Preamble

This code of ethics establishes the ethical values and behavioral standards that must be preserved and developed by all POSCO Group employees by inheriting the foundational spirit of patriotism in steelmaking based on sacrifice and service while reflecting the new spirit of the times.

It is our unchanging value to establish a corporate image that can be trusted by all stakeholders with the highly prioritized value criteria of integrity, fairness, and honesty.

As a result, POSCO SILICON SOLUTION enacted the code of ethics in 2023 that must be adhered to by all employees, and explicitly included US Human Rights that proclaims support and respect for human life and dignity in 2014.

At this time, POSCO has amended the code of ethics with tighter ethical standards according to the intent of management innovation that places the highest value on ethics in management.

All employees of POSCO Group must strictly comply with the principles of ethics and uphold the guidelines set forth by this code of ethics in all aspects of business.
This is how we all can proudly preserve the credibility of POSCO as we know it today, built on the blood, sweat, and tears of our founding members.

Principles of Ethics

• Duty of Compliance with the Code of Ethics

  ①We must comply with related rules and regulations in all areas of the world where POSCO SILICON SOLUTION is conducting business operations.

  ②We must retain our dignity as POSCO SILICON SOLUTION employees and make efforts to maintain the company's reputation.

  ③We must preserve integrity, fairness, and trust throughout all jobs and business relations.

  ④We must not become engaged in activities in which there are conflicts of interests between the company and individuals.

  ⑤We must not irrationally discriminate against other employees or stakeholders based on race, nationality, gender, age, educational background, religion, region, disability, marital status, and sexual orientation, and must respect the dignity and diversity of each individual.

  ⑥We must make efforts to create a safe workplace and protect the environment.

  ⑦We must be devoted to establishing an ethical culture by taking responsibility and upholding ethical conduct.

• Role and Responsibility of Employees

  Employees must understand and practice all aspects of the code of ethics, and comply with domestic and international laws regarding anti-corruption as members of a global company. 1) Understanding and Complying with the Code of Ethics.

  ①We must fully understand and faithfully comply with all aspects of the code of ethics.

  ②Regarding situations in which there are conflicts concerning the code of ethics, decisions must be made after consulting with the department head or the Ethics Management Office. We must report to or consult with the Ethics Management Office immediately without making an internal report to the department head for issues that hold a risk of secondary victimization, such as the violation of sexual ethics, and/or workplace bullying.

  ③We must take responsibility for unethical conduct.

  2) Reporting and Consulting Unethical Conduct

  ①If we find out that our or others' behavior conflicts with the code of ethics, we must immediately report to and consult with the department head or the Corporate Audit Department. We must report to or consult with the Ethics Management Office immediately without making an internal report to the department head for issues that hold a risk of secondary victimization, such as the violation of sexual ethics, and/or workplace bullying.

  ②We must be aware of various methods to report or consult about cases in which there are conflicts over the code of ethics.

  3) Role and Responsibility of the Leader

  The leader must perform a key role in enhancing the competitiveness of the company by preventing and eradicating unethical conduct through ethical compliance.

  ①Decision-making : The leader has the obligation to make decisions with ethics being the top priority whenever the company’s benefits conflict with ethics

  ②Operational accountability : The leader possesses unlimited liability in unethical conduct, and must take supervisory responsibility in case of unethical conduct by his or her subordinates

  ③Job performance : The leader strictly abides by the law, does not pursue private interests, is devoted to creating corporate values, and does not deal with corrupt stakeholders.

  ④Elimination of favors and solicitations :The leader aims to eliminate all forms of favors and solicitations and eliminates business influence in relation to outsiders.

  ⑤Respect for humans : The leader strives to eliminate conduct that impairs respect for fellow humans such as sexual harassment and verbal abuse in the organization.

  ⑥Prevention of conflicts of interests: The leader makes efforts to prevent conflicts of interest with personal stakeholders who are employees of affiliated companies and eliminate unfair trade practices of offering preferential treatment on the grounds of personal interest.

  ⑦Practical activities : The leader is devoted to increasing the level of ethical practice to that of world-class levels by taking the initiative in operating the ‘Ethical Practice Programs’.
  The leader must also prevent unethical conduct of members, and take the following measures in case of such conduct.

  4) Training and counseling on ethics

  ①The leader must provide training and counseling on ethics for relevant staff.

  ②The leader must have relevant staff understand the importance of compliance with the code of conduct and practice of ethical conduct.

  5) Precautions for unethical conduct

  ①In case of unethical conduct that occurs habitually, the leader must isolate the cause, improve the process, and fundamentally take preventive measures.

  ②The leader must report to or consult with the Corporate Audit Department immediately after receiving a report that a member has violated the code of ethics

• Penalty for Violation of the Code of Ethics

  Employees violating the code of ethics may receive certain penalties including dismissal according to related regulations. Penalties against violating the code of ethics will apply to all related parties, and if the violation also violates the law, the parties will be reported to the competent authority. In particular, the zero tolerance policy is applied to unethical conduct such as accepting bribes, embezzlement, fabrication of information, and disrespect for humans

  ①If one has violated the code of ethics or demanded others to do so

  ②If one has not immediately reported a violation of the code of ethics that he or she is aware of or is skeptical about

  ③If one does not cooperate with the investigation of the Corporate Audit Department regarding matters that may have violated the code of ethics

  ④If one takes retaliatory action against other employees who reported an issue regarding ethical management​

Practice Guidelines

• Practice of Ethics and Compliance with Law

  As a global enterprise, we will nurture ethical corporate culture by performing management activities faithful to basic principles and complying with laws and ethics. 1) Money and Other Valuables

  ①Money and other valuables mean money (e.g. cash, gift certificates, and memberships) and things that can bring economic benefits.

  ② By all means, employees must not demand or receive money and valuables from stakeholders. However, this does not include gifts for promotion or publicity that do not exceed 50,000 KRW, souvenirs with the company’s logo, and souvenirs generally provided by all participants of the events hosted by stakeholders.

  ③If employees had no choice but to receive a gift or souvenir with a value exceeding KRW 50,000, they must return it immediately. If it is difficult to return it, they must report it to the Corporate Audit Department. The Corporate Audit Department must process the received gift and souvenir according to a method specified separately.

  ④If money and other valuables were received unknowingly or involuntarily, such money and valuables should be returned, or if not returnable, should be reported to the Corporate Audit Department.

  2) Entertainment

  ①Entertainment means a variety of activities carried out for the purpose of business networking and business meetings including meals, drinks, golf, shows and games.

  ②Employees must not exchange in forms of entertainment with stakeholders that exceed 100,000 KRW per person. If this is required due to the nature of the business, employees must obtain approval from their department head in advance. If they have inevitably participated in a form of entertainment that exceeds 100,000 KRW, they must report to the Corporate Audit Department. Entertainment at drinking places with hosts/hostesses is prohibited regardless of the amount.

  3) Convenience

  ①Convenience means provision or receipt of benefits such as transportation, accommodation, sight-seeing and support for an event.

  ②Provision or receipt of convenience exceeding customary level whether transportation or accommodation is prohibited, except for the convenience generally provided to all participants in the event.

  ③In the event that entertainment exceeding customary level was received or provided unavoidably, such activity should be reported to the Corporate Audit Department.

  4) Congratulatory or Condolatory Money

  ①Employee should not notify his or his co-worker's congratulatory or condolatory event to interested parties. Notification through a third party will be deemed notification by the employee himself/herself.

  ②Information on congratulatory or condolatory event should be provided through the congratulatory/condolatory bulletin board, and use of work e-mail or sending out a written notice (wedding invitation or obituary notice) for such purpose is prohibited. The permitted scope of the relatives for the purpose of notification of congratulatory or condolatory event is limited to the employees (except inside and outside director of board members) or their spouses' grandparents, parents and children.

  ③Employees are encouraged not to spend more than 50,000 KRW, which is a generally accepted amount based on social customs, as expenditure for congratulations and condolences among employees.

  ④In no event employees may receive any congratulatory or condolatory money from an interested party. In the event that any congratulatory or condolatory money was received unavoidably, the money should be returned to the provider or forwarded to the Corporate Audit Department.

  ⑤Upon the request of the Corporate Audit Department, employees and executives should submit a record relating to the congratulatory or condolatory money received from and returned to the interested party.

  ⑥One should not receive congratulatory or condolatory wreath from the interested party. In the event that the wreath was received unavoidably, it should not be displayed.

  ⑦Executives and employees will not throw an extravagant wedding at an expensive venue such as a five star hotel.

  5) Requests/Recommendations

  ① Employees must not make requests/recommendations regarding the following matters through in-house acquaintances or outsiders, and must register on the 'Clean POSCO E&C System' upon receiving requests/recommendations.
  Request for special favors in equipment/material purchasing and various contracts Request for preferential treatment and special favors in various personnel affairs such as employment, promotions, rewards and punishment, and change of assignment Request for preferential treatment such as excessive conveniences and favors beyond conventional procedures Request for negligence in management and supervision such as inspection or repair

  ②(2) Employees must not make any illegal requests either directly or through a third party in relation to the duties listed in the Improper Solicitation and Graft Act.

  6) Pecuniary Transactions

  ①One should not engage in pecuniary transactions with an interested party such as lending or borrowing of money, providing a guarantee, or leasing of a real estate.

  ②In the event one had to enter into a pecuniary transactions with an interested party unavoidably, it should be reported to the Corporate Audit Department.

  7) Support for Events

  ①One should not receive any support from an interested party, whether money or other valuables, in relation to any event organized by the department or as company extracurricular activities.

  ②Any form of convenience received from an interested party such as transportation, venue or services in relation to such event will be deemed receipt of money or other valuables for the event.

  ③In the event that the interested party's support to an event was received unavoidably, it should be reported to the Corporate Audit Department.

  8) Inappropriate Use of Budget Resources

  ①One should not use budget resources (such as meeting expenses and business promotion expenses) for personal purposes.

  ②As a general rule, company expenditure should be paid by a corporate credit card in accordance with the purpose of the budget and the guidelines prescribed by law.

  9) Protection of Information and Assets

  ①One should strictly protect confidential or important information of the company.

  ②One should relay important information that comes to one's attention promptly to the person who needs to know such information for performance of his job.

  ③One should not fabricate information or disseminate false information.

  ④One should refrain from using company supplies and facilities for purposes not directly related to work.

  10) Compliance with Antitrust Laws

  ①One should comply with relevant international and local antitrust laws and not engage in anti-competitive practices such as collusion with competitors with respect to production, prices, bidding or market segmentation.

  ②One should not demand any form of compensation or make inappropriate request to customers or business partners using one's dominant position.

  ③One should respect the rights and property of others including their intellectual property rights, and should not try to enter into transactions or make profits by infringing upon such rights.

  ④One should legitimately obtain and use other company information including competitor's information.

  11) 이해충돌 방지

  ①이해충돌이란 거래 관계사 임직원과의 사적 이해관계가 임직원의 직무수행에 부적절한 영향을 미치는 경우를 뜻한다.

  ②퇴직임직원을 포함한 사적 이해관계가 있는 거래 관계사 임직원의 부적절한 요청사항은 철저히 배제하여 이해충돌을 방지한다.

  ③사적 이해관계가 있는 거래 관계사 임직원과 비공식적인 접촉을 하지 않으며, 의도하지 않은 접촉 시에는 부서 상급자 또는 윤리경영사무국 윤리책임관에게 보고한다.

  ④회사의 승인을 받지 않은 퇴직임직원 모임에는 참석하지 않는다.

  ⑤퇴직임직원 모임은 퇴임 후에 가입하고, 현재 가입되어 있는 경우 부서 상급자에게 보고 및 탈퇴한다.

  ⑥거래 관계사 임직원과 사적 이해관계가 있는 경우 부서 상급자 또는 윤리책임관과 상담 후 결과에 따라 업무 재배정 등의 조치에 동의한다.

  ⑦사적 이해관계를 이유로 특정 개인, 법인 등을 우대하여 부당한 수의계약 체결, 고가 구매, 물량 몰아주기, 거래정보 사전유출 등의 불공정 거래를 하지 않는다.

  ⑧퇴직 후에도 포스코 및 포스코그룹사와의 이해 충돌을 방지한다.

  12) 회계처리

  ①회계처리기준을 위반하여 재무제표를 작성하여서는 안된다.

  ②회계부정행위를 하거나, 인지한 경우 윤리경영사무국에 신고하여야 한다.

• Employees and Executives' Work Life Balance

  We will pursue personal growth and corporate development by maintaining work and life balance, and create a happy workplace by establishing a corporate culture of mutual respect. 1) Pursuit of Work Life Balance

  ①We will try to improve the quality of life of the executives and employees by providing benefits helpful for maintaining stable life.

  ②We will support executives and employees to achieve their individual visions, and allow them flexibility in terms of the time, places and methods in performing the work.

  2) Provision of Opportunity for Education and Growth

  ①We will organize work environment and systems where creativity can be enhanced.

  ②We will support executives'and employee's education and participation in development programs such that they can fully develop their potentials.

  3) Fair Evaluation and Compensation

  ①We will make impartial and systematic evaluation system of the executives and employees based on their individual competency and performance and provide appropriate compensation therefor.

  4) Creation of Healthy Organizational Culture

  ①Executives and employees will work for open corporate culture through open communication.

  ②Executives and employees will work for open corporate culture through open communication.

• Creation of Customer Value and Building Trust

  Recognizing that customers' trust and success is the future for us, we will always respect customers' opinions, understand customers and create values that are helpful for customers' growth. 1) Realization of Customer Satisfaction

  ①We will perform customer-oriented work where the voice of customers is heard and respected.

  ②We will actively accommodate customer’s legitimate demand and reasonable suggestions.

  2) Creation of Customer Value

  ①We will satisfy customer's needs by providing the best products through continuous technology development.

  ②Executives and employees will try to understand the domestic and overseas market situation and develop service mind that respects customers' culture and practices.

  3) Obtaining Customer Trust

  ①We will pay due attention to the safety and health issue of the customers in our management activities, and not provide any product or service that might threaten customer's safety and health.

  ②We will protect customer information and comply with relevant laws and regulations.

  ③We will provide accurate information to customers on a timely basis.

• Duty of Good Faith and Fair Dealings Toward Investors

  We will maximize investors' values by realizing legitimate profits through transparent decision making and effective management activities. 1) Pursuit of Increased Shareholder Value

  ①We will make profits through transparent decision making and efficient management, and increase corporate and shareholder value at the same time.

  2) Impartial Provision of Investment Information

  ①We will not provide information that might affect the decision making of investors to only certain investors, nor provide partial information.

  ②We will not directly trade stocks or securities nor recommend trading to others using insider information obtained while working for the company.

  3) Transparent Calculation and Provision of Financial Information.

  ①We will process all financial information based on accurate transactions records implementing appropriate process and control.

  ②We will prepare financial reports in accordance with generally accepted accounting standards.

  ③We will provide sufficient and accurate information regarding management of the company to investors so that investors may freely make investment decisions at its own responsibility.

• Building Win-Win Relations with Business Partners

  We will establish fair trade system based on mutual trust and build a corporate eco-system where interested parties co-exist and grow together. 1) Building Mutual Trust

  ①We will pursue fair dealings with our business partners on equal footing and based on mutual respect.

  ②We will strictly protect information received from transactions with business partners in accordance with the terms of the relevant contract and the relevant laws.

  ③We will support business partners to comply with anti-competition related laws and regulations.

  2) Pursuing Mutual Growth with Business Partners

  ①We will pursue mutual benefits by sharing fruitful outcome with business partners.

  ②We will cooperate and communicate openly with business partners such that business partners may provide high quality products and services.

  ③We will provide fair opportunities and reasonable transaction terms to business partners so that they could grow as our long term business partner.

  3) Support for Continuing Development of Business Partners

  ①We will endeavor to build a stable supply chain by providing technical and financial supports to business partners.

  ②We will endeavor to expand the potential pool of business partners that can grow with us in harmonious development of overall corporate eco-system.

• Contribution to the Country and Society

  We will contribute to the growth of the country and society by fulfilling our responsibilities and duties as a global corporate citizen. 1) Roles and Attitude as a Corporate Citizen

  ①We will respect the laws and the regulations of the local laws and regulations as well as local culture and tradition, and endeavor for mutual development with the country and society.

  ②We will encourage participation of and endeavor to communicate with interested parties in performing management activities that may affect country and society.

  ③We will encourage business partners to participate in activities for the development of the country and the society.

  2) Contribution to the Development of the Country and the Society

  ①We will discharge our obligations in the community by creating and maintaining stable jobs and paying taxes in time.

  ②We will actively participate in social service activities, such as volunteer works and disaster relief work, and initiate non profit activities in various fields including culture, arts, sports and education.

  ③We will provide support for residents' effort to improve quality of their lives and pursuit of happy life.

• Protection of Environment and Preservation of Eco-system

  We will establish an environmental management system, strengthen our ability to deal with environmental risks and implement environment-friendly management through open communication. 1) Implementation of Environmental Management System

  ①We will effectively implement environmental management system, evaluate impacts and risk of business activities on environment and analyze and manage the results of environmental management.

  ②We will share benefits and issues with various interested parties, and jointly carry out environmental protection activities.

  ③We will convince business partners to believe that protection of environment is fundamental social responsibility of a company, and support business partners to comply with laws and regulations related to environmental protection.

  ④We will support business partners to manufacture products and provide services while protecting the public health and minimizing adverse effects on the environment and the natural resources of the community.

  2) Complying with Environmental Laws and Improvement on Environmental Impacts

  ①We will endeavor to comply with environmental laws and to improve impacts on the environment in the overall process of developing, producing and using products.

  ②We will minimize discharge of pollutants by introducing environment-friendly manufacturing process and applying technologies optimized for prevention of pollution.

  2) Dealing with Climate Changes

  ①회사는 안정적인 일자리 창출과 유지, 성실한 세금 납부를 통해 지역사회에서의 의무를 다한다.

  ②자원봉사, 재난구호 등 사회봉사활동에 적극 참여하고 문화, 예술, 스포츠, 학문 등 각 분야에서의 공익활동을 전개한다.

  ③지역주민의 삶의 질을 향상시키고 행복한 삶을 누릴 수 있도록 지원한다.

  3) Dealing with Climate Changes

  ①We will endeavor to reduce consumption of fossil fuels or materials, and to minimize discharge of greenhouse gas by improving energy efficiency.

  ②We will enhance competitiveness by developing innovative low-carbon technology.

  4) Protection of Environment and Eco-system

  ①We will endeavor to restore the eco-system and preserve biological diversity through effective use of natural resources and by-products.

•  Protection of and Respect for Human Rights

  We will respect human rights, support international standards for human rights and strengthen dignity of all interested parties by improving freedom, safety and quality of life. 1) Respect for International Standards Regarding Human Rights

  ①We will support and respect internationally recognized standards on human rights, such as Universal Declaration of Human Rights, Guiding Principles on Business and Human Rights, UN Global Compact, and OECD Guidelines for Multinational Enterprises.

  ②We will establish clear policy and system for protection of human rights and endeavor not to violate human rights in our management activities.

  ③We will support business partners to comply with internationally recognized human rights standards and regulations, protect their employees’human rights and treat them fairly.

  ④국제노동기구(ILO)의 협약 및 대한민국이 비준한 협약을 존중하며, 특히 아동노동금지 및 강제노동, 강제노동철폐협약을 존중한다.

  2) Due diligence in Relation to Human Rights

  ①We may, at our discretion, conduct due diligence on management activities that might violate human rights or cause complaints.

  ②We will endeavor to find reasonable resolutions if, upon conclusion of the human rights due diligence, we believe our management activities have violated human rights or caused complaints.

  ③We will communicate with the relevant interested parties regarding human rights related activities and results thereof.

  3) Protection of Executives and Employees

  ①We will not engage in verbal, physical or demonstrative acts that may offend others or infringes other's human rights such as sexual harassment.

  ②We will respect privacy of executives and employees, will not slander or defame others, and will protect personal information.

  ③We will not compel works through mental or physical coercion.

  ④We will comply with local labor laws and international standards with respect to the age and labor conditions of minors.

  ⑤We will strictly comply with safety regulations, and will take appropriate actions upon discovery of risk factors.

  4) Respect and Equality

  ①We will not discriminate or harass for reasons of race, nationality, gender, age, educational background, religion, regional origin, disability, marital status, and sexual orientation.

  ②We will provide equal employment opportunity to those who possess necessary qualification and capability.

  ③We will maintain work environment that respects cultural diversity.

  5) Assurance for Legitimate and Humane Employment Terms

  ①We will take prompt actions for human rights issues raised by executives and employees through the company grievance procedure.

  ②We will offer adequate employment terms such as guaranteeing proper working hours to enable the employees to maintain life with dignity.

  6) Efforts to Respect Community Human Rights

  ①We will endeavor to listen to the opinions of the community and resolve issues of violation of human rights caused by our management activities in the community.