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ESG

Ethical Management

Code of Ethics System Operations and Training Activities Reporting System Clean POSCO System

A corporate culture that prevents improper solicitation is
fostered by recording and managing all recommendations and
requests for improper solicitation.

Preventive Measures Against
Unethical Conduct

Employees who receive improper solicitation requests are provided with clear grounds to refuse them through the registration process. At the same time, individuals making such requests become aware that records are maintained, which helps prevent future improper solicitations.

Practicing the Spirit of
Whistleblowing

An honest and transparent corporate culture is fostered when employees conscientiously register improper solicitation requests they receive. The registration of improper solicitation requests is regarded as a voluntary disclosure, helping protect employees acting in good faith from future issues or liabilities.

Operating Procedures

Step 1

Employees register the requester's information and relevant details in the system after receiving an improper recommendation or solicitation request.

Step 2

The Integrity Management Group receives and reviews submitted reports.

Step 3

After reviewing the details, the results are communicated to the relevant department.

Step 4

When necessary, the Integrity Management Group conducts a detailed investigation and takes appropriate action if issues are identified.

Eligible Registrants

All employees involved in the recommendation or improper solicitation process, including recipients, intermediaries, and working-level personnel who receive or relay recommendations or improper solicitation requests.

Registration Method

Employees who receive recommendations or improper solicitation requests must accurately register all relevant details without omission, including a comprehensive account of who, what, where, when, why, and how.

Registration Timing

Relevant details must be registered in the system within 24 hours of receiving a recommendation or improper solicitation request. However, the registration period may be extended in cases involving special circumstances such as meetings or business trips.

Detailed Standards

Definition of Solicitation

Solicitation refers to any form of request or expression intended to influence the job performance or decision-making of employees for the benefit of oneself or others.

Standards for Assessing Fairness in Work Performance and Decision Making (Based on Anti-Corruption & Civil Rights Commission guidelines)
  • Any act in which a conflict of interest arises for an employee as a result of accepting or rejecting an improper solicitation request
  • Any act in which a solicitation creates psychological pressure that may interfere with the fair and impartial performance of duties
Scope of Recommendations and Solicitations Subject to Registration
  • The Clean POSCO System is designed to proactively prevent misconduct arising from improper solicitation requests. To support this purpose, the scope of solicitation has been expanded beyond the legal definition to include any expression of intent that may undermine fairness.
  • In cases where it is unclear whether a matter constitutes an improper solicitation request or a normal business activity, all related details should be registered in the system without attempting to determine whether it qualifies as a solicitation.
  • Employees who fail to register recommendations or improper solicitation requests despite being aware of them may be subject to strict disciplinary action.
Examples of Acts That Must Be Registered as Improper Solicitation
  • Requests for preferential treatment related to equipment or material purchases and various contracts.
  • Requests for preferential treatment or special favors in personnel matters such as hiring, promotion, rewards and disciplinary actions, or job reassignment.
  • Requests for preferential treatment, including the provision of convenience or special favors that fall outside established standards and principles.
  • Requests to neglect management or supervisory duties such as inspections and evaluations.
Examples of Acts That Do Not Require Registration
  • Cases in which the requester withdraws the solicitation after being immediately informed of its rejection due to concerns about identity disclosure resulting from solicitation registration.
  • Requests for cooperation made through official documents.
  • Requests for cooperation involving simple confirmation, inquiries, petitions, or similar matters related to the duties of relevant organizations or departments.
Actions taken in response to recommendations and improper solicitation registrations

The results of recommendations and improper solicitation registrations are separately managed by relevant departments such as HR and procurement, and appropriate disciplinary or corrective measures may be taken against the employees or companies involved.