Fair Information Disclosure to Shareholders

- Through transparent management, provide shareholders with all necessary information equally, without favoring select individuals or groups.
- Respect shareholders’ rights, and when requested, offer information that does not affect business operations to protect their interests.

Maintaining Accurate and Transparent Financial Information

- Maintain accurate and honest financial records through proper and efficient management and control systems.
- Prepare financial statements in accordance with generally accepted accounting principles (K-GAAP).

Promoting Work-Family Harmony

- Support employees in achieving a balance between work and personal life.
- Provide welfare benefits that help improve overall quality of life.
- Maintain appropriate working hours and employment conditions to ensure harmony between work and family life.

Providing Opportunities for Growth

- Offer diverse training programs to help employees enhance their skills in alignment with their career goals.
- Create an environment where employees can freely express creative ideas and suggestions for improvement and have them reflected in their work.

Fair Evaluation and Compensation

- Operate a fair HR system and employee training that ensures equal treatment and rewards based on merit.
- Evaluate employees fairly based on performance and competencies and provide compensation accordingly.

Creating a Healthy Organizational Culture

- Provide a pleasant and productive working environment.
- Foster open communication and a culture of mutual respect and collaboration across departments.
- Prohibit all forms of harassment, including verbal, physical, and visual abuse, including sexual harassment.
- Respect personal privacy and avoid any defamatory or degrading language or behavior.
- Establish and enforce strict safety protocols to protect employee well-being.
- Respond swiftly to human rights or safety concerns raised through the company’s grievance system.

Mutual Trust with Partners

- View partner companies not just as suppliers, but as long-term collaborators working toward shared goals.
- Strive to build strong, trust-based relationships with all partners.
- Comply with all fair trade regulations in contracts and ensure equitable and just terms for all partners.

Pursuing Joint Growth with Partners

- Operate transparent and fair processes in all dealings with partner companies.
- Maintain stable, long-term partnerships, and listen to and respect their legitimate needs and feedback.

Supporting Partner Development

- Recognize that our partners’ competitiveness is directly linked to our own.
- Provide fair opportunities for partner selection and offer support to help them strengthen their capabilities.

Pursuing Fair Competition

- We recognize that fair and principled competition improves service quality and ultimately leads to greater client satisfaction.
- We strictly avoid collusion or other forms of unfair business practices and compete fairly in the marketplace.
- We strive to establish a competitive order that enhances the efficiency and sustainability of the market.

Compliance with Fair Trade Regulations

- We work to gain competitive advantage through legitimate means in compliance with applicable laws.
- We support international anti-corruption efforts, including the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and adhere to all related anti-corruption and fair trade regulations.

Harmony with Society

- As a responsible member of society, the Company must grow in harmony with the community. We comply with all local regulations and fulfill our legal and ethical responsibilities in every region where we operate.
- We utilize our technology, knowledge, human resources, and assets efficiently to grow into a sound and sustainable enterprise that contributes to national development and regional welfare.
- We uphold social ethics and practice nondiscrimination in hiring based on gender, education, origin, religion, race, nationality, or disability.
- We support and respect international human rights standards, including 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.

Contribution to Society and the People

- We create high-quality jobs and fulfill our tax obligations faithfully, contributing to the community and national interest.
- Through voluntary employee participation, we actively support social contributions such as volunteer work, domestic and international disaster relief, and public interest activities in culture, the arts, sports, and academia.

Environmental Protection

- Recognizing the importance of environmental issues worldwide, we strive to become an eco-friendly company that uses resources responsibly.
- We are committed to minimizing wasteful consumption and preserving and improving the environment.

Definitions

The following terms apply to this Code of Conduct:
Gifts: Includes cash, gift certificates, securities, merchandise, etc.
Entertainment/Hospitality: Includes meals, drinks, sports (e.g., golf), performances, leisure, etc.
Convenience: Includes transportation, lodging, tours, event support, etc.
Manager: Refers to team leaders or account managers and above.
Interested Parties (Stakeholders):
Any individual or organization currently doing business with or likely to do business with the Company;
Any person or entity whose rights or interests may be influenced by the actions or decisions of employees.
Customary Level: A reasonable and socially accepted level of benefit that does not influence fair business decisions or create a sense of obligation. For public officials, this aligns with the standards of the Public Official Code of Conduct; for other stakeholders, it aligns with their organization’s ethics code.

Gifts

- Gifts from stakeholders must be politely declined or returned, unless they fall under acceptable items such as promotional souvenirs with logos or general gifts distributed at events.
- Employees must not offer or accept gifts among themselves that exceed customary levels.
- Any gift unintentionally received must be returned immediately; if not possible, it must be reported to a manager.
- Managers must handle reported gifts transparently and report outcomes to the Ethics Office.

Entertainment/Hospitality

- Employees must not offer or accept entertainment from stakeholders beyond a customary level. Any such incident must be reported to the Ethics Office.
- Prior approval from both the manager and the Ethics Office is required when hosting or attending an event involving entertainment that exceeds customary levels.
- Under no circumstances should an employee pay for or receive sponsorship for stakeholder-related entertainment.
- When in doubt, consult the Ethics Office before proceeding.

Convenience

- Employees must not offer or receive convenience items (e.g., travel, accommodation) that involve costs beyond customary levels.
- Exceptions may include standard amenities provided equally to all attendees at official events.
- Any incident involving excess convenience must be reported immediately to the Ethics Office.

Condolence and Celebration Money

- Employees must not inform stakeholders of their own or colleagues’ personal occasions (e.g., weddings, funerals). Even informing them through a third party is considered an act of notification.
- Announcements regarding personal events among employees should be posted only on the company’s Notes Avenue bulletin board. Sending individual internal emails or printed notices (such as wedding invitations or obituary cards) is discouraged.
- Notifications are limited to immediate family members of the employee or their spouse (grandparents, parents, children).
- Monetary contributions among employees should not exceed KRW 50,000, which is considered a customary social norm.
- Employees must never accept condolence or congratulatory money from external stakeholders. If received, it must be returned or reported to the Ethics Office and donated appropriately.

Prohibition of Financial Transactions

- Employees and their family members must not lend or borrow money to/from other employees or stakeholders.
- This prohibition applies regardless of whether interest is charged or not.

Prohibition of Sponsorship for Events

- No sponsorship (monetary or otherwise) is allowed from stakeholders for internal company events such as company outings, sports events, workshops, or club activities supported by the company.
- Likewise, stakeholders must not be permitted to sponsor these events in any form.
- Receiving or offering conveniences such as vehicles, venues, or services for such events is also considered sponsorship and is prohibited.

Prohibition of Improper Budget Usage

- Company funds must never be used for personal purposes.
- In principle, all business expenses must be paid using the corporate credit card, and must be used in accordance with the budget’s intended purpose, legal standards, and internal regulations.

Prohibition of Acts That Damage Dignity

- Employees must act as representatives of the company, protecting its reputation, honor, and ethical standing.
- Employees must refrain from any misconduct, including inappropriate personal behavior or illegal actions, that could harm the company’s or their own reputation.

Duty to Report and Protection of Confidentiality

- Employees who witness or are asked to participate in violations of this Code must promptly report the incident to the Ethics Office through any convenient means (phone, email, mail, or in person).
- Senior managers must immediately report any violation of the ethics policy that they become aware of by any means.
- Failure to report a known violation may result in loss of protection or disciplinary action.
- The Ethics Office may conduct fact-checking investigations when necessary, and related employees must fully cooperate.
- Neither the Ethics Office nor employees may disadvantage or disclose the identity of whistleblowers.
- If the whistleblower may suffer personnel disadvantages, appropriate protective measures (e.g., reassignment) will be considered upon request.
- Anyone who learns about a report or reporter through duty or by chance must keep the information confidential. Violating this obligation may lead to disciplinary action.
- If an employee involved in unethical conduct voluntarily reports the incident to a senior manager or the Ethics Office within five business days of the act, disciplinary action may be reduced or waived.