03 Special Code of Conduct for Personnel Positions

Chapter 1. General Provisions

1. Objective

The personnel 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 Company allows the personnel duty performers to lead the Company’s business ethics in parallel with this Special Code of Conduct for Personnel Position.

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

2. Coverage

This Special Code of Conduct for Personnel Positions shall apply to all Employees directly or indirectly related to the personnel duties (hereinafter referred to as the “Duty Performers”) as follows:

• Authorized persons responsible for hiring, changing and placing, evaluating, and providing education and training to the Employees of the Company;
• Superior managers on duty who may be involved in determining personnel benefits or disadvantages for specific officers and employees; 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 Personnel Positions, the Company regulations shall be revised to meet the standards of this Special Code of Conduct for Personnel Positions.

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

If this Special Code of Conduct for Financial and Accounting 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 Personnel Positions and submit a written pledge to observe this Special Code of Conduct for Personnel Positions.

Chapter 2. Principles of Performance of Duties

1. Attitudes for Performance of Duties

The duty performers shall perform relevant personnel 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 positions.

2. Confidentiality and Security Maintenance

Personnel information on all Employees shall be kept in secret, and disclosure of personnel information of the Employees without reasonable procedures shall be prohibited.

“Personnel Information” shall refer to a series of individual information including hiring, treatment, promotion, rotation, personnel evaluation, etc. and all Employees’ personal information of physical condition, academic background, hometown, family relation, license, career, medical history, etc. and any information that gathers and processes these information in such a method of statistics. In addition, any and all information normally or practically classified into personnel information shall be deemed to be personnel information although it is not specified in this Special Code of Conduct for Personnel Positions.

The duty performers shall take all measures to maintain security for documents, materials, records, etc. related to performance of personnel duties.

The duty performers shall not disclose to a third party any personnel information they have acquired on duty without appropriate approval thereof, in violation of which they shall be subject to disciplinary action.

The duty performers shall not make efforts to acquire personnel information beyond the scope necessary to perform duties in an unreasonable way by taking advantage of their positions beyond the scope necessary to perform duties, and shall have the obligation to maintain security also for any information that they have come across by accident.

3. Prevention of Abuse of Position

The duty performers shall perform personnel duties of hiring, evaluating, promoting, or taking disciplinary action against the Employees of the Company in a fair and transparent way, based on the relevant person’s capacity and accurate facts according to the Company’s personnel policies and systems.

The duty performers shall be strictly prohibited to applying nepotism through private friendships, emotional prejudice, request for special consideration, or private interest, etc., in violation of which they shall be subject to disciplinary action.

The duty performers shall not unreasonably discriminate the Employees of the Company or those persons who apply to the Company as officers or employees on grounds of hometown, gender, physical condition, age, academic background, etc.

The duty performers shall not request, receive, or promise any and all money and valuables, gifts, or entertainments related to requests for special consideration of personnel matters among the Employees of the Company; provided, however, that gifts or any monies for congratulations or condolences with no relationship regarding the above consideration shall be permitted to a minimum extent not undermining manners and dignity.

4. Prohibited Activities

With respect to their duties the duty performers shall not request, receive from, or promise the following matters to the Employees of the Company and a third party nor shall they give them to another third party or request the Employees of the Company and the third party to do so.

• Monetary gains, including the money and valuables, securities, gifts, gift vouchers, etc.;
• Giving special consideration for personnel matters or direct or indirect personnel benefits to the Employees of the Company or third parties by taking advantage of their positions;
• 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
• Obtaining 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 Personnel Positions, and shall report to Business Ethics Team any matter that is or is likely to violate this Special Code of Conduct for Personnel Positions.

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 Personnel 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 Personnel Positions is enacted and effective from October 4, 2005.