SAMBOO METAL

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

KOR

ENG

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

Ethics
Management

Samboo Metal Co., Ltd. pursues sustainable development
through eco-friendliness, social responsibility, and transparent management.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

HOME

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

Ethics

We fulfill our social responsibilities and duties as a member of the local community and aim to be an ethical company based on the spirit of compliance and ethical awareness.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

Ethics Charter

Ethical Management Guidelines

Fair Trade Compliance Program

Public Interest Reporting System

Ethics Charter

01. We do our best in our work with honesty and sincerity, and aim to be a reasonable and transparent ethical company based on a strong spirit of law compliance and a high level of ethical awareness.

02. We place customer satisfaction as our top priority and realize customer value creation and impressive management.

03. We fulfill our social responsibilities and obligations as members of the local community, and as partners in creating new value through communication with stakeholders, we pursue continuous common prosperity based on mutual trust and respect.

04. We create equal and fair opportunities for self-realization and a safe and healthy working environment based on human relations and labor-management cooperation that respect and consider the human rights of each Lim Ji-won.

05. We respect the culture and customs of all regions and countries where we conduct business activities, and create a culture of fair competition and fair trade based on mutual respect.

06. We value autonomy, responsibility, creativity and challenging spirit, cultivate humanity and morality, and protect the honor and dignity of Samboo Metal people by observing etiquette and etiquette.

Ethics and Compliance Management Operation Guidelines

Article 1 (Purpose)

This guideline specifies the behavioral principles and value judgment standards of executives and employees stipulated in the ethics charter of Samboo Metal Co., Ltd. and stipulates matters necessary to improve the ethical and law-abiding management of Samboo Metal Co., Ltd.
The purpose of this guideline is to effectively manage ethical risks that may arise through the prevention, identification and control of ethical risk factors, and to create a transparent and ethical management culture by complying with laws and regulations related to ethics and compliance management.

Article 2 (Basic Principles)

When carrying out the company's business, executives and employees must be familiar with and comply with the company's internal regulations, including the ethics charter, executive and employee code of conduct, executive and employee conduct guidelines, fair trade compliance operation guidelines, and these guidelines.

Article 3 (Scope of Application)

These guidelines apply to all executives and employees of Samboo Metal Co., Ltd.
In handling business related to ethics and compliance management, these guidelines shall be followed, except as specifically stipulated in relevant laws and regulations.
Details necessary for operating ethics and compliance management and complying with ethics and compliance laws can be separately determined.

Article 4 (Definition)

The definitions of terms used in this guideline are as follows.

“Ethical compliance management” refers to considering ethics as the top priority in the management and corporate activities of Samboo Metal Co., Ltd., setting the standard for all business activities based on the code of ethics, and performing transparent, fair, and reasonable work.
“Ethical risk” refers to a situation that is expected to result in significant financial or non-financial losses due to violation of ethical compliance management.
“Ethical risk factors” refer to factors that can create ethical risks, such as hindering the achievement of the purpose of ethical compliance management.

Article 5 (Will to implement)

The company must achieve a company trusted by customers by establishing a sustainable ethical management culture.
The company must actively strive to spread a fair culture through fair and transparent work processes.
Executives and employees must express their commitment to ethics and compliance management internally and externally, strive to ensure that ethics and compliance management is effectively operated, and fulfill their practical responsibilities in this regard.

Article 6 (Ethics and Compliance Committee)

The company must achieve a company trusted by customers by establishing a sustainable ethical management culture.
The company must actively strive to spread a fair culture through fair and transparent work processes.
Executives and employees must express their commitment to ethics and compliance management internally and externally, strive to ensure that ethics and compliance management is effectively operated, and fulfill their practical responsibilities in this regard.

Article 7 (Definition)

When determining core values and management policies, a company must consider ethics and compliance management as a priority value.
The company must establish and implement its ethics and compliance management policy by considering the following matters.

Person responsible for discovering, identifying, controlling, improving ethical risks, etc.
Matters related to monitoring and improvement of ethics and compliance management
Matters regarding sanctions and incentives related to ethics and compliance management
Other matters related to efficient operation of ethics and compliance management

The head of each department may implement the following matters in relation to ethics and compliance management.

Establishment of a comprehensive plan for promoting ethics and compliance management that reflects the characteristics of each department
Check your own performance against the plan and improve weak areas
Present opinions on improving the ethics and compliance management system to the Ethics and Compliance Management Committee

The heads of each department must actively cooperate in implementing internal and external policies related to ethics and compliance management.

Article 8 (Internal and External Communication)

The company may disclose ethics and compliance management information internally and externally in accordance with relevant laws and regulations.
The company seeks to establish and expand channels for communication with stakeholders by actively collecting and reflecting internal and external opinions related to ethics and compliance management. You must make an effort.

Article 9 (Ethical Risk Prevention)

The company must strive to change the awareness and increase understanding of executives and employees to spread ethics and compliance management, and may conduct the following training and awareness surveys.

Ethics and compliance management training for executives and employees
Preventative training for executives and departments with high risk of ethical risk
Ethics and compliance training and consulting for partner companies and stakeholders
Perception survey related to ethics and compliance management, human rights management, etc.

Article 10 (Identification of ethical risks)

When performing work, executives and employees must prevent ethical risks by checking compliance with relevant laws and regulations and ethical risk factors in advance.
The head of each department determines ethical risks by taking into account the characteristics of each department's work and organization, instances of ethical risks, conflict of interest situations, and matters pointed out by external organizations. Must be identified.

Article 11 (Ethical Risk Control)

When requested by the Ethics and Compliance Committee, the head of each department must submit identified ethical risks and preventative measures.
The Ethics and Compliance Committee identifies the importance of ethical risks submitted by the heads of each department and manages them comprehensively.
If it is determined that a residual ethical risk exists even though ethical risk prevention measures have been implemented, the Ethics and Compliance Committee will provide additional Measures can be requested.

Article 12 (Monitoring and Improvement)

The Ethics and Compliance Committee must identify and improve weak areas through periodic monitoring of matters related to ethics and compliance management.
The Ethics and Compliance Committee may request improvement from the head of each department according to the monitoring results, and the head of each department must actively cooperate with the above requests. do.

Fair Trade Compliance Program

1. Basic principles

All executives and employees must comply with laws and regulations related to fair trade and all company regulations, and actively participate and cooperate in in-house ethics and compliance management operations and activities. do.
Executives and employees may violate, or have doubts about, violations of fair trade-related laws or company regulations while performing their duties. In this case, you must go through the process of consulting with the ethics and compliance management department in advance through reports and inquiries.
If executives and employees become aware of violations or potential violations of fair trade laws by the company, themselves, or other executives and employees in relation to company business, they must immediately do so. The ethics and compliance management department must be notified.
The company must not give instructions that violate relevant laws and regulations, and executives and employees must not give instructions that violate laws and regulations. You must refuse, and if you are continuously forced to follow the above instructions, you must immediately report this to the ethics and compliance management department.
The heads of each department must supervise the compliance of their employees and take appropriate measures to ensure that they do not violate their compliance obligations.

2. Practice voluntary compliance with the Fair Trade Act

Guidelines for conduct in the area of unfair communal conduct

Do not request, provide, or exchange with competitors trade terms, including price, or data necessary to determine them
If there is an inquiry or request about price or transaction terms from a competitor, state that it is impossible to provide it and keep a record of it.
If there is a request or recommendation for collusion from the other party or a meeting, exchange meeting, etc., clearly reject it, and in the future, the other party or Refrain from contact such as gatherings
Information related to competitors must be obtained legally, and the acquisition process and source must be clearly recorded
If you wish to participate in a bid, information related to the selection of the company expected to receive the order regarding performance, target, product, etc. must be submitted to other companies expected to participate in the bid. Do not exchange with business
Do not adjust the order quantity, ratio, etc. for bidding jointly with other business operators
Exchange of information on the price level or trend of the product or service subject to bidding between businesses intending to participate in the bidding; No collection or provision of information or promotion of information exchange between companies in the same industry
Do not prepare or deliver bid-related documents for other businesses participating in the same bid
In relation to a project for which our company has been successful, the act of selecting another business that participated in the bid as our subcontractor constitutes collusion. Avoid this as it may raise suspicion. However, in cases where sourcing from the relevant company is absolutely necessary, the business case will be processed after review by the legal department. Obtain written approval from the orderer
If you are asked to participate in a bid as a bridesmaid, you must flatly refuse it
Do not use expressions that may be misunderstood by outsiders even though there is no evidence of collusion in the company's internal materials or emails related to bidding (prior consultation with the company) Completed, cooperation or strengthening of cooperation, planned support from our company, etc.)
It is absolutely impossible to determine the bidding price, the prospective successful bidder, or the order quantity through agreement or consultation with other business operators. Things to keep in mind

Guidelines for conduct in the field of general unfair trade practices

If there is a company that wants to do business with us, do not ask the company to perform unfair actions unrelated to the transaction in return for starting the transaction. thing
Do not refuse to initiate a transaction because the company does not respond to the request for the above unfair acts (the above unfair acts may involve a third party designated by the company) There may be acts such as mandating the purchase of goods or services or requesting the provision of money or entertainment)
Selection of business partners or rejection of transactions must be handled in accordance with the relevant internal company regulations
When providing the same products or services, do not set significantly disadvantageous price conditions for non-affiliated companies without justifiable reasons.
Do not discriminate on transaction terms, service contents, etc. with only certain businesses without reasonable grounds
Providing illegal money or entertainment (kickbacks) to customers or customer representatives in order to enable customers to purchase or use our services, products, etc. Do not provide
Information about our services and products provided to customers must always provide only truthful information, and in order to attract customers, False or exaggerated information must not be delivered to customers
Do not take actions that interfere with or infringe on competitors’ business activities in order to encourage customers to do business with us
Do not require customers to purchase other unnecessary services or services as a condition of providing our services or services (no tying)
We must not sell goods or services at significantly low prices in order to strengthen our control over the industry or prevent the entry of new businesses.
When dealing with a partner company, conditions are put forward that objectively cannot be achieved by the company, and under the pretext that the company will not be able to achieve them. Do not impose disadvantages such as reduced transaction volume or elimination of business partners
Do not recruit key competitors' personnel for a specific business by providing excessive profits, etc.
Do not set contract terms that unfairly disadvantage the other party (unconditional refund of the entire contract amount if the company is at fault, etc.)
In relation to the company's business performance, receive guidance from our company regarding the contents, items, prices, charges, etc., different from the original contract contents, or Do not engage in unfair management interference, such as requiring permission
Do not trade our products, services, etc. to specific regions or parties without justifiable reasons
Do not use the other party’s technology without permission when conducting business
Failure to pay a fair refund to a company that terminates its existing business relationship with us and changes its business partner to another company, or Do not interfere with the transfer to a customer by unilaterally returning all inventory or canceling or not returning collateral or guarantee insurance.
Making unreasonable demands on the company or failing to comply with them because the company deals with our competitors or handles products from competitors. Do not impose any disadvantages, such as terminating the transaction, just because you did not do so
Making unreasonable demands on the company or making transactions without reasonable grounds because the company's dependence on us for transactions is very high. Do not unfairly disadvantage people by refusing them

Guidelines for action in the field of unfair support

Under the Fair Trade Act, the prohibition on ‘general acts of unfair support (transactions of a significant scale and favorable terms, toll transactions)’ applies not only to transactions between the company and its affiliates. Please keep in mind that this regulation also applies to transactions between our company and non-affiliates
If you wish to pursue internal transactions with affiliates (including both private contracts and competitive bidding), internal transactions must be conducted in advance in accordance with company regulations and guidelines. After deliberation, it will be reviewed whether it violates the Fair Trade Act
Please note that under the Fair Trade Act, acts of unfair support are subject to punishment for both the company that received such unfair support and the company that provided the unfair support.
If a customer, an affiliate, requests to perform additional work not included in the contract without payment for it, this is After notifying that there is a possibility of unfair support prohibited under the Fair Trade Act, we will perform this after concluding a reasonable change contract for additional work. thing
Adding companies without a role (including affiliates and non-affiliates) to the transaction stage, or paying excessively high or low compensation compared to their role. Do not pay
Do not intervene in the transaction process without a special role or receive compensation that is excessively high or low compared to your role
Acts such as exempting the other party from liability in terms of the contract entered into mutually as a transaction with an affiliate, extending the payment deadline for the contract, etc. Acts of indirectly supporting the other party through Strictly comply with the terms of the mutually concluded contract
In case of internal transactions with affiliates, the prices stipulated in the Fair Trade Act, such as comparison procedures with normal prices and review of security, efficiency, urgency, etc. Will go through procedures
Even if the act of support to an affiliate does not fall under the ‘act of unfair support to a specially related person’ under the Fair Trade Act, the ‘general Keep in mind that this may be considered an act of ‘unfair support’ and do not engage in such acts of unfair support

The heads of each department must supervise the compliance of their employees and take appropriate measures to ensure that they do not violate their compliance obligations.

3. Practice voluntary compliance with the Subcontracting Act

Guidelines for conduct in the field of subcontracting law

The Subcontracting Act is basically a regulation that applies to subcontracting transactions between our company and small and medium-sized suppliers, but there are some provisions such as prohibition of payment and retaliation. Please note that the regulations also apply to transactions between our company and mid-sized companies
Contact the legal department to confirm whether the company is a small or medium-sized business
Never instruct a company to do work before the subcontract is concluded
If a subcontract is concluded in a form other than the Fair Trade Commission's standard contract, the contract must be reviewed in advance by the Legal Department and the Subcontracting Act Check whether there are any violations (unfair special provisions, etc.)
Advance payments and subcontract payments must be paid in accordance with the provisions of the Subcontracting Act (within 15 or 60 days, maintaining the cash ratio)
If the payment deadline under the Subcontracting Act is exceeded, it will be reported immediately according to the internal process and payment of late interest according to the Subcontracting Act will be made to the company.
Do not refuse or return requests for receipt or inspection of goods or services delivered by the company without justifiable reasons, and if there are justifiable grounds for refusal, etc. In this case, please leave clear evidence such as an official document or a written explanation for failing to pass the inspection
If the originally determined subcontract amount is reduced or all or part of the work is canceled, the details must be provided in writing, such as an agreement. Notify the company and compensate for any damage caused to the company
Do not unfairly demand that companies provide economic benefits, including money, goods, services, etc.
Technical data must be requested by issuing a legitimate request according to the company's technical data request process
Technical data received from the company must not be misused or leaked in accordance with the contents of the request or confidentiality agreement
If there is a request from the company to adjust the subcontract price, the request will be faithfully complied with in accordance with the provisions of the Subcontracting Act
Do not unfairly interfere with company management other than making business contact related to the transaction in question
Unless it falls under an exception under the Subcontracting Act (e.g. work that takes a long time to inspect due to its nature), the inspection results must be notified within 10 days. thing

Public Interest Reporting System

1. Unethical behavior subject to reporting

Illegal financial transactions: Unethical financial practices such as illegal financial transactions, theft, and embezzlement
Human rights violations: Unethical acts such as human rights violations, discrimination, sexual harassment, harassment, etc. of employees or other stakeholders
Environmental destruction: Actions that cause damage to the environment or illegal acts of environmental destruction due to an organization's activities
Security violation: Unethical behavior regarding the organization's security, such as leaking corporate secrets or personal information
Inappropriate work behavior: Inappropriate work behavior within the organization, such as unfair work behavior, unfair competitive behavior, and false reporting.
Reliability and quality issues: If there is a problem with the quality or safety of the organization's products or services, report on them Violation: Organization You can report information about internal violations of laws, regulations, government guidelines, etc.

2. Reporting procedure

Offline reporting channel

Employees can submit reports in a questionnaire form through the suggestion box located in the lounge on the first floor of Samboo Metal Co., Ltd. The information reported was sent to the Innovation Planning Team. Review, determine if it is true, coordinate opinions with the informant, and discuss processing period and method.

Online reporting channel

You can report unethical behavior through ‘Reports and Other Inquiries’ at the customer center on the Samboo Metal Co., Ltd. website. or homepage for employees Reports can be made through the anonymous bulletin board at ‘http://samboonotice.modoo.at’. What was reported The Innovation Planning Team reviews, determines whether it is true, coordinates opinions with the informant, and discusses the processing period and method.

Procedure for protecting informant’s anonymity
1. We operate a suggestion box and anonymous Internet bulletin board so that informants can report anonymously.
2. To prevent harm to the informant, anonymity must be strictly maintained except by the team in charge.
3. In order to protect the identity of the informant, when a full investigation is conducted, the reporter will be held after work or after work so that discussions can be held inconspicuously. Avoid working hours.
4. To maintain confidentiality, the informant and the team members in charge must write a confidentiality agreement regarding the report and take action on the report. do.
5. Nevertheless, if the identity of the informant is exposed and harm is caused to the informant, the damage can be minimized by providing support to the informant. Let it happen.

Report handling procedures
1. Report received
2. Innovation Planning Team Reviews reported contents and investigates to determine if they are true
3. After confirming the facts, coordinate opinions with the informant to determine the direction of action
4. Action
5. After taking action, the results are delivered to the informant

Reporting Officer
- Reporting officer: Innovation Planning Team Manager Choi Byeong-chan
- Deputy Manager: General Affairs Team Assistant Manager Baek Seung-chan

For Sustainable Value,
For a Better Future

Samboo Metal will continue
to develop for a better tomorrow
with never-ending passion.

Samboo Metal Co., Ltd. CEO Choi Jeong-moon Location 274-11, Yongjeon Industrial Complex-gil, Samrangjin-eup, Miryang-si, Gyeongnam Tell +82-55-802-7700 Fax +82-52-802-7772 E-mail samboometal@samboometal.com