Article 1 (Purpose)

The purpose of these Practice Guidelines for the Code of Ethics (hereinafter referred to as the “Guidelines”) is to provide the judgment criteria for decision-making and action so that the members of the Company can practice the Code of Ethics with a proper understanding thereof.

Article 2 (Applicable Principles)

1.Members shall judge and act on the basis of the Code of Ethics and these Guidelines when faced with an ethical conflict in relation to their job duties. 2.These Guidelines present the bare minimum standards, as a show of respect for the healthy consciousness and common sense of the members. Thus, if a member is not confident in his/her judgment and the judgment criteria pertaining to the situation in question are not clearly defined, he/she shall act according to the advice given by the leader of the organization or the department in charge of ethical management.

Article 3 (Scope of Application)

These Guidelines apply to the members of the Company. It is, however, also recommended that all stakeholders understand and practice these Guidelines.

Article 4 (Faithful Job Performance)

Members shall make their best efforts to perform their respectively assigned job duties in legitimate ways, with an understanding of the goals and values pursued by the Company, and comply with the related laws, regulations, and the Company’s regulations and policies concerning the work in question.
Members shall make an effort to fulfill their responsibilities and obligations as members of society, bearing in mind that their behavioral and verbal conduct are directly associated with the public confidence in and reputation of the Company.

Article 5 (Resolution of Conflict of Interest)

a: Members shall try to avoid any behavior or relationship that would be in conflict with the interests of the Company in relation to their job performance. If there is any conflict of interest, members shall consider the Company’s interests first. Upon discovery of a violation of this clause, the department in charge of ethical management shall be notified.

b: Conflicts of interest that may arise as result of a member illegitimately exercising his/her influence on business affairs or that may influence the judgment or action of a member are as follows:

1.The act of entering into a contract or doing business with the Company directly or via a third party;
2.The act of doing business with a competitor or a busines partner of the Company directly or via a third party;
3.The act of holding a job position concurrently at another company that is of interest to the Company without the Company’s approval;
4.The act of establishing a business relationship, such as through a monetary loan, joint investment, loan guarantee, lease of real estate properties or movable assets, etc., with a busines partner of the Company;
5.The act of being compensated by a busines partner directly or via a third party;
6.The act of acquiring stocks, bonds, etc. of a business partner directly or via a third party (excluding cases in which it was approved by the Company);
7.The act of having a family member or relative do business with the Company and/or its business partners;
8.The act of illegitimately obtaining personal gains by using the Company’s assets or management information;
9.The act of exerting unfair influence, such as requesting a supplier to consider someone in particular in the hiring process or requesting various favors, by abusing one’s status at the Company.

c: Paragraph (b）above consist of examples of actions that result in a conflict of interest, and even in other cases, members must strictly judge whether their actions f all under the category of conflict of interest and apply and comply with these Guidelines.

Article 6 (Protection of the Company’s Assets and Information)

a: Members shall protect and legitimately use the Company’s tangible and intangible assets.

b: Protection of property:

1.Members shall not use the Company’s assets for their own benefits or for a third party or provide them to a third party without the approval of the Company.
2.Members shall not assign or loan the Company’s assets to themselves or a third party at a low price, or purchase or lease their own assets or the assets of a third party at a high price using the Company’s account.
3.In the event of a situation that will bring a significant loss to the Company or a possibility thereof, members shall report the matter immediately to the Company and take action to minimize the loss.
4.The Company’s budget shall not be used for personal purposes. Instead, it shall be used in accordance with the purposes and standards set forth by the Company.

b: Information protection:

1.Members shall not engage in any acts of pursuing personal gains by using undisclosed information of the Company acquired through their job duties or by providing such information to a third party. 2.Members shall not divulge or provide the Company’s information and trade secrets to any internal or external parties without prior approval and shall fully cooperate in the storage and inspection of electronic documents sent outside the Company in accordance with the Company’s information security policy. 3.The Company’s information assets shall be strictly managed in accordance with the security management regulations.

Article 7 (Receiving Gifts, Entertainment, etc.)

Members shall keep their work life and personal life strictly separate and conduct business in a fair and transparent manner. Members shall not receive or provide money, valuables, gifts, entertainment, favors, etc. for personal purposes from or to stakeholders such as suppliers. However, in order to maintain healthy relationships with others for business purposes, reasonable gifts or entertainment can be exchanged within the scope deemed appropriate by society and according to the Improper Solicitation and Graft Act. Detailed guidelines regarding this mater may be established and implemented in an organizational unit in consultation with the department in charge.

Article 8 (Mutual Respect Among Members)

Members shall respect each other and their colleagues and observe the basic propriety in the workplace so as to eliminate any obstacles to happiness in the workplace and create a sound organizational atmosphere.
Members shall not discriminate each other on the basis of sex, education, region of origin, marital status, race, nationality, religion, etc.
Members shall not sexually harass or impose personal burdens on others that may violate human rights and undermine the work atmosphere.

Article 9 (Fair Trade)

1.The Company and its members shall ensure fair transactions with suppliers and build mutual trust and partnerships so as to establish win-win relationships.
2.The Company and its members shall compete fairly with competitors under the principle of free competition.
3.Transaction conditions, procedures, and contracts shall be made transparent, in accordance with the laws and regulations as well as market order.
4.Suppliers shall not provide any money, valuables, entertainment, favors, etc. to the executive and employees of the Company.
5.A supplier that provides illegitimate gains to an executive and/or employee of the Company, thereby undermining the Company’s ethical management, may be placed in a disadvantageous position in terms of business as a result.

Article 10 (Mutual Respect and Pursuit of Joint Advancement)

1.All suppliers shall be guaranteed an equal position and mutual respect.
2.Suppliers shall be able to freely voice their opinions in regard to the business dealings with the Company, and efforts shall be made toward improved competitiveness for both parties and joint advancement.

Article 11 (Pursuit of Customer Satisfaction and Protection of Customer Information)

1.The Company and its members shall make every effort to grasp the customer expectations and demands when it comes to quality, reliability, and safety, and supply products and services that meet such expectations and demands.
2.Product performance and risks must be accurately communicated to customers order for them to make reasonable choices, and false or exaggerated advertisements shall not be used.
3.The Company shall comply with the laws concerning customer information protection, and members handling the personal information of customers shall protect personal information in accordance with relevant laws and regulations and the Company’s policies and regulations, and shall not use customer information for purposes other than the purpose for which it was provided or provide customer information to a third party, unless customer consent has been obtained or such is permitted by law.

Article 12 (Drafting and Disclosure of Management Information)

1.Accounting information shall be accurately recorded and maintained in accordance with the generally accepted accounting principles and relevant laws and regulations, and information shall not be distorted or concealed.
2.Management information shall be disclosed to external stakeholders in a fair and transparent manner in accordance with relevant laws and regulations and the Company’s regulations and policies.

Article 13 (Fair Trade and Competition)

1.Members must clearly understand and comply with laws and regulations related to fair trade and the Company’s regulations on managing compliance with fair trade.
2.Any matters that may be interpreted as violations of laws and regulations related to fair trade must be dealt with after a sufficient consultation with the department in charge of fair trade or legal affairs.

Article 14 (Prohibition of Improper Solicitation and Receiving Money or Valuables)

1.Members must clearly understand and comply with the Improper Solicitation and Graft Act.
2.Any matters that may be interpreted as violations of the above law must be dealt with in advance by consulting the department in charge of legal affairs.

Article 15 (Responsibilities for Safety, Health, and the Environment)

1.Members shall comply with domestic and foreign laws and regulations and international conventions related to safety, health, and the environment, and pursue continuous improvement.
2.A safe working environment shall be created by complying with safety regulations.
3.Members shall actively participate in environmental protection activities in recognition of the importance of environmental issues.

Article 16 (Responsibility)

1.All members, who are responsible for complying with the Code of Ethics and these Guidelines, shall inquire and consult with the leader of the organization or the department in charge of ethical management for any questions that they have and act in accordance with the interpretations provided.
2.The leader of the organization shall be responsible for active support and management so that the affiliated members and the stakeholders involved in the businesses of the Company have a proper understanding of and comply with the Code of Ethics and these Guidelines. The leader of the organization must also set a good example by complying with the Code of Ethics and these Guidelines by responsible and faithful decision-making and action.

Article 17 (Reporting of Violations and Protection of Whistleblowers)

1.Any member who becomes aware of any violations of the Code of Ethics and/or these Guidelines shall the matters to the leader of the organization or the department in charge of ethical management so that it can be resolved promptly, thereby protecting the Company and its members from such violations.
2.The identity of the whistleblower and details of the report shall be protected, and there shall be no penalty whatsoever for legitimate whistleblowing.
3.Those who cooperated in the investigation related to the report shall be equally protected.
4.If a whistleblower judges that his or her identity will become exposed or that there is a possibility that his/her life may be threatened due to the report he/she has filed,or he/she is actually placed in a disadvantageous situation, the whistleblower may request the department in charge of ethical management for protection measures, andthe department in charge of ethical management shall check the facts related to the matter and take measures to resolve the issue. Measures to prevent recurrences thereof, including restrictions against related individuals, shall be established and implemented.
5.Anyone who has violated the provisions concerning whistleblower protection (act of seeking retribution by placing the person in a disadvantageous situation, etc., divulging the identity of the whistleblower and the content of the report, the act of figuring out who the whistleblower is or instructing such acts, etc.) shall be handled in accordance with the regulations of the Personnel Committee.
6.Rewards may be given to whistleblowers who have contributed significantly to the Company.

Article 18 (Duty of Compliance and Pledge)

1.The members of the company shall be obligated to comply with these Guidelines and to sign the Pledge to Practice Ethical Management on a regular basis every year.
2.Violations of these Guidelines shall be handled in accordance with the Company’s policies and regulations.