Ethical Management
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Chapter 1 General Rules

Article 1 (Purpose) This Code of Ethics (hereinafter referred to as the "Code") aims to establish standards for actions to be observed by executives and employees of the Seohan Group (hereinafter referred to as the "Company") to promote sustainable development and prevent corruption and create a clean organizational climate based on honesty and trust.

Article 2 (Definitions)
The meanings of terms used in this Code shall be as follows:

1. ‘The term "person related to duties" means an individual or organization that falls under any of the following items as a person related to the affairs under the jurisdiction of executives and employees:
1) An individual or organization who is or is apparently seeking to do business with the Company
2) An individual or organization subject to audit, inspection, crackdown, approval, guidance, etc
3) An individual or organization directly receiving benefits or disadvantages by decision, appraisal, examination, assessment, mediation, etc
4) An individual or organization that is evident to enter into or intend to enter into a contract with the Company
5) An individual or organization that requires a specific act from the company, or is affected by financial interests due to the exercise of executive and employee's authority or misfortune
6) An individual or organization directly disadvantaged by the decision or execution of policies, projects, etc
7) Other individuals or organizations related to the affairs prescribed by the representative director to prevent corruption

2. The term "duty-related executives and employees" means any of the following employees among other executives and employees who directly receive profits or disadvantages in relation to the performance of their duties:
1) A subordinate who receives a duty order in connection with the duties under his/her jurisdiction;
2) Executives and employees who perform duties such as personnel management, budget, audit, award training, evaluation, etc., and the relevant executives and employees directly related thereto;
3) Where entrusting or entrusting administrative affairs, executives and employees who are delegated or entrusted with the administrative affairs;
4) Other executives and employees determined by the representative director

3. The term "gift" means goods, securities, accommodation, membership, admission tickets and other equivalents provided without consideration (including when the consideration is significantly lower than market prices or trading practices).
4. The term "entertainment" means providing hospitality for food, golf, etc., or convenience for transportation, accommodation, etc.

Article 3 (Scope of application)
This Code applies to all executives and employees belonging to the company.
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Chapter 2 Pursuing Sustainable Development

Article 4 (In pursuit of customer satisfaction)
1. The company shall be responsible for improving the standard of living by providing products and services desired by customers.
2. Executives and employees shall engage in their work with all time and attention during the business hours so that the company can fulfill the responsibilities under paragraph 1.
3. Executives and employees shall endeavor to improve quality by complying with the company's policies, policies, and procedures for quality control.

Article 5 (Fair Competition)
1. Executives and employees should recognize and treat other employees, customers, partners and other stakeholders as partners for joint survival and prosperity in a fair manner.
2. Executives and employees shall comply with the laws on fair trade and competition, such as the Monopoly Regulation and Fair Trade Act and the Subcontracting Fair Trade Act.
3. Executives and employees shall not lobby the government (including local governments) on behalf of the company or contribute political contributions (money donations, goods or services) without the written permission of written permission.

Article 6 (Honest competition)
1. Data for sales or marketing activities shall be based on a clear basis and shall comply with relevant laws and regulations, such as the Act on Fair Labeling and Advertising.
2. Executives and employees should provide important product information that can influence customer decision-making based on evidence.
3. Executives and employees shall report any problems such as defects or defects of the product to the company immediately.

Article 7 (Transparent Report)
1. Executives and employees shall manage their accounts accurately and transparently based on facts in accordance with relevant laws and generally accepted accounting principles.
2. Employees shall not enter false information or misleading information in accounting data.

Article 8 (Respect for Human Rights)
1. Executives and employees shall comply with laws and regulations on working hours and shall not force other executives and employees to work overtime.
2. Employees shall treat other employees with respect and dignity and shall not discriminate based on race, skin color, gender, sexual orientation, gender identity, gender identity, marital status, pregnancy, parental status, religious, political views, nationality, ethnic background, social origin, birth status, age, or other characteristics.
3. Executives and employees shall not commit physical punishment, physical or verbal abuse, harassment, harassment, intimidation, or other acts that violate personal rights.
4. Executives and employees shall comply with safety and health laws.
5. The Representative Director shall take measures to minimize the risk of exposure to employees and shall provide appropriate health and safety information, such as proper handling and labeling of chemicals and machinery,Education should be provided.

Article 9 (Environmental preservation)
1. Executives and employees shall not damage the surrounding facilities and environment so that residents of the community can enjoy a pleasant residential environment.
2. Executives and employees shall do their best to protect nature and prevent environmental pollution.
Article 10 (Careful Communication)
1. Executives and employees shall not defame others, denigrate suppliers or customers, disclose trade secrets, or post, write, or display data that violates copyright and patent rights.
2. Executives and employees shall not comment on matters related to the company, such as news media reporters, industry experts, or stakeholders, and shall inform the company's public relations department.

Article 11 (Information Protection and Security)
1. Executives and employees shall be responsible for maintaining the security of confidential information under laws, contracts or regulations, such as trade secrets, proprietary information related to the company, customers or partners, and shall not divulge such information to anyone outside the company.
2. When collecting, using, and providing personal information, executives and employees shall comply with relevant statutes, such as the Personal Information Protection Act, the Information and Communication Network Promotion and Information Protection Act, and take the best measures to prevent leakage of personal information.
3. Employees shall not use or provide personal information collected in the course of performing their duties to third parties outside the scope agreed by the data subject at the time of collection.

Article 12 (Protection of Intellectual Property)
1. Employees are responsible for protecting intellectual property rights such as patents, utility model rights, trademarks, design rights, copyrights, intellectual property rights, and trade secrets (hereinafter referred to as "intellectual property rights") and report them to the relevant department immediately.
2. When employees invent or create intellectual property rights, etc., they shall immediately report to the company and actively cooperate in acquiring intellectual property rights in the company's name, such as the succession of intellectual property rights and patent applications.
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Chapter 3 Ethical Performance of Duties

Article 13 (Handling of unfair instructions, etc.)
1. Executives and employees shall not give instructions (hereinafter referred to as "unfair instructions") to subordinates to engage in unethical acts in violation of laws or regulations for their own or others' interests or to significantly harm fair performance of duties.
2. In the case of paragraph (1), a subordinate who has received an illegal instruction may explain the reason to the relevant superior and may not follow the instruction.
3. If the same instruction continues despite failure to comply with the instructions under paragraph (2), he/she shall immediately consult with the ethics management responsibility (meaning the ethics management officer designated under Article 41; the same shall apply hereinafter) or report to the CEO.
4. The ethics management officer who has received consultation under paragraph (3) shall check the details of the instructions and report them to the CEO if he/she deems it necessary to cancel or change the instructions.
5. The representative director who has received a report under paragraph (3) or (4) shall take appropriate measures, such as revocation or change of instructions, if deemed necessary. In this case, regarding the wrongful instruction, Necessary measures, such as disciplinary action, may be taken against a superior who repeats the same instruction despite nonperformance under paragraph (2).

Article 14 (Avoidance of duties of interest)
1. Executives and employees shall avoid participation and decision-making in the relevant work if their duties are related to the interests of those falling under any of the following subparagraphs:
1) The person, his/her spouse, lineal ascendant and descendant, and relatives within the fourth cousin (meaning relatives under Article 767 of the Civil Act; hereinafter the same shall apply)
2) Where the principal, spouse, lineal ascendant and descendant or relative within the fourth cousin is a person related to the duties;
3) Where an organization in which he/she served within two years or an agent of that organization is a person related to the duties or a person deemed difficult to perform his/her duties fairly due to continuous friendship, blood ties, school ties, delay, religion, etc.;

2. If an employee intends to evade his/her duties pursuant to paragraph (1), he/she shall notify the head of the department or the ethics management officer, and if it is unclear whether he/she should avoid it, he/she shall request counseling from the ethics management officer.

3. Upon receipt of a notification or request for consultation under paragraph (2), the head of the department or ethics management officer shall report to the CEO if it is deemed inappropriate for the employee to continue his/her duties in consideration of the following subparagraphs: Provided, That where the head of the department may temporarily rearrange the duties of the relevant executives and employees within the scope of his/her authority, the relevant duties may not be reallocated and reported.
1) the degree of interest
2) The role and importance of the relevant executives and employees in the performance of their duties, such as the degree of exercise of discretion in the performance of the relevant duties
3) Internal and external sensitivity of the work concerned
4) Difficulty level when entrusting the duties to other executives and employees
5) Degree of impairment of fairness in other duties

Article 15 (Exclusion of Privilege)
In performing his/her duties, executives and employees shall not give preferential treatment to a specific person or discriminate against a specific person on the grounds of delay, blood ties, school ties, religion, etc.

Article 16 (Restriction on personal contact with job-related persons)
1. Executives and employees shall not make personal contact with their counterparts (including retirees who are related to their duties) from the time of commencement to the time of termination of their duties. However, in the event of contact due to unavoidable reasons, it shall be reported to the head of the department under his/her jurisdiction (post-report in the absence of the head of the department), and in this case, no act such as leakage of internal information of the company shall be made.

2. The term "private contact" in paragraph (1) means any of the following:
1) If you travel privately with a job related person
2) Where gambling entertainment (mahjong, hwatu, card, etc.) is performed with a person related to his/her duties;

3. The "unavoidable reason" in paragraph (1) refers to any of the following cases. However, this does not apply to the case of paragraph (2) 2.
1) In the case of joining with executives and employees of affiliates on the grounds of consultation, etc. for the promotion of projects at the letter group level
2) Where he/she has contacted an event, etc. attended by a person related to his/her duties without knowing that he/she was present in advance;

Article 17 (Restriction on requests for sponsorship to those related to their duties)
1. Executives and employees shall not request sponsorship from persons related to their duties while conducting events organized or supported by the company, such as sports competitions and volunteer activities. However, this is not the case if the event is explicitly organized or supported jointly with job-related persons.
2. The term "support" under paragraph (1) means receiving expenses, goods, services, manpower, or places, etc. directly or indirectly necessary for the progress of the event.

Article 18 (Prohibition of Use other than the Purpose of Budget) Employees shall not cause property damage to the company by using the budget for performing their duties, such as travel expenses and entertainment expenses, for purposes other than the purpose.

Article 19 (Handling of unreasonable demands by politicians, etc.)
1. Executives and employees shall be treated after consulting with the representative director or ethics management officer if they are forced to perform unfair duties or received unfair solicitation from public officials, politicians, political parties, etc.
2. Upon receiving a request for counseling under paragraph (1), the representative director or the ethics management officer shall take appropriate measures to ensure that the relevant executives and employees perform their duties fairly.

Article 20 (Prohibition of solicitation of personnel, etc.)
1. Executives and employees shall not have another person make a request to the person in charge of personnel affairs in order to have an unfair influence on personnel appointment, promotion, transfer, etc.
2. Executives and employees shall not use their positions to unfairly intervene in personnel appointments, promotions, transfers, etc. of other executives and employees.
3. Executives and employees shall not directly or indirectly request personnel appointments from related companies such as Planning Headquarters, Affiliates, Whusung Group, and Hyundai Kia Motors Group for the appointment, promotion, or transfer of family members, acquaintances, etc.
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Chapter IV Prohibition of receipt of unjust enrichment, etc

Article 21 (Prohibition of intervention of interest, etc.)
No employee shall use his/her position to obtain unfair profits or have another person obtain unfair profits.

Article 22 (Prohibition of Private Use of Positions)
Executives and employees shall not use or allow them to use the company's name or position, etc. for private interests beyond the scope of their duties.

Article 23 (Prohibition of mediation, solicitation, etc.)
1. Executives and employees shall not mediate, solicit, etc. to ensure the fair performance of duties of other executives and employees for the unfair benefit of themselves or others.
2. Executives and employees shall not introduce job-related persons to other job-related persons or public officials under Article 2, Subparagraph 3 of the Act on the Establishment and Operation of the Anti-Corruption and Civil Rights Commission for the unjust benefit of others.

Article 24 (Restriction on transactions using job-related information) Employees shall not trade or invest in property related to stocks, securities, real estate, etc. using undisclosed information learned while performing their duties, or provide such information to others to assist in property transactions or investment.

Article 25 (Prohibition of private use and profit of business property and business opportunities)
1. Executives and employees shall not use or profit from the company's possession (including ownership, lease, lease, etc.) of business vehicles, memberships, real estate, etc. for private purposes without justifiable reasons.
2. Executives and employees shall not use the goods, gift certificates, etc. provided incidentally by using the budget for private purposes without justifiable reasons, but shall use them for the purpose of promoting the project, etc.
3. When an employee discovers a business opportunity based on his/her position, property or information, he/she shall ensure that it can be used as a business opportunity for the company and shall not be misappropriated privately.
4. Executives and employees shall not engage in any activities that compete with the company.
5. Executives and employees shall not accept paid or unpaid positions that may conflict of interest with the company without the approval of the company.
Article 26 (Restriction on the act of receiving money, goods, etc.)
1. Executives and employees shall not receive money, real estate, gifts, or entertainment (hereinafter referred to as "money and valuables, etc.") from persons related to their duties. However, this shall not apply in any of the following cases:
1) Money, goods, etc. provided by legitimate authority, such as the performance of debts due to private transactions (excluding gifts) that do not violate this Code, other corporate regulations, and statutes
2) Food or convenience provided within the scope of ordinary practice (less than 30,000 won) where it is unavoidable in the course of performing his/her duties
3) Transportation, accommodation or food provided uniformly by the Organiser to the attendees at official functions related to the duties
4) Souvenirs or promotional items for distribution to an unspecified number of people
5) Money, goods, etc. publicly provided to help executives and employees in difficult situations due to illness, disaster, etc
6) Other money, goods, etc. provided to the extent permitted by the representative director for smooth performance of duties, etc

2. Employees shall not receive money, valuables, etc. from employees related to their duties. However, this is not the case in any of the following cases.
1) Where falling under any of the subparagraphs of paragraph (1);
2) A small amount (less than 50,000 won) of gifts provided within the scope of ordinary customs (such as condolences, congratulatory gifts, etc.)
3) Money, goods, etc. publicly provided by employee mutual aid associations, etc
4) Money, goods, etc. provided by a superior to a subordinate for the purpose of enhancing morale, such as consolation, encouragement, reward, etc

3. Executives and employees shall not receive money, valuables, etc. in connection with their duties from a person who was a job-related person or a person who was a job-related employee. However, this shall not apply to cases falling under any of the subparagraphs of paragraph (1) and (2).

Article 27 (Restriction on receipt, etc. of money and valuables by spouses, etc.)
Executives and employees shall ensure that their spouses or lineal descendants do not receive money, goods, etc. prohibited from receiving pursuant to Article 26.
Article 28 (Restriction on the act of giving money, goods, etc.)
1. Executives and employees shall not provide bribes, etc. to executives and employees who are prohibited from receiving bribes, etc. from them pursuant to Article 26 (2). However, the cases prescribed in each subparagraph of Article 26 (2) are excluded.
2. Executives and employees shall not provide money, goods, etc. to public officials or politicians related to their duties for the purpose of the company's interests. However, cases prescribed in each subparagraph of Article 26 (1) are excluded.
3. Executives and employees shall not provide money, goods, etc. to a person whose spouse or lineal ascendant is prohibited from providing money, etc. under paragraphs (1) and (2).
Article 29 (Conclusion and Performance of a Clean Contract)
1. Executives and employees shall perform their duties fairly and transparently in accordance with the procedures prescribed by relevant laws, regulations, and company policies in bidding, contract and contract performance, etc. implemented by the company.
2. Executives and employees shall not use their superior position in transactions to demand prohibited money, goods, etc. in the process of bidding, contract, and contract performance under paragraph (1), or make unfair demands such as coercion of unfair trading conditions or interference in management.
3. Executives and employees shall use the company's business and conference facilities for business consultations or meetings with job-related persons in the process of bidding, contract and contract implementation under paragraph (1), and in the case of unavoidable business trip, etc You must comply with the company regulations.
4. Do not share meals, etc. with job-related persons during the performance of duties under paragraph (3), and do not receive meal expenses, etc. from job-related persons, notwithstanding Article 26 (1) 2.
5. Executives and employees shall check whether there is a relationship falling under Article 14 with the contractor and the contractor's executives and employees, and report to the head of the department as soon as they are aware of it. Upon receipt of the report, the head of the department shall take appropriate measures, such as the change of the person in charge of affairs, and may, if necessary, consult with the ethics management officer.
6. Executives and employees who have concluded a contract shall keep the contract (including electronic copies, hereinafter the same shall apply in this Article).
7. The ethics management officer shall inspect the violation of laws and regulations, fairness, integrity, etc. of concluded contracts at least once a year, and may inspect them occasionally, if necessary.
8. Executives and employees shall actively cooperate in the inspection under paragraph 7, such as submitting a contract and providing contact information of the other party to the contract.
9. Where an inspection under paragraph (7) finds violations of laws and regulations, or unfair acts, it shall be dealt with in accordance with this Code and the regulations related to disciplinary action and compensation.
10. The ethics management officer shall notify the executives and employees of the results of the inspection under paragraph (7) and the matters necessary for improvement.
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Chapter 5 Development of a Sound Work Culture

Article 30 (Report of external lectures, meetings, etc.)
1. When lectures, lectures, presentations, discussions, evaluations, evaluations, consultations, resolutions (hereinafter referred to as "external lectures and meetings"), executives and employees shall report in advance to the requestor, reason, date, and price of their department. However, this is not the case if the requestor for external lectures or meetings is the state or local government (including its affiliated institutions).
2. The consideration that executives and employees may receive when giving external lectures, meetings, etc. pursuant to paragraph (1) shall not exceed the standards normally applied by the requestor of external lectures, meetings, etc.

Article 31 (Prohibition of borrowing money, etc.)
1. Employees shall not borrow or lend money to job-related persons (excluding relatives within the fourth cousin) or job-related employees, and shall not rent real estate free of charge (including cases where the consideration for rent is significantly lower than market prices or trading practices). However, cases of borrowing money from financial companies, etc. under Article 2 of the Real Name Financial Transactions and Confidentiality Act are excluded.
2. Notwithstanding the main clause of paragraph (1), employees who intend to borrow or lend money to the person related to their duties or employees related to their duties due to unavoidable circumstances, and employees who intend to borrow real estate free of charge shall report to the CEO do.

Article 32 (Establishment of Sound Economic and Cultural Activities)
1. Executives and employees shall take the initiative in establishing a sound culture of celebration and celebration.

2. Executives and employees shall not inform job-related persons of the congratulatory investigation. Provided, That in any of the following cases, a congratulatory investigation may be notified:
1) a notice to relatives
2) Notification to employees belonging to organizations that are currently working or have worked in the past
3) Notification through an in-house communication network, etc. that is permitted only for employees under subparagraph 2
4) Notification to members of religious organizations, social organizations, etc. to which employees themselves belong
5) notification by a posting on account of his sns

3. The officers and employees of cash exceeding one hundred thousand won in relation to a boat race giving money or not be. However, the following except if applicable, on the one.
1) Money, goods, etc. related to celebrations exchanged between executives and employees and relatives
2) Money and valuables related to celebrations, etc. provided by religious organizations, social organizations, etc. to which employees themselves belong, as prescribed by the articles of association, rules, etc. of such organizations, etc
3) Money, goods, etc. related to celebrations paid in the name of the representative director and the chief executive officer;
4) Money, goods, etc. related to the celebration according to the standards and amount set by the CEO himself. However, it cannot exceed 300,000 won..

Article 33 (Restriction on golf with interested parties)
Executives and employees engaged in contract, examination, permission, and inspection duties shall not play golf with a person who can directly benefit or give a superior position in his/her duties. However, this is not the case in any of the following cases:
1. Where necessary for public purposes such as establishing and implementing policies or exchanging opinions;
2. Where necessary for business consultation with public institutions, private organizations, affiliates, etc
3. Where interested parties are included in social organizations such as family gatherings, alumni associations, and fellowships;
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Chapter 6 Measures in Case of Violation, etc

Article 34 (Consultation on violation)
1. When it is unclear whether the employee violates this Code while performing his/her duties, he/she shall deal with it after consulting with the ethics management officer.
2. The ethics management officer shall record and manage the contents of the consultation.

Article 35 (Report and confirmation of violation)
1. Any person who finds out that an employee has violated this Code may report it to the ethics management officer.
2. A person who reports pursuant to paragraph (1) shall specifically present the personal information of himself/herself and the violator and the details of the violation. Provided, That if there are other matters concerning anonymous reporting, it shall be followed.
3. The ethics management officer shall investigate violations reported pursuant to paragraph (1) and report the results to the CEO.

Article 36 (Guarantee of the reporter's status)
1. The CEO and the ethics management officer shall ensure confidentiality of the reporter and the details of the report under Article 35 and ensure that the reporter is not disadvantaged by the report.
2. Notwithstanding the preceding paragraph, a reporter who is disadvantaged may request the ethics management officer, the representative director, or the planning headquarters to take protective measures and remedy disadvantages, and in which case the CEO and the ethics management officer shall take necessary measures.
3. Where an act of violation is found by a report under Article 35, it may be reduced or exempted in the disciplinary action, etc. against the reporter.
4. Paragraphs (1) through (3) shall apply mutatis mutandis to counseling and reporting under this Code.

Article 37 (Disciplinary action)
1. The CEO shall take necessary measures, such as disciplinary action, against executives and employees who have committed acts in violation of this Code.
2. The types, procedures, levels, and effects of disciplinary action under paragraph (1) shall be governed by the company's disciplinary regulations. However, where disadvantages, etc. are inflicted on the reporter in violation of Article 36, disciplinary action may be imposed in addition.

Article 38 (Disposal of prohibited money, goods, etc.)
1. Executives and employees who have received money, goods, etc. in violation of this Code shall immediately return money, goods, etc. that exceed the standards or are prohibited from receiving them to the provider.

2. If there is a risk of loss, corruption, deterioration, etc. of money, etc. to be returned pursuant to paragraph (1), the address of the provider or provider is unknown, or it is difficult to return it to the provider, the ethics management officer shall immediately report it.

3. The ethics management officer who has received a report under paragraph (2) may handle the money, goods, etc. in accordance with any of the following standards:
1) Dispose of money, goods, etc. that are not of economic value due to corruption, deterioration, etc
2) Donate money and valuables, etc. that are likely to damage economic value due to corruption, deterioration, etc. to social welfare facilities, public interest organizations, etc
3) In cases other than subparagraphs 1 and 2, donations to social welfare facilities, public interest organizations, etc., except as otherwise provided for in other Acts
4) Other standards determined by the CEO

4. The ethics management officer shall record and manage the money and valuables handled pursuant to paragraph (3) in the receipt ledger, including the provider and the recipient, the date and time of delivery, and notify the provider of the relevant facts. However, if the address of the provider is unknown, the results of the processing shall be disclosed so that outsiders can read it, and the detailed disclosure method may be separately determined by the ethics management officer.
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Chapter 7 Auxiliary Provisions

Article 39 (Education)
1. The CEO shall establish and implement an education plan for employees to comply with this Code.
2. The education under paragraph (1) shall be conducted at least once a year.
3. An ethics management officer may order an external entrusted education for a person who has been confirmed to have violated the Code pursuant to Article 35 (3).

Article 40 (Integrity Education by Life Cycle) The CEO shall provide ethics education by level considering the life cycle for new employees, promotions, etc. in order to create a clean and clean workplace climate.

Article 41 (Designation of Ethics Management Officer)
1. The representative director shall appoint the head of the department in charge of planning, personnel, legal affairs or audit as the ethics management officer.
2. The ethics management officer shall perform the following duties:
1) Matters concerning the education and counseling of the Code;
2) Matters concerning the inspection and evaluation of compliance with the Code;
3) Matters concerning the receipt of reports of violations of the Code, the handling of investigations, and the protection of the reporter;
4) Other matters necessary for the operation of the Code
3. The ethics management officer shall not divulge any information he/she has learned while performing his/her duties under paragraph (2).

Article 42 (Check compliance)
1. The ethics management officer shall regularly check the status of implementation of the Code and compliance of employees at least once a year.
2. In addition to the regular inspection under paragraph (1), the ethics management officer may conduct occasional inspections at times of vulnerability to corruption, such as during the holiday season and before and after holidays.
3. The ethics management officer shall report the results of the inspection under paragraphs 1 and 2 to the CEO.

Article 43 (Award)
The representative director may provide rewards to executives and employees who have contributed to the implementation and development of this Code, such as reflecting them in personnel evaluation.

Article 44 (proposal)
Executives and employees may propose to the ethics management officer on inefficient business handling practices and issues to be improved.

Article 45 (Operation of Code of Ethics)
The representative director may enact and implement detailed matters necessary for the operation of this Code.
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Supplementary Provisions
Article 1 (Effective Date) This Code shall come into effect as of June 15, 2018. However, Articles 29 (7) to 10 and 42 shall come into effect from January 1, 2019.