Fair Trade

ESG

POSCO FLOW is committed to fair and transparent business
practices that support a sound and competitive market environment.

Fair Trade Consultation
& Reporting Fair Trade Compliance Program
Operating Guidelines

Fair Trade Compliance
Message

To all employees of POSCO FLOW, I would like to express my sincere appreciation to all employees for their continued dedication to their respective roles despite challenging business conditions.

The logistics operations you manage play a vital role in connecting domestic and global supply chains while supporting the foundation of the national economy.

For the industry to grow stably and sustainably, transparent business practices and a fair competitive environment must be firmly established. Accordingly, the importance of fair-trade compliance continues to grow.

Through the Fair-Trade Compliance Program (CP), the company continues to strengthen its compliance framework so that employees clearly understand and comply with applicable laws, regulations, and internal standards. At the same time, the company is committed to fostering a healthy business culture built on mutual respect and responsibility with business partners and stakeholders.

To further strengthen and embed a culture of fair-trade compliance, the following commitments will be actively carried out.

First, Promoting Fair Competition

Unfair practices, abuse of superior bargaining position, unfair support practices, and other conduct that undermines fair competition in subcontracting and outsourced service transactions will be strictly prohibited.
Transparent procedures and standards will be maintained throughout the entire bidding and contracting process to ensure fair competition.

Second, Strengthening the Foundation for Shared Growth with Business Partners

Unfair terms and improper demands based on a superior bargaining position will be eliminated, and a business culture built on mutual trust will be established.
Principles related to payment and settlement processes will be strictly observed to support the stable operations of business partners.

Third, Enhancing Employee Compliance and Ethical Awareness

Fair trade guidelines and compliance considerations will be communicated regularly so that employees can effectively apply them in the workplace.
The offering or acceptance of improper benefits, including gifts and entertainment, will be strictly prohibited, and reporting and consultation channels will be actively promoted to prevent and eliminate inappropriate practices.

Fourth, Embedding the Fair Trade Compliance Program (CP) into the Corporate Culture

To ensure that the CP becomes more than just a formal system and is firmly embedded in the corporate culture, the effectiveness of the operational framework will be continuously reviewed and improved.
Potential risks arising in the workplace will be proactively managed, and when necessary, immediate corrective and recurrence prevention measures will be implemented.

The company firmly recognizes fair trade compliance not merely as adherence to regulations, but as a core value essential to sustainable growth and trust-building. Based on fair and transparent management practices, the company will continue to fulfill its responsibilities as a trusted company to customers, business partners, and society. All employees are also encouraged to once again recognize the importance of fair trade compliance and to continue exercising principled judgment and responsible execution in their respective roles. Thank you.

Seungjo Kim
Compliance Officer, POSCO FLOW

Fair Trade Compliance
Program

CP (Compliance Program)

The Fair Trade Compliance Program (CP) is an internal compliance framework voluntarily established and operated to prevent violations of fair trade laws proactively. The program includes commitment from top management, designated compliance officers responsible for overseeing program operations, monitoring systems for fair trade compliance risks, training programs, compliance manuals, disciplinary measures for violations, and document management practices.

CP Objectives To promote employee awareness of the importance of the Compliance Program (CP) and provide guidance on its core elements and implementation standards.

Purpose of Implementation 01
Establishing an ongoing compliance management framework through the proactive prevention and recurrence prevention of unfair practices that undermine fair market competition
Purpose of Implementation 02
Fostering a fair trade compliance culture and enhancing employee awareness
Purpose of Implementation 03
Reinforcing fair trade compliance as an essential element of management and business operations

Vision and Strategy

Vision Establishing a compliance-driven and fair competition-oriented
management system as a leading global logistics company

Mission Building a CP framework to proactively prevent, detect, and address unfair trade practices through comprehensive risk management across the business environment

Creating a sustainable virtuous cycle

Strategy 01 Establishing a Fair Trade
Compliance Program (CP)
Strategy 02 Preventing legal violations
through practical implementation
Strategy 03 Evaluating and advancing
the compliance system

Creating a sustainable virtuous cycle

CP Operational Process

CP Establishment and Planning

Development and Distribution
of the Compliance Manual

Operation of Training Programs

Document Management

Routine Inspection
and Monitoring

Evaluation of Operational Performance

CP Establishment and Planning
- Reporting to top management
Development and Distribution
of the Compliance Manual
- Production of electronic documents and printed booklets
Operation of Training Programs
- Fair Trade e-learning programs
- CP training for high-risk departments
- Training for new employees
- CP training led by external experts
- CP Training Survey
- Evaluation of CP training effectiveness
- Evaluation of CP operational effectiveness (CP training section)
Document Management
- Management and retention of CP-related documents, including policies and guidelines
Routine Inspection
and Monitoring
- Self-inspection checklists
- Consultations and pre-operation reviews
- External expert advisory services
- Fair trade monitoring
Evaluation of Operational Performance
- Incentives
- Disciplinary measures for violations
- CP awareness surveys
- Evaluation of CP operational effectiveness
- Reporting on CP operational performance and plans

CP Framework

POSCO FLOW has established a Fair Trade Compliance framework built on Prevention, Detection, and Response to proactively manage and mitigate the risks of legal and regulatory violations.

Prevention
Risk Prevention and Follow-up Management
Coaching and follow-up measures for system improvements
Dispute resolution and recurrence prevention
Collaborative networking and evaluation of CP activities
Response
CP Policy Development and Preventive Activities
Support for management-led CP activities
Establishment and revision of compliance guidelines
Customized training, consultation, and information support
Detection
Risk Monitoring
Compliance risk assessments
Self-inspections by operational departments
Ongoing monitoring

Eight Core Elements for CP Implementation

Under the Regulations on the Operation and Incentives of Fair Trade Compliance Programs,

companies must satisfy eight core elements in order to be officially recognized as having implemented a Compliance Program (CP).
These eight core elements serve as the foundation for establishing a strong culture of compliance and maintaining a fair competitive order.

Establishment and Implementation of CP Standards and Procedures
Necessary standards and procedures must be established and implemented so that employees clearly understand and comply with fair trade laws and regulations related to their duties.

01
Commitment and Support from Top Management
Top management must publicly communicate its commitment and policies regarding compliance with fair trade laws and regulations and actively support the operation of the CP.

02
Appointment of a Compliance Officer Responsible for CP Operations
The board of directors or other highest decision-making body must appoint a Compliance Officer within the organization and assign responsibility for the effective operation of the CP.

03
Development and Utilization of the Compliance Manual
The Compliance Manual is prepared under the responsibility of the Compliance Officer and includes fair trade laws and regulations, as well as CP standards and procedures.

04
Continuous and Systematic Compliance
Training
Effective and regular training must be provided on CP standards and procedures, as well as compliance requirements related to fair trade laws and regulations, for top management and employees in high-risk areas such as purchasing and sales departments.

05
Establishment of an Internal Monitoring System
A reasonably designed monitoring and auditing system must be established and operated to prevent or detect unlawful conduct at an early stage.

06
Disciplinary Measures for Employees Violating Fair Trade Laws and Regulations
Internal regulations must be established and implemented to ensure that employees responsible for violations of fair trade laws and regulations are subject to disciplinary measures proportionate to the severity of the violation. In addition, when violations of laws or regulations by employees are identified, prompt corrective action must be taken, and preventive measures must be implemented to prevent similar incidents from recurring.

07
Evaluation of Effectiveness and Improvement Measures
Regular reviews and evaluations of CP standards, procedures, and operations must be conducted to ensure the continued effectiveness of the CP, and improvement measures must be implemented based on the results.

08

Establishment and Implementation of CP Standards and Procedures
Necessary standards and procedures must be established and implemented so that employees clearly understand and comply with fair trade laws and regulations related to their duties.

01
Appointment of a Compliance Officer Responsible for CP Operations
The board of directors or other highest decision-making body must appoint a Compliance Officer within the organization and assign responsibility for the effective operation of the CP.

03
Continuous and Systematic Compliance
Training
Effective and regular training must be provided on CP standards and procedures, as well as compliance requirements related to fair trade laws and regulations, for top management and employees in high-risk areas such as purchasing and sales departments.

05
Disciplinary Measures for Employees Violating Fair Trade Laws and Regulations
Internal regulations must be established and implemented to ensure that employees responsible for violations of fair trade laws and regulations are subject to disciplinary measures proportionate to the severity of the violation. In addition, when violations of laws or regulations by employees are identified, prompt corrective action must be taken, and preventive measures must be implemented to prevent similar incidents from recurring.

07

Commitment and Support from Top Management
Top management must publicly communicate its commitment and policies regarding compliance with fair trade laws and regulations and actively support the operation of the CP.

02
Development and Utilization of the Compliance Manual
The Compliance Manual is prepared under the responsibility of the Compliance Officer and includes fair trade laws and regulations, as well as CP standards and procedures.

04
Establishment of an Internal Monitoring System
A reasonably designed monitoring and auditing system must be established and operated to prevent or detect unlawful conduct at an early stage.

06
Evaluation of Effectiveness and Improvement Measures
Regular reviews and evaluations of CP standards, procedures, and operations must be conducted to ensure the continued effectiveness of the CP, and improvement measures must be implemented based on the results.

08

Organizational Structure

CEO

Board of Directors

Compliance Officer

Overall management of the Fair Trade Compliance Program (CP)
Promotion of fair trade awareness among employees
Management of the operational organization
Management of fair trade compliance responsibilities and performance
Oversight of compliance monitoring

Dedicated Organization

Operation of the eight core elements of the Fair Trade Compliance Program
Operation of the self-inspection system
Operation of Training Programs
Establishment of compliance monitoring systems
Internal supervision and measurement of operational effectiveness

Departmental Compliance Representatives
[Compliance Council]

Chairperson: Compliance Officer
Members: Heads of Each Group
Implementation Leaders: Working-Level Representatives from Each Group
Review of key CP matters
Sharing of CP operational updates
Consultation with the Compliance Officer

Department-Level Fair Trade Compliance Practice Leaders

Monitor potential violations of fair trade laws and regulations
Provide training and guidance on fair trade compliance matters
Report violations and take appropriate action when necessary

공정거래 자율준수 조직도: 대표이사 - 이사회, 자율준수관리자, 전담조직, 부서별 자율준수 담당자[자율준수협의회], 부서별 공정거래 자율준수 실천리더

CP Highlights

2026.02 Appointment of a Fair Trade Compliance Officer (Seungjo Kim, Head of Integrity Management Office)
2025.12 Establishment of a compliance management system
2024.12 Earned an AA rating in the 2024 Fair Trade Commission CP Evaluation for the second consecutive year, the first in the logistics industry
2024.01 Appointment of a Fair Trade Compliance Officer (Jaeman Kim, Head of Corporate Planning Office)
2023.12 Earned an AA rating in the 2023 Fair Trade Commission CP Evaluation
2022.12 Implementation of CP awards under the names of the CEO and Compliance Officer
2022.03 First Compliance Council meeting held in 2022
2021.10 Development of a Fair Trade Compliance Index in 2021
2021.07 Appointment of a Fair Trade Compliance Officer (Seungseop Lee, Standing Auditor)
2013 Introduction of the Fair Trade Compliance Program (CP) at POSCO Terminal

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