SKC

Ethical Management

SKC’s ethical management – Definition and our core values

‘Ethical Management’ refers to business administration, which takes ethical responsibility, as well as economic and legal responsibilities, and pursues the observance of corporate ethics as the principles of conduct to carry our for our sustainable development.
We take the SKMS as the basis of corporate governance and create values for the related parties, such as clients and shareholders, to play key roles in the betterment of society and economic development and make a contribution to the happiness of humankind.

Customers Customer satisfaction and trust
Environment Eco-friendly management
Community Creating a happy community
Members Ethical management mindset
Business partners Ecosystem featuring fairness/accompanied growth
Shareholders Enhancement of corporate value

Ethical management framework (3C)

Code of Conduct: Uppermost regulations specified and codified aimed to put ethics/compliance-related ideas into practice, by setting ethical norms and action guidelines

Compliance system: Organization and operating system aimed to put ethics/compliance-related ideas into practice; Tip-off/consulting, periodic compliance-related inspection, through ethical management organizations

Consensus formation: Putting ethical management–related objectives into practice through education for employees, CEO messages, and relevant PR; Dissemination of the culture of fair trade, through the operation of programs concerning ethical management system to business partners

Ethical management activities

At SKC, we strive to foster a corporate culture that focuses on transparency and fairness based on norms for ethical management and relevant action guidelines.

SKC’s ethical management organizations strive to upgrade the company’s ethical management, through the prevention of unethical behaviors(e.g. CEO messages, pledge to ethics practice, education, and PR),monitoring(whistleblowing system; periodic inspection), and follow-up management(ethical management survey, dissemination of information on cases of unethical acts).

Ethical norms/action guidelines: We set ethical norms/action guidelines designed to foster a transparent and fair corporate culture and view them as criteria for our management acts and judgment of values.

CEO Message & having employees submit ethical management affidavits: Each year, our CEO refreshes his commitment to ethical management. Our employees submit ethics pledge for putting the ethics-related ideas into practice.

Ethical management education: We hold regular educational sessions for inspiring ethics-related consciousness in employees (including part-time and contractors). We also strive to disseminate the culture of fair trade, through relevant education for our business partners.

Ethical management-related PR: We engage in ethical management-related in-house activities, such as reminders about prohibition of acceptance of money/valuables particularly on national holidays, gift-reporting hotline, publication of booklet about FAQs on ethics-related matters.

Ethical Reporting and Counselling system: We operate various channels in order to enable all stakeholders to freely consult and report on ethical management issues, and we strive to prevent repetition of unethical behaviors by dissemination of information of unethical cases.

Ethical management practice surveys: We conduct surveys to measure the level of commitment of our employees to ethical management and improve vulnerable areas.

Self-Monitoring system: We have compiled a checklist of ethical risks for each major business area such as purchasing, human resources, expenses, and investment management, and perform voluntary risk assessment ‘self-monitoring system’ every year. The Ethics Management Department checks the effectiveness of the checklist every year and determines whether it is inappropriate based on the extracted data.

Audit ∙ Diagnostics: SKC conducts inspections of all companies, including its headquarters, investment companies, and ongoing projects, with an aim to at least once every three years for compliance with regulations and business procedures, compliance with relevant laws and Compliance(unethical behavior, including anti-corruption), etc. Violations detected through internal audit and management are regularly reported to the CEO and the SKC Audit Committee through the Internal Audit Organization.

Ethical training

Ethical management education, Month, Details로 구성
Ethical management education	Month	Details
Ethical training(online)	June-August	All employees(including part-time and contractors) of SKC and Subsidiaries*
Ethical practice workshop	August-September	All organizations of SKC and Subsidiaries*
Partner ethical training	September-October	29 business partner companies participated
SKC Ethical training	-	Operating own ethical training program on demand

* SK nexilis, SK enpulse, SK picglobal, Absolics, SK TBMGEOSTONE, SK Leaveo, ISC

Audit ∙ Diagnostics

SKC aims to regularly audit itself and subsidiaries’ businesses once every three years. Prior to the regular audit, risks relevant to all business are assessed early in the audit year. The annual internal audit plan is developed for businesses/organizations assessed to be exposed to high risks; and the audit plan is reported to and approved by the audit committee.

In addition to performing audits, we monitor the status of actions to address audit findings, and periodically report to the audit committee to ensure that such findings are followed up on.

Audit ∙ Diagnostics Status

Year, Audit Scope, Audit Coverage로 구성
Year	Audit Scope	Audit Coverage
2022	·Nexilis	Purchase (inspection) process
2023	·Absolics ·Group Audit - SKC - Nexilis - Enpulse - Picglobal - Pucore	Establishment of a new factory (SHE, etc.) Business at large New Business / Mgmt. infra Business at large Business at large Business at large Business at large
2024	·Nexilis ·ISC ·Picglobal	Business of Overseas corporations / SCM & Strategic facilities Establishment of the ethical management system & Purchase (inspection) process Purchase (inspection) process

※ Exclusion of divestment and termination business

Ethical management education, Month, Details로 구성
Ethical management education	Month	Details
Ethical training(online)	June-July	All employees(including part-time and contractors) of SKC and Subsidiaries*
Ethical practice workshop	August-September	All organizations of SKC and Subsidiaries*
Partner ethical training	August	27 business partner companies participated
SKC Ethical training	-	Operating own ethical training program on demand
Anti-corruption training(online)	September	All employees(including part-time and contractors) of SKC

* SK nexilis, SK enpulse, SK picglobal, SK pucore, Absolics, SK TBMGEOSTONE, Ecovance

Audit ∙ Diagnostics

Audit ∙ Diagnostics Status

Year, Audit Scope, Audit Coverage로 구성
Year	Audit Scope	Audit Coverage
2020	·Nexilis ·Enpulse ·Telesys	Business at large Business at large Business at large
2022	·Nexilis	Purchase (inspection) process
2023	·Absolics ·Group Audit - SKC - Nexilis - Enpulse - Picglobal - Pucore	Establishment of a new factory (SHE, etc.) Business at large New Business / Mgmt. infra Business at large Business at large Business at large Business at large

※ Exclusion of divestment and termination business

Code of Ethics for Employees

Statement of the criteria for employees’ conduct and value judgment

Client We gain trust from our clients through client satisfaction management and grow together with them.
Shareholders To create shareholder value, we increase corporate value by reinforcing transparency and efficient management.
Employees All SKC employees fulfill their duties dutifully with accountability.
Society We become a trusted firm by observing the social norm and make a contribution to a society through social and cultural activities.

SKC Corporation (hereinafter the “Company”) establishes its business management foundation based on SK Management System (SKMS): to create value for various stakeholders, including customers, employees, shareholders, business partners, and society; to play a crucial role in social and economic development; and, to further contribute to the happiness of humanity.
To this end, the Company shall enact and practice the Code of Ethics to exercise fair and transparent business management using the Code as a reference for actions and values in all business management activities.

1. Attitude Toward Customers: “We practice customer satisfaction management to gain trust from our customers and ultimately grow together with them.”; 1. Customer-Centered Management
We respect and prioritize our customers’ diverse opinions in the Company’s business management activities.; 2. Customer Value Enhancement
We strive to provide the best products and services required by our customers.; 3. Protecting Customer Personal Information and Trade Secrets
We safeguard our customers’ property and information in compliance with relevant laws and regulations.

2. Basic Ethics of Employee: “SKC employees perform their duties to the best of their abilities with accountability for representing the Company.”; 2.1 Fostering a Sound Corporate Culture
Employees shall respect one another, create an atmosphere to work voluntarily with high motivation, enhance competitiveness through personal capability development, and uphold their own honor and dignity.; 2.2 Fair Performance of Duties
Employees shall perform their duties in a fair and transparent manner, clearly distinguishing between personal and company matters, and strictly adhere to internal and external regulations that require their compliance.; 2.3 Employee Safety
The Company shall establish employee safety and health systems and maintain a safe working environment by complying with relevant laws and regulations.

3. Responsibility to Shareholders: “We enhance corporate value through transparent and effective business management to create shareholder value.”; 3.1 Enhancing Corporate Value
We maximize corporate value through continuous innovation and effective business management and share our achievements with shareholders.; 3.2 Protecting Shareholders’ Rights and Interests
3.2.1 We practice transparent business management centered around the board of directors and respect shareholders’ legitimate demands and proposals.
3.2.2 We prepare business management data according to relevant laws and accounting standards and faithfully disclose it according to applicable laws and regulations to protect shareholders’ interests.

4. Business Partner Relationship: “We provide fair opportunities to our business partners, pursue mutual benefits and co-development to achieve shared growth based on trust.”; 1. Mutual Growth
4.1.1 We do not engage in unfair practices using our superior position with our business partners and shall pursue mutual benefits and shared growth by providing fair trade opportunities.
4.1.2 We protect the trade secrets of our business partners and refrain from using them for purposes other than those intended.

5. Responsibility for Society: “We adhere to social norms to become a company trusted by society and contribute to society through social and cultural activities.”; 5.1 Compliance with the Law
We comply with the laws and regulations of the countries where we operate and respect their traditions and culture.; 5.2 Anti-Corruption
We strive for the development of a corruption-free and fair society complying with relevant anti-corruption laws and international conventions in the countries where we operate.; 5.3 Respect for Human Dignity
We protect fundamental human rights and do not discriminate against any stakeholders.; 5.4 Eco-friendly Business Management
We adhere to international standards, relevant laws, and internal regulations related to environmental protection and practice eco-friendly business management.; 5.5 Health and Safety Compliance
We take the lead in building a safe society by managing health and safety risk factors and complying with relevant international standards, laws, and internal regulations.; 5.6 Social Contribution Activities
We actively engage in social contribution activities tailored to local characteristics and contribute to social development.

6. Application of the Code of Ethics: 6.1 Scope of Application and Compliance Obligations
6.1.1 The Code of Ethics applies to the Company and all its employees. All employees are obliged to comply with this Code of Ethics. Stakeholders shall also understand and be encouraged to practice the Code of Ethics.
6.1.2 In case of violation of this Code, the Member who violates this Code may be subject to disciplinary action according to the relevant company regulations and procedures.; 6.2 Code of Ethics Guide
The organization responsible for ethical management shall establish and operate the Code of Ethics Guide for employees to correctly interpret and implement the Code of Ethics.

【Addenda】: This Code of Ethics shall take effect on March 1, 2006.
The first revision of this Code of Ethics shall take effect from July 31, 2023.

Code of Ethics Guide

Specific regulations for the implementation of the Code of Ethics

Employees’ basic duties Observance of basic ethics for employees, prohibition of acts under conflict of interests, ban on bribery and corrupt practices
Protection of company’s properties Physical property, intellectual property
Observance of laws Observation of domestic and international laws and regulations (fair trade, accounting management, quality/safety/environment management)
Work handling procedures Organization in charge, protection of whistle blowers, consultation / reporting procedures

1. General Principles
1.1 Objectives: The following the Code of Ethics Guide serves to provide SKC employees with standards of practice and decision-making that assist in their proper understanding and application of the Code of Ethics.
1.2 Scope of Application: All employees of SKC and firms under the control of SKC(“Company”) shall understand and observe the Code of Ethics and Code of Ethics Guide. Interested parties of the Company are recommended to understand and practice the terms outlined in this Code of Ethics.
1.3 Definition of Terminology: The meanings of the terms used in this guideline are as follows.

1.3.1 Employees: Executives and employees working for Company (Including regular, temporary, and other non-regular employees)
1.3.2 Money or other valuables: Economic benefits including money (cash, gift card, voucher, lottery, etc.) and other items
1.3.3 Treats or favors: Drinking occasions, golf, performance, domestic and overseas tour and business trips, speculative games, etc.
1.3.4 Convenience: Supports other than money or other valuables, or treats such as transportation, accommodation, tour guide, or event assistance
1.3.5 Stakeholders: Any organization that includes all natural persons and corporations in and outside the company, such as agents, distributors, supplier, and subcontractors that are affected by the Employee’s business conduct or decision-
2. Workplace Conduct
2.1 Business Conduct and Integrity: 2.1.1 Employees shall fulfill their duties and take responsibility for the results based on the principle of good faith.
2.1.2 Employees clearly understand their roles and understand and observe the Code of Ethics and related regulations.
2.1.3 If any of the employees violates the Code of Ethics, sees the other person violating it, or is forced to violate it, such incident shall be reported to the Company immediately.
2.2 Settlement of Conflicting Interests: 2.2.1 Employees must put in effort to ensure that no action or relationship regarding business practices comes into conflict with the interests of the Company. In the case of conflicting interests, Employees must foremost prioritize Company interests and notify the Ethics Committee in the case of emerging violations.
2.2.2 Examples of conflict of interest
A. Employees enter into an agreement or engage in business with the Company directly or through a third party
B. Any financial conflict of interest or involvement of rights/obligations with the Company’s rival or contractual party directly or indirectly
C. Misappropriation for personal benefits by taking advantage of the Company’s assets or information
D. Exerting unfair influence on vendors by taking advantage of their job position such as special consideration for a job position and any special benefits
E. Engaging in a side job which may have a negative influence on the fulfillment of obligations at work
F. Acquisition of the partner’s stocks in an unfair fashion
2.3 Anti-bribery and corruption: 2.3.1 Employees shall fulfill all management activities in an open and transparent manner.
2.3.2 Employees are prohibited from getting special treatment or benefit (money valuables, entertainment and hospitality, convenience) from contractual or related parties regardless of the relevance with the job.
2.3.3 If any special treatment or benefit is obtained regardless of your intentions, you shall return it immediately or report it to the Company.
2.3.4 However, to preserve a decent and sound relationship meals or gifts which are permitted under the current laws and business practices are acceptable.
2.4 Protection of the Company’s assets: 2.4.1 Physical properties
A. Employees are prohibited of using the Company’s assets for personal purposes or transfer or lease them to a third party without getting approval from the Company.
B. The Company’s budget shall be used according to the designated purpose. Processes shall be recorded in accordance with accounting standards and procedures.
C. If a loss occurs in (or there is a possibility of loss of) the Company’s assets, it shall be reported to the Company immediately, and any necessary actions to prevent such loss shall be taken. 2.4.2 Intellectual property
A. The Company’s internal management information shall not be disclosed to the outside without getting approval in advance.
B. Client information shall not be provided to third parties in an illegal fashion. In addition, Employees shall not engage in any unfair or illegal practices which can harm a client’s interests.
C. The Company’s intellectual property rights such as patent, copyright trademark are actively protected.
D. The Company’s secret information shall be kept confidential according to related laws and regulations. To disclose it to the outside, approval shall be obtained in advance in accordance with related procedures.
E. Other companies’ intellectual property rights shall also be protected. In particular, the use of illegal software is strictly prohibited.
2.5 Mutual Respect in Workplace: 2.5.1 Employees must respect their colleagues and maintain basic etiquette and integrity required in the workplace to foster a healthy corporate environment. And Employees must not discriminate one another for reasons of gender, education, region of origin, marital status, race, nationality, religion, and the like.
2.5.2 Employees shall not engage in disrespectful or overbearing behaviors including verbal abuse and violence, acts of sexual harassment that sexually offend other colleagues or such words or deeds that may be misunderstood. physical and mental health of other Employees, such as giving private orders taking advantage of one’s job position or duty.
2.5.3 Employees shall not create a working environment that undermines the physical and mental health of other Employees, such as giving private orders taking advantage of one’s job position or duty.
3. Observance of related laws and the Company’s management policies: All business management activities in the Republic of Korea and abroad shall be implemented in accordance with local laws and regulations and business practices.
Fare Trade and Competition: 3.1.1 All transactions shall be performed in accordance with related laws and bylaws under free competition principle.
3.2 Disclosure and Reporting of Business Information: 3.2.1 Accounting information shall be recorded accurately according to related laws, business accounting standards and bylaws. Any falsification or misstatement of accounting information is strictly banned.
3.2.2 Management information on interested parties shall be disclosed in a fair and transparent fashion in accordance with related laws and bylaws.
3.2.3 Any falsification or misstatement (e.g., concealment, exaggeration/omission, delay) of management information is prohibited.
3.3 Product quality and Responsibility in Safety, Health, Environment: 3.3.1 Product quality and safety management shall observe related laws and meet the client’s requirements. Product performance and risk-related information shall be disclosed as is.
3.3.2 Safety, health & environment-related domestic and international laws and international conventions shall be observed. In addition, employees shall be active in creating safe work environments and participating in environmental protection activities.
3.4 Observance of Domestic and international laws and international conventions relating to anti-corruption: 3.4.1 In accordance with the Improper Solicitation and Graft Act, it is prohibited requesting special treatment or benefits (or any promise to provide such benefit) to related parties such as government officials.
3.4.2 Domestic and international laws relating to anti-corruption such as Foreign Corrupt Practice Act (the U.S.), Bribery Act (the U.K.) and Act on Preventing Bribery of Foreign Public Officials in International Business Transactions shall be strictly observed.
4. Operation of the Code of Ethics Guide
4.1. Department: 4.1.1 The department relating to the operation of the Code of Ethics and Code of Ethics Guide for employees shall be the Management Efficiency Team (Ethics management team).
4.1.2 Said ethical management organization shall get advices from employees, perform guidance and education on employees and properly punish those who violate such rules.
4.2. Reporting Violations and Protection of whistleblowers: 4.2.1 The employee who recognizes the violation of the Code of Ethics or Code of Ethics Guide shall report it to the department leader or Ethical Management Department immediately.
4.2.2 The Company shall not treat the whistleblower in an inappropriate manner at work for his/her fair reporting, and related statements or submission of data..
4.2.3 During the whistleblowing investigation, those who cooperate shall be protected as equally as the whistleblower.
4.2.4 In the event of any unfair treatment, the whistleblower may request proper protection such as corrections or job relocation to the Ethical Management Department. Then, the Ethical Management Department shall investigate the case, take proper actions and establish a plan to prevent the recurrence of such incident including punishment of the responsible parties.
4.2.5 The whistleblowing investigator shall keep the related information confidential to protect the whistleblower.
4.2.6 Any person who violates the said whistleblower protection provision (e.g., retaliation such as disadvantage in personnel, disclosure of the whistleblower’s identity or leak of the related information, and order to find the whistleblower) shall be punished in accordance with related regulations.
4.3. Investigation guideline for the protection of whistleblower: 4.3.1 The investigator shall perform the investigation by taking the protection of the whistleblower as a top priority and must observe the following:
A. The investigator shall not leak or imply any information regarding whistleblowing without getting approval from the whistleblower.
B. All whistleblowing-related data are open to authorized persons only and kept confidential. Paper documents acquired by mail or fax shall be kept in a separate place and locked properly.
C. Any leak of whistleblower’s information obtained during the investigation shall be punished in accordance with related laws. If one of the following events occurs, however, an exception can be made:
- A matter which can cause serious accident or discontinuance of business
- Serious corruption, leak or falsification of the Company’s secret, press release, etc.
D. The Ethical Management Department Manager is liable to educate and manage the security management guidelines regarding whistleblowing-related investigation.
4.4. Consultation / Reported to: For inquiry or consultation regarding the Code of Ethics and Code of Ethics Guide, refer to the contact information below. Reporting can be made by email, phone, mail or in person regardless of its format.

Homepage: https://ethics.sk.co.kr/advice/advice.aspx
Email: skc.ethics@sk.com
Phone: 080-890-6262
Fax : 02-537-2649
Adress: Block B, K Twin Tower, 50 Jongro 1-gil, Jongro-gu, Seoul, South Korea, Ethics Mamagement team(Audit)

SKC