05 Special Code of Conduct for Design Positions

Chapter 1. General Provisions

1. Objective

The design duty is a professional one requiring higher morals in its features than other general duty performers. Therefore, the Company shall impose additional moral obligations on the design duty performers to allow them to lead the Company’s business ethics.

The objective of this Special Code of Conduct for Design Positions is to establish a rightful corporate culture by maintaining the dignity of all Employees directly or indirectly related to the design 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 Design Positions shall apply to all Employees directly or indirectly related to the design duties (hereinafter referred to as the “Duty Performers”) as follows:

• Persons responsible for designs, such as members of the design sector; 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 Design Positions, the Company regulations shall be revised to meet the standards of this Special Code of Conduct for Design Positions.

3. The Operations of this Special Code of Conduct or Design Positions

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

Chapter 2. Principles of Performance of Duties

1. Attitude for Performance of Duties

The duty performers shall clearly recognize that customer satisfaction is the source of the Company’s growth, and consider customers’ requests in conformity with laws, the first criteria for performing duties.

The duty performers shall perform relevant design related duties in a transparent and fair way, and make their best efforts to make reasonable and economic designs.

The duty performers shall establish the co-work system among relevant departments, and pursue the optimization of work functions through organic communication channels among the duty performers.

The duty performers shall comply with the policies on the Company’s safety management and the obligation to prevent safety accidents.

2. Transparency in Business Transaction Relations

The duty performers shall observe laws related to their duties, and make efforts to maintain fair business transaction relationships.

The duty performers shall make technical evaluations on business partners regarding designs pursuant to the fair and transparent principles, and ensure that the best products can be supplied.

Transaction relations with business partners shall be made based on contracts, and if there is a change in the agreement, the change(s) shall be recorded and managed pursuant to the appropriate procedures for performing duties.

The duty performers shall not exercise their influence or engage in unfair transactions or unethical activities by abusing their market positions.

The duty performers shall create the trust relationship of co-existence with business partners.

3. Strict Information Control

The duty performers shall clearly recognize that not only the design documents created, collected, or arisen in the course of performing duties but also design related matters, such as technologies and know-how are the Company’s assets, and shall strictly implement the safety control measures.

The duty performers shall not bring out or disclose to the outside any design related matters without approval by the Company, and shall provide the information to authorized persons to an authorized extent

The duty performers shall systematically classify and manage all design related matters to create values, and provide the matters to ensure that relevant duty performers can effectively use the matters.

4. Prevention of 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.

5. Prohibited Activities

The duty performers in principle shall not perform the following works regarding their duties.

• Obtaining any and all monetary and non-monetary gains by receiving money and valuables, entertainments, conveniences from business partners or interested parties, having a dual position with, receiving guarantee of employment of, or making investments jointly with the officers or employees of a business partner, etc.;
• Where a duty performer conduct technical reviews, excluding a particular company without a special reason;
• Specifying requirements that may undermine fair competition in order to designate a specific product;
• Registering at will any unverified company;
• Over- estimating or under- estimating factors for quotation;
• Changing at will raw materials or specifications after signing a contract;
• Unreasonably approving prior works by tolerating at will deterioration of quality, excessively calculating the number of blueprints, etc.;
• Where a duty performer prepare specifications in writing, preparing it for a specific company or designating special items or words for a specific company; provided, however, that in unavoidable cases, the duty performer shall manage such specifications after obtaining approval from his or her superior manager.

Chapter 3. Handling Violations of Rules

1. Reporting of Violations

The duty performers shall comply with this Special Code of Conduct for Design Positions, and shall report to Business Ethics Team any matter that is or is likely to violate this Special Code of Conduct for Design 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 Design 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 Design Positions is enacted and effective from May 2, 2007.