POSCO GY-SOLUTION

Obligations to Comply with Code of Ethics
As a global company, we solidify an ethical corporate culture by adhering to the fundamentals and principles through management activities that respect law and ethics.

Stakeholder
Refers to individuals, such as employees, who might be directly affected in their rights or interests due to one's job performance, as well as customers, suppliers, affiliates, subcontracted partners, domestic and foreign public officials, and organizations.

• ① Gifts
  • - The term “gifts” encompasses items of monetary value, such as cash, gift cards, vouchers, and physical goods.
  • - No gifts should be offered, solicited, or accepted from any stakeholders under any circumstances, with the following exceptions:
    · Marketing or promotional gifts valued at or below 50,000 KRW. However, for agricultural, marine, and processed products (flowers included), the value cap is 100,000 KRW.
    · Company-branded souvenirs or those generally provided to attendees at stakeholder-organized events, not exceeding a value of 50,000 KRW.
  • - Seeking or accepting gifts from foreign entities during overseas business trips is prohibited.
  • - Unanticipated or unavoidable receipt of a gift should lead to its return. If a return is impracticable, it should be reported to the Jeongdo Management Office.
  • - Employees leveraging company-specific knowledge or positions for external lectures leading to income (such as speaker fees) should donate 50% of the earnings.
  
  
• ② Entertainment
  • - “Entertainment” refers to various activities for business-related human gatherings and interactions, including dining, social drinks, golfing, performances, and other leisure activities.
  • - Exchanges of hospitality exceeding 100,000 KRW per person with stakeholders are prohibited. If work-related entertainment of over 100,000 KRW per person must be exchanged, it requires prior approval from the department head.
    Inevitable hospitality exchanges exceeding 100,000 KRW per person should be reported to the the Jeongdo Management Office. However, for public officials, journalists, and teachers, subject to the Anti-Graft Act, meals worth up to 30,000 KRW per person can be provided if there's a legitimate purpose, such as effective job performance, socializing, or etiquette.
    ※ Stakeholders: This term refers to individuals, customers, trading companies, business corporations, partners, domestic and international public institutions, and international organizations (including their employees) who can directly or indirectly influence or be influenced by one's duties in terms of rights or interests.
  • - Entertainment at venues with hostesses is strictly prohibited regardless of cost.
  
  
• ③ Convenience
  • - “Convenience” refers to benefits such as transport, accommodation, tourism, event support, etc.
  • - Excessive transport, accommodation, or similar conveniences shall not be given or received. However, conveniences typically provided to all event attendees are exempted.
  • - If unavoidably received or given, conveniences that exceed the permissible scope must be reported to the Jeongdo Management Office.
  
  
• ④ Condolence or Celebration Money
  • - No disclosure should be made to stakeholders about personal or colleagues' life events, including indirect notification through a third party.
  • - Internal notifications of such events should be conducted through designated company channels. Direct emails or formal invitations are not permitted. The scope of relatives in this context is limited to the immediate family: the employee, their spouse, parents, children, and grandparents.
  • - Employee-to-employee condolence or celebration money should align with societal norms, which suggests a recommended amount of 50,000 KRW. For external stakeholders, including floral wreaths, the maximum limit is 100,000 KRW. However, for those subject to the Anti-Corruption and Bribery Prohibition Act, the total amount should not exceed 50,000 KRW, excluding floral wreaths.
  • - Under no circumstances should we accept any condolence or celebration money from external stakeholders. It must be returned or donated to the Jeongdo Management Office if received unavoidably.
  • - If requested by the Jeongdo Management Office, employees shall provide proof of refund for any such funds received from stakeholders.
  • - No floral wreaths shall be accepted from stakeholders. If received unavoidably, it shall not be displayed.
  • - Employees are encouraged not to hold extravagant wedding ceremonies at luxury hotels.
  
  
• ⑤ Personnel Solicitation
  • - No solicitations or recommendations shall be made through company or external contacts for the following matters.
    · Special favor requests regarding equipment/material purchases and various contracts.
    · Favoritism or special privilege requests concerning personnel matters such as hiring, promotion, rewards, disciplinary actions, or job transfers.
    · Requests for excessive convenience or privileges outside of standard procedures.
    · Requests to neglect oversight duties such as inspections and audits.
  • - Illicit solicitations directly or through third parties relating to the tasks listed under the Anti-Solicitation Act should not be made.
  
  
• ⑥ Money Transactions
  • - Money transactions, such as loans, loan guarantees, or real estate leases, with stakeholders shall not be conducted.
  • - In unavoidable cases where money transactions occur with stakeholders due to personal relationships, these shall be reported to the Jeongdo Management Office.
  
  
• ⑦ Event Sponsorship
  • - No sponsorship or gifts should be accepted from stakeholders during company-supported events or activities, including departmental events or hobbyist activities.
  • - Any convenience provided for the event, such as vehicles, venues, or services, is considered a form of sponsorship.
  • - If an event sponsorship is unavoidably received, it shall be reported to the Jeongdo Management Office.
  
  
• ⑧ Improper Use of Budgeted Funds
  • - Company budgetary resources, such as meeting expenses or business promotion expenses, shall not be used for private purposes.
  • - The use of corporate cards is mandated when executing expenses, and the use of budget must align with the purpose and the standards set by law.
  
  
• ⑨ Protection of Information and Assets
  • - Company confidential or critical information must be strictly protected.
  • - Critical information shall be shared immediately with the necessary personnel upon identification.
  • - No distortion of information or spreading of false facts shall occur.
  • - Company property and facilities shall not be used for non-business-related purposes.
  
  
• ⑩ Fair Trade
  • - By adhering to international standards and national fair-trade regulations, we will not engage in unfair trade practices such as collusion with competitors on production, prices, bidding, and market segmentation. We strive to compete fairly in the market.
  • - We will not use our dominant position to demand any form of payment or an unfair request from customers and trading companies.
  • - We respect the rights and property of others, including intellectual property rights, and will not infringe upon these for any transaction or gain.
  • - Corporate information, including competitor information, is obtained and used only through legitimate means.
  
  
• ⑪ Preventing Conflicts of Interest
  • - A conflict of interest arises when a personal relationship with a trading company's employee exerts improper influence on an employee's job performance.
  • - Inappropriate requests from trading company employees with whom a personal relationship exists, including retired employees, are strictly excluded to prevent conflicts of interest.
  • - Informal contact with trading company employees with a personal interest shall be avoided. If contact is made unintentionally, it shall be reported to the department head or the Ethics Officer of the Jeongdo Management Office.
  • - Employees shall not attend gatherings of retired employees without company approval.
  • - Retired employee groups shall be joined after retirement. If an employee is currently a member, they shall report to the respective department head and withdraw.
  • - If there is a personal interest in a trading company employee, the employee shall consult with the department head or the Ethics Officer and agree to measures such as reassignment of duties depending on the result.
  • - Favors shall not be given to specific individuals or corporations due to personal interest, leading to unfair contract settlements, overpriced purchases, order accumulation, premature disclosure of transaction information, and other forms of unfair trading.
  • - Even after retirement, conflicts of interest with POSCO and POSCO Group companies shall be prevented.

We champion the harmonious growth of our team and company by fostering an optimal work-life balance, creating a gratifying and balanced work environment underpinned by a culture of mutual respect and understanding.

• ① Achieving a Balanced Work-Life Culture
  • - We provide benefits and support systems designed to enhance the quality of life for our employees and maintain their well-being.
  • - We encourage our employees to realize their personal goals, offering flexibility in work arrangements, including time, location, and method.
  
  
• ② Empowering Employees Through Education and Growth Opportunities
  • - We foster an environment that enables innovative thinking underpinned by supportive systems and structures.
  • - We offer development and training programs aimed at nurturing the talents and skills of our employees, helping them reach their full potential.
  
  
• ③ Fair Assessment and Compensation Practices
  • - We uphold fair evaluation principles, basing performance assessments on each employee's skill sets and achievements. These evaluations guide our comprehensive and fair compensation policies.
  
  
• ④ Encouraging a Sound Organizational Culture
  • - Our employees foster an inclusive company culture, promoting open dialogue and transparency.
  • - Our employees promote the removal of silos within our organization and cultivate a cooperative work atmosphere.

We understand that our future prosperity hinges on earning our customers' trust and facilitating their success. Therefore, we make it a point to respect customer feedback, understand their needs, and contribute to their growth by creating valuable solutions.

• ① Achieving Customer Satisfaction
  • - We prioritize customer-focused operations by respecting our customers' insights and concerns.
  • - We willingly and proactively respond to our customers' valid requests and constructive suggestions.
  
  
• ② Generating Customer Value
  • - We constantly innovate and develop our technology to deliver superior products, aiming to exceed our customers' expectations.
  • - Our employees cultivate a customer-centric mindset, considering domestic and international market conditions while respecting diverse customer cultures and customs.
  
  
• ③ Upholding Customer Trust
  • - We prioritize our customers' safety and well-being in all our operations, ensuring we provide no products or services that could compromise their health.
  • - We adhere to information security regulations to protect our customers' data.
  • - We are committed to providing our customers with accurate and timely information.

We aim to maximize investor value by generating fair and justifiable profits through transparent decision-making processes and practical management activities.

• ① Enhancing Shareholder Value
  • - By practicing transparent decision-making and implementing efficient management strategies, we generate profits while enhancing corporate and shareholder value.
  
  
• ② Ensuring Fair Distribution of Investment Information
  • - We avoid selective distribution of critical information that could influence an investor's decision, ensuring all investors receive relevant details.
  • - We prohibit the use of insider information for personal gain, neither using it to trade stocks and securities nor suggesting others to do so.
  
  
• ③ Delivering Transparent Financial Information
  • - Financial data is meticulously compiled through suitable processes and controls, ensuring it accurately represents transactional facts.
  • - We prepare financial reports in line with globally recognized accounting standards.
  • - We furnish investors with precise and comprehensive operational information, allowing them to make informed investment decisions responsibly.

We establish a business ecosystem rooted in mutual trust and fair trading, enabling us to thrive in unison with our stakeholders.

• ① Cultivating Mutual Trust
  • - Our transactions with trading partners are predicated on a foundation of mutual respect and equity, ensuring fairness in every deal.
  • - We adhere strictly to pertinent laws and contractual terms to safeguard the information derived from our trade transactions.
  • - We assist our trading partners in observing fair trade regulations and principles.
  
  
• ② Advancing Shared Growth with Trade Partners
  • - By sharing the fruits of our collective performance, we strive for mutual benefit with our trade partners.
  • - Through open communication and collaboration, we support our trade partners in delivering superior quality products and exceptional services.
  • - We ensure equitable opportunities and reasonable trade conditions, propelling our relationships toward true partnerships.
  
  
• ③ Backing Sustained Development of Trade Partners
  • - By providing technical and financial support to our trade partners, we endeavor to construct a stable supply network.
  • - In pursuit of comprehensive corporate symbiosis, we widen the scope of our shared-growth trade partners.

As global corporate citizens, we shoulder our responsibilities and duties to contribute to national and societal advancement.

• ① Role and Approach as Corporate Citizens
  • - We respect local laws, regulations, cultures, and traditions and put our efforts into fostering joint progress with the national community.
  • - We ensure open communication by incorporating stakeholder involvement in our business activities connected with the national community.
  • - We encourage our trading partners to engage in initiatives geared towards national and societal development.
  
  
• ② Contributing to National and Societal Advancement
  • - We fulfill our responsibilities in local communities through creating and preserving stable employment and diligent tax contribution.
  • - We actively partake in societal services such as volunteer work and disaster relief and spearhead public initiatives across diverse fields, including culture, arts, sports, and academia.
  • - We support efforts to enhance the quality of life for residents.

We are committed to building robust environmental management systems, strengthening our capabilities to respond to environmental risks, and maintaining open communication.

• ① Establishing Environmental Management Systems
  • - We efficiently manage our environmental systems to achieve our environmental objectives, evaluating and controlling the impacts and risks of our business activities on the environment while systematically analyzing our performance in environmental management.
  • - We engage various stakeholders in sharing results, addressing issues, and collectively pursuing environmental conservation efforts.
  • - We build a consensus with our trade partners regarding the company's fundamental social responsibility towards environmental protection and assist them in adhering to environmental laws and regulations.
  • - We support our trade partners in safeguarding public health and safety during product manufacturing and service provision while minimizing adverse effects on local environments and natural resources.
  
  
• ② Upholding Environmental Regulations and Curbing Environmental Impact
  • - While strictly adhering to environmental regulations, we strive to curb the environmental impact at every stage, from product development to production and use.
  • - We minimize the emission of pollutants by introducing eco-friendly production processes and applying optimal pollution prevention technologies.
  
  
• ③ Tackling Climate Change
  • - We work towards reducing greenhouse gas emissions through decreased use of fossil fuels and raw materials and improved energy efficiency.
  • - We strive to bolster our competitive
  
  
• ④ Safeguarding the Environment and Ecosystem
  • - We make concerted efforts towards restoring natural ecosystems and preserving biodiversity by efficiently using natural resources and by-products.

We uphold human rights, endorse applicable international guidelines, and champion the inherent dignity of every stakeholder through fostering freedom, ensuring safety, and advancing the quality of life.

• ① Respect for International Human Rights Standards
  • - We respect and support international human rights standards such as 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.
  • - We strive to prevent human rights abuses throughout our business operations by implementing clear human rights protection policies and systems.
  • - We support our business partners in adhering to the human rights regulations stipulated by international standards, protecting their employees' rights, and providing fair treatment.
  
  
• ② Due Diligence for Human Rights
  • - We reserve the right to conduct necessary audits on any business activities that may infringe upon human rights or cause dissatisfaction.
  • - If it's determined that our business activities have violated human rights or caused dissatisfaction, we seek appropriate solutions.
  • - We communicate with relevant stakeholders regarding the content and results of human rights-related activities.
  
  
• ③ Employee Protection
  • - We prohibit any verbal, physical, or visual conduct that infringes upon the rights of individuals, including sexual harassment.
  • - We respect each employee's privacy, avoiding slander or defamation and ensuring that personal information is not disclosed.
  • - We prevent the occurrence of tasks performed involuntarily due to psychological or physical coercion.
  • - We adhere to national labor laws and international standards for labor conditions and minimum working age for minors.
  • - We strictly follow safety regulations and take appropriate actions regarding any identified hazards.
  
  
• ④ Respect and Equality
  • - We do not discriminate or harass anyone based on race, nationality, sex, age, education, religion, region, disability, marital status, or gender identity.
  • - We offer equal employment opportunities to those who meet the qualifications and skills required for the job.
  • - We maintain a work environment that respects cultural differences.
  
  
• ⑤ Assurance of Lawful and Humane Employment Conditions
  • - We address human rights issues raised by employees promptly through the company's grievance-handling system.
  • - We guarantee conditions that allow a dignified lifestyle, including maintaining appropriate working hours.
  
  
• ⑥ Efforts to Respect Human Rights in Local Communities
  • - If our business activities infringe upon the rights of local community members, we solicit their opinions and strive to resolve human rights issues.