Fair Trade

Voluntary Compliance Program
What is a Voluntary Compliance Program (CP)?
Voluntary CP refers to the internal compliance system put in place voluntarily by companies to comply with the Fair Trade Act and prevent violations of the act. POSCO GY-SOLUTION introduced the CP on June 1, 2023 and has implemented the system ever since.
Seven major elements
1. Management's declaration of their commitment to voluntary compliance
  • - Demonstration of interest and willingness by the CEO and all employees to practice voluntary compliance.

2. Designation and operation of the Voluntary Compliance Manager
  • - A person who effectively manages the Company’s CP with practical rights and responsibility as the mainstay of the CP operation.
  • - The Voluntary Compliance Manager is designated or dismissed by the committee to ensure he/she is given clear rights and responsibilities.

3. Formulation & distribution of the Voluntary Compliance Manual
  • - The Voluntary Compliance Manual should include important information regarding the application of the Fair Trade Act in a clear manner that is easily understandable.
  • - The manual should include acts in violation of the Fair Trade Act, restrictions on executives and employees who violate the act, and the report procedure when an executive or an employee learns about the violation of law.

4. Operation of education programs
  • - Executives and employees who are working in departments that are prone to legal violations must receive at least two hours of training for every half quarter to ensure they clearly understand acts that violate the Fair Trade Act.
  • - The Voluntary Compliance Manager must supervise the entire training, discover areas that need special training, and reorganize the course depending on the revision in the Fair Trade Act.

5. Establishment of a monitoring system
  • - An internal monitoring system that consist of audit, review, and report must be established for effective operation of the CP.
  • - The Voluntary Compliance Manager must report matters he/she was reported with to the CEO. The CEO must report what he/she deems as important issues to the committee.

6. Restrictions on the violation of relevant laws
  • - Restrictive measures against executives and employees who violate laws must be established and operated.
  • - In case the degree of violation or the responsibility he/she must take is minor, he/she may be subject to other disadvantage in addition to HR restrictions.

7. Document management system
  • - The system is needed as evidence for problematic behaviors under the Fair Trade Act, to receive benefits from the incentive system, and for the evaluation and supervision of the CP operation status.
Voluntary Compliance Council
Functions
  • - Deliberation on important matters of the voluntary CP and advice on Voluntary Compliance Managers.
  • - Each member self-evaluates him/herself for violations of laws in respective areas.
  • - Coordination of work with relevant departments.