1. Maintain Healthy Relationships with Interested Parties

1. 1) We will not partake in cash loans or solicitations that can negatively affect the lawful conducting of our business.
2. 2) We will not receive any money and other valuables, entertainment, and convenience, etc. excluding standard souvenirs and gifts.
3. 3) Congratulatory or condolatory events will not be notified to interested parties who may affect business practices, and congratulatory or condolatory money will not exceed socially accepted levels based on the principle of give and take.
4. 4) While conducting business, we will not give preference to or discriminate against specific individuals or companies based on regionalism, kinship, school relations, etc.
5. 5) Solicitations to HR personnel to negatively impact the placement of oneself or others, including appointment, promotion, transfer etc., is forbidden.
6. 6) Wrongful acts using one’s superior position are forbidden.

2. Avoiding Tasks Concerning Interested Parties

1. 1) If one’s work is related to interested parties, one must avoid participation and decision-making in relation to that task.
2. 2) To avoid a task because of relations with interested parties, one must notify a superior or an ethics committee member (relevant BU head).

3. Record Storage Management of Information and Resource Usage

1. 1) Financial management, including accounting records, should be accurately and transparently recorded and managed, based on related laws and generally accepted accounting principles.
2. 2) One must not use information gained during the conducting of business for monetary transactions, including stocks or for investments; moreover, one must not provide such information to others to aid in monetary transactions or investments
3. 3) One must not use or gain profit through real estate, movable assets, goods, and budget, etc., provided by the company for personal use without justifiable cause.

4. Attitude of Employees

1. 1) We will create a more harmonious organizational culture by fostering an environment in which suggestions and difficulties can be freely expressed.
2. 2) Superiors will develop and actively support the talents of their subordinates for the purpose of cultivating talented personnel.
3. 3) One shall not abuse ones authority to provide advantages to people whom one has a personal relationship with, such as relatives, and by general principle, executives and employees who have personal relationships will not work in the same department as each other.
4. 4) Guidelines related to safety will be strictly followed to preemptively prevent various accidents.

5. Healthy Social Life

1. 1) We will faithfully follow all domestic and international laws, regulations, administrative norms, etc. that a company must follow related to social activity and business transactions.
2. 2) We will not gain profits through unfair means that conflict with business and trade ethics.
3. 3) We will consider competition as an opportunity for mutual development and not participate in any activity that undermines economic market order.
4. 4) We will actively and voluntarily participate in social and cultural projects to fulfill our social responsibilities as a company.

6. Establishment of Ethical Management

1. 1) We will establish a corporate culture that practices ethical management.
2. 2) If one is alerted of violations to the code of ethics by oneself or others, they must report this to a superior or an ethics committee member.
3. 3) Separate guidelines may be determined for the efficient implementation of the code of ethics.

1. Definitions

1. 1) Money and other valuables refer to monetary items (e.g., cash, gift certificates, and memberships) and non-monetary items that can bring economic benefits, such as movable assets, real estate, object, entertainment etc.
2. 2) Entertainment refers to meals, drinks, golf, shows, amusements, etc.
3. 3) Convenience refers to provision or receipt of benefits, such as transportation, accommodation, sight-seeing, support for an event, etc.
4. 4) Interested parties include the following:
   1. (1) Customers including the unspecified masses who purchase or use Sunjin products and services.
   2. (2) Companies who are in a cooperative business relationship to provide Sunjin products and services, such as purchasing, OEM, and logistics.
   3. (3) Specific clients whose transactions are conducted using Sunjin products and services.
   4. (4) Counterparties who are in a relationship that can have a direct or indirect impact on other businesses.
5. 5) Generally accepted amount refers to an amount that is universally fitting of social customs, as can be understood by healthy common sense of an ordinary person.
6. 6) Personnel related to business refer to individuals or companies that having a working or transaction relation with Sunjin.
7. 7) Actions of family members, relatives, and acquaintances using the name of a Sunjin executive or employee to violate these guidelines will be deemed as actions taken by the executive or employee themselves.

2. Receipt of Money and Other Valuables

1. 1) One must not demand or accept money and other valuables from interested parties for any reason. However, this is does not hold true in the following situations:
   1. (1) Money and other valuables provided following lawful titles, such as payment of debt.
   2. (2) Gifts of generally accepted amounts related to conducting business (cases when the provider has done so voluntarily and with pure intentions, and when doing so is recognized by social norms to be mutually non-obligatory).
   3. (3) Money and other valuables that a superior provides to a subordinate as motivation, including consolation, encouragement, and reward.
   4. (4) Transportation, accommodation, food that is uniformly provided to participants by the host during work-related official events.
   5. (5) Souvenirs or promotional goods produced to be distributed to unspecified masses.
   6. (6) Money and other valuables that are openly provided to executives and employees who are in difficult circumstances, such as illness or disasters.
   7. (7) Other money and valuables that are within the amount allowed by the head of the affiliated organization for the smooth conducting of business.
   8. (8) Money and valuables openly provided by employee mutual aid societies etc.
2. 2) If that money and other valuables were unavoidably received without the knowledge of oneself, it must be returned immediately. In cases when returning is difficult, it must be reported to a superior or an ethics committee member (relevant BU head).

3. Entertainment

1. 1) Entertainment that exceeds the generally accepted amount must not be accepted, and in the case of participating in events that offer such entertainment, one must report to a superior or an ethics committee member (relevant BU head).
2. 2) In cases when entertainment exceeding generally accepted amounts is being provided, prior approval must be received from a superior or an ethics committee member (relevant BU head).

4. Convenience

1. 1) One must not receive transportation, accommodation, etc., paid for by interested parties. However, this excludes events where the interested party uniformly provides the convenience to all participants.
2. 2) If, however, one unavoidably receives convenience exceeding the accepted amount, they must report to a superior or an ethics committee member (relevant BU head).

5. Congratulatory or Condolatory Money

1. 1) An employee shall not inform interested parties of their or their co-workers’ congratulatory or condolatory event. Notification through a third party will be deemed notification by the employee themselves.
2. 2) If the congratulatory or condolatory money received exceeds social norms, the full amount must be returned. If the return is not possible, then this must be reported to a superior or an ethics committee member (relevant BU head), and the ethics committee member (relevant BU head) must report and deposit this amount to the ethics committee head.

6. Pecuniary Transactions

1. 1) One should not engage in pecuniary transactions with interested parties, such as lending or borrowing of money, providing a guarantee, or leasing of real estate.
2. 2) In the event one enters into an avoidable pecuniary transaction with an interested party owing to personal relationships, it should be reported to a superior or an ethics committee member (relevant BU head).

7. Contract Signing and Execution

1. 1) The execution of all construction, services, purchase, etc., contracts, must be completed in a fair and transparent manner, following related legal processes.
2. 2) One must not make unfair demands such as unfair trade conditions etc. using their position of power in the transaction during the bidding and contract execution process.

8. Support for Events

1. 1) One should not receive any support from an interested party in relation to any event organized by the department or as company extracurricular activities.
2. 2) If receiving support from interested parties for an event is unavoidable, it should be reported to a superior or an ethics committee member (relevant BU head).

9. Inappropriate Use of Budget Resources

1. 1) One shall not use budget resources for personal purposes.
2. 2) As a general rule, company expenditure should be paid by a corporate credit card in accordance with the work goals and the guidelines prescribed by the company.

10. Respect for Life, Safety Management, and Accident Prevention

1. 1) All executives and employees shall prioritize life and safety management.
2. 2) All executives and employees shall follow safe driving regulations, including traffic rules, and must not drive under the influence, regardless of being at work or personal situations.
3. 3) Regular inspections following industry safety standards will be strictly conducted in an effort for preemptive safety management and accident prevention.
4. 4) Safety accidents shall be preemptively prevented through the understanding of the proper usage of equipment. In addition, for swift action during accidents, compulsory education and virtual training shall be conducted on a regular basis and as is required.

11. Mutual Respect of Executives and Employees

Executives and employees will follow basic etiquette required for work.

1. 1) They shall not participate in faction forming or discrimination based on school relations, religion, blood relations, regionalism, age, disability, marital status, nationality, race, etc.
2. 2) Vulgar language, including rough words and verbal abuse, that insults the character of a superior, co-worker, or subordinate shall not be allowed.
3. 3) Sexual discrimination or harassment shall not occur at the workplace.

Consultation etc. required for implementation can be conducted.

12. Handling of Reports

1. 1) Anyone who becomes aware of violations of the code of ethics by oneself or others much report this to a superior, an ethics committee member (relevant BU head), or the ethics committee head.
2. 2) The CEO and ethics committee head must guarantee confidentiality of the reporter and the contents of the report, and must ensure that no discrimination or disadvantage occurs because of the report.
3. 3) If one follows regulations and self-reports violations by self, with regard to disciplinary actions toward the reporter, it may be reduced or exempted.

13. Conducting Preemptive Education

1. 1) The CEO and ethics committee head must conduct regular or frequent training each year for the compliance with the executives and employee code of ethics, etc.
2. 2) Superiors or ethics committee member (relevant BU head) can conduct consultations required for employees to fully understand and implement these guidelines.

14. Rewards and Disciplinary Action

1. 1) For employees who contribute to the establishment of ethical management business culture, the CEO and ethics committee head can reflect this in their evaluation, or provide rewards or appropriate compensation following related regulations.
2. 2) For employees who violate these guidelines, the CEO and ethics committee head can take appropriate action following related regulations, such as referring the employee to the personnel committee following an ethics committee hearing.
3. 3) The type, process, and force of disciplinary action shall follow what has been determined by the company, such as employment guidelines etc.

15. Interpretation

For questions related to items that are not specifically determined in these practice guidelines, enquiries are to be addressed by a superior or an ethics committee member (relevant BU head) as well as the ethics committee head, and one should follow their interpretation.

16. Establishment of an Ethics Committee

1. 1) An ethics committee must be established by the CEO to respond to queries regarding ethical management.
2. 2) The ethics committee shall be composed of a head, secretary, and members. All shall be appointed by the CEO. The head may create a TF following the approval of the CEO.
3. 3) The ethics committee may deliberate on the following items.
   1. (1) Deliberations on the establishment and amendments to the ethics charter and code of ethics, etc.
   2. (2) Deliberation on various cases of reported ethical management violations
   3. (3) Interpretations on the application of guidelines, etc
   4. (4) Other various matters required for the establishment and operation of ethical management corporate culture
4. 4) The rules for resolution by the ethics committee are as follows.
   1. (1) Deliberations begin with a majority of registered members being present, and resolutions are made through the approval of the majority of members attending. In case of a tie in votes, resolutions will follow the decision of the committee head.
   2. (2) If an issue is relatively minor or when there are difficulties in convening a meeting, resolutions can be executed through writing by the committee head.

17. Additional Rules

These rules are effective as of July 1, 2011.