POSCO PRTECH

This Code of Ethics encapsulates our founding spirit of “Patriotic Service through Steel,” merged with contemporary ethos, embodying the ethical values and conduct standards that every POSCO Group employee must continually uphold and evolve.

Integrity, fairness, and honesty are the highest standards of value for us, and they help us establish a trustworthy corporate image among all stakeholders. In line with these values, POSCO instituted the Code of Ethics in 2003 for all its employees to follow. In 2014, we explicitly included the principle of respect for human rights in our Code of Ethics, as championed by the United Nations. Upon establishing our maintenance and repair business, in alignment with our management philosophy that places ethics as a top priority, we developed the POSCO PR-TECH Code of Ethics.

Following the preamble, this Code of Ethics comprises the principles of ethical management that reflect employee compliance and responsibility and guidelines for ethical decision-making. All employees of the POSCO Group must strictly adhere to the ethical principles and guidelines set out in this Code in all aspects of their work.

We are guarding the legacy of the POSCO Group, built through the blood and sweat of our predecessors and founding generation.

• 1. We are dedicated to observing all applicable laws and regulations in every jurisdiction where POSCO Group operates.
• 2. As representatives of POSCO Group, employees are expected to uphold their professional integrity and endeavor to safeguard the company's esteemed reputation.
• 3. Maintain honesty, fairness, and trust in all business operations and relationships.
• 4. Do not engage in activities that conflict with the interests of the company.
• 5. Respect individual dignity and diversity, and do not unfairly discriminate based on race, nationality, gender, disability, religion, etc., against employees and stakeholders.
• 6. Strive to create a safe workplace and protect the environment.
• 7. Employees should strive to instill an ethical culture by practicing ethical behavior.

Employees must fully comprehend and adhere to ethical standards. As members of a global enterprise, they must abide by international and domestic anti-corruption legislation.

• 1. Understanding and Compliance with the Code of Ethics
  • - Understand and faithfully comply with all contents of the code of ethics.
  • - Consult with the department head or the Jeongdo Management Office when confronted with situations that may contravene the code of ethics.
  • - Be responsible for any unethical actions taken.
  
  
• 2. Reporting and Consulting on Unethical Behaviors
  • - If you become aware of unethical behaviors by yourself or others that contravene the code of ethics, immediately report, or consult with your department head or the Jeongdo Management Office.
  • - Be aware of the various methods available to report or consult on code of ethics violations.
  
  
• 3. Roles and Responsibilities of Leaders

  As a leader, play a pivotal role in enhancing the company's core competitiveness by preventing and eradicating unethical behavior through compliance with ethics.

  
  

  (1) Decision Making

  When the interests of the company and ethics conflict, there is an obligation to prioritize ethical decision-making.

  (2) Management Responsibility

  Leaders bear unlimited responsibility in the event of unethical behavior and are responsible for managing unethical behavior by their subordinates.

  (3) Business Performance

  Comply fully with the law, avoid personal gains, do not deal with corrupt stakeholders, and put the utmost effort into creating corporate value for the company.

  (4) Exclusion of Solicitation

  Eradicate all solicitations and exclude exertion of business influence in connection with outsiders.

  (5) Respect for Humanity

  Strive to eradicate behaviors that harm respect for humanity in the organization, such as sexual harassment and verbal abuse.

  (6) Avoiding Conflicts of Interest

  We diligently work to avert any conflicts of interest with associates employed by businesses we transact with and steadfastly strive to stamp out any unfair dealings borne out of personal interests.

  (7) Actions to Uphold Our Principles

  We dutifully execute our responsibilities and roles, aiming to propel our standards of ethical practice to rank among the best in the world.

  
  

  Leaders are entrusted with the prevention and proper response to unethical conduct by their subordinate employees.

  
  

  (1) Ethical Education and Consultation

  • - Leaders shall provide ethical education and consultation to their staff.
  • - Leaders must make their staff understand the importance of compliance with and practicing the code of ethics.

  (2) Preventive Measures against Unethical Behavior

  • - If unethical behavior occurs habitually, uncover the cause and improve processes to prevent such behavior fundamentally.
  • - If you receive a report that a staff member has violated the code of ethics, immediately report or consult with the Jeongdo Management Office.

Employees found in breach of the Code of Ethics may, in accordance with relevant policies, be subject to disciplinary measures up to and including termination. Notably, we uphold a zero-tolerance stance against acceptance of gifts, embezzlement, data manipulation, and sexual misconduct.

• ※ Acceptance of gifts : Receiving money or goods from interested parties beyond socially acceptable norms.
  ※ Embezzlement : Illegally misappropriating company funds or assets.
  ※ Data manipulation : Distorting, concealing, or spreading business information contrary to the truth.
  ※ Sexual misconduct : Inflicting sexual humiliation on others through sexual harassment or assault.

• Subject to Disciplinary Action
  • - Transgressions of the code of ethics or instigating others to breach these standards.
  • - The failure to promptly disclose known or suspected ethical violations.
  • - Lack of cooperation in the Jeongdo Management Office investigations into possible ethical transgressions.
  • - Retaliatory conduct against employees who have reported ethical management issues.