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| Guidelines on the obligation of employees and transactions with
firms that entail a conflict of interest |
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1. Employees shall not use the expenses,
assets or information of the
Company for personal gain, including working
hours, and shall
consistently do their best to protect
the properties and information of the
Company. |
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| 1-1 |
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Employees shall not have other occupations including side
jobs.
In inevitable cases, the CEO’s approval shall be obtained
via the CFO in writing within a period of one week, and the
CFO shall keep the document. |
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| 1-2 |
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Employees are prohibited from making stock investments using
inside information. |
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| 1-3 |
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Employees shall make efforts to protect internal information,
particularly in respect to the computerization and data of
PC. |
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| 2. Contributions and Monetary Trading between
Employees |
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| 2-1 |
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Excessive borrowing of money (more than 5,000,000 won)
or loan guarantees (more than 5,000,000 won) between employees
shall be prohibited in principle.
For inevitable cases, it shall be reported within one week
to the CFO in writing (including e-mail). |
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| 2-2 |
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Solicitations between employees for personnel reassignment,
or excessive contributions or gifts are prohibited. |
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| 2-3 |
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Employees shall not offer excessive gifts (more than 30,000
won per person with the total amount in excess of 100,000
won) or excessive entertainment (more than 30,000 won per
person) to superiors. |
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| 3. Gifts, Entertainment and Monetary Transactions
with Customers |
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| 3-1 |
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Employees shall not receive excessive entertainment from
customers in relation to work activity (in excess of 100,000
won per person).
In the event of an inevitable receipt of excessive entertainment,
it shall be reported to the direct superior in writing within
a period of one week (including e-mail), and the direct superior
shall report this fact to the CFO. Related data shall be treated
as personal and confidential information. |
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| 3-2 |
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Employees shall not receive excessive money, goods (marketable
securities such as cash and gift certificates, replacement
certificates) or gifts from customers in relation to work
activity (in excess of 100,000 won).
In the event of an inevitable receipt of excessive money,
goods or gifts, it shall be reported to the direct superior
in writing within a period of one week, and the direct superior
shall report this fact to the CFO. Related data shall be treated
as personal and confidential information.
The CFO shall report this information to the CEO in writing,
and the case will be disposed following the decision of the
CEO. Employees shall not accept excessive contribution funds
in personal events like marriage, birthday parties and funerals.
Customers shall not be invited to the birthday celebrations
of children, anniversaries of parents and the like. However,
an exception may be made if the parties involved have worked
for a long time at the construction site, plant and the like.
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| 3-3 |
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In the event that an employee is inevitably treated with
a round of golf in relation to work activities, it shall be
reported to the direct superior in writing within a period
of one week (including e-mail). The direct superior shall
collect this information and report it to the CFO, and the
CFO shall keep the document. |
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| 3-4 |
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Employees shall not be provided with financial favors such
as loans, lease and other transactions as engineered by any
relative (direct family, in-law and spouse family within cousinship)
belonging to a firm that that has a transactional relationship
with the Company. In the event of an inevitable cause, it
shall be reported to the CFO within a period of one week in
writing or via e-mail, which shall be documented by the CFO. |
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| 3-5 |
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Employees shall not be engaged in any investments, loans
or employment directly or indirectly involving the businesses
associated with the Company.
In the event of an inevitable cause, he/she shall obtain the
CEO’s written approval, which shall be documented by the CFO. |
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4. When conducting transactions with a company
of interest relationship,
employees shall not exercise their influence and shall transact
fairly. |
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| 4-1 |
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The executives and team manager, or higher positioned
employees, shall draft an interest relationship statement
once a year and submit it to the CFO.
In respect to retirees, they shall not be recorded on the
interest relationship statement but uniformly drafted by
the Purchasing (Outsourcing) Department. |
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| 4-2 |
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The submitted interest relationship statement shall be
treated as personal confidential information and shall be
kept with the personnel record card. |
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| 4-3 |
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Each employee shall inform the companies with which he/she
is engaged of the interest relationship statement, and assure
them that he/she will not exercise undue influence in accordance
to the statement. |
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5. Reports of good faith and honesty on the
violation or possible violation
of this Code shall not be countered with any harmful action whatsoever
to the person reporting (such as disclosure of his/her name). |
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| 5-1 |
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The superior or CEO who receives a report on violations
(embezzlement of Company assets, etc.) that significantly
affect the Company shall immediately take appropriate preventive
and corrective measures. |
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6. If these Guidelines are violated, the
violating party may be disciplined
in accordance with Company regulations. |
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