly;
C) Misappropriation for personal benefits by taking advantage of the Company’s assets or information;
D) Exerting unfair influence on vendors by taking advantage of job position such as special consideration for a job position and any special benefits;
E) Engaging in a side job which is tough enough to have a negative influence on the fulfillment of obligations at work; or
F) Acquisition of the partner’s stocks in an unfair fashion

3.3. Anti-bribery and corruption
All employees shall fulfill all management activities in an open and transparent manner. They are prohibited from getting special treatment or benefit from the contractual or related party regardless of any relevance with the job.
If any special treatment or benefit is obtained regardless of your intention, you shall return it immediately or report it to the Company.
For the maintenance of decent and sound relationship, however, meals or gifts which are permitted under the current laws and business practices are acceptable.
4. Protection of the Company’s assets
4.1. Physical properties
The employees are prohibited to use the Company’s assets for personal purposes or transfer or lease them to a third party without getting approval from the Company.
The Company’s budget shall be used according to the designated purpose, and the processes shall be recorded in accordance with accounting standards and procedures.
If a loss occurs in (or there is a possibility of loss of) the Company’s assets, it shall be reported to the Company immediately, and any necessary actions to prevent such loss shall be taken.

4.2. Intellectual properties
The Company’s internal management information shall not be disclosed to the outside without getting approval in advance.
The client information shall be provided to a third party in an illegal fashion. In addition, Employees shall not engage in any unfair or illegal practices which can harm a client’s interests.
The Company’s intellectual property rights such as patent, copyright trademark are actively protected.
The Company’s secret information shall be kept confidential according to the related laws and regulations. To disclose it to the outside, approval shall be obtained in advance in accordance with the related procedures.
Other companies’ intellectual property rights shall also be protected. In particular, the use of illegal software is strictly prohibited.
5. Observance of related laws and the Company’s management policies
All business management activities in the Republic of Korea and abroad shall be implemented in accordance with local laws and regulations and business practices.
All transactions shall be performed in accordance with the related laws and bylaws under free competition principle.
The accounting information shall be recorded accurately according to the related laws, business accounting standards and bylaws. Any falsification or misstatement of accounting information is strictly banned.
The management information on interested parties shall be disclosed in a fair and transparent fashion in accordance with the related laws and bylaws.
Any falsification or misstatement (e.g., concealment, exaggeration/omission, delay) of management information is prohibited.
The product quality and safety management shall observe the related laws and meet the client’s requirements. The product performance and risk-related information shall be disclosed as it is.
The safety, health & environment-related domestic and international laws and international conventions shall be observed. In addition, employees shall be active in creating safe work environments and participating in environmental protection activities.
In accordance with the Improper Solicitation and Graft Act, it is prohibited from requesting special treatment or benefits (or any promise to provide such benefit) to the related party such as government officials.
The domestic and international laws relating to anti-corruption such as Foreign Corrupt Practice Act (the U.S.), Bribery Act (the U.K.) and Act on Preventing Bribery of Foreign Public Officials in International Business Transactions shall be strictly observed.
6. Work handling procedures
6.1. Department
The department relating to the operation of the Code of Ethics and Code of Ethics Guide for employees shall be Management Audit Team I.
The said ethical management organization shall get advices from employees, perform guidance and education on employees and properly punish those who violating such rules.

6.2. Protection of whistleblowers
The employee who recognizes the violation of the Code of Ethics or Code of Ethics Guide shall report it to the department leader or Ethical Management Department immediately.
The Company shall not treat the whistleblower in an inappropriate manner at work for his/her fair reporting, related statements or submission of data.
During the investigation on the whistleblowing, those who have been cooperative with the investigation shall be protected as equally as the whistleblower.
In the event of any unfair treatment, the whistleblower may request proper protections such as correction or job relocation to the Ethical Management Department. Then, the Ethical Management Department shall investigate the case, take a proper action and establish a plan to prevent the reoccurrence of such incident including the punishment of the responsible parties.
The whistleblowing investigator shall keep the related information confidential to protect the whistleblower.
Any person who violates the said whistleblower protection provision (e.g., retaliation such as disadvantage in personnel, disclosure of the whistleblower’s identity or leak of the related information, order to find the whistleblower, etc.) shall be punished in accordance with the related regulations.

6.3. Investigation guideline for the protection of whistleblower
The investigator shall perform investigation by taking the protection of the whistleblower as a top priority and must observe the followings:
A) The investigator shall not leak or imply any information regarding whistleblowing without getting approval from the whistleblower.
B) All whistleblowing-related data are open to authorized persons only and kept confidential. The paper documents acquired by mail or fax shall be kept in a separate place and locked properly.
C) Any leak of whistleblower’s information obtained during the investigation shall be punished in accordance with the related laws. If one of the following events occurs, however, an exception can be made:
- A matter which can cause serious accident or discontinuance of business; or
- Serious corruption, leak or falsification of the Company’s secret, press release, etc.
D) The Ethical Management Department Manager is liable to educate and manage the security management guidelines regarding whistleblowing-related investigation.

6.4. Consultation / Reported to
For inquiry or consultation regarding the Code of Ethics and Code of Ethics Guide, refer to the contact information below. Reporting can be made by email, phone, mail or in person regardless of its format.

Block B, The K Twin Towers, 50 Jongro 1-gil, Jongro-gu, Seoul, South Korea, Ethical Management Manager, Management Audit Team 1