Article 1 Purpose

The purpose of the Shinsung Group's "Ethical Management Regulations" is to guide appropriate conduct in implementing and applying these regulations, promote ethical practices, and establish procedures for reporting matters involving money, entertainment, hospitality, convenience, and other forms of benefits.The company, along with its employees and officers, shall strictly adhere to these Ethical Management Practice Guidelines as a standard for ethical decision-making and behavior in fulfilling their duties.

Article 2 Definitions

1. Money: Refers to cash, checks, trademarks, securities, credit or debit cards, goods (gifts), memberships, vouchers, discount coupons, admission tickets, condolence money, subrogation of debt, reimbursement of expenses, debt guarantees, acquisition of shares from related business partners, transactions significantly deviating from fair market value, or other forms of financial or economic gain.
2. Entertainment or Hospitality: Refers to benefits or support provided through meals, drinks, entertainment establishments, gambling, horse racing, speculative activities, sports, fishing, travel, events, and similar activities.
3. Convenience: Refers to non-monetary support such as accommodation, transportation, travel assistance, supplies, event support, employment or job placement, and transaction guarantees, excluding money, entertainment, or hospitality.
4. Acceptance: Refers to receiving money, entertainment, hospitality, or convenience without compensation.
5. Officers and Employees: Includes all employees and officers of the company, including regular and contract employees.
6. Stakeholders: Refers to all individuals, corporations, or organizations, internal and external to the company, whose tangible or intangible interests are affected by the actions or decisions of employees and officers.
7. Whistleblower: Refers to any employee obligated to report the receipt of money or any awareness of such activities.

Article 3 Prohibition on Accepting Money, Entertainment, or Conveniences

1. Employees are, in principle, prohibited from accepting money, gifts, entertainment, or other conveniences (hereinafter referred to as “economic benefits”) from stakeholders or colleagues, regardless of the amount, location, or purpose. If offered, they must be politely declined or returned.
2. If economic benefits are received from stakeholders, employees must report them according to the designated reporting procedures.
3. Notwithstanding paragraph 1, the following cases are permitted:
 ① Monetary condolences or gifts: Cash or gifts within socially accepted norms, only in cases of personal events with clear justification. (However, pre-notifying stakeholders or public announcements through superiors, colleagues, or subordinates are strictly prohibited.)
  - Monetary condolences: Up to KRW 50,000 for individuals and KRW 100,000 for corporations, limited to events involving the immediate family of the employee.
  - Gifts: Customary gifts valued at no more than KRW 100,000 (including floral arrangements).
 ② Modest entertainment or hospitality among employees: Small-scale gatherings aimed at fostering teamwork within the organization are allowed only for the first round unless exceptional circumstances arise.
 ③ Promotional items or conveniences: Small souvenirs, promotional materials, or samples provided equally to all participants during official events.
 ④ Participation in recreational activities: Activities such as golf, fishing, or tourism, provided they are pre-approved by an executive and expenses are borne individually by participants.
4. Accepting economic benefits through family, relatives, or acquaintances will be regarded as the employee’s own act./div>

Article 4 Handling of Received Economic Benefits

1. In cases where economic benefits are unavoidably received, employees must submit a “Receipt of Economic Benefits Report” to the Ethics Management Office within three business days.
 ① Returnable items must be returned to the stakeholder, affiliated corporation, or organization that provided them, along with appropriate documentation.
 ② A return letter, signed by the responsible executive, must be sent to the provider, explaining the reason for the return and steps to prevent recurrence, along with proof of return.
 ③ When submitting the “Receipt of Economic Benefits Report,” employees must include relevant documentation, such as a copy of the return letter or bank deposit slip.
2. f an employee becomes aware of improper conduct by a colleague, they must report it to the Ethics Management Office via email or written correspondence. The Ethics Management Office will ensure the whistleblower’s anonymity and confidentiality and take all necessary measures to protect them.
3. Failure to report the receipt of economic benefits from stakeholders will result in disciplinary action in accordance with the Rewards and Punishments Regulations.
4. In cases where judgment is unclear due to the lack of specific guidance, the Ethics Management Office shall review the matter and take appropriate action.

Article 5 Prohibition of Unauthorized Use of Company Assets and Embezzlement of Funds

1. All tangible and intangible assets of the company shall not be used for personal purposes or non-business-related activities. (This includes samples provided for business purposes.)
2. Employees shall not use information or knowledge obtained through their position or duties for personal gain, including engaging in business or supporting the operations of other companies.
3. The following violations are strictly prohibited, regardless of whether the misappropriated funds or assets are returned: unauthorized withdrawal of company funds, personal loans from company funds, manipulation of accounting records, illegal use of corporate cards, creating cash through unauthorized discounts, falsifying receipts for expense claims, or submitting false claims for various allowances and welfare benefits.
4. If company assets are unavoidably used for personal purposes, employees must report the usage to the Ethics Management Office immediately and reimburse the incurred costs in accordance with the company’s accounting policies.
5. Employees who become aware of the misuse of company assets or embezzlement by other employees must report it to the Ethics Management Office.

Article 6 Prohibition of Document Manipulation and False Reporting

1. All records, reports, and documents must be prepared accurately and honestly, including accounting records and financial statements, which must comply with applicable laws (e.g., commercial law, tax law) and corporate accounting standards.
2. Employees shall not falsify or manipulate documents, figures, or reports for the purpose of exaggerating performance or concealing deficiencies.
3. Supervisors shall not instruct subordinates to engage in falsification or manipulation of documents or figures. Subordinates who knowingly comply with such unlawful instructions will be deemed equally responsible for the violation.
4. Employees have the right to refuse unlawful or improper instructions from supervisors regarding falsification or manipulation and must report such instructions to the Ethics Management Office.
5. Employees who refuse unlawful or improper instructions will not be subjected to any disadvantage or retaliation.

Article 7 Compliance with Information Security

1. Confidential or sensitive company information shall not be disclosed externally without proper authorization.
2. Customer information shall not be disclosed without the customer’s prior consent and approval through the company’s official procedures.
3. The use of unauthorized software is prohibited. All software must be legally procured through the appropriate internal department.
4. Employees shall not distort, falsify, or damage company-related information, nor shall they use such information for personal gain.
5. Employees shall not disseminate false information or rumors about the company.

Article 8 Social Media (SNS) Usage Guidelines

1. Employees shall not disclose confidential internal information, unannounced company events, incidents, or rumors through social media platforms.
2. Employees shall not disparage customers, shareholders, business partners, competitors, or colleagues, nor engage in disputes or antagonistic behavior on social media regarding company-related matters.
3. Employees shall not use the company’s name, logo, trademarks, images, or others’ intellectual property without proper authorization.

Article 9 Prohibition of Workforce Leakage

1. Employees shall not facilitate recruitment or introductions that lead to the leakage of company personnel to competing companies.
2. Employees shall not disclose internal organizational structures or personnel information to competitors or headhunters without authorization.

Article 10 Prohibition of Workplace Harassment and Sexual Misconduct

1. Employees shall refrain from inappropriate conversations, using language or behavior that causes sexual humiliation or discomfort, or engaging in unwelcome physical contact.
2. Unnecessary physical contact and remarks emphasizing fixed gender roles are prohibited.
3. Employees shall not engage in verbal or physical abuse that causes physical or mental distress to colleagues.

Article 11 Proper Job Performance

1. Employees shall not engage in actions or behavior that tarnishes the reputation of the company or its employees.
2. Employees must fulfill their assigned duties and responsibilities and shall not cause losses to the company by neglecting their work..
3. Supervisors must fulfill their duty of care toward subordinates and shall not issue improper instructions unrelated to company business.
4. Employees shall not engage in behavior or maintain lifestyles that disrupt job performance or damage the company’s reputation.
5. Employees shall refrain from engaging in non-work-related activities during working hours.
6. Employees shall not engage in behavior that undermines workplace discipline, such as unauthorized leave, early departures, tardiness, or failure to comply with designated break times.
7. Employees must obtain prior approval from the Ethics Management Office before attending external official events, forums, or training as speakers, panelists, or instructors.
8. Employees shall not violate anti-graft laws or engage in improper solicitations that deviate from normal business practices.

Article 12 Fair Selection and Support of Companies

1. The company establishes and applies fair and objective criteria in the selection and support of partners and trading counterparts.

Article 13 Prohibition of Unfair Trade Practices

The company, its officers, and employees shall strictly refrain from engaging in the following unfair trade practices:
1. Unfairly refusing to transact with or discriminating against a trading partner.
2. Unjustly enticing or coercing a competitor's customer to conduct business with the company.
3. Exploiting the company's dominant position to unfairly influence transactions with a counterparty.
4. Deliberately obstructing or interfering with the business operations of a partner company.

Article 1 Date of enforcement

These ethical management practice guidelines will be effective from August 1, 2020.

Article 2 Interpretation

In cases of ambiguity or disputes regarding the interpretation of these Guidelines, employees shall seek clarification from the Ethics Management Office. Any unresolved issues will be referred to the Ethics Management Committee for final resolution..

Article 3 Amendment

These ethical management practice guidelines are revised after deliberation by the Ethics Management Committee.