01 Special Code of Conduct for Purchasing Positions

Chapter 1. General Provisions

1. Objective

The purchasing duty is a professional one requiring higher morals and integrity in its features than other general duty performers and, therefore, it is necessary to impose additional moral obligations. Accordingly the personnel duty performers may lead the Company’s business ethics in addition to this Special Code of Conduct for Purchasing Positions.

The objective of this Special Code of Conduct for Purchasing Positions is to establish a rightful corporate culture by maintaining the dignity of all Employees directly or indirectly related to the purchasing duties and the reputation of the Company, and securing transparency and fairness in the course of performing duties.

2. Coverage

This Special Code of Conduct for Purchasing Positions shall apply to all Employees directly or indirectly related to the purchasing duties (hereinafter referred to as the "Duty Performers") as follows:

• Members in the purchase department that purchase the Company’s required articles and services, and persons for performing relevant duties in a department entrusted to place orders; and
• All Employees that may directly or indirectly affect the decision-making related to the above duties.

If the Company regulations conflict with this Special Code of Conduct for Purchasing Positions, the Company regulations shall be revised to meet the standards of this Special Code of Conduct for Purchasing Positions.

3. The Operations of this Special Code of Conduct for Purchasing Positions

If this Special Code of Conduct for Purchasing Positions or the Business Ethics Guidelines are unclear or if there are conflicting interpretations, Business Ethics Team shall be consulted. Business Ethics Team’s interpretation and decision on unclear and/or conflicting interpretations shall be final to be followed by all Employees.

All the Duty Performers shall confirm that they understand this Special Code of Conduct for Purchasing Positions and submit a written pledge to observe this Special Code of Conduct for Purchasing Positions.

Chapter 2. Principles of Performance of Duties

1. Attitudes for Performance of Duties

The duty performers shall perform relevant purchase duties in a transparent and fair way.

The duty performers shall not unreasonably exercise their influence to others or engage in unethical activities by abusing their superior positions.

The duty performers shall establish the trust relationship with business partners to fulfill the purpose of joint prosperity, and make their best efforts to prevent information of business partners from being disclosed.

2. Transparency in Transaction Relations

The duty performers shall observe relevant laws to maintain fair transaction relationships.

The duty performers shall choose business partners pursuant to transparent principles, and shall not engage in suspending transactions or restricting entries with no clear reason.

The duty performers shall not engage in unfair transactions by delaying payments by abusing their market positions, unreasonably assisting a business partner’s personnel or assets, etc.

3. Conflicts of Interest

In the event that it is difficult for the duty performers to perform their duties fairly and efficiently because there are conflicts between the Company’s and their personal interest, they shall report it to Business Ethics Team and their superior manager.

If there is a report by the duty performers or a superior manager finds that conflicts of interest are likely to occur, the manager shall exchange the authorized person or take all measures for supervising duties.

4. Prohibited Activities

With respect to their duties, the duty performers shall not request, receive from, or promise the following matters to the Company's business partners or interested parties regarding their duties nor shall they give them to a third party or request the business partners or interested parties to do so.

• Monetary gains, including the money and valuables, securities, gifts, gift vouchers;
• Having entertainments at unhealthy business places or receptions beyond the social norms;
• Providing accommodations for business trip, assisting personal leaves, or providing accommodations of sponsorship for purposes other than the purpose on duty;
• Making any and all transactions, such as transacting personal or real properties, or providing or being provided with payment guarantees for loans or lending or borrowing of money, that may be conspicuously favorable or unfavorable to one transacting party; and
• Having a dual position with, acquiring a share of, receiving guarantee of employment of, or making investments jointly with the officer or employee of a business partner; and
• Obtaining any and all monetary and non-monetary amenities by taking advantage of their interests.

Chapter 3. Handling Violations of Company Regulations

1. Reporting of Violations

The duty performers shall observe this Special Code of Conduct for Purchasing Positions, and shall report to Business Ethics Team any matter that is or is likely to violate these rules of ethics.

The Company ensures that all the matters on handling reports and the identities of reporters shall be kept in strict secret, and that any disadvantages shall not be given as a result of reporting; provided, however, that even if there is a fault on the part of a duty performer, where he or she has voluntarily reported it, the mitigating circumstances shall be taken into consideration.

2. Handling Violations and Taking Disciplinary Action

Business Ethics Team shall conduct investigation for violations reported and received, and report the results thereof to the CEO.

In the event that a duty performer has violated this Special Code of Conduct for Purchasing Positions, he or she shall be subject to disciplinary action pursuant to the Company regulations.

Chapter 4. Additional Provisions

1. Effective Date

This Special Code of Conduct for Purchasing Positions is enacted and effective from October 4, 2005.