POSCO GY-SOLUTION

This guide is designed to supplement the anti-corruption policy, supporting and providing employees with behavioral guidelines and judgment criteria related to the policy, assisting them in adhering to the procedure. Separate standards can be established as needed to operate the code of ethics efficiently.

Considering the nature, scale, and other factors of the industry and activities where the company operates, this was designed to address potential bribery situations the company might face.

Refers to all employees affiliated with the company and all cooperative businesses that have signed a contract and provide products, goods, or services for the company's operations.

The term "company" denotes any domestic corporation, office, etc., regardless of its name, under the substantial control and authority of POSCO GY-SOLUTION. It refers to a group of individuals assembled to achieve POSCO GY-SOLUTION's business objectives.

"Employee" refers to the company's employees, including the company's representatives, executives, and staff, regardless of their employment status or position, and who work under the company's control. Depending on the situation, contract employees, dispatched employees, volunteers, and unpaid workers can also be included in this definition.

"Stakeholder" refers to the company's consumers, shareholders, business partners, the government, and employees.

"Business Partner" denotes external parties who have formed or planned to create a business relationship with the company.

"Business" encompasses all activities related to the company's general operations besides those for revenue and can be interpreted broadly depending on the situation.

"Bribery" means any act of offering, promising, giving, receiving, or soliciting any undue advantage of any value, which might be considered illegal or corrupt, whether directly or indirectly, and irrespective of location, as an incentive or reward for a person acting or refraining from acting in relation to their duties.

"Public Officials, etc." refers to any individual who falls under one of the following categories:

• • - Persons recognized as public officials under the "State Public Officials Act," "Local Public Officials Act," or any other relevant law regarding their qualifications, appointment, training, service, compensation, status protection, etc.
  • - Leaders and their employees of public-related organizations and institutions under the "Act on Public Official Ethics" and the "Act on the Operation of Public Organizations."
  • - Principals, teaching staff, and employees of all levels of schools established under the "Elementary and Secondary Education Act," "Higher Education Act," "Early Childhood Education Act," and other relevant laws, and the head and employees of school corporations under the "Private School Act."
  • - Representatives and their employees of media companies.
  
  

"Conflict of Interest" signifies a situation where the judgment of a public official or a company's task manager in performing their duties is obstructed due to business, monetary, familial, or personal interests.

"Improper Solicitation" refers to the act of soliciting public officials, as stipulated in the Solicitation Prohibition Act, to handle duties in violation of the law.

Employees must not directly or indirectly offer, propose, promise, or approve the provision of bribes such as money or valuables to customers (clients), partner companies, public officials, or the like in connection with their duties.

• - Gifts refer to items provided without compensation (excluding all items other than money and food), which should be pure, appropriate for the situation, and within the customs. For domestic public officials, the limit is 50,000 won. Moreover, it is prohibited to provide gifts related to their duties to public officials or their spouses that exceed 1 million won in a single instance or 3 million won in a fiscal year.
• - Gifts in the form of samples without markings for specific individuals, whether clients (clients) or public officials, should not be provided.

• - Payments such as congratulatory money, condolence money, and customary items can only be made when indispensably necessary due to customs or socio-cultural reasons.
• - For public officials, the amount must not exceed 100,000 won. When condolence money and gifts/food are received together, the combined value should not surpass 100,000 won.

• - Reasonably priced meals (including alcohol) within the customs are permitted during the execution of duties. However, lavish meals exceeding local laws or norms are prohibited. Especially when offering meals to domestic public officials, the limit is set at 30,000 won.
• - It is permissible to uniformly provide simple beverages and foods during official events or business discussions.
• - The following types of entertainment or hospitality are prohibited:
  • ① Alcohol: Luxurious entertainment venues such as room salons, lounges, and nightclubs.
  • ② Sports: Entertainment golf, entertainment skiing, etc.
  • ③ Recreation: Casinos, racetracks, and other forms of gambling.
  • ④ Relaxation Facilities: Saunas, massage parlors, luxury barber shops, and other lavish facilities.

• - It is permissible to uniformly provide transportation (rail/air/bus tickets, vehicle support), accommodation, and communication facilities to participants in official duties-related events.
• - Travel expenses must clearly relate to the company's business (promotion, demonstration, training of our products/services) and must be reasonable considering the recipient's position and the purpose of the provision.
• - The service providers (airlines & hotels) should pay accommodation or flight expenses directly. Do not pay or reimburse these expenses directly in cash to client employees or public officials.
• - Do not pay for non-business-related travel expenses.
• - Do not cover the travel expenses of public officials' spouses or families.
• - Minimize non-purposeful trips, entertainment, and general tourism.

Providing political funds or donations in the company's name is prohibited. However, contributions to charitable organizations are allowed. Still, "quid pro quo donations" with the potential risk of being perceived as bribes or for any other unjust benefits are prohibited.

• - Any unfair solicitations to public officials are strictly prohibited.
• - Types of prohibited acts of unfair solicitations include the following:
  • ① Intervention in licensing or permissions.
  • ② Influencing administrative sanctions, penalties, reductions, or exemptions.
  • ③ Interference in hiring and promotions.
  • ④ Interference in selecting or dismissing roles influencing decisions in public institutions.
  • ⑤ Meddling in awards or honors managed by public agencies.
  • ⑥ Leaking confidential information related to bids or auctions.
  • ⑦ Interference in the selection or dismissal of specific contractors.
  • ⑧ Meddling in grants, financial support, or investments.
  • ⑨ Irregular trade in goods and services produced or supplied by public agencies.
  • ⑩ Manipulating school admissions or grades.
  • ⑪ Handling of military service examinations.
  • ⑫ Interference in various evaluations or judgments conducted by public agencies.
  • ⑬ Manipulation of administrative guidance, surveillance results, or overlooking illegal activities.
  • ⑭ Meddling in the investigation or trial of cases.
  
  

Offering an honorarium to public officials for lectures, speeches, articles, etc. (hereinafter referred to as "lectures and the like") in relation to their duties at educational events, promotions, discussions, seminars, public hearings, or other meetings should not exceed the amount specified in the Anti-Solicitation and Graft Act. Suppose an employee becomes aware of a violation or attempted violation of this policy and guide. In that case, they must immediately preserve any evidence (including all documents, electronically recorded materials, and data) and report it to the Fair Trade Support Team in the Jeong-do Management Office. When doing business with partners, it is essential to thoroughly convey this policy and ensure that bribery-related laws are adhered to, reflecting this in contracts. Suppose a partner violates or is suspected of violating related laws such as the Anti-Solicitation and Graft Act. In that case, the contract should specify the right to investigate, terminate the business agreement, and claim damages. However, considering the nature of the transaction, negotiation progress, and other relevant circumstances, it might be reasonable not to specify such clauses in certain situations.

If an employee instructs a violation of this policy and guide or, despite being aware of the breach, fails to promptly report it to the Jeong-do Management Office's Fair Trade Team, our company may refer the employee to the Personnel Committee to decide on disciplinary actions. Should an employee violate the Anti-Solicitation and Graft Act or related regulations, resulting in a fine or penalty, the company will not assume any responsibility for the illegal act. The employee may be referred to the Personnel Committee to determine possible disciplinary measures. If our partner company breaches this policy or regulations, such as the Anti-Solicitation and Graft Act, we may terminate our contractual relationship with the said partner company.

• - Exceptions
  • - Specific actions requested according to legally defined procedures and methods.
  • - Publicly demanding specific actions (e.g., gathering stakeholder opinions during policy decisions or task execution).
  • - Elected public officials forwarding complaints for the public good (ensuring sound legislative activities).
  • - Demands for task completion within a legally defined period.
  • - Requests for verification or proof regarding job-related or legal matters.
  • - Requests to explain or interpret laws or systems through inquiries or consultations.
  • - Other actions not against societal norms (exceptions are recognized if, among the 15 unfair solicitations, they are deemed valid against the entire legal order). Unfair solicitations towards public officials are fundamentally prohibited.