포스코엠텍

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..

• ① People recognized as public officials under the State Public Officials Act, the Local Public Officials Act, and other laws in relation to their qualifications, appointments, education and training, service, remuneration, guarantee of status, etc.
• ② The heads of public organizations and institutions and their executives and employees in accordance with the Public Service Ethics Act, and the Act on the Management of Public Institutions.
• ③ Schools established under the Elementary and Secondary Education Act, the Higher Education Act, the Early Childhood Education Act, and other laws, and the heads, teachers, and staff of school juristic persons pursuant to the Private School Act.
• ④ The representative, executives and employees of media companies.

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.

• ① Gifts refer to goods, etc. (any goods excluding money and food) provided at no cost. They must be given with pure intentions and be appropriate for the given situation that does not go beyond the customary practice. The cost of such gifts must not exceed KRW 50,000 for Korean public officials. You must not provide gifts the public official or his/her spouse in relation to his/her work. The cost of such gifts must not exceed KRW 1 million per gift, or KRW 3 million per fiscal year.
• ② You must not offer gifts as samples without any indications to customers or public officials intended to be used by a specific person.

• ① A congratulations and condolences allowance can only be provided when it is absolutely necessary due to custom or for cultural reasons, such as congratulatory money, donations, and congratulatory and condolence goods.
• ② The cost of a congratulations and condolences allowance must not exceed KRW 100,000. Provided you have received gifts or food gifts along with the condolences allowance, the value of all gifts must not exceed KRW 100,000.

• ① In the course of performing duties, you may be provided with meals (including drinks) at a reasonable price that does not go beyond customary practices. However, luxurious meals that violate local laws or norms are prohibited. In particular, for Korean public officials, you can only provide meals that do not exceed KRW 30,000.
• ② You may offer simple drinks or food in official events or business discussions related to duties.
• ③ However, you may not provide entertainment as listed below.
  • ⑴ Drinks: Luxurious entertainment establishments, such as room salons, karaoke bars, or nightclubs
  • ⑵ Sports: Golf rounds or skiing.
  • ⑶ Entertainment: Speculative entertainment, such as casinos or horse races.
  • ⑷ Relaxation facilities: Luxurious facilities, such as steam baths, massage parlors, and high-end barbershops.

• ① You may offer convenience services, such as transportation (e.g. train, flight, bus, vehicle support), accommodations, and communication tools, provided uniformly to participants to an official work-related events.
• ② The purpose and the usage for travel expenses must be related clearly to the Company’s business (e.g. Company’s products, service promotion, demonstration, training), and provided at a reasonable level in consideration of the recipient’s position and the purpose of the expense.
• ③ You must not provide accommodation fees or flight fares directly to the Customer employees or public officials in cash, nor provide them with a refund. Instead, you must pay the money directly to the service provider (the airline or the hotel).
• ④ You must not provide travel expenses for non-work related purposes.
• ⑤ You must not provide travel expenses for the spouse or families of public officials and etc.
• ⑥ You must minimize tourism or entertainment that is not part of the purpose of the business.

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.

• ① Illegal solicitation of public officials, etc. is prohibited in principle.
• ② The types of prohibited illegal solicitation is as follows:
  • ⑴ Authorization, permission, etc.
  • ⑵ Administrative actions, imposing penalties, mitigation and exemption of punishments.
  • ⑶ Interventions in HR for employment or promotions.
  • ⑷ Interventions in decision making in public institutions. Interventions in selecting the position or screening job candidates.
  • ⑸ Interventions in the selection or elimination of award winners in events hosted by public institutions.
  • ⑹ Leaking confidential information related to bidding, auction, etc.
  • ⑺ Intervention in the selection and rejection of a contract from a specific individual.
  • ⑻ Intervention in allocating subsidies and supporting investment.
  • ⑼ Abnormal trade of goods and services produced and supplied by public institutions.
  • ⑽ Manipulating the processing of school admission grades, etc.
  • ⑾ Handling of duties related to military service, such as conscription inspection.
  • ⑿ Intervention in various evaluation and decision making tasks conducted by public institutions.
  • ⒀ Ignoring illegal actions, such as manipulation of results from administrative crackdown.
  • ⒁ Intervention in investigation, trials, etc.
  • ⒂ Abuse of power based on status regarding types A through O.

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.

• ① Request for specific actions in accordance with the procedures and methods stipulated in laws and standards.
• ② Public requests for specific actions (collecting stakeholder opinions when making policy decisions or when undertaking tasks).
• ③ When elected public officials forward complaints from a third party for public interest (ensuring sound legislative activity).
• ④ Request to handle duties within the statutory deadline, etc.
• ⑤ Request for confirmation/certification of job/legal relationships.
• ⑥ Request for explanation and interpretation of laws and systems, etc. through inquiry and consultation.
• ⑦ Other acts that do not go against the norms of society. (Exceptions are recognized if justified in light of the overall legal order among the 15 types of illegal solicitation.)

• ① Request for specific actions in accordance with the procedures and methods stipulated in laws and standards

  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

  
  
• ② Heads of related organizations and institutions and their employees

  Category	Heads of institutions	Executives	Other employees
  Maximum amount	KRW 400,000	KRW 300,000	KRW 200,000

  
  
• ② Heads and staff of schools, employees of school judicial persons, representatives and employees of media companies

  Category	Heads of institutions	Executives
  Maximum amount	KRW 1 million	KRW 1 million