Compliance officer Message
Dear colleagues,
POSCO INTERNATIONAL Corporation has laid down the Compliance Controlling Standards in keeping with
relevant laws and has continued to carry out compliance controlling activities accordingly. We also
adopted the Fair Trade Compliance Program (or CP) to create a culture of fair trade that is based on
free will so we can prevent unfair practices.
The Department of Legal Affairs updated the Guidebook on Fair Trade Compliance 2022 and introduced the
Fair Trade Compliance Program. It also explains important fair trade laws, along with violation cases,
and provides a checklist of things that we must take note of in future business as a reference.
The Fair Trade Act, in particular, was completely revised and toughened to oversee business activities
more closely than before. Therefore, we must take careful attention for the changing business
environment and potential risks.
I would like to ask you all to take an active part in engaging in more fair and transparent business
activities by embracing these fair trade practices and complying with applicable laws.
Compliance Program(CP)
The Fair Trade Compliance Program is an internal compliance system that is established and operated by
the Fair Trade Commission guide in accordance with the Fair Trade Commission to prevent violations in
advance. It is introduced and implemented on the Dec. 13th 2011
8 Key Factors to Fair Trade
Preparation and practice of CP criteria and process
Provision of CP operation criteria and employees' guidance
Willingness and support of CEO for compliance
Demonstration of interest and willingness by the CEO and all
employees to practice voluntary compliance
Official announcement, both internal and external, of strong
determination of the Voluntary Compliance Manager
Appointment of Compliance officer in Charge of the CP
Appointment of a Compliance Manager with practical
responsibility and authority for Compliance Program
Development and Use of a CP Manual
Preparation of a business-specific manual as an enterprise
guidelines for voluntary compliance with fair competition rules
Upload and distribution of an Manual on internal network
accessible by employees anytime
Education Programs
Provide specific training considering the different positions
and departments
Special sessions provided to departments that are highly likely
to violate laws
Increase effectiveness by special Compliance Trainers
Internal Monitoring System
Form a system that prevents and handles unfair acts
Periodic reporting of supervision activities to the CEO and the
board of directors
Sanctions on executives and staff members who breach the law
related to fair trade
Take disciplinary actions on anyone who violates fair trade laws
according to the company policy depending on the importance of the issue.
Effectiveness Evaluation and Improvement Measures
Awarding to departments and individuals with excellent voluntary
compliance
Implement effectiveness evaluation of overall CP operation
through various methods
CP Operation Results
Anti-Corruption Prevention
Anti-Corruption Compliance Guidelines
Anti-Corruption Compliance Pledge Statement
POSCO INTERNATIONAL Anti-Bribery Compliance Training
2025-2026 Modern Slavery and Human Trafficking Prevention Declaration
- POSCO International declares that slavery and human trafficking are strictly
prohibited, and that such acts of human rights violations are never
permitted. The Company will make continuous efforts to respect and protect
human rights in all business activities and will cooperate with all
suppliers and partners to this end.
- POSCO International will actively work to identify and eliminate the risks
of slavery and human trafficking throughout the Company's value chain. We
will also provide education and training to protect human rights so that all
employees can share and practice their understanding and responsibility for
human rights. These efforts will ensure that the Company's business operates
in a sustainable and ethical manner and will play an important role in
fulfilling the Company's social responsibilities.
- As part of the expression of this will, the CEO of POSCO International
announced the following in the company-wide CEO Message in April
2024.
"The Company complies with the global Modern Slavery Act (MSA) in the UK and
is strengthening its management system to ensure that any form of modern
slavery and human rights violations do not exist in the Company's premises
as well as in the supply chain. If we find any related infringements, we
will respond promptly and transparently."
- Additionally, in February 2025, through the POSCO Group Human Rights
Management Declaration, POSCO International expressed its commitment to the
protection of human rights as follows:
“We declare that we will do our utmost to protect and promote the human
rights of not only POSCO Group employees but all stakeholders. (Omitted)
POSCO Group takes a leading role in preventing human rights violations and
remedying victims by considering the following human rights impacts in all
management activities. Furthermore, recognizing that priorities in human
rights impact management may change due to shifts in the business
environment or expansion, we continuously adjust the areas of human rights
impact management through regular human rights due diligence and
consultation with internal and external stakeholders. We prohibit, human
trafficking and child labor, and ensure that all workers have the right to
work voluntarily.”
- In accordance with the Modern Slavery Act 2015 of the UK, POSCO
International publishes 2025-2026 Modern Slavery and Human Trafficking
Prevention Declaration. This Declaration contains the actions and future
plans that we have undertaken to mitigate the risk of human rights
violations related to modern slavery and human trafficking, across our own
or managed premises and supply chain.
ⅢCorporate Structure, Business and
Supply Chain
-
1. Corporate Structure
- POSCO International is an affiliate of POSCO Group, and POSCO
Holdings is the parent company that is the largest shareholder of
POSCO International.
- As of March 2026, POSCO International has a total of 44
subsidiaries, including 4 domestic companies and 40 overseas
companies as consolidated subsidiaries.
-
2. Business Operation
- POSCO International is a member of the POSCO Group, which has
developed into a global steel company based on constant efforts
toward innovation and technological development. The Company
operates in various fields such as steel, energy, and food, and is
rapidly reborn as a global general business company operating in
various business groups beyond the traditional trading company. We
are expanding our new business-linked investments, including the
various areas mentioned above, and working with domestic and global
suppliers. As of March 2026, POSCO International employs a total of
26,936 employees with 1,728 at the headquarters and 25,208 at
overseas operations and has more than 126 corporate/branch offices
and networks in 51 countries.
-
3. Supply Chain
- POSCO International's main industrial ranges in its supply chain
are steel, steel materials (coal, slag, iron ore, etc.) and
secondary battery materials (lithium, nickel, etc.), agricultural
products (rice, wheat, corn, etc.), vegetable oil (palm oil),
biomaterials (bioplastics, synthetic rubber, etc.), automobile parts
(motor core, etc.) and energy (natural gas, LNG, solar power, wind
power, hydrogen, etc.).
- As of March 2026, there are a total of 46 countries with
approximately 1,100 suppliers providing goods and services to POSCO
International.
ⅣRisk of Modern Slavery Practices
- POSCO International's main business is investment, international trade,
and manufacturing, and it operates manufacturing facilities including
natural gas fields in Myanmar, palm oil farms in Indonesia, and motor core
manufacturing facilities in India, Poland and Mexico. Special attention and
protection are needed in our business areas, especially in overseas
manufacturing facilities.
ⅤRelevant Policies and Operational
Guidelines
-
1. Company Regulations, etc. Related to the Obligation to Respect Human Rights
- On February 20, 2025, POSCO Group proclaimed a Human Rights
Management Declaration with the participation of six subsidiaries,
including POSCO International. Based on the Universal Declaration of
Human Rights, the International Bill of Human Rights, the UN Guiding
Principles on Business and Human Rights, the International Labour
Organization Fundamental Conventions, the OECD Guidelines for
Multinational Enterprises, the United Nations Convention on the
Rights of the Child, the United Nations Declaration on the Rights of
Indigenous Peoples, the Declaration on the Right and Responsibility
of Individuals, Groups and Organs of Society to Promote and Protect
Universally Recognized Human Rights and Fundamental Freedoms, and
other international standards that specify the rights of migrant
workers, women, persons with disabilities, etc., we aim to establish
and operate a system for practicing and monitoring human rights
management.
- The Human Rights Management Policy sets forth the Company's
principle of not only not forcing workers to work against their free
will by means of violence, intimidation, confinement, and other
means of unjustly restraining their mental or physical freedom,
including human trafficking, but also prohibiting the estimation of
compensation for non-performance of labor contracts, not restricting
the status of workers by money lending, and prohibiting additional
compulsory contracts incidental to labor contracts. In addition,
POSCO International prohibits child labor in principle, and underage
labor conditions and minimum working age standards comply with
national labor laws and international standards.
- POSCO International has established a human rights management
process to supplement and improve the weak areas in the mid- to
long-term by regularly checking the status of the company's human
rights management based on the OECD Business Due Diligence
Guidelines, and operates a field-oriented human rights management
process that puts the protection of human rights of all members at
home and abroad as the top priority. Along with external
professional organizations, we have developed a human rights due
diligence checklist based on international human rights norms such
as UN companies and human rights implementation guidelines and are
conducting human rights impact assessments centered on major
overseas investment sites.
- To emphasize the importance of human rights across the enterprise,
POSCO International has established rules that respect and comply
with internationally recognized global human rights principles and
standards, including the Modern Slavery Prevention Act, in its Code
of Ethics Practice Guidelines, personnel regulations, and local
employment management guidelines.
-
POSCO International manages long-term work through supply chain
management, which prioritizes observance of statutory working hours,
guarantee of sufficient leave, fair employment and compensation
without gender discrimination, and protection of human rights and
safety in accordance with the International Labor Organization major
conventions and personnel regulations based on domestic labor laws.
We conducted a survey on overseas investment corporations equipped
with manufacturing and production facilities on the exploitation of
child labor, the performance of harmful tasks for the vulnerable,
including female workers, and the hygiene management status of
employees' accommodations. By improving the health and safety
regulations the business is using, we are providing a safe and
vibrant work environment by blocking factors that threaten our
business activities and the health and safety of supply chains.
Through those efforts, POSCO International respects basic human
rights and creates a healthy working environment.
-
2. Regulations or Guidelines for the Prevention of Labor Exploitation at the level of Supply Chain
- POSCO International clearly recognizes that environmental and social
issues arising from partners, including human rights violations, may
affect our sustainability. In order to create a robust industrial
ecosystem, we manage supply chain risks based on the POSCO Group's
Supplier Code of Conduct and support the development of capabilities
and the protection of human rights in the supply chain.
- POSCO International's supplier code of conduct ensures that all
companies dealing with us are committed to sustainability and human
rights protection. The Supplier code of conduct consists of 35 items
in a total of 6 categories related to the basic norms in the fields
of human rights, labor, environment and anti-corruption, as set out
in the UN Global Compact. Recently we revised the basic human rights
respect items of our employees among our suppliers' code of conduct
to comply with modern slavery laws in the United Kingdom.
- POSCO International has established a supply chain policy,
establishing supplier code of conduct on basic matters concerning
labor rights, environment, safety and health, ethics, and management
systems that suppliers and subcontractors who supply products and
services to the Company and its affiliates, joint ventures, etc.
should comply with. In particular, through the Labor Rights section,
we are stating that all suppliers of the Company shall not tolerate
illegal underage labor, human trafficking, forced labor, etc. in
accordance with the UN Guiding Principles On Business and Human
Rights, the Universal Declaration of Human Rights, and the ILO
(International Labor Organization) International Labor Standards,
and shall do their best to respect and protect the human rights,
working hours, and freedom of association and collective bargaining
of all workers, and shall not discriminate against workers on the
grounds of race, nationality, gender, age, academic background,
religion, region, disability, marital status, gender identity, etc.
- The Company links the supplier acknowledgement process for the
Supplier Code of Conduct with supply chain ESG document-based due
diligence to ensure that suppliers are aware of and comply with the
Company's human rights and modern slavery prevention principles,
including the prohibition of forced labor, child labor and human
trafficking. For key suppliers, the Company also assesses the level
of implementation based on responses to the checklist.
- POSCO International recognizes the importance of responsible
minerals as a global corporation and intends to join the
international community's efforts to create responsible procurement
practices for companies, such as cooperation in the policy of
responsible minerals from customers and support for responsible
mineral management of suppliers. In principle, we restrict
transactions with suppliers that have a negative social impact, and
we try to avoid using mining minerals in disputed areas. Based on
the POSCO Responsible Mineral Management Guidelines, a separate
POSCO International Responsible Mineral Management Guidelines
reflecting the characteristics of the industry as a general business
company was established and since then a more effective responsible
mineral management system has been operated.
ⅥHuman Rights Protection Due
Diligence and Risk Management
-
1. Human Rights Impact Assessment
- POSCO International participated in the POSCO Group Human Rights
Management Task Force in 2024 and contributed to the establishment
of a group-wide human rights management system. Based on this, we
are strengthening human rights due diligence to protect the rights
of employees at domestic and overseas business sites, including by
conducting a human rights impact assessment for domestic employees
in 2025 and expanding human rights due diligence across domestic and
overseas business sites in 2026.
-
In particular, in April 2025, we conducted on-site due diligence
on palm plantations located in Indonesia in collaboration with a
third-party human rights due diligence expert organization. The
results of this due diligence and the key areas for improvement were
disclosed to stakeholders through the FY2025 Sustainability
Management Report.
-
In 2026, we plan to conduct a pilot Human Rights Impact Assessment
across seven overseas subsidiaries, including those in Indonesia,
Malaysia, the United States, Singapore and Vietnam. Through
document-based assessments and employee surveys, we will review the
human rights risk management systems of overseas business sites, the
accessibility of grievance mechanisms, the protection of vulnerable
workers, and risk factors related to modern slavery.
-
2. Risk Management at the Supply Chain Level
- Supply Chain Management Process:
POSCO International has established and are operating a company-wide
supply chain management system that reflects the industrial
characteristics of global general business companies in order to
proactively respond to the EU's Corporate Sustainability Due
Diligence Directive (CSDDD) and systematically manage the negative
human rights/environment impacts that may occur in the Company's
entire supply chain.
As stated in the 2022 MSA Declaration, after the merger of POSCO
Energy on January 1, 2023, the Company promoted a task that further
reflected the supply chain analysis results of the energy business
in its supply chain management system. Through this, we are
reorganizing our policies related to the supply chain, our criteria
for classifying the importance of the supply chain, and our
checklists and guidelines for supply chain due diligence, and we are
establishing a unified supply chain management system at the
enterprise level.
In particular, in the checklist for written due diligence on the
supply chain, questions were added to confirm whether regular risk
assessments were conducted and there is any case of modern slavery
practices and violations of laws and regulations related to modern
slavery to identify and review risks related to forced labor,
illegal child labor, or human trafficking in the company's supply
chain.
In 2025, POSCO International leveraged a cloud-based supply chain
ESG management solution to promote practical prevention and
improvement activities regarding negative human rights and
environmental impacts for approximately 1,100 supplier companies.
Based on the results of a pilot document-based due diligence
conducted with 96 suppliers, we enhanced the operational framework
for ESG document-based due diligence for key suppliers. In 2026, 180
suppliers were selected for document-based due diligence out of a
total of 1,125 suppliers, taking into consideration their business
importance and ESG risks. These suppliers account for approximately
90% of the Company's total procurement spending.
- Responsible Mineral Management Process:
POSCO International has established a responsible mineral policy to
ensure that conflict minerals such as 3TGs [Tin, Tantalum, Tungsten,
and Gold], which have served as funds for warlords and
anti-government organizations in African countries such as the
Democratic Republic of the Congo, and minerals such as cobalt, which
pose human rights and environmental issues during the mining process
do not serve as a source of funding for armed conflicts or become
associated with human rights and environmental risks. Through this
policy, the Company affirms its commitment to using only responsibly
sourced minerals that are mined in a manner that respects human
rights and protects the environment. The Company also cooperates
with customers' responsible minerals policies and supports suppliers
in managing responsible minerals..
- Responsible Minerals Management Process of POSCO Group:
In accordance with the POSCO Group's Guidelines for Responsible
Minerals Management, POSCO International has established procedures
to restrict transactions with suppliers that have a negative impact
on the environment and society and prohibit the trade of minerals
mined in conflict zones. Based on the CAHRA (Conflict Affected and
High Risk Area) criteria, CAHRA targets are selected by
investigating relevant countries and territories, including Africa
conflict zones. The Company conducts investigations on the
supplier's management information and whether or not it has a policy
on responsible minerals to identify possible risk of responsible
minerals from the supplier registration stage. We also determine
whether the smelter associated with the supplier is CAHRA and verify
that the company is certified by third-party due diligence and
certification schemes, such as the Responsible Minerals Assurance
Process (RMAP) of the Responsible Minerals Initiatives (RMI). If the
company is judged to be ineligible through this screening process,
it may be excluded from the supplier registration. The Company
obtains consent from registered suppliers to comply with the
Company's Responsible Mineral Policy and confirms the status of
Conflict Mineral Report Template/Cobalt Report Template (CMRT/CRT)
requests and smelter certification.
Furthermore, responsible mineral risk assessments are conducted for
suppliers in transactions, and the results are divided into three
classes: "high-risk suppliers", "suppliers requiring monitoring",
and "general suppliers." In the case of high-risk suppliers, we
request professional due diligence from third-party independent
organizations to conduct risk inspection and improvement activities.
If necessary, we actively support suppliers' improvement activities,
such as providing educational contents for responsible minerals, and
confirm that improvement activities are completed within 120 days of
the notification of the results of the due diligence. If improvement
activities are not completed, the supplier may be removed from the
registration pool.
As of 2026, POSCO International is engaged in businesses involving
critical minerals for secondary batteries, including nickel, cobalt,
lithium and graphite. To the best of the Company's knowledge, we are
not directly engaged in transactions involving 3TGs or cobalt mined
or sourced from conflict-affected or high-risk areas where there is
a heightened risk of modern slavery practices. Should the Company
pursue new transactions involving cobalt, tungsten or other minerals
originating from high-risk areas in the future, it will consult with
the relevant departments prior to commencing such transactions to
review the country of origin, whether the source falls within a
high-risk area, and the need to apply the Responsible Minerals
Management Process.
-
3. Other Due Diligence and Risk Management Measures
- Conducting a Survey on the Labor Environment of Overseas Investment
Corporations: POSCO International is conducting a survey on overseas
investment corporations equipped with manufacturing and production
facilities on the exploitation of child labor, the performance of
harmful tasks for the vulnerable, including female workers, and the
hygiene management status of employees' accommodation.
- International Key Organizations Compliance Legal Due Diligence: In
order to inspect the compliance and legal system of major overseas
business sites, POSCO International has been conducting on-site due
diligence by the Compliance Department of the Legal Office from the
first quarter of 2024. The compliance legal due diligence examines
the violation of local laws by major overseas workplaces, the status
of education required by local laws, and the status of responses
related to corruption risks. In particular, we check the personnel
labor system at each workplace to see if illegal forced labor is
being carried out, and we provide awareness-raising education to
prevent it. In March 2025, compliance training was conducted in
local languages for high-risk organizations in countries such as
Mexico, Indonesia, Vietnam, and South Africa, etc. These activities
included listening to the concerns of local employees, preventing
risks of violations of local mandatory laws, and checking legal
systems, thereby strengthening compliance efforts.
-
Receipt of Compliance Pledges from Third Parties, Monitoring of
Implementation Status, and Provision of Training: POSCO
International conducts Integrity Due Diligence and obtains
compliance pledges from third-party representatives who act on
behalf of the Company or interact with public officials and other
stakeholders in the course of providing services for the Company.
Through these measures, the Company strives to prevent bribery,
money laundering and other corrupt practices by third parties. In
addition, the Company has supported the establishment of its
anti-corruption compliance framework by monitoring the
implementation of third-party management practices at overseas
organizations and providing local compliance training.
- Enhanced Investment Risk Management from ESG Perspective:
The Company specified in the investment management regulations that
the proposal department should consult with the in-house specialized
departments from the initial stage of the investment review on
whether to fulfill the corporate social responsibility to the local
community and reflect it in the investment plan. In the investment
review stage, ESG risk was set as a major investment management
item, the attendance of the in-house ESG department was mandated,
and the Company has also established a process whereby, even after
an investment has been made, the continued viability of the business
may be reassessed if ESG-related issues arise.
ⅦGrievance Handling and Employee
Training
-
1. Grievance Handling System
- One-Voice Process for Response to ESG Issues:
POSCO International has established an ESG issue response process
for questions frequently received from various stakeholders to
promote One-Voice response to issues. Received ESG issues are
reported to management and the board of directors through the ESG
Council after the analysis and status check, and One-Voice responses
are conducted according to the response direction established based
on the discussions.
- Operation of Stakeholder Communication Channels:
POSCO International operates various communication channels for each
stakeholder. (1) In the case of the supply chain, opinions can be
received through the website and e-mail; and (2) In relation to
community members, the local community-level grievance settlement
system is operated, while opinions can also be received through the
website and e-mail.
- Establishment of a New Department to Establish a Corporate Culture
of Respect for People:
In 2023, POSCO International established the Ethics Management
Bureau consisting of five employees in the Righteousness Management
Office, to revitalize the in-house grievance handling channel.
- Guidance and Promotion of the Internal Grievance Settlement
Reporting System:
POSCO International always guides the reporting center through an
ethical campaign held once a month under the theme of ethical
management/respect for people, and has improved accessibility by
attaching QR stickers to work spaces such as office walls and
conference rooms. Regular and class-specific training always
includes relevant content such as applicable regulations and
reporting channels. In addition, to ensure objective and fair
investigations, the Company has established a manual for
investigating violations of respect for people, standardized
investigation procedures, while operating an investigation channel
managed by external experts for handling such violations.
- Preliminary Diagnosis and Active Monitoring of Respect for
People:
POSCO International conducts a monthly survey of all executives and
employees on witnessing/experiencing any unethical conduct or
violations of the respect for people through a mobile work app. In
addition, for domestic and overseas officials and executives, the
Company conducts an annual anonymous ethical level diagnosis survey
among their direct reports.
-
2. Improvement of In-house Culture and Training of Executives and Employees
- Translation of Five Major Compliance and Ethics Codes into 10
Local Languages and Distribution of Educational Videos in Local
Languages:
In 2023, POSCO International translated and distributed the code of
ethics, anti-corruption compliance guidelines, conflict of interest
prevention guidelines, workplace sexual harassment prevention
guidelines, and supplier code of conduct out of the rules of the
Company into 10 languages (English, Myanmar, Chinese, Indonesian,
Vietnamese, Uzbek, Portuguese, Spanish, Turkish, and Ukrainian) in
consideration of the location of major workplaces of the Company and
compliance risks by country so that domestic and foreign executives
and employees can understand major compliance codes. In addition,
ten local-language training videos were produced, in which legal
counsel in each jurisdiction directly explained the five key
compliance and ethics standards in the relevant local language, and
these videos were distributed through the Company's e-learning
platform, helping local executives and employees better understand
and comply with POSCO International's major compliance ethics norms.
The code of ethics includes compliance with the Modern Slavery
Prevention Act.
- English Translation of the Company Rules and Implementation of
English-Language E-learning Courses on the Company Rules:
The Company produces online English videos in which external experts
explain the compliance control regulations, ethical norms, and
compensation guidelines for reporting unethical acts and provides
them to all executives and employees.
- Executive Ethics Pledge and Requiring All Employees to Sign an
Ethics Pledge:
At the beginning of each year, all executives of the Company sign an
Executive Ethics Pledge, committing to the prevention of unethical
conduct, demonstrating ethical leadership by example, and promoting
a strong commitment to ethical practices among their employees.
Also, at the beginning of each year, the Company seeks a pledge of
ethics to all executives and employees at home and abroad to comply
with the Company's code of ethics, to comply with domestic and
foreign anti¬corruption and fair trade laws, to avoid any act that
undermines the respect for people, such as violation of sexual
ethics or harassment, and to prioritize ethics if the Company's
interests and ethics conflict. In 2024, we are extending the ethics
pledge program to include global staff.
- Operation of a Structured Ethics Training Program to Promote Ethical
Awareness among Employees:
POSCO International operates a structured training program designed
to help employees in Korea and overseas internalize compliance
principles and ethical standards in their day-to-day work. At the
beginning of each year, executive-led ethics dialogues are conducted
to foster ethical awareness through a cascading approach, extending
from the CEO to executives, managers and employees. In addition,
enhanced ethics training is provided to employees working in
high-risk departments with elevated compliance risks, while
managers, who play a key role in promoting ethical compliance,
received separate preventive training programs that incorporate
monitoring and counseling. Furthermore, in addition to legally
required training on workplace harassment and sexual harassment
prevention, the Company offers ethics management and ESG training as
mandatory e-learning courses, enabling all employees, regardless of
position or employment status, to participate in a wide range of
ethics training programs. The Company also supports employees in
making ethics-based decisions and taking ethical actions by
publishing and distributing an ethics dilemma casebook and operating
an AI-powered ethics chatbot.
- Procedures for Consultation with the Relevant Departments:
The ESG Strategy Section of the Legal Affairs Office, the Ethics Management
Bureau in Righteousness Management Office and the department responsible for
Sustainability Management, which are departments related to POSCO
International's compliance with the MSA, held several consultations from
2023 to the first half of 2025 to collect MSA compliance measures,
enactments, revisions and implementation histories for related corporate
rules, domestic and overseas human rights impact assessments, supply chain
ESG document-based due diligence activities, matters scheduled for
disclosure in the Sustainability Report, grievance handling mechanisms and
employee training activities. Also, they shared opinions on preparing
measures to comply with the MSA and writing a declaration, and discussed
future human rights protection due diligence and risk management plans.
ⅨEffectiveness Evaluation and Future
Plans
-
1. Effectiveness Evaluation
- Annual Evaluation of the Corporate Ethics Index of POSCO Group
Companies:
In conducting the annual evaluation of the POSCO
Group
companies’ corporate ethics index, the evaluation items include the
operation of ethical norms and systems, surveys on the respect for
people, and measures to prevent recurrence, and the results are
submitted to POSCO for evaluation. In addition, the Company uses
human rights impact assessments, employee human rights awareness
surveys, supply chain ESG document-based due diligence, the status
of implementation of supplier corrective action plans, the operation
status of grievance handling channels, and the completion status of
related training programs as key performance indicators to assess
the effectiveness of its human rights and supply chain risk
management activities. With respect to supply chain ESG
document-based due diligence, the Company reviews suppliers’
responses to checklists, supporting documentation submitted,
identification of high-risk issues, and the submission and
implementation of corrective action plans in order to assess the
level of management of human rights and labor-related risks within
the supply chain.
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2. Future Plan
- POSCO International plans to continuously conduct compliance
management for third parties and assess compliance risks for
overseas organizations. Additionally, the company intends to
strengthen compliance support and oversight for compliance
management across all overseas organizations.
- In the next fiscal year, if there are organizations that need
improvement after conducting an ethics diagnosis of overseas
organizations as before, the relevant organizations and related
departments will be notified of the improvement so that measures can
be taken.
- Regarding the supply chain ESG management system, in 2026, the
Company plans to leverage a cloud-based supply chain ESG management
solution to obtain acknowledgements of the Supplier Code of Conduct,
conduct ESG checklist-based document-based due diligence, review
supporting documentation, and manage corrective action plans for key
suppliers selected based on business importance and ESG risk
assessments. In particular, for areas closely associated with modern
slavery risks, including forced labor, child labor, human
trafficking, working hours, wages, non-discrimination, and
occupational health and safety, the Company plans to identify
high-risk indicators and, where necessary, implement phased
follow-up measures, such as requesting corrective actions, requiring
corrective action plans, and conducting on-site due diligence.
- With respect to human rights impact assessments, the Company plans
to enhance its domestic Human Rights Impact Assessment framework in
2026 and conduct pilot assessments at seven overseas subsidiaries.
Based on the assessment results, the Company will review the human
rights risk management systems of overseas business sites, the
accessibility of grievance mechanisms, the protection of vulnerable
workers, and risk factors related to modern slavery. Where
necessary, the Company will establish improvement initiatives and
follow-up management plans.
- We plan to conduct regular due diligence on trading
corporations/branches and investment corporations. When conducting
on-site due diligence, we plan to use a checklist to inspect and
report on the risk of violating modern slavery regulations by
checking the employment status of trading corporations/branch
offices and the institutional processes of investment corporations.
- We operate external counseling/investigation channels to enhance
the expertise and fairness of ethics counseling/investigation. We
would like to promote ethical counseling for executives and
employees by operating such channels in collaboration with external
professional organizations so that they guarantee professionalism
and confidentiality.
- We will conduct on-site inspections to check compliance matters,
including compliance with modern anti-slavery laws, at major
overseas workplaces, and if we find anything to supplement, such as
compliance education or counseling support, we will actively support
it.
This report was approved by the Board of Directors of POSCO
International and signed by the CEO.
June 26, 2026
POSCO INTERNATIONAL Corporation
CEO Kye-in Lee
