Ethical management
Report Center
Reporting Unethical Behavior
Report any corrupt behaviors of POSCO INTERNATIONAL employees, including accepting bribes and entertainment.
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Abuse of Authority
Report any verbal or physical assault by POSCO INTERNATIONAL employees.
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Bullying & Sexual Harassment
Report any bullying and/or sexual harassment in the workplace.
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Compliance
(Fair Trade/
Subcontracting, etc.)
Report any employee who violates or is likely to violate legal obligations.
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CEO Message on Fair Trade & Anti-Corruption
Dear Esteemed POSCO International Employees,
The business environment surrounding the Company is expected to remain uncertain and challenging this year as well due to internal and external variables such as continued international disputes and global economic recession.
Even in such a crisis, the Company clearly states the following to solidify the corporate culture that prioritizes fair trade, anti-corruption, and management with respect for human dignity.
1. We recognize that the voluntary practice of fair trade is essential to the Company's competitiveness and will practice it in good faith.
The Company has established compliance control standards in accordance with relevant laws and regulations, continued compliance control activities accordingly, and actively worked to establish a fair and free market economic order and create a culture of fair trade. Please be aware that unfair trade is not only illegal but will negatively impact the Company's reputation.
2. We will strengthen assessment to eradicate corruption risks and corruptive practices.
The Company complies with global anti-corruption laws, anti-corruption laws of the countries in which it conducts business, and the Company's Anti-Corruption guidelines. In particular, the Company strictly responds to the four major misconducts - corruption, fraud, conflict of interest, and sexual exploitation - with a zero tolerance policy and immediate reporting system, taking disciplinary actions and holding the managing person in charge accountable. We ask that all executives and employees take the lead in practicing ethics and do their best to create a safe and healthy working environment.
3. We will continue our efforts to prevent forced labor in all our business sites and supply chains.
The Company complies with global Modern Slavery Acts (MSA), including those in the United Kingdom and Australia, and continues to strengthen its controls to ensure that any form of modern slavery and human rights abuses are not only absent from the Company's business sites but also from its supply chains. If the Company discovers a related infringement case, it will respond quickly and transparently.
The Company is legally complying with all regulations, including operating the fair trade compliance program, based on the active participation of all executives and employees. The Company will continue to strengthen our corporate culture of fairness, legality, and respect for human beings by taking strict measures against unfair trade, corruption, and anti-human rights.
We once again urge our executives and employees to strictly adhere to the applicable regulations and guidelines in all their work and under all circumstances.
April 26, 2024

POSCO International Corporation CEO
Lee Gye-In
Preamble of the Code of Ethics
This code of ethics establishes the ethical values and behavioral standards that must be preserved and developed by all employees of POSCO INTERNATIONAL Corporation.

It is our unchanging value to establish a corporate image that can be trusted by all stakeholders with the highly prioritized value criteria of integrity, fairness and honesty.

As a result, POSCO INTERNATIONAL enacted the Code of Ethics in 2003 that must be adhered to by all employees, and in 2014, explicitly incorporated the UN human rights management advocating for the respect of human dignity. This time, POSCO INTERNATIONAL has amended the Code of Ethics with heightened ethical standards in accordance with the intent of management innovation that places the highest value on ethics in management.

This code of ethics consists of the preamble, followed by the principles of ethics that reflect compliance and responsibility of employees regarding the code of ethics, and practical guidelines that set the standard for ethical decision-making.

All employees of POSCO INTERNATIONAL must strictly comply with the principles of ethics and practical guidelines set by this code of ethics in all aspects of business.
This is how we all can achieve continuous and sustainable growth of POSCO INTERNATIONAL. 
Principles of Ethics
ⅠDuty of Compliance with the Code of Ethics
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  • We must comply with relevant rules and regulations in all areas of the world where POSCO INTERNATIONAL is conducting business operations.
  • We must retain our dignity as POSCO INTERNATIONAL employees and make efforts to maintain the company's reputation.
  • We must preserve integrity, fairness and trust throughout all jobs and business relations.
  • We must not become engaged in activities in which there are conflicts of interests between the company and individual.
  • We must not irrationally discriminate against other employees or stakeholders based on race, nationality, gender, disability and religion, and must respect the dignity and diversity of each individual.
  • We must strive to create a safe workplace and protect the environment.
  • We must be devoted to establishing an ethical culture by taking responsibility and practicing ethical conduct.
ⅡRole and Responsibility of Employees
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Employees must understand and practice all aspects of the code of ethics, and comply with domestic and international laws regarding anti-corruption as members of a global company.

Understanding and Complying with the Code of Ethics.
  • We must fully understand and faithfully comply with all aspects of the code of ethics.
  • Regarding situations in which there are conflicts concerning the Code of Ethics, decisions must be made after consulting with the department head or the Righteous Management Office.
  • We must take responsibility for unethical conduct.


Reporting and Consulting Unethical Conduct
  • If one finds out that own behavior or others' behavior conflicts with the Code of Ethics, one must immediately report to and consult with the department head or the Righteous Management Office or use one of the following methods:
    • Website: www.poscointl.com/reportCenter.html
    • Visit the Righteous Management Office
    • If one chooses to remain anonymous, we ask that you provide sufficient detail and factual information to allow POSCO International to effectively follow up on the concerns raised.
  • We must be aware of various methods to report or consult about cases in which there are conflicts over the code of ethics.
ⅢRoles and Responsibilities of Leaders
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Leaders must perform a key role in enhancing the competitiveness of the company by preventing and eradicating unethical conduct through ethical compliance.

  • Decision-making
    • Leaders have the obligation to make decisions with ethics being the top priority whenever the company's benefits conflict with ethics.

  • Managerial Accountability
    • Leaders possess unlimited liability in unethical conduct, and must take supervisory responsibility in case of unethical conduct by his or her subordinates.

  • Job performance
    • Leaders strictly abide by the law, do not pursue private interests, are devoted to creating corporate values, and do not deal with corrupt stakeholders.

  • Elimination of favors and solicitations
    • Leaders aim to eliminate all forms of favors and solicitations and eliminate business influence in relation to outsiders.

  • Respect for humanity
    • Leaders strive to eliminate conduct that impairs respect for fellow humans such as sexual harassment and verbal abuse in the organization.

  • Prevention of conflicts of interest
    • Leaders strive to prevent conflicts of interest with individual stakeholders working for the business partners and to eradicate unfair transactions that involve preferential treatment on the ground of private interests.

  • Practical activities
    • Leaders are devoted to increasing the level of ethical practice to that of world-class levels by fulfilling the foregoing roles and responsibilities.



Leaders must also prevent unethical conduct of members, and take the following measures in case of such conduct.

  • Ethics education and counseling
    • Leaders must provide training and counseling on ethics for relevant staff.
    • Leaders must allow relevant staff to understand the importance of compliance with the Code of Ethics and practice of ethical conduct.

  • Measures to prevent unethical conduct
    • In case of unethical conduct that occurs habitually, leaders must carry out fundamental preventive measures involving identifying the cause and improving the relevant process.
    • Leaders must report to or consult with the Righteous Management Office immediately after receiving a report that a member has violated the Code of Ethics.
ⅣDisciplinary Actions for Violations of the Code of Ethics
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Employees in violation of the Code of Ethics may be imposed with certain disciplinary actions including dismissal according to related regulations. In particular, disciplinary actions must be applied for employees’ unethical conduct such as corruption, conflicts of interest, fraud, and sexual exploitation and abuse as outlined in the UN Guidelines , and the non-tolerance policy must be applied for paying or accepting bribes, embezzlement, fabrication of information, and violation of sexual ethics.

Conduct subject to disciplinary actions
  • If one has violated the code of ethics or demanded others to do so
  • If one has not immediately reported a violation of the code of ethics that he or she is aware of or is skeptical about
  • If one does not cooperate with the investigation of the Righteous Management Office regarding matters that may have violated the code of ethics
  • If one takes retaliatory action against other employees who reported an issue regarding ethical management

Practice Guidelines
ⅠPractice of Ethics and Compliance with Law
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As a global enterprise, we will nurture ethical corporate culture by performing management activities faithful to basic principles and complying with laws and ethics.

Compliance with Anti-Corruption Laws
  • - One should comply with relevant international and local anti-corruption laws and engage in any form of bribery or corruption, including facilitation fees.
  • - One should not engage in any business dealings with a third party in order to facilitate the payment of bribes or kickbacks.
  • - One should not provide entertainment or convenience to a third party, except where in compliance with this Code of Ethics and the company’s policies and procedures.
  • - One should ensure that all transactions are recorded and maintained in accordance with the internal accounting/management system and accurately and in reasonable detail reflect the true nature of all transactions, including no use of assets not reflected in the company’s books and records.

Money and Other Valuables
  • - Money and valuables refer to things that can bring economic benefits such as money (cash, gift certificates, vouchers, etc.), securities, and goods.
  • - By all means, employees must not demand or receive money and valuables from stakeholders. However, this does not include:
    • gifts for promotion or publicity that do not exceed 50,000 KRW; however, up to 100,000 KRW is allowed for agricultural and fishery products and processed goods (including flowers); or
    • souvenirs with the company's logo that do not exceed 50,000 KRW, and souvenirs generally provided by all participants of the events hosted by stakeholders.
  • - Employees must not ask for or receive any gift from an overseas organization (companies, branches, etc.) during their business trip abroad.
  • - If money and other valuables were received unknowingly or involuntarily, such money and valuables should be returned, or if not returnable, should be reported to the compliance department.
  • - If an employee uses the company's knowledge or position for external lecturing and earns income (such as lecturer fees), they must donate 50% of the earnings.

Entertainment
  • - Entertainment means a variety of activities carried out for the purpose of business networking and business meetings including meals, drinks, golf, shows and games.
  • - Employees must not exchange in forms of entertainment with stakeholders that exceed 100,000 KRW per person. If this is required due to the nature of the business, employees must obtain approval from their department head in advance. If they have inevitably participated in a form of entertainment that exceeds 100,000 KRW, they must report to the Righteous Management Office.
    However, with respect to persons subject to the Anti-Graft law, such as public officials, journalists, and school staff, food and beverages not exceeding 30,000 KRW per person may be provided only with proper and legitimate purpose such as business duties and social gatherings, etc. are recognized.
    Regardless of the amount, entertainment at drinking places with hosts/hostesses is prohibited regardless of the amount.

Convenience
  • - Convenience means provision or receipt of benefits such as transportation, accommodation, sight-seeing and support for an event.
  • - Provision or receipt of convenience exceeding customary level whether transportation or accommodation is prohibited, except for the convenience generally provided to all participants in the event.
  • - In the event that entertainment exceeding customary level was received or provided unavoidably, such activity should be reported to the Righteous Management Office.

Congratulatory or Condolatory Money
  • - Employee should not notify his or his co-worker's congratulatory or condolatory event to interested parties. Notification through a third party will be deemed notification by the employee himself/herself.
  • - Information on congratulatory or condolatory event should be provided through the congratulatory/condolatory bulletin board, and use of work e-mail or sending out a written notice (wedding invitation or obituary notice) for such purpose is prohibited. The permitted scope of the relatives for the purpose of notification of congratulatory or condolatory event is limited to the employees or their spouses' grandparents, parents and children.
  • - In principle, employees are encouraged not to spend more than 50,000 KRW, which is a generally accepted amount based on social customs, as expenditure for congratulations and condolences among employees.
  • - In the case of providing congratulatory or condolatory gifts to external stakeholders, it is allowed up to 100,000 KRW, including congratulatory or condolatory wreath. However, congratulatory or condolatory gifts excluding congratulatory or condolatory wreath cannot exceed 50,000 KRW for those who are subject to the Anti-Graft Law.
  • - In no event employees may receive any congratulatory or condolatory money from an interested party. In the event that any congratulatory or condolatory money was received unavoidably, the money should be returned to the provider or forwarded to the Righteous Management Office.
  • - Upon the request of the Righteous Management Office, employees and executives should submit a record relating to the congratulatory or condolatory money received from and returned to the interested party.
  • - One should not receive congratulatory or condolatory wreath from the interested party. In the event that the wreath was received unavoidably, it should not be displayed.
  • - Executives and employees will not throw an extravagant wedding at an expensive venue such as a five star hotel.

Requests/Recommendations
  • - Employees must not make requests/recommendations regarding the following matters through in-house acquaintances or outsiders, and must register on the 'Clean POSCO INTERNATIONAL System' upon receiving requests/recommendations. However, registration is not necessary if such requests/recommendations are immediately refused and thus are withdrawn by those who requested.
    • Request for special favors in equipment/material purchasing and various contracts
    • Request for special favors in connection with the performance of his/her job based on his/her personal connection.
    • Request for preferential treatment and special favors in various personnel affairs such as employment, promotions, rewards and punishment, and change of assignment
    • Request to neglect management and supervision tasks such as inspection and review
  • - Grafts are not allowed in any cases regarding with the duties that are listed by the Anti Graft Law.

Pecuniary Transactions
  • - One should not engage in pecuniary transactions with an interested party such as lending or borrowing of money, providing a guarantee, or leasing of a real estate.
  • - In the event one had to enter into a pecuniary transactions with an interested party unavoidably, it should be reported to the compliance department.
  • - No lending or borrowing of money, offering of guarantee or leasing or renting of properties shall be allowed between members of the Company.
  • - No member of the Company shall use his/her position or job to engage, or cause any other member to engage, in any lending or borrowing of money. Any member found in violation of this article shall be reported immediately to the Righteous Management Office.

Support for Events
  • - One should not receive any support from an interested party, whether money or other valuables, in relation to any event organized by the department or as company extracurricular activities.
  • - Any form of convenience received from an interested party such as transportation, venue or services in relation to such event will be deemed receipt of money or other valuables for the event.
  • - In the event that the interested party's support to an event was received unavoidably, it should be reported to the Righteous Management Department.

Inappropriate Use of Budget Resources
  • - One should not use budget resources (such as meeting expenses and business promotion expenses) for personal purposes.
  • - As a general rule, company expenditure should be paid by a corporate credit card in accordance with the purpose of the budget and the guidelines prescribed by law.
  • - The Company may recover any of the Company’s funds or assets used or spent for a member’s personal gain from that member.

Protection of Information and Assets
  • - One should strictly protect confidential or important information of the company.
  • - One should not fabricate information or disseminate false information.
  • - One should refrain from using company-owned cars, supplies and facilities for purposes not directly related to work.

Compliance with Antitrust Laws
  • - One should comply with relevant international and local antitrust laws and not engage in anti-competitive practices such as collusion with competitors with respect to production, prices, bidding or market segmentation.
  • - One should not demand any form of compensation or make inappropriate request to customers or business partners using one's dominant position.
  • - One should respect the rights and property of others including their intellectual property rights, and should not try to enter into transactions or make profits by infringing upon such rights.
  • - Company information, including information on competitors, should be acquired and used only through legitimate methods.
  • - The Company shall compete in accordance with the relevant laws and regulations as well as local business practices.
Prevention of conflicts of interest
  • - Conflict of interest refers to a case in which private interests with employees of a business partner have an inappropriate effect on the performance of duties by employees of the Company.
  • - One should prevent conflicts of interest by refusing any improper request from executives and employees of a business partner with whom one has private interests.
  • - One should not engage in any contact beyond the scope of his or her duty with executives and employees of a business partner with whom has private interests, and shall report any unintentional contact to the superior or the compliance officer.
  • - One should not attend any meetings of retired/resigned employees that are not approved by the Company.
  • - One should join such meetings of retired/resigned employees only after his/her retirement, and should report to the superior and withdraw from the meetings if enrolled during his/her employment with the Company.
  • - If one has private interests with the executives and employees of an affiliated company, one must comply with the measures, such as reassignment of job duties, as a result of consultation with the superior or the compliance officer.
  • - One should not engage in any unfair transactions for reasons of private interests, including entering into improper private contracts, buying at excessive prices, buying excessive volume from interested parties, and improper disclosure of information.
  • - One should exercise his/her best efforts to prevent conflicts of interest with POSCO INTERNATIONAL Corporation and POSCO Group even after retirement/resignation.
ⅡWork-life balance of employees and executives
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We will pursue personal growth and corporate development by maintaining work and life balance, and create a happy workplace by establishing a corporate culture of mutual respect.

Pursuit of Work Life Balance
  • - We will try to improve the quality of life of the executives and employees by providing benefits helpful for maintaining stable life.
  • - We will support executives and employees to achieve their individual visions, and allow them flexibility in terms of the time, places and methods in performing the work.

Provision of Opportunity for Education and Growth.
  • - We will organize work environment and systems where creativity can be enhanced.
  • - We will support executives' and employee's education and participation in development programs such that they can fully develop their potentials.

Fair Evaluation and Compensation
  • - We will make impartial and systematic evaluation system of the executives and employees based on their individual competency and performance and provide appropriate compensation therefor.

Creating a healthy organizational culture
  • - Executives and employees will work for open corporate culture through open communication.
  • - Executives and employees will remove barriers between departments and pursue cooperative atmosphere.
ⅢCreation of Customer Value and Building Trust
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Recognizing that customers' trust and success is the future for us, we will always respect customers' opinions, understand customers and create values that are helpful for customers' growth.

Realization of Customer Satisfaction
  • - We will perform customer-oriented work where the voice of customers is heard and respected.
  • - We will actively accommodate customer's legitimate demand and reasonable suggestions.

Creation of Customer Value
  • - We will satisfy customer's needs by providing the best products.
  • - Executives and employees will try to understand the domestic and overseas market situation and develop service mind that respects customers' culture and practices.

Securing customer trust
  • - We will pay due attention to the safety and health issue of the customers in our management activities, and not provide any product or service that might threaten customer's safety and health.
  • - We will protect customer information and comply with relevant laws and regulations.
  • - We will provide accurate information to customers on a timely basis.
ⅣDuty of Good Faith and Fair Dealings Toward Investors
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We will maximize investors' values by realizing legitimate profits through transparent decision making and effective management activities.

Pursuit of Increased Shareholder Value
  • - We will make profits through transparent decision making and efficient management, and increase corporate and shareholder value at the same time.

Fair provision of investment information
  • - We will not provide information that might affect the decision making of investors to only certain investors, nor provide partial information.
  • - We will not directly trade stocks or securities nor recommend trading to others using insider information obtained while working for the company.

Transparent Calculation and Provision of Financial Information
  • - We will process all financial information based on accurate transactions records implementing appropriate process and control.
  • - We will prepare financial reports in accordance with generally accepted accounting standards.
  • - We will provide sufficient and accurate information regarding management of the company to investors so that investors may freely make investment decisions at its own responsibility.
ⅤBuilding Win-Win Relations with Business Partners
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We will establish fair trade system based on mutual trust and build a corporate eco-system where interested parties co-exist and grow together.

Building Mutual Trust
  • - We will pursue fair dealings with our business partners on equal footing and based on mutual respect.
  • - We will strictly protect information received from transactions with business partners in accordance with the terms of the relevant contract and the relevant laws.
  • - We will support business partners to comply with anti-competition related laws and regulations.

Pursuing Mutual Growth with Business Partners
  • - We will pursue mutual benefits by sharing fruitful outcome with business partners.
  • - We will cooperate and communicate openly with business partners such that business partners may provide high quality products and services.
  • - We will provide fair opportunities and reasonable transaction terms to business partners so that they could grow as our long term business partner.

Support for Continuing Development of Business Partners
  • - We will endeavor to build a stable supply chain by providing technical and financial supports to business partners.
  • - We will endeavor to expand the potential pool of business partners that can grow with us in harmonious growth of overall corporate eco-system.
ⅥContribution to the Country and Society
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We will contribute to the growth of the country and society by fulfilling our responsibilities and duties as a global corporate citizen.

Roles and Attitude as a Corporate Citizen
  • - We will respect the laws and the regulations of the local laws and regulations as well as local culture and tradition, and endeavor for mutual development with the country and society.
  • - The Company shall not engage in any act that may harm the national economy or cause disharmony among the public, including, but not limited to, real estate speculation.
  • - We will encourage participation of and endeavor to communicate with interested parties in performing management activities that may affect country and society.
  • - We will encourage business partners to participate in activities for the development of the country and the society.

Contribution to the Development of the Country and the Society
  • - The Company shall pursue continuous innovation and keep challenging itself to contribute to the growth of national exports and trade surplus. It shall strive to create new value for the country and society through the development of resources overseas.
  • - We will discharge our obligations in the community by creating and maintaining stable jobs and paying taxes in time.
  • - We will actively participate in social service activities, such as volunteer works and disaster relief work, and initiate non-profit activities in various fields including culture, arts, sports and education.
  • - We will provide support for residents' effort to improve quality of their lives and pursuit of happy life.

No involvement in politics
  • - The Company shall not get involved in politics and ensure that no political activity takes place within its workplaces. The Company shall, however, respect its members’ rights to vote.
  • - The Company shall, whether directly or indirectly, give or offer to give any illegal donation to, or bear any expenses for, any candidate for a public post or any political party.
  • - Members of the Company may express their political stance or make contributions to candidates or parties of their own choosing only as individuals. No member shall engage in any act that can be deemed as a stance or contribution on behalf of the Company.
ⅦProtection of Environment and Preservation of Ecosystem
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We will establish an environmental management system, strengthen our ability to deal with environmental risks and implement environment-friendly management through open communication.

Implementation of Environmental Management System
  • - We will try to minimize impacts of business activities on environment.
  • - We will jointly carry out environmental protection activities with various interested parties.

Complying with Environmental Laws and Improvement on Environmental Impacts
  • - We will endeavor to comply with environmental laws and to improve impacts on the environment in the overall process of developing, producing and using products.
  • - We will minimize discharge of pollutants by introducing environment-friendly manufacturing process and applying technologies optimized for prevention of pollution.

Dealing with Climate Changes
  • - We will endeavor to reduce consumption of fossil fuels or materials, and to minimize discharge of greenhouse gas by improving energy efficiency.
  • - We will strengthen competitiveness through the development of low-carbon innovative technologies

Protection of Environment and Ecosystem
  • - We will endeavor to restore the eco-system and preserve biological diversity through effective use of natural resources and by-products.
ⅧProtection of and Respect for Human Rights
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We will respect human rights, support international standards for human rights and strengthen dignity of all interested parties by improving freedom, safety and quality of life.

Respect for and Compliance with Human Rights-related International Standards
  • - We respect and endorse internationally-recognized standards on human rights, such as the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN Global Compact, and the OECD Guidelines for Multinational Enterprises.
  • - We also comply with the Modern Slavery Act and other relevant laws and regulations to prevent slavery, forced labor and human trafficking from ever occurring in the operations we own or control and across our supply chain.
  • - We will establish clear policy and system for protection of human rights and endeavor not to violate human rights in our management activities.
  • - We will comply with internationally recognized human rights standards and regulations, protect our employees' human rights and treat them fairly.

Due diligence in Relation to Human Rights
  • - We may, at our discretion, conduct due diligence on management activities that might violate human rights or cause complaints.
  • - We will endeavor to find reasonable resolutions if, upon conclusion of the human rights due diligence, we believe our management activities have violated human rights or caused complaints.
  • - We will communicate with the relevant interested parties regarding human rights related activities and results thereof.

Protection of Executives and Employees
  • - We will not engage in verbal, physical or demonstrative acts that may offend others or infringes other's human rights such as sexual harassment.
  • - We will respect privacy of executives and employees, will not slander or defame others, and will protect personal information.
  • - We will not compel works through mental or physical coercion.
  • - We will comply with local labor laws and international standards with respect to the age and labor conditions of minors.
  • - We will strictly comply with safety regulations, and will take appropriate actions upon discovery of risk factors.

Respect and Equality
  • - We will not discriminate or harass for reasons of race, nationality, gender, age, educational background, religion, regional origin, disability, marital status, and sexual orientation.
  • - We will provide equal employment opportunity to those who possess necessary qualification and capability.
  • - We will maintain work environment that respects cultural diversity.

Ensuring legal and humane conditions of employment
  • - We will address human rights issues raised by employees promptly using the Company's grievance handling system.
  • - We will offer adequate employment terms such as guaranteeing proper working hours to enable the employees to maintain life with dignity.

Efforts to Respect Community Human Rights
  • - We will endeavor to listen to the opinions of the community and resolve issues of violation of human rights caused by our management activities in the community.
Ⅸ Management and Operation of Ethical Standards
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Compliance with Ethical Standards
  • - The Code of Ethics shall be used as the standard for behavior and value judgment and shall be observed.
  • - The Righteous Management Office shall be responsible for administering the Code of Ethics.
  • - Separate standards may be adopted for efficient administration of the Code of Ethics, as necessary.

Responsibilities of Executives and Department Heads
  • - Executives and department heads must provide training and counseling sessions from time to time so that their subordinates would have sufficient understand of this Code of Ethics.
  • - Executives and department heads must take appropriate measures to prevent their subordinates from violating this Code of Ethics.

Duty to report and confidentiality
  • - If one becomes aware of any violation of the Code of Ethics, one must report it to the Righteous Management Department in the fastest and most convenient manner possible.
  • - Executives and department heads must report to the Righteous Management Office as soon as they receive a report that an employee has violated the Code of Ethics.
  • - Righteous Management Office may verify the facts of the reported case if necessary, and the related executives and employees must actively cooperate therewith.
  • - Executives and employees should never treat the whistleblower in a disadvantageous manner or divulge his or her identity. Here, the term “whistleblower” shall refer to employees of the Company and any of the Company’s third parties including but not limited to suppliers, contractors, vendors, service providers, and consultants who disclose or report in good faith actual or potential ethical misconduct in the workplace or business.
  • - In the event of any disadvantageous treatment to the whistleblower, etc., appropriate measures shall be taken to accommodate such whistleblower’s needs, such as reassignment of his/her job.
  • - Executives and/or employees must keep confidential any whistleblowing/report they become aware of, irrespective of how they came to such awareness, and disciplinary actions may be imposed for disclosure.
  • - The operating standards for compensation for reporting unethical conduct, such as the acceptance of money or goods from stakeholders, are established separately (Guidelines for Compensation for Reporting Unethical Conduct).

Rewards and Penalties
  • - The Company may grant rewards or appropriate compensation in accordance with the relevant policies to executives and employees who have contributed in furtherance of the purposes of the Code of Ethics.
  • - The Company will strictly reprimand employees who have violated the Code of Ethics in accordance with the relevant policies.
  • - The Righteous Management Office, once it becomes aware of any violation of the Code of Ethics through reporting or notification, may propose disciplinary actions against the violator and/or other necessary measures to the HR committee.
  • - The Company may restrict access to and transactions with the Company by employees who have left the Company due to their violation of the Code of Ethics.

Guidelines for Compliance with International Anti-Corruption Law
  • - The Company shall establish and implement the ‘Guideline for Compliance of the Anti-Corruption Laws’ for the purpose of the Company compliance with all applicable anti-corruption laws, the detailed standards of which shall be determined separately.

Interpretation
  • - Any act in violation of this Code of Ethics conducted by an employee’s family, relatives, acquaintances, etc. under the name of such employee shall be deemed an act by the employee.
  • - For any matter not expressly provided in the Code of Ethics or in case of any conflict over interpretation thereof, the interpretation by the Righteous Management Office shall be followed.

Amendment
  • - The Righteous Management Office may amend the Code of Ethics if necessary. However, matters deemed material by the Righteous Management Office shall be amended only with the approval of the Representative Director.

Implementation
  • These provisions shall enter into force on January 25, 2016.
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  • These provisions shall enter into force on September 28, 2016.
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  • These provisions shall enter into force on January 9, 2018.
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  • These provisions shall enter into force on March 6, 2018.
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  • These provisions shall enter into force on October 26, 2018.
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  • These provisions shall enter into force on September 15, 2019.
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  • These provisions shall enter into force on July 3, 2020.
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  • These provisions shall enter into force on June 4, 2021.
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Ethical Practices
Purpose/Operation Process
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Purpose of the Clean POSCO INTERNATIONAL System
To create a corporate culture in which solicitation is impossible by recording and managing all recommendations and solicitations.

  • Preventive Measures Against Unethical Behavior
    • Employees who receive solicitations will have the justification to refuse said solicitation on the grounds of the report, and there will be a preventive effect on people making solicitations in the future due to concern for leaving a record of such actions.
  • Practicing the Spirit of Informing
    • Creates an atmosphere of sincerity and transparency by having company executives and employees conscientiously and voluntarily report any solicitations they may receive.
    • The fact that they have reported the solicitation is deemed as being voluntary with the person reporting the action being exempt from any liability for problems and/or responsibilities to protect good employees.


Operation Process of the Clean POSCO INTERNATIONAL System

  • Informant
    • All executives and employees involved in all phases of recommendations and solicitations, including the recipient of said recommendation or solicitation, the person who was notified of the news, and staff.
  • How to Report
    • Any executive or employee who has received recommendations or solicitations must register the case as is without any omissions or adjustments to the story providing information based on the five Ws and one H.
  • When to Report
    • The informant must report the case on the system within 24 hours following any such recommendation or solicitation.
      However, the deadline may be delayed under special circumstances (e.g. meetings or business trips).
  • Recommendation/Solicitation Registration Process
    STEP. 1
    After receiving a recommendation / solicitation, employees voluntarily register the solicitor and details in the company's internal system.
    STEP. 2
    The Righteous Management Office receives the registration and verifies the details.
    STEP. 3
    After verifying the details, relevant departments such as HR Support and the respective sales department are notified.
    STEP. 4
    If necessary, the Righteous Management Office will conduct detailed investigation, and take appropriate action in case of issues arising.
Detailed Standards
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Detailed Standards of the Clean POSCO INTERNATIONAL System

  • Definition of Solicitation
    • Solicitation refers to all expressions of intention by the solicitor, including requests that may affect the work and decisions of Company executives or employees for the purpose of his/her or other people’s gains.
  • Standards for Determining Fairness That Affects the Work or Decision Making
    • Acts that create a stake for an employee when he/she accepts or refuses solicitations.
    • Acts that put an employee under psychological pressure when he/she handles fair work.
  • Scope of Matters Subject to Recommendation/Solicitation Report
    • As the Clean POSCO INTERNATIONAL System was developed to prevent misconduct due to solicitation, we have expanded the scope of solicitation beyond that as specified by law as an expression of our willingness to prevent anything that could undermine fairness.
    • When it is unclear whether something is deemed as solicitation or as a normal business activity, in principle, such cases must be reported 100% on the system without making a decision on whether the case is in fact solicitation or not.
    • Any executive or employee who does not report the case even if he/she was aware that it is a recommendation/solicitation may face severe sanctions by the HR.
      Actions that Must Be Recorded as Recommendations/Solicitations
      1.Any request for preferential treatment regarding equipment/material purchase, and various contracts.
      2.Any request for preferential treatment in various HR issues, such as employment, promotion, rewards, punishments, and new appointments.
      3.Any request for preferential treatment, such as excessive convenience/preferential treatment beyond normal procedures.
      4.Any request to neglect management/supervision tasks such as inspections.
      Actions that do not need to be recorded as recommendations or solicitations
      1.In a case where the request is withdrawn immediately by expressing the intention of refusal at the time of the request.
      2.Request for collaboration made via official documents.
      3.Normal work instructions from the superior in the organization. * Make a report if it is determined that the instructions violate the Company policy.
      4.Simple confirmation of facts, inquiries, complaints, etc.
      5.Request for cooperation to carry out a task of related organizations or departments.
  • Processing Matters Subject to Recommendation/Solicitation Report
    • Results of a recommendation/solicitation must be managed separately by relevant departments, such as HR and sales, and penalties may be imposed on relevant employees and/or companies.
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Reporting Unethical Behavior
Actions subject to reporting
  • The act of receiving money and valuables from stakeholders (including family members and relatives).
  • The act of shifting the cost of entertainment and meals higher than the usual level onto stakeholders.
  • The act of joining any golf meetings or using membership paid by stakeholders (except for official events).
  • The act of receiving hospitality paid by stakeholders, such as transportation and accommodation and accepting bribery.
  • The act of borrowing money from stakeholders and requesting loan guarantees.
  • The act of requesting preferential treatment and special favors to stakeholders in various personnel affairs.
  • The act of informing stakeholders about congratulatory or condolatory events and receiving any congratulatory or condolatory money from them.
  • The act of engaging in unfair business practices, such as bid rigging for concluding any contract with POSCO.
  • Any other violations of the Code of Ethics.
Consult or Report Us Now
Protection of the identity of informants and those who cooperate
Provision of compensation to informants
Guideline for Compensation for Reportingdown_icon
To keep an informant’s identity confidential during the compensation payment process, the head of the audit function inside the Legal Affairs Office receives the compensation and delivers it to the informant in a way that ensures confidentiality and he or she wants.
Prohibition of disclosing and tracking down informants and those who cooperate
  • Prohibition of disclosing the identity of informants and those who cooperate
    Any executives and employees who become aware of the identity of informants and those who cooperate, whether on duty or by accident, are prohibited from disclosing their identities.
  • Prohibition of tracking down informants and those who cooperate
    The accused person, his/her department and other relevant departments are strictly prohibited from carrying out any activities that may disclose the identity of informants and those who cooperate, such as making inquiries to the Legal Affairs Office and engaging in investigation activities to find out their identity.
  • Prohibition of identity disclosure by audit personnel
    It is prohibited to disclose or imply the identity of informants and those who cooperate without their consent.
  • Punishment in case of violation
Prohibition of unfair treatment of informants and those who cooperate
  • Investigation of identity disclosure
    When the identity of an informant and those who cooperate is disclosed, it shall be reported to the Legal Affairs Office.
    The Legal Affairs Office launches its investigation into how their identity was disclosed and punishes responsible persons.
  • Prohibition of unfair treatment
    Any unfair treatment of informants and those who cooperate is prohibited, and punishment for violation shall be stipulated in relevant documents.
How to report
Category Description
Where to report Legal Affairs Office
How to report Informants can choose the most convenient way among the website, mail, phone, fax, physical visit and others.
Instruction Specify the personal information of the informant himself/herself and the accused person as well as the details of the violation according to the 5W1H method with relevant evidence attached.
However, in the case of a matter of urgency (e.g. unethical behavior is underway at the moment of reporting), it can be reported without evidence.
Office in charge Cyber reporting
Go to the company website (www.poscointl.com) and click “Report Center > Consult and Report(Click)“

Phone/fax/physical visit (Legal Affairs Office)
Telephone: 82-2-759-2194 / Fax: +82-2-2076-2825

Mail
Compliance and Fair Trade Section, Legal Affairs Office, POSCO INTERNATIONAL, 165, Convensia-daero, Yeonsu-gu, Incheon, 21998, Republic of Korea
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Abuse of Authority
신고대상 행위
  • All unfair trade practices, such as forced purchase, price adjustment and management interference using a dominant position.
  • Verbal abuse, assault, insult, physical abuse, humiliation, unfair work instructions, etc. using a superior position.
  • All other unfair and inhumane behaviors.
Consult or Report Us Now
Protection of the identity of informants and those who cooperate
Provision of compensation to informants
To keep an informant’s identity confidential during the compensation payment process, the head of the audit function inside the Legal Affairs Office receives the compensation and delivers it to the informant in a way that ensures confidentiality and he or she wants.
Prohibition of disclosing and tracking down informants and those who cooperate
  • Prohibition of disclosing the identity of informants and those who cooperate
    Any executives and employees who become aware of the identity of informants and those who cooperate, whether on duty or by accident, are prohibited from disclosing their identities.
  • Prohibition of tracking down informants and those who cooperate
    The accused person, his/her department and other relevant departments are strictly prohibited from carrying out any activities that may disclose the identity of informants and those who cooperate, such as making inquiries to the Legal Affairs Office and engaging in investigation activities to find out their identity.
  • Prohibition of identity disclosure by audit personnel
    It is prohibited to disclose or imply the identity of informants and those who cooperate without their consent.
  • Punishment in case of violationspan>
Prohibition of unfair treatment of informants and those who cooperate
  • Investigation of identity disclosure
    When the identity of an informant and those who cooperate is disclosed, it shall be reported to the Legal Affairs Office.
    The Legal Affairs Office launches its investigation into how their identity was disclosed and punishes responsible persons.
  • Prohibition of unfair treatment
    Any unfair treatment of informants and those who cooperate is prohibited, and punishment for violation shall be stipulated in relevant documents.
How to report
Category Description
Where to report Legal Affairs Office
How to report Informants can choose the most convenient way among the website, mail, phone, fax, physical visit and others.
Instruction Specify the personal information of the informant himself/herself and the accused person as well as the details of the violation according to the 5W1H method with relevant evidence attached.
However, in the case of a matter of urgency (e.g. unethical behavior is underway at the moment of reporting), it can be reported without evidence.
Office in charge Cyber reporting
Go to the company website (www.poscointl.com) and click “Report Center > Consult and Report(Click)“

Phone/fax/physical visit (Legal Affairs Office)
Telephone: 82-2-759-2194 / Fax: +82-2-2076-2825 Mail
Compliance and Fair Trade Section, POSCO INTERNATIONAL, 165, Convensia-daero, Yeonsu-gu, Incheon, 21998, Republic of Korea
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Bullying & Sexual Harassment
Actions subject to reporting
  • Any actions in the workplace that attack an employee’s personality and dignity. Actions that hurt other employees physically or mentally, or degrade the work environment by taking advantage of one’s superior position.
  • Actions that cause the other person to be sexually humiliated or offended by sexual comments or requests for sexual favors in relation to work by taking advantage of one’s superior position.
  • Putting someone at a disadvantage at work for not accepting sexual comments or sexual favors.
Consult or Report Us Now
Protection of the identity of informants and those who cooperate
Provision of compensation to informants
To keep an informant’s identity confidential during the compensation payment process, the head of the audit function inside the Legal Affairs Office receives the compensation and delivers it to the informant in a way that ensures confidentiality and he or she wants.
Prohibition of disclosing and tracking down informants and those who cooperate
  • Prohibition of disclosing the identity of informants and those who cooperate
    Any executives and employees who become aware of the identity of informants and those who cooperate, whether on duty or by accident, are prohibited from disclosing their identities.
  • Prohibition of tracking down informants and those who cooperate
    The accused person, his/her department and other relevant departments are strictly prohibited from carrying out any activities that may disclose the identity of informants and those who cooperate, such as making inquiries to the Legal Affairs Office and engaging in investigation activities to find out their identity.
  • Prohibition of identity disclosure by audit personnel
    It is prohibited to disclose or imply the identity of informants and those who cooperate without their consent.
  • Punishment in case of violation
Prohibition of unfair treatment of informants and those who cooperate
  • Investigation of identity disclosure
    When the identity of an informant and those who cooperate is disclosed, it shall be reported to the Legal Affairs Office.
    The Legal Affairs Office launches its investigation into how their identity was disclosed and punishes responsible persons.
  • Prohibition of unfair treatment
    Any unfair treatment of informants and those who cooperate is prohibited, and punishment for violation shall be stipulated in relevant documents.
How to report
Category Description
Where to report Legal Affairs Office
How to report Informants can choose the most convenient way among the website, mail, phone, fax, physical visit and others.
Instruction Specify the personal information of the informant himself/herself and the accused person as well as the details of the violation according to the 5W1H method with relevant evidence attached.
However, in the case of a matter of urgency (e.g. unethical behavior is underway at the moment of reporting), it can be reported without evidence.
Office in charge Cyber reporting
Go to the company website (www.poscointl.com) and click “Report Center > Consult and Report(Click)“

Phone/fax/physical visit (Legal Affairs Office)
Telephone: 82-2-759-2194 / Fax: +82-2-2076-2825

Mail
Compliance and Fair Trade Section, POSCO INTERNATIONAL, 165, Convensia-daero, Yeonsu-gu, Incheon, 21998, Republic of Korea
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Compliance
(Fair Trade/Subcontracting, etc.)
Actions subject to reporting
  • In case of a violation or potential violation of executives' and employees' compliance obligations.
  • Unfair collaborative practices, such as bid rigging between competitors, to conclude a deal.
  • Unfairly refusing a transaction or treating transaction partners differently.
  • Engaging in unfair trading practices by exploiting one's position.
  • Supporting related parties or other companies by transacting under unfair and significantly advantageous terms.
  • Transactions such as forced purchases, payment adjustments, and management interference through dominant positions.
  • Transactions such as cancellation of consignment, unfair returns, unfair special contracts, requests for technical data, etc., utilizing a dominant position.
  • Other actions that may undermine fair trade or violate subcontracting laws.
Consult or Report Us Now
Protection of the identity of informants and those who cooperate
Provision of compensation to informants
To keep an informant’s identity confidential during the compensation payment process, the head of the audit function inside the Legal Affairs Office receives the compensation and delivers it to the informant in a way that ensures confidentiality and he or she wants.
Prohibition of disclosing and tracking down informants and those who cooperate
  • Prohibition of disclosing the identity of informants and those who cooperate
    Any executives and employees who become aware of the identity of informants and those who cooperate, whether on duty or by accident, are prohibited from disclosing their identities.
  • Prohibition of tracking down informants and those who cooperate
    The accused person, his/her department and other relevant departments are strictly prohibited from carrying out any activities that may disclose the identity of informants and those who cooperate, such as making inquiries to the Legal Affairs Office and engaging in investigation activities to find out their identity.
  • Prohibition of identity disclosure by audit personnel
    It is prohibited to disclose or imply the identity of informants and those who cooperate without their consent.
  • Punishment in case of violation
Prohibition of unfair treatment of informants and those who cooperate
  • Investigation of identity disclosure
    When the identity of an informant and those who cooperate is disclosed, it shall be reported to the Legal Affairs Office.
    The Legal Affairs Office launches its investigation into how their identity was disclosed and punishes responsible persons.
  • Prohibition of unfair treatment
    Any unfair treatment of informants and those who cooperate is prohibited, and punishment for violation shall be stipulated in relevant documents.
How to report
Category Description
Where to report Legal Affairs Office
How to report Informants can choose the most convenient way among the website, mail, phone, fax, physical visit and others.
Instruction Specify the personal information of the informant himself/herself and the accused person as well as the details of the violation according to the 5W1H method with relevant evidence attached.
However, in the case of a matter of urgency (e.g. unethical behavior is underway at the moment of reporting), it can be reported without evidence.
Office in charge Cyber reporting
Go to the company website (www.poscointl.com) and click “Report Center > Consult and Report(Click)“

Phone/fax/physical visit (Legal Affairs Office)
Telephone: 82-2-759-2194 / Fax: +82-2-2076-2825

Mail
Compliance and Fair Trade Section, POSCO INTERNATIONAL, 165, Convensia-daero, Yeonsu-gu, Incheon, 21998, Republic of Korea