Corruption Prevention Policy
- Ethical Management
- Corruption Prevention Policy
The purpose of this guide is to support this policy as a supplement to the Corruption Prevention Policy, and to provide the executives and employees with the code of conduct and standards for judgment related to this Policy to help them comply with this policy.
Considering the characteristics and the scale of the industry and the activities the Company is engaged in, this guide is designed to handle situations involving bribes that the Company may be faced with.
All business partners that conclude a trade contract with the Company executive and employees to provide products, goods and services for the Company’s business.
The Company refers to a group of people assembled to achieve POSCO M-Tech's business goals, regardless of its name, such as a domestic corporation or office over which POSCO M-Tech has substantial control.
Executives and employees refer to executives and employees of the Company who are hired to undertake the Company business regardless of the form of employment and position, including the representative, executive and employee, who are under the Company’s control. Note that gig workers, dispatched workers, volunteers, and unpaid workers may be included in the scope of executives and employees as needed.
Stakeholders refer to Company’s consumers, shareholders, business associates, the government, Company executives and employees.
Business associates refer to external parties who has formed or is planning to form a certain business relationship with the Company.
Business refers to all activities related to general operation of the Company apart from the Company’s sales activities regardless of the form of work. Business may be interpreted broadly as needed.
Bribes refer to proposals, promises, provisions, receipt, and soliciting of unfair gains of all values, regardless of monetary, non-monetary, direct, and location (within a country) in violation of laws, in return for taking specific actions and inducing someone to take specific actions when performing the duties.
Public officials, etc. refer to public officials or people engaged in public service who fall under one of the below categories..
Conflict of interests refer to the situation where a judgement made by a public official or a person in charge of a Company’s tasks is interrupted by business, monetary, blood relationships, or personal interests.
Illegal solicitation refers to solicitations for public officials, etc. to perform a task in violation of laws as specified in the Anti-Graft Act.
Executives and employees shall not directly or indirectly provide, propose, or promise or approve of bribes such as money or valuables in relation to their work to their customers, partner companies, and public officials, etc.
You are prohibited from providing political funds or donations on behalf of the Company. Donations provided to charity organizations are allowed. However, offering donations in return that may be considered as bribes or donations aimed at getting illegal gains is prohibited.
Once executives and employees learn about an action that violates, or an attempt to violate this policy or guide must preserve the evidence (all documents that can be used as evidence, including electric records and data) and report the case to the Fair Trade Support Team, Righteous Management Office.
When dealing with business partners, you must fully communicate this policy and ensure to comply with bribe-related laws and include it in the contract. You must specify in the contract that you have the right to investigate the case, cancel the contract, and claim for damages in the event the business partner violates or is suspected of violating relevant laws including the Anti-Graft Act. However, you may not specify this in the contract when there are reasonable reasons in consideration of general circumstances, such as the characteristics of the deal and the process of negotiations.
Provided an executive or an employee instructs someone to violate this policy, or does not report to the Fair Trade Team of the Righteous Management Office immediately after being aware of those violations, the Company may refer the executive or the employee to the HR committee and decide whether to take disciplinary action. In case an executive or an employee violates relevant laws such as the Anti-Graft Act and is fined, the Company does not take any responsibility for that illegal action of the executive or the employee, and may refer him/her to the HR committee to decide whether to take disciplinary action. If a partner company violates this policy or relevant laws such as the Anti-Graft Act, the Company may terminate the contractual relationship with the partner company.
|Category||Minister or higher||Vice Minister or higher||Level 4 or higher||Level 5 or lower|
|Maximum amount||KRW 500,000||KRW 400,000||KRW 300,000||KRW 200,000|
|Category||Heads of institutions||Executives||Other employees|
|Maximum amount||KRW 400,000||KRW 300,000||KRW 200,000|
|Category||Heads of institutions||Executives|
|Maximum amount||KRW 1 million||KRW 1 million|