Chapter 1 General Provisions

Article 1 (Purpose)

The purpose of these regulations is to establish the fundamental procedures and standards for ensuring compliance with fair trade laws, including the Fair Trade Act and the Subcontracting Act (hereinafter referred to as "fair trade-related laws"), by executives and employees.

Article 2 (Scope of Application)

All executives and employees of the company must comply with these regulations.

Article 3 (Definitions of Terms)

The definitions of terms used in these regulations are as follows:

• 1."Fair Trade Compliance" (hereinafter referred to as "Compliance") refers to executives and employees voluntarily adhering to fair trade-related laws, company regulations, and processes applicable to the company.
• 2."Competition Authorities" refers to government agencies responsible for enforcing fair trade-related laws, including the Fair Trade Commission and its affiliated institutions.
• 3."Fair Trade Compliance Program (CP: Compliance Program)" (hereinafter referred to as "Compliance Program" or "CP") refers to a system that provides behavioral elements and implementation measures for practicing compliance. This includes activities such as employee training, CP monitoring, and the operation of the CP Committee to ensure fair trade compliance.
• 4."Fair Trade Compliance Manager" (hereinafter referred to as "Compliance Manager") refers to the person responsible for overseeing the implementation of compliance.
• 5."Fair Trade Compliance Committee" (hereinafter referred to as "Compliance Committee") refers to an internal consultative body organized to assist the Compliance Manager and promote a culture of compliance within the company.
• 6."Fair Trade-Related Laws" refers to the following laws under the jurisdiction of the Fair Trade Commission:
  • 1)Monopoly Regulation and Fair Trade Act (Fair Trade Act)
  • 2)Fair Transactions in Subcontracting Act (Subcontracting Act)
  • 3)Act on the Regulation of Terms and Conditions
  • 4)Act on Fair Labeling and Advertising
  • 5)Act on Door-to-Door Sales
  • 6)Installment Transactions Act
  • 7)Fair Transactions in Franchise Business Act
  • 8)Framework Act on Consumers
  • 9)Act on the Consumer Protection in Electronic Commerce
  • 10)Consumer Cooperatives Act
  • 11)Product Liability Act
  • 12)Act on Fair Transactions in Large Retail Business
  • 13)Act on the Adjustment of Unfair Concerted Acts Exempted from the Monopoly Regulation and Fair Trade Act
  • 14)Fair Agency Transactions Act
• 7."CP High-Risk Departments" refers to departments within the following headquarters or business units that have a high risk of violating fair trade-related laws
  • 1)Purchasing Headquarters
  • 2)Sales Headquarters
  • 3)Seat R&D Business Unit
  • 4)P/T R&D Headquarters
  • 5)Management Support Headquarters
  • 6)Finance Headquarters

Chapter 2 Organizational Structure and Responsibilities

Section 1 Board of Directors and Representative Director

Article 4 (Board of Directors)

• 1.The Board of Directors appoints the Compliance Manager through a mediation and guarantees the following responsibilities and independent authority for the establishment and effective operation of the Compliance Program (CP):
  • 1)Direct reporting to the Board of Directors
  • 2)Independence
  • 3)Appropriate authority and status
  • 4)Provision of sufficient resources for CP operation
• 2.The Board of Directors reviews the operation of the CP twice a year.

Article 5 (Representative Director)

• 1.The Representative Director must actively support the Compliance Manager with the necessary human and material resources for efficient job performance.
• 2.The Compliance Manager and the CP overseeing department must not suffer any disadvantages in performing their duties.
• 3.The Representative Director declares commitment to establishing a culture of fair trade compliance and ensures that employees actively adhere to CP standards, continuously announcing this commitment externally.

Section 2 Compliance Manager

Article 6 (Appointment and Dismissal)

The appointment and dismissal of the Compliance Manager are as follows:

• 1.The appointment and dismissal of the Compliance Manager must be approved by the Board of Directors.
• 2.The appointment and dismissal of the Compliance Manager must be approved by the Board of Directors.
• 3.The company must clearly communicate to all employees the appointment of the Compliance Manager, as well as their role and independence.

Article 7 (Authority)

The Compliance Manager has the following authority:

• 1.The right to inspect and investigate the state of compliance.
• 2.The right to request improvements and corrective actions for violations of fair trade-related laws or compliance regulations.
• 3.The right to request submission of necessary materials and information for job performance.
• 4.The right to refer employees who violate fair trade-related laws to the disciplinary committee and request sanctions.
• 5.The right to reward departments and employees who contribute to fostering a culture of compliance.
• 6.Any other authority deemed necessary by the Board of Directors.

Article 8 (Duties)

The duties of the Compliance Manager are as follows:

• 1.Duty of care as a prudent manager.
• 2.Duty to operate the Compliance Program efficiently.

Article 9 (Responsibilities)

The Compliance Manager performs the following responsibilities to ensure the efficient operation of the Compliance Program:

• 1.Operation of the Compliance Program
• 2.Establishment of compliance-related plans.
• 3.Organization, task allocation, and overall management of the Compliance Committee.
• 4.Reporting compliance activities and status to the Representative Director or Board of Directors (once per quarter).
• 5.Establishing criteria and guidelines for assessing CP-related risks.
• 6.Conducting compliance status inspections at least once every 6 months.
• 7.Reviewing and implementing sanctions against violators of fair trade-related laws, if necessary.
• 8.Requesting improvements and corrective actions for violations of fair trade-related laws, if necessary.
• 9.Conducting employee education on fair trade-related laws and evaluating its effectiveness (customized training based on department and job characteristics).
• 10.Establishment and operation of the Compliance Code of Conduct.
• 11.Maintaining records of compliance activities and results.
• 12.Cooperation and support with competition authorities and other relevant agencies.
• 13.Other necessary tasks as deemed appropriate.

Article 10 (Independence)

The company ensures the independence of the Compliance Manager as follows:

• 1.Employees must cooperate in good faith when the Compliance Manager requests the submission of materials or information for job performance.
• 2.The company must not impose unfair personnel disadvantages on the Compliance Manager due to their job-related duties.
• 3.The company must actively support the Compliance Manager with the necessary human and material resources for efficient job performance.
• 4.If the Compliance Manager conducts training on fair trade-related laws, the company must ensure that proper education is provided.
• 5.The Compliance Manager has the right to report directly and promptly to the Board of Directors or the Representative Director regarding matters related to their responsibilities.

Article 11 (Dedicated Department)

The department designated by the compliance manager will oversee the overall compliance work within the company, assisting the compliance manager in carrying out his/her duties.

Article 12 (Compliance Officer)

• 1.The compliance manager may appoint a compliance officer and, if necessary, delegate responsibility and authority to him/her
• 2.Unless otherwise specified, the head of the dedicated compliance department serves as the compliance officer.

Section 3 Compliance Program Operation Members

Article 13 (Appointment)

• 1.A team with a high relevance to fair trade-related laws will be selected to appoint the compliance program (CP) operation members (hereafter referred to as CP members).
• 2.The head of the team (department head) will be appointed as the chief CP member, and the deputy CP member will be a manager (G3 level or higher) selected by the team leader.
• 3.The appointment of the chief CP member must be clearly communicated to all employees.

Article 14 (Duties of CP Members)

The CP members will perform the following duties:

• 1.When advancing tasks, they must review in advance whether there are any violations of fair trade-related laws and, if they recognize any unfair practices, they must request a preliminary review from the dedicated department.
• 2.They must regularly monitor and inspect to ensure that employees do not engage in violations of fair trade-related laws. If any violations are detected, they must immediately report them to the dedicated department.
• 3.In the event of illegal conduct, they must closely cooperate with the dedicated department to minimize the administrative actions taken.
• 4.They will document and manage the results of compliance activities, such as improvements in fair trade-related tasks, and send them to the dedicated department.
• 5.They must actively cooperate with the necessary tasks, such as submitting materials and collecting opinions, during investigations by the Fair Trade Commission to ensure a systematic and proactive approach.
• 6.Before submitting statements or requested materials externally, they must have them reviewed by the compliance manager, compliance officer, and the dedicated department.

Section 4 Compliance Committee

Article 15 (Purpose)

• 1.The purpose of the compliance committee is to enhance the fair trade mindset of employees to prevent legal violations in advance.
• 2.It serves as a forum for preliminary discussions and advice, as well as an internal monitoring function to prevent violations of fair trade-related laws.
• 3.In the event of a legal violation, it responds proactively to minimize business losses.

Article 16 (Establishment and Composition)

• 1.The compliance manager may operate the compliance committee, which is composed of the dedicated compliance department and CP members, as an advisory body.
• 2.The chairperson of the compliance committee shall be the compliance manager.
• 3.The compliance manager will designate the secretary of the compliance committee and the chief CP member (team leader).
• 4.An annual personnel change (appointment) will be carried out for the compliance manager, head of the dedicated compliance department, and all chief CP members.
• 5.Personnel changes for some chief CP members In the event of organizational changes or requests to replace the team leader responsible for operations, etc., will be made as soon as possible after the occurrence.

Article 17 (Operation and Roles)

• 1.The compliance committee may be convened upon request by the compliance manager, the head of the dedicated compliance department, or two or more CP members.
• 2.The compliance committee will hold regular meetings 6 times a year (bi-monthly), but ad-hoc meetings may be held when necessary.
• 3.The compliance committee performs the following roles:
  • 1)Setting the basic policies for the company's compliance program
  • 2)Reviewing the compliance operation plan and implementation results
  • 3)Reviewing and deciding on necessary actions for compliance
  • 4)Acting as a pre-discussion body to recommend or advise on necessary compliance actions
  • 5)Reviewing and deciding on disciplinary actions for employees violating fair trade-related laws
  • 6)Responsible for improving and disseminating the compliance program
  • 7)The compliance manager may separately define any additional details related to the compliance committee.

Article 18 (Decision-Making and Record Keeping)

• 1.Matters raised at the compliance committee will be decided by a majority of the attending members, and if there is a tie, the proposal will be considered rejected.
• 2.When there is a matter raised at the compliance committee, the following items must be recorded in the minutes:.
  • 1)Date, time, location, and list of members present
  • 2)Agenda, meeting content, and results
  • 3)Other necessary matters
• 3.In addition to the minutes, meeting materials, attendance records, etc. will be maintained.

Section 5 Employees

Article 19 (Obligations)

• 1.All employees must comply with fair trade-related laws.
• 2.Each team leader (department head) must seek advice from the compliance manager and dedicated department if they believe there may be a violation of fair trade-related laws in the course of their work.
• 3.If a team leader discovers any violations of fair trade-related laws while performing their duties, they must report it to the compliance manager and the dedicated department without delay.
• 4.Business departments must seek a preliminary review from the dedicated compliance department when engaging in transactions with related companies, such as those involving family members' investments, as designated by the dedicated compliance department.
• 5.Employees must actively participate in and cooperate with the company’s compliance program.
• 6.Unless there is a legitimate reason, employees must participate in CP training and complete any additional special training if required.

Article 20 (Reporting and Protection of Whistleblowers)

• 1.Employees must report to their team leader or the dedicated department if they become aware of any violation of fair trade laws in the course of work or if they themselves have committed a violation.
• 2.Reports should be made in the quickest and most convenient way possible, providing detailed descriptions of the violation.
• 3.Employees must not disadvantage or disclose the identity of whistleblowers or reporters.
• 4.Disadvantages includes personnel actions such as dismissal, firing, or disciplinary measures, as well as actions causing mental or physical harm such as public disclosure of names, bullying, physical assault, verbal abuse, improper audits or investigations or disclosure of the result thereof, the termination of contracts, or any economic disadvantage.
• 5.The company will take personnel actions, such as reassignment, if necessary, to protect the whistleblower or reporter from any potential adverse effects.
• 6.Employees must maintain the confidentiality of any information they learn about whistleblowing or reporting, even if it is obtained in the course of their duties or by chance. Any disclosure of such information may result in disciplinary action.
• 7.The company has an obligation to protect whistleblowers who report violations of fair trade laws within the company by ensuring confidentiality, safeguarding their identity, and providing relief from liability.

Chapter 3: Operation of the Compliance Program

Section 1 Declaration of Compliance Commitment

Article 21 (Declaration of Compliance Commitment)

• 1.The representative director must declare a commitment to the implementation of the compliance program to create an environment where employees comply with fair trade laws and actively practice the compliance program.
• 2.The declaration of commitment must be officially documented and made accessible to the company’s employees as well as its suppliers.
• 3.The declaration and commitment must be announced at least once a year using various media, including the company’s website, and must include employees, clients, suppliers, and other stakeholders as the target audience.

Section 2 Compliance Manual

Article 22 (Compliance Manual))

• 1.The compliance manager must create and distribute a compliance manual (regulation manual) that provides detailed guidelines for compliance with fair trade-related laws.
• 2.The compliance manual should be written with the company’s organizational structure and characteristics in mind, and it must be user-friendly for employees.
• 3.When there are changes to relevant laws, regulations, or rules, the compliance manual must be promptly updated to reflect those changes.
• 4.The compliance manual and checklist should be distributed first to CP high-risk departments.

Section 3 Pre-Consultation System

Article 23 (Pre-Consultation System)

• 1.Employees must consult with the compliance manager and the dedicated compliance department in advance regarding fair trade-related laws and any other compliance-related matters.
• 2.The dedicated compliance department operates the following pre-consultation systems:
  • 1)Legal Support System: Prior to contract signing (new or renewal), the contract’s content and compliance with fair trade-related laws must be reviewed through the legal support system
  • 2)Pre-Review of Private Contracts: Cooperation and approval for documents (approvals, reports) related to private contracts with affiliates.
  • 3)CP Committee: A company-wide consultation body that provides pre-advice and shares information on compliance issues regarding fair trade-related laws.
  • 4)Ad-Hoc Consultation: Employees are guided to seek pre-consultation on fair trade issues when advancing tasks, such as through emails.
• 3.The company effectively operates the various pre-consultation systems mentioned in Paragraph 2 and includes related standards in its internal regulations.
• 4.The company must document the content of consultations through the pre-consultation system.
• 5.The company will use the pre-consultation system to prevent employees from violating fair trade-related laws and will manage related cases.

Section 4 Monitoring System

Article 24 (Monitoring System)

• 1.The department in charge of compliance shall monitor compliance with fair trade-related laws and regulations at least once a half year and report the results to the CEO.
• 2.The department in charge of compliance establishes a regular monitoring plan related to CP every year in consideration of the following matters, and conducts monitoring according to the plan.
  • 1)Compliance with the company's business process: Prior business consultation system
  • 2)Compliance with fair trade-related laws and regulations: Fair Trade Act, Subcontracting Act, etc.
  • 3)Matters that are deemed necessary to be monitored according to the company's situation in addition to fair trade-related laws and regulations
• 3.The monitoring plan of the compliance department establishes and operates an independent plan separate from the monitoring plan of the management improvement team, which is the internal audit department.
• 4.The auditor who conducts monitoring related to CP may be composed of personnel who satisfy one or more of the following conditions.
  • 1)A member of the compliance department who has a domestic lawyer or overseas lawyer qualification
  • 2)A member of the compliance department who has sufficient ability to carry out compliance checks in the judgment of the head of the compliance department
• 5.The authority of the auditor to carry out the monitoring is as follows.
  • 1)A member of the compliance department who has a domestic lawyer or overseas lawyer qualification
  • 2)A member of the compliance department who has sufficient ability to carry out compliance checks in the judgment of the head of the compliance department
  • 3)Improvement and correction request based on CP monitoring results
  • 4)Requests for other matters necessary for CP monitoring 구
• 6.The duties of the auditor to carry out the monitoring is as follows.
  • 1)Fair monitoring shall be carried out.
  • 2)Information acquired during the monitoring process may not be used for any purpose other than job purposes.
  • 3)Monitoring shall be carried out based on facts and evidence, and sufficient records and data shall be obtained in relation to the monitoring.
• 7.The individual monitoring work of the compliance department follows the following procedures.
  • 1)The monitoring plan including the specific plan such as the purpose. contents and method of the inspection, the composition of the inspection personnel, the inspection checklist, and the on-site interview implementation plan shall be reported to the Compliance Manager, and the approval shall be obtained before proceeding.
  • 2)If necessary, the department in charge may hold a meeting with the head of the department subject to inspection before the start of the monitoring to discuss the scope and purpose of the inspection and the inspection schedule.
  • 3)The department in charge may decide on the findings and related improvement measures in consultation with the head of the department subject to inspection.
  • 4)The department in charge prepares a report on the results of individual monitoring and reports it to the Compliance Manager, and manages the implementation of improvement measures.
• 8.Employees of the department subject to inspection shall cooperate so that monitoring activities can be carried out smoothly.

Section 5 CP Risk Assessment Criteria and Procedures

Article 25 (CP Risk Assessment Criteria)

• 1.CP risk assessment refers to the risk assessment of the high-risk department in relation to the fair trade-related laws and regulations.
• 2.CP risk assessment is conducted in conjunction with compliance management system (ISO37301) risk assessment.
• 3.When assessing CP risk, the risk is evaluated using the following indicators (heat map).

  Heat map

  1. Impact-Likelihood Heatmap

  

  영향력 표로 영향력, 설명, 가이드 정보제공

  Impact	Description	Guide
  Catastrophic	Asset recovery is impossible, or the scale of damage is extremely large.	To be decided based on the company's losses and reputation, etc.
  Significant	Requires review and approval by top management or senior executives.
  Moderate	Review and approval by senior management may be required.
  Low	There is a slight impact on assets.
  Negligable	The impact on assets is minimal.

  발생가능성 표로 영향력, 설명, 가이드 정보제공

  Likelihood	Description	Guide
  Frequent	The possibility of these issues arising is very high.	To be decided based on the frequency of potential issue occurrence, as well as the current and future likelihood of occurrence.
  Probable	The possibility of these issues arising is high.
  Occasional	There is a moderate possibility of these issues arising.
  Remote	The possibility of these issues arising is low.
  Improbable	The possibility of these issues arising is almost none.

• 4.The department in charge of compliance checks and updates the CP risk assessment criteria once a year.
• 5.The department in charge of compliance shall conduct CP risk assessment at least once a year and report the results to the Compliance Manager and the CEO.
• 6.Employees of departments subject to CP risk assessment shall cooperate to ensure that CP risk assessment is carried out smoothly.

Article 26 (CP Risk Assessment Procedure)

• 1.The detailed procedure for CP risk assessment is as follows.
  • 1)Check the work process and obligations of the department subject to CP risk assessment
  • 2)Identify potential risk factors and causes that may occur in the work process
  • 3)Use the heat map to identify unique risks
  • 4)Establish primary control mechanism and identify residual risks
  • 5)Establish secondary control mechanism for residual risk s
  • 6)Designate a risk management person and set a risk management (monitoring) cycle
• 2.The department subject to CP risk assessment shall actively cooperate with the entire process of CP risk assessment so that the department in charge of compliance can effectively assess CP risks and establish improvement measures.

Section 6 Implementation of Educational Programs

Article 27 (Purpose)

The Compliance Manager and the Compliance Department shall plan and operate training programs to establish a culture of fair trade compliance within the company and to prevent employees from violating the law.

Article 28 (Scope of application)

It applies to fair trade-related education operated by the Company.

Article 29 (Classification of Education)

Education shall be divided into basic education, intensive education, special education, and executive education.

• 1."Basic education" refers to compliance training conducted once a year for all employees and introduction to CP through the company's website.
• 2."Intensive education" refers to specialized training such as fair trade law training and subcontracting law training for CP high-risk departments.
• 3."Special education" refers to training for students who have not completed CP education.
• 4."Executive training" refers to training for key employees with decision-making authority.

Article 30 (Responsibilities and Authority)

• 1.The responsibilities and authority of the Compliance Manager in relation to the implementation of the training program are as follows.
  • 1)Identify tasks related to compliance regulations and assign tasks to relevant executives and employees.
  • 2)Provide training. if necessary, in the event of a change in the main contents of the compliance regulations or revision of the Fair Trade Act.
  • 3)Determine the details required in relation to the training separately.
• 2.The responsibilities and authority of the department in charge of the implementation of the training program are as follows.
  • 1)Establish and report an annual training plan every year, and consider the characteristics and circumstances of each department when establishing an education plan.
  • 2)Evaluate and report on individual education courses.
  • 3)Select the subjects for each training course and inform the subjects of the training schedule.
  • 4)Report on the results of the annual training every year.
  • 5)For those who have not completed the training, extend the existing training period or provide a special training to complete the training.

Article 31 (Procedures)

Training related to compliance shall be conducted based on the following basic principles, except in special cases.

• 1.Establishment of an educational plan
  • 1)A training plan shall be established on a monthly basis every year.
  • 2)The training plan shall include the purpose and objectives, the target persons and department, the instructor, the content of the training, the teaching method, the evaluation of effectiveness, the schedule, etc.
  • 3)When establishing a training plan, the results of the evaluation of the effectiveness of the previous training, the VOC of executives and employees, and the revision of the Fair Trade Act and mandatory laws and regulations shall be reflected.
  • 4)When establishing a training plan, a separate training program shall be prepared for employees who are likely to violate fair trade-related laws and regulations.
  • 5)When establishing a training plan for the next year, the Compliance Manager shall reflect the improvement points based on the evaluation results of the previous year's education effectiveness.
• 2.Selection and guidance of training subjects
  • 1)The department in charge selects the trainees for each job and position according to the type of training course and informs each team of them.
  • 2)The department in charge separately conducts training for CP high-risk departments and collect feedback.
• 3.Implementation
  • 1)In principle, the training should be conducted by the department in charge under the direction of the Compliance Manager.
  • 2)The trainee shall check the training room, instructors, and materials before proceeding with the training.
  • 3)The person in charge of the department in charge shall manage the schedule of the training course.
  • 4)To prevent the occurrence of non-completion, the completion of the education shall be encouraged, and for those who have not completed the course, the training period shall be extended or special education shall be provided to complete the education.
• 4.Reporting of training results
  • 1)A report on the training results shall be prepared and kept after approval by the Compliance Manager.
• 5.Evaluation of effectiveness after training
  • 1)After the training, the understanding and satisfaction of employees shall be evaluated.
  • 2)Satisfaction with education, understanding of education, appropriateness of instructors and teaching plans, and improvement points shall be used as effectiveness evaluation indicators.
    - Attendance rate: Number of participants÷ education targets
    - Understanding: Evaluate employees' comprehensive understanding of the core content of the training
    - Satisfaction: An index that evaluates employees' overall satisfaction with the training (content, time, appropriateness)
    - Adequacy of instructors and teaching plans: An evaluation index of whether suitable instructors have been selected for education and whether the teaching plan used during training is well structured
    - Improvements: An evaluation index to identify improvements and complementary points in CP education and reflect them in future education plans
• 6.Matters not stipulated in this regulation related to the CP training program shall be separately determined by the Compliance Manager and implemented by the Compliance Department.

Section 7 Sanctions against Employees who Violate Fair Trade-related Laws and Regulations

Article 32 (Purpose)

The purpose is to maintain equity and transparency in sanctions for violations of the law by employees to prevent the recurrence of violations of the law in the future.

Article 33 (Scope of Application)

• 1.When taking sanctions against violators of the Fair Trade Act, the Compliance Manager shall impose sanctions in accordance with the disciplinary standards of the "Employment Rules" and "Personnel Management Regulations".
• 2.If there are unavoidable circumstances, such as changes in the company's management conditions or laws and regulations, these provisions may not be applied.

Article 34 (Criteria for Sanctions)

• 1.If violations of the Fair Trade Act, Subcontracting Act, or other relevant laws significantly disrupt fair trade order or cause losses to the company or its business partners, sanctions may be applied differently based on the extent of the financial loss, the amount related to the illegal or unfair conduct, and the degree of reputational damage to the company.
• 2.If the violator and their manager have fulfilled their duty of care as responsible employees, if the company's loss is minimal, or if the violation has been corrected before or during monitoring, sanctions may be reduced or exempted.
• 3.Mitigation of sanctions will only be considered if supporting evidence from the monitoring results is available.
• 4.The sanction criteria under this regulation shall, in principle, apply to those primarily responsible for the violation.
• 5.Violations not specified in this regulation shall be handled in accordance with the company's HR policies and employment rules.
• 6.In unavoidable circumstances, such as changes in the company’s management conditions or relevant laws, this regulation may not be applied.

Section 8 Rewards for Employees

Article 35 (Reward for Contribution to Compliance Operation)

The company may provide rewards or appropriate compensation to employees and teams who have been recognized for their contributions in the operation of the Compliance Program in accordance with company regulations, HR policies, and employment rules.

Article 36 (Reward Inspection Results of Compliance with Fair Trade-related Laws)

The Compliance Manager may grant rewards or appropriate compensation to teams and employees who demonstrate excellence in compliance with fair trade-related laws, in accordance with company regulations, HR policies, and employment rules.

Article 37 (Reward for Whistleblowers)

The company may grant rewards or appropriate compensation to whistleblowers who report internal violations of fair trade-related laws if their contributions are recognized, in accordance with company regulations, HR policies, employment rules, or this regulation.

Section 9 Whistleblowing System

Article 38 (Whistleblowing System)

• 1.The Compliance Manager must establish an internal whistleblowing system that includes procedures and standards for reporting legal violations.
• 2.The Compliance Manager must ensure that employees who report violations through the internal whistleblowing system are fully protected from retaliation, discrimination, or any adverse personnel actions from other departments. Additionally, the Compliance Manager and employees of the Fair Trade Compliance Department must guarantee the confidentiality of whistleblowing reports, except for purposes related to handling the report.
• 3.If a report is deemed to have contributed to the prevention of legal violations, the Compliance Manager may provide incentives to the reporting employee.
• 4.The establishment of the internal whistleblowing system and the handling of reports shall follow the provisions of the "Whistleblower System Operation Regulations," specifically: Article 5 (Receipt of Reports), Article 6 (Management of Reported Cases), Article 7 (Investigation Decision and Initiation), Article 8 (Reporting Investigation Results), and Article 9 (Notification of Investigation Results).
• 5.If a legal violation is discovered or there is a high possibility of a violation, the whistleblower may report it through the cyber whistleblowing system on the company website, by mail, email, or fax, in accordance with Article 5 (Receipt of Reports) of the "Whistleblower System Operation Regulations.“
• 6.The regulations regarding the protection of whistleblowers shall follow Article 11 (Whistleblower Protection) of the "Whistleblower System Operation Regulations.

Section 10 Reporting System

Article 39 (Direct Reporting System)

• 1.If the Compliance Manager confirms a clear violation of the law by an employee (including an act that the Compliance Manager judges to be highly likely to violate the law), the Compliance Manager may report it directly to the President without sharing the relevant facts with the relevant departments or seeking their cooperation, considering the urgency and importance of the act.
• 2.The CEO shall check the results of the report pursuant to Paragraph 1 above and take measures to resolve problems if necessary.

Chapter 4 Document Management

Section 1 Document Management

Article 40 (Purpose)

The purpose is to effectively manage the operation status of the Compliance Program and to provide incentives.

Article 41 (Scope of Application)

Applies to the systematic creation, storage, and disposal of the company’s fair trade-related documents.

Article 42 (Definitions of Terms)

The definitions of the terms used in these provisions as follows.

• 1."Document management" refers to the management of the flow of documents that occur during the performance of work, from storage to disposal.
• 2."Storage" refers to the fact that a completed document is still in use in the office.

Article 43 (Responsibilities and Authority)

The responsibilities and authority of the Compliance Manager are as follows.

• 1.Basic documents related to compliance shall be maintained, managed, and controlled under the responsibility of the Compliance Manager.
• 2.Documents that are deemed to be legally important must be thoroughly prepared and stored so that they can be used as evidence in the future.
• 3.All documents related to compliance activities must be accurately recorded and contain up-to-date information.

Article 44 (Documents subject to Management)

All departments shall keep compliance-related documents falling under the following items.

• 1.Department-specific distributed compliance manuals
• 2.Contracts and annexed documents signed by the department
• 3.Agreements, memoranda, etc., drafted with external business counterparties by department
• 4.Documents related to compliance training
• 5.Documents received by the department related to relevant laws, such as those from the Fair Trade Commission and Korea Fair Trade Mediation Agency, which are deemed necessary to be retained
• 6.Documents related to the evaluation of the effectiveness of compliance program
• 7.Other documents related to fair trade laws that are deemed necessary to be retained

Chapter 5 Evaluation of Operational Performance

Section 1 Evaluation of Operational Performance

Article 45 (Evaluation of Effectiveness)

• 1.In order to operate the compliance program continuously and effectively, the Compliance Manager shall review the effectiveness evaluation related to the operation of the compliance program at least once a year and utilize the results to improve and develop the compliance program.
• 2.When evaluating the effectiveness of the compliance program, it should be evaluated according to the following items.
  • 1)Actual performance compared to the annual compliance program operation plan
  • 2)Understanding and awareness levels of employees regarding the compliance program
  • 3)Appropriateness of the budget and personnel for the fair trade department
  • 4)Outcomes of compliance program-related training
  • 5)Performance of the incentive system
  • 6)Inspection of legal violation records and prevention effects
  • 7)Satisfaction with the CP operation by the compliance department

Article 46 (Evaluation of Compliance Management KPIs)

• 1.The company establishes compliance management as an organizational KPI to build a fair trade compliance culture, enhance employees' legal awareness, and establish a legal management system.
• 2.The components of the compliance management organizational KPI are as follows:
  • 1)Compliance self-assessment completion rate (for assigned personnel)
  • 2)Ethics and compliance pledge collection rate
  • 3)Compliance training completion rate
• 3.The results of the compliance management KPI evaluation are reflected in the evaluation of the organization (headquarters and departments).
• 4.The compliance management KPI evaluation scores and grades are as stated in Attachment 1 ('24 Compliance Management KPI Operation Plan), and the evaluation criteria for compliance management KPIs may be changed at the company's discretion.
• 5.The overall matters related to the compliance management organizational KPI are decided in consultation with the company's KPI department.

Article 47 (Follow-up Management)

The Compliance Manager reports the results of the effectiveness evaluation and improvement plan to the CEO and reflects them in the improvement of the CP system.

Chapter 6 Disclosure

Section 1 Disclosure

Article 48 (Disclosure)

The Compliance Manager shall post the operation status of the Compliance Program on the Company's website and make external disclosure if necessary.

Chapter 7 Delegation

Section 1 Delegation

Article 49 (Delegation)

The Compliance Manager may separately establish and operate the details for the efficient and smooth operation of these Regulations.

Chapter 8 Supplementary Provisions

Article 1 (Effective Date)

These revised regulations shall take effect on May 20, 2024. (These regulations shall take effect on January 2, 2019)

Article 2 (Consultation)

If any questions arise in interpreting or implementing competition law-related tasks, consultation with the Compliance Manager or the Compliance Committee should be sought, and advice should be obtained.

Article 3 (Relationship with Other Regulations Within the Company)

Compliance regulations shall take precedence over other regulations within the company.

Chapter 1 General Provisions

Article 1 (Purpose)

HYUNDAI TRANSYS Co., Ltd. (hereinafter referred to as the "Company") establishes and enforces the "Regulations on Sanctions for Employees Violating Fair Trade Laws" to ensure fairness and transparency in sanction measures for violations of fair trade-related laws (hereinafter referred to as the "Law") and thereby to prevent future violations of the Law.

Article 2 (Scope of Application)

These regulations apply to employees who violate the Law, within the scope of the disciplinary standards set forth in the Company’s personnel management regulations and employment rules.

Article 3 (Definitions)

The terms used in these regulations are defined as follows:

• 1)"Personnel Management Regulations and Employment Rules" refer to the Company's general/research personnel management regulations and employment rules.
• 2)"Sanction Measures" refer to strict disciplinary actions taken by the Company against employees who engage in structural or repeated violations of the Law, with the goal of fostering awareness of voluntary compliance with fair trade practices.

Chapter 2 Authority and Procedures

Article 4 (Disciplinary Request)

If the Compliance Manager identifies a violation of the Law by an employee through monitoring, reports, or other methods, they may review the necessary sanction measures under these regulations and request disciplinary action against the violating employee from the Human Resources Department and the Disciplinary Committee.

Article 5 (Corrective and Preventive Measures)

If a violation under Article 4 is minor and can be immediately corrected, the Compliance Manager may require corrective and preventive measures from the relevant employee or department without imposing disciplinary action.

Article 6 (Procedures)

• 1)When the Compliance Manager requests disciplinary action, the Personnel Committee or Disciplinary Committee shall review and decide on the imposition of sanctions based on the monitoring investigation report submitted by the Compliance Manager, taking into account the severity of the violation and relevant circumstances of the violator.
• 2)The CP Department shall assist the Compliance Manager in handling the procedures under Articles 4 through 6 and maintain records of sanction measures.

Chapter 3 Types and Criteria of Sanctions

Article 7 (Types of Sanctions)

The types of sanctions that may be imposed on individuals who violate fair trade laws shall follow the disciplinary action criteria outlined in the personnel management regulations for general/research employees.

Article 8 (Criteria for Sanctions)

• 1.If a violation of the Fair Trade Act, Subcontracting Act, or other related laws significantly disrupts fair trade order or causes losses to the company or its business partners, the severity of the sanctions may be adjusted based on the amount of financial loss, the scale of the illegal or unfair activity, and the extent of damage to the company’s reputation.
• 2.If the violator and their supervisor have exercised due diligence as responsible employees, if the company has suffered minimal losses, or if corrective actions were completed or in progress before monitoring took place, sanctions may be mitigated or waived.
• 3.Mitigation of sanctions shall only be considered when supporting evidence from monitoring results is available.
• 4.The sanction standards under these regulations shall, in principle, apply to those primarily responsible for the violation.
• 5.Violations not specified in these regulations shall be handled in accordance with the company’s personnel regulations and employment rules.
• 6.If unavoidable circumstances arise, such as changes in the company’s business environment or legal regulations, these regulations may not be applied.

Chapter 4: Supplementary Provisions

Article 1 (Effective Date)

• 1.These regulations were first established and enforced on July 17, 2023.