Practice Guidelines lay down the scope of acceptable conduct and practice standards in relations to business execution of employees for efficient application of the Code of Ethics.
2. Scope of application
The Company practices the Code of Ethics according to these standards.
3. Definition of terms
These standards define the terms as follows.
Individuals such as executives and employees who may benefit directly and indirectly by the duties they perform; customers, clients, partners, public officers in Korea and abroad, and other related organizations.
3.2 General standards
A universally reasonable standards that other employees and the general public can understand based on sound sense of judgement. A degree of something that the beneficiary can handle fairly without feeling pressured.
4. Responsibility and authority
4.1 Responsibilities of executives and heads of department
- 1) An executive or a head of a department must provide training or consultation constantly so that their team members can fully understand these standards.
- 2) An executive or a head of a department must take appropriate precautions to prevent their team members from violating these standards.
5. Business procedures
5.1 Ethical Practice and Compliance
As a global company, the Company establishes an ethical corporate culture by complying with the laws and ethics through management activities that strictly follow the basis and the principle.
1) Money and valuables
(1) Money and valuables refer to money (cash, gift cards, vouchers) and goods that can bring economic benefit.
(2) You must not provide or accept money or valuables to/from stakeholders for any reason. However, exceptions are made in the following cases.
- Gifts for promotional purposes that cost 50,000 won or less. However, agricultural and fishery products and processed products (including flowers) that cost up to 100,000 won are allowed.
- Gifts displaying a stakeholder's company logo that do not exceed 50,000 won, and gifts given to all attendees in general at events organized by stakeholders are allowed.
(Stakeholders: Individuals such as executives and employees who may benefit directly and indirectly by the duties you perform; customers, clients, partners, public officers in Korea and abroad, and other related organizations.)
- You must not request or receive gifts from overseas offices when traveling abroad for business purposes.
(3) If you have received money or valuables without being aware of this, you must return them, and if it is difficult to do so, you must report the matter to the Right Path Management Group.
(1) Entertainment means various activities for the purpose of business meetings and exchanges such as meals, drinking, golf rounds, enjoying a performance, and amusement.
(2) You must not provide or accept entertainment to/from stakeholders that exceeds 100,000 won per person. In case you must do so, you need to seek approval from the department head in advance. If the expense exceeds 100,000 won per person due to inevitable circumstances, it must be reported to the Right Path Management Group.
For those subject to the Anti-graft Act, such as public officers, journalists, and school personnel, you may provide meals that don’t exceed 30,000 won per person only for legitimate purposes that are recognized as they are for the smooth progress of a given task, social reasons or the formality. You are prohibited from offering entertainment in bars that offer hostess or host services.
(1) Hospitality means offering or accepting services including transportation, accommodation, tourism, and event support.
(2) You must not provide or receive hospitality services including transportation and accommodation that exceed general standards. However, hospitality services generally provided to all participants in events are excluded.
(3) If the expense exceeds the permitted amount due to inevitable circumstances, it must be reported to the Right Path Management Group.
4) Congratulations and condolences allowance
(1) You must not notify stakeholders of your own or your colleague’s congratulatory and condolatory events; notifying them of these events through a third party is also considered as being a notification from you..
(2) You must use a company forum to provide any notification of congratulatory or condolatory events; you must not inform them of these events by using your company mail or sending an invitation card (wedding invitations and obituaries). When providing information about congratulatory or condolatory events, the scope of relatives are limited to your immediate family: your parents and parents-in-law, grand parents and grand parents-in-law, and your children..
(3) A general standard of 50,000 won is recommended for expenditure for congratulations or condolences. No more than 100,000 won can be provided to stakeholders as a congratulations or condolences allowance, which includes the price of standing sprays and flowers..
(4) You must never receive congratulations or condolences allowance from stakeholders outside the company under any circumstance. If you have inevitably received a congratulations or condolences allowance from stakeholders outside the company, you must return the money or deposit the money to the Right Path Management Group..
(5) When requested by the Right Path Management Group, executives and employees must submit relevant materials such as a record of returned allowances received from stakeholders..
(6) You must not accept congratulations or condolence flowers from stakeholders. If you have accepted them due to unavoidable circumstances, you must not display them..
(7) Executives and employees must not hold extravagant weddings in luxury hotels, etc.
(1) Do not make solicitation or recommendation related to the following through an acquaintance within the company or an outsider. If you receive such solicitation or recommendation, you must register the case on the Company’s Clean POSCO FUTURE M System.
• Any requests for preferential treatment for the purchase of equipment and materials, and for diverse contracts.
• Any requests for preferential treatment for personal matters including employment, promotions, rewards and penalties, and transfers.
• Any requests for preferential treatment for excessive preferential treatment that goes beyond normal practices.
• Any requests to neglect management and supervision tasks, such as inspections and examinations.
(2) You must not make any illicit solicitation directly or through a third-party regarding tasks subject to the Anti-graft Act.
6) Pecuniary transactions
(1) You must not be involved in pecuniary transactions with stakeholders, such as lending money, offering loan guarantees, and leasing real estate.
(2) If you engage in pecuniary transactions with a stakeholder due to unavoidable reasons, you must report the case to the Right Path Management Group.
7) Event contributions
(1) You must not accept event contributions or donations from stakeholders in events sponsored by the Company, such as department events or club activities.
(2) If you use a vehicle / venue / service provided from a stakeholder for your convenience, you are deemed as having accepted donations or contributions.
(3) If you get these donations or contributions in inevitable circumstances, you must report it to the Right Path Management Group.
8) Unfair use of company budget
(1) You must not use the Company budget, such as budget allocated to meetings and project implementation, for personal purposes.
(2) For business expenses, you must use a corporate card; the card must be used only to serve the purpose, pursuant to relevant laws.
9) Protection of information and properties
(1) You must strictly safeguard confidential information or other important information.
(2) If you find out important information, you must inform a person in charge of it.
(3) You must not manipulate information or disseminate false information.
(4) You must not use Company’s equipment or facility for purposes that are not directly related to work.
10) Fair Trade
(1) You must comply with international standards, laws and regulations related to fair trade in order to not engage in unfair trade practices, including collusion related to production, price, bidding and market sharing, etc; you must compete in the market in a fair manner.
(2) You must not take advantage of a superior position to demand any form of rewards or other unreasonable gains from customers or companies you are trading with.
(3) You must respect the rights and properties of others, including intellectual properties, and not violate them to win in a trade or gain profit from it.
(4) Corporate information including that of competitors must be acquired and used by fair means.
11) Prevention of conflicts of interest
(1) Conflict of interest refers to situations when executives and employees of a company you are trading with have personal interests with you, which puts a negative impact on the performance of duties by POSCO executives and employees.
(2) You must completely exclude inappropriate requests from executives and employees of companies you are trading with, if they have private interests with you. The same applies to retired POSCO executives and employees.
(3) Do not make unofficial contact with executives and employees of companies you are trading with, if they have private interests with you. In case you have contacted them unintentionally, report it to the senior officer in your department or the Ethics Officer at the Right Path Management Office.
(4) Do not attend meetings of retired POSCO executives and employees that are not approved by the Company.
(5) Do not join a group for retired POSCO executives and employees before you retire. If you are already a member, report to a senior officer in your department and leave the group.
(6) If you have private interests with executives and employees of companies you are trading with, consult your senior or the Ethics Officer, and follow the actions to be taken, such as job reassignment.
(7) Do not engage in unfair trade, including signing of an unfair trade contract, purchasing products at a higher price, favoring certain companies in biddings, and leaking of trade information in advance by giving preference to a specific individual or a company for reasons of private interest.
(8) Prevent conflicts of interest with POSCO and the POSCO Group even after retirement.
5.2 Work-life balance
The Company seeks the development of both individuals and the Company through work-life balance. The Company creates a happy workplace by establishing a corporate culture of respect towards one another.
1) Pursuit of work-life balance
(1) We promote improved quality of life by offering welfare benefits that help stabilize the living conditions of employees.
(2) We support employees by helping them to achieve their goals and assist them to work flexibly in terms of time, place, and means.
2) Provision of opportunities for education and growth
(1) We create a work environment and systems that promote creative thinking.
(2) We support employees with training programs to improve their capabilities and foster self-development.
3) Fair assessment and compensation
(1) The Company conducts fair assessment based on the capabilities and performance of each employee and reflect them systematically to ensure the provision of appropriate compensation.
2) Executives and employees lift barriers between organizational bodies and encourage a climate of cooperation.
5.3 Creating customer value and securing trust
Recognizing that customer trust and success is our future, we respect customer opinions at all times, understand customers, and create value that promotes their development.
1) The realization of customer satisfaction
(1) We listen carefully to the voice of the customers and conduct our duties in a customer-centric fashion.
(2) We readily accept legitimate customer requests and reasonable suggestions.
2) The creation of customer values
(1) We meet customer needs by providing the best products through continuous technological development.
(2) Our employees understand the market trend in Korea and abroad and develop a service mindset that respects the customer’s culture and customs.
3) Securing customer trust
(1) We certainly consider customer safety and health, and don’t provide products or services that threaten them.
(2) We protect each customer’s information and comply with the laws and regulations regarding information protection.
(3) We provide accurate information to customers in a timely manner.
5.4 Duty of good faith to investors
We maximize investor value by making profit on the basis of transparent decision making and efficient management activities.
1) Pursuit of increased shareholder values
(1) We make profit on the basis of transparent decision making and efficient management activities and enhance both corporate value and shareholder value.
2) Fair provision of investor information
(1) We do not provide information that may affect the investment decisions of shareholders to only some shareholders, or offer select information.
(2) We do not directly trade stocks and securities using inside information acquired at work, or solicit trade to others.
3) Calculation and provision of transparent financial information
(1) Financial information must be calculated using an appropriate process or control based on precise trade facts.
(2) Financial reports must be made according to generally recognized accounting standards.
(3) A sufficient amount of correct management information must be provided to help investors to make investment decisions based on free will and responsibility.
5.5 Building mutually beneficial relations with business partners
We must establish a fair business order based on mutual trust and build a corporate ecosystem where we coexist and develop with our stakeholders.
1) Building mutual trust
(1) We must ensure that we do business fairly on an equivalent relationship with partners on the basis of mutual respect.
(2) We protect information acquired from doing business with our partners according to the related laws, regulations, and provisions in contracts.
(3) We support our business partners to observe fair trade laws and regulations.
2) Co-prosperity with our business partners
(1) We share accomplishments with our business partners and seek mutual prosperity.
(2) We support our business partners to provide high-quality products and services though smooth communication and cooperation with them.
(3) We offer equal opportunities and ensure reasonable business requirements for our business partners to develop relationships into companionships.
3) Supporting the continued development of business partners
(1) We offer technical and financial support to our business partners to help them build a stable supply chain.
(2) We expand the scope of our growth partners for the comprehensive prosperity of the entire business ecosystem.
5.6 Contribution to the country and the society
We fulfil our responsibility and duty as a corporate citizen to contribute to national and social development.
1) The role and attitude of a corporate citizen
(1) We strive to achieve mutual development with local communities and respect their respecting local laws, regulations, culture and customs.
(2) We strive to communicate with stakeholders by involving them in our management activities that are related with the local society.
(3) We strive to support our business partners to participate in the activities aimed at the development of the local society.
2) Commitment to the country and the society
(1) The Company fulfils its duty in the local community by creating and maintaining jobs and by faithfully paying taxes.
(2) The Company participates in charities including volunteer activities and disaster relief, and engage in pro bono activities in different areas, such as culture, art, sports, and academia.
(3) The Company assists local residents to improve their quality of life.
5.7 Preservation of the environment and the ecosystem
We build a sustainable management system, strengthen our capabilities to respond to risks and implement sustainable management through open communication.
1) Building a sustainable management system
(1) We operate a sustainable management system efficiently to evaluate the impact and risk of our activities, manage and analyze our sustainable management performance systemically, in order to, ultimately, reach our sustainability goals.
(2) We share accomplishments and issues with various stakeholders and engage in sustainability activities together.
(3) We form a consensus with partners regarding environment protection as a social obligation, and support them to comply with environment laws and regulations.
(4) We assist our business partners to safeguard public health and safety when producing products or services. At the same time, we help them minimize any negative impact on local environments and natural resources.
2) Compliance with environment laws and improvement in environmental impact
(1) We abide by environment laws and try to improve the impact on the environment in all processes, including development, production, and use of products.
(2) We minimize emissions of harmful substances by introducing environmentally friendly process and applying the optimum technology that prevents environmental pollution.
3) Response to climate change
(1) We strive to reduce greenhouse gas emissions by using fewer fossil fuels or raw fossil materials and improving energy efficiency.
(2) We strengthen our competitiveness by developing innovative low-carbon technology.
4) Protection of the environment and the ecosystem
(1) Through the efficient use of natural resources and by-products, we work to restore the natural ecosystem and preserve biodiversity.
5.8 Protection and respect for human rights
We uphold human rights, endorse international human rights standards, and establish human dignity of all stakeholders through enhancement of the quality of life.
1) Respect for international human rights standards
(1) We respect and support the internationally accepted human rights standards, such as the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN Global Compact, and the OECD Guidelines for Multinational Enterprises.
(2) We have established clear human rights policies and systems and strive not to violate human rights in the course of our management activities.
(3) We support our business partners to observe human rights laws as required by international human rights standards. We help them protect the human rights of their employees and treat them fairly.
(4) We respect the International Labour Organization (ILO) conventions and conventions ratified by the Republic of Korea, especially the convention on the prohibition of child labor and forced labor, and the convention on the abolition of forced labor.
2)Obligation to perform due diligence to respect human rights
(1) We may conduct due diligence as needed for management activities that violate human rights or cause complaints.
(2) We seek reasonable solutions if, as a result of due diligence, the Company is considered to have violated human rights during the course of management activities.
(3) We communicate with stakeholders regarding the result of human rights-related activities.
3) Protecting executives and employees
(1) Company executives and employees do not engage in verbal, physical, or visual behavior that is offensive to others, including sexual harassment, which infringes on human rights of an individual.
(2) We respect privacy of our individual employees. We do not slander others nor leak personal data.
(3) We prevent people from working involuntarily due to mental or physical coercion.
(4) We observe the labor law of each country we operate in and international standards for employment standards and the minimum age of employment for minors.
(5) We strictly follow safety rules and take appropriate measures for all risks identified.
4) Respect and equality
(1) We do not discriminate or harass people on the basis of race, nationality, gender, age, academic background, religion, region, disabilities, marriage status, gender identity or any other reasons.
(2) We provide equal employment opportunities to people who meet job qualifications.
(3) We maintain the work environment by respecting various cultural differences.
5) Guarantee of legal and humane employment requirements
(1) We take prompt action on human rights issues raised by our employees through our complaints support system.
(2) We guarantee employment requirements, including appropriate working hours so our employees can live a life of dignity and a life that is worthy of a human being.
6) Efforts to respect human rights in the community
(1) In case a human rights violation in the community is committed in the course of the Company’s management activities, we gather opinions and take measures to resolve the human rights issues.
6. [Supplementary rules] Management and operation of the Code of Ethics
6.1 Compliance with the Code of Ethics
1) We must abide by the Code of Ethics as a standard for our behavior and judgement of values.
2) Right Path Management Group is responsible for general management of the Code of Ethics, while management departments of respective areas take responsibility of detailed operation of the Code of Ethics. (Management departments for different areas: Departments responsible for risk management, reporting, and evaluation in eight different areas when practicing the Code of Ethics.)
3) We can set a separate set of standards for efficient operation of the Code of Ethics.
6.2 Responsibilities of executives and heads of department
1) An executive or a head of a department must provide training or consultation constantly so that their team members can fully understand these standards.
2) An executive or a head of a department must take appropriate precautions to prevent their team members from violating these standards.
6.3 Obligation to report and confidentiality
1) If you find out about a violation of the Code of Ethics, you must report the case to the Right Path Management Group in the fastest and the most convenient way possible.
2) Upon receiving a report that an employee in your team or department has violated the Code of Ethics, you must immediately report the case to the Right Path Management Group.
3) Right Path Management Group may verify the facts as needed about the reported case, and all employees involved must cooperate readily with the verification.
4) Executives and employees must not put the person who reported the case or an informant at a disadvantage or disclose his/her identity.
5) In case there is a risk that the reporter or an informant may become subject to adverse personnel actions, personnel measures may be taken, such as position change at his/her desire.
6) In the case that an executive or an employee finds out about the report, he/she must keep it confidential. He/she may become subject to disciplinary action when revealing it.
7) Standards for reporting of unethical behavior, such as receiving bribes from stakeholders, and rewards for reporting such behavior, will be set separately.
8) Ensure confidentiality, anonymity and protection of informants, except to the extent prohibited by law. There must be a communication process in place for employees to raise concerns without fear of retaliation.
6.4 Rewards and penalties
1) The Company can provide reward or appropriate compensation to executives and employees who have contributed in achieving the goal of the Code of Ethics according to relevant regulations.
2) The Company strictly reprimands executives and employees who have violated the Code of Ethics according to relevant regulations.
3) The Company may restrict access or trade by executives and employees who have retired by violating the Code of Ethics.
1) If a family member, a relative or a personal acquaintance of an executive or employee has violated the Code of Ethics using his/her name, this is also considered to be an action taken by the executive or the employee.
2) For things that have not been specified in the Code of Ethics or things that cause dispute over its interpretation, consult the Right Path Management Group and follow their interpretation of the case.
1) Right Path Management Group, when necessary, may revise the Code of Ethics. For cases that a senior auditor deems important, the revision must be made after getting an approval from the CEO.
7. Records and management
Records and management
||Records and attachments
||Department that stores the standards
||Report on the implementation of the obligation to report the Ethical Practice Standards
||Right Path Management Group