Ethics & Compliance: No compliance, No gain

Hyundai Steel practices transparent management and builds customer trust through its Compliance Program (CP) for fair trade

Code of ethics and compliance declaration

CEO message

Hello, valued employees.
This is President Seok Kang-hyeon.

The time to wrap up the year 2024 is upon us. I would like to express my sincere gratitude and offer words of encouragement to all employees who are diligently fulfilling their roles, despite the challenging business environment both internally and externally.

This year, the company has carried out significant activities related to compliance management, including inspections and training. As a result, we achieved a positive outcome of ‘AA (Excellent)’ in the “Compliance Program Evaluation” conducted by the Fair Trade Commission.
I believe this success is a result of the correct mindset and behaviors instilled in our employees, and I take great pride in the spirit of compliance that has stood out, even in a challenging business environment.

However, we must not become complacent with this achievement. We must continue our efforts to become a truly trusted company for all stakeholders, including our customers.
As you all know, the steel industry is currently navigating a long tunnel, facing challenges due to reduced investments in demand industries and the rapidly changing global landscape.
In these challenging circumstances, we must reflect on ourselves and actively develop and produce our products and services in the right way, adopting a more proactive mindset.
We must strengthen our capabilities by embracing fair competition.

I would like to emphasize the following three points to foster a healthy organizational culture based on ethical values, where all employees support and encourage one another.

First, we must neither give nor follow unjust directives. While you may be tempted to take shortcuts or engage in unethical practices to achieve business goals, please remember that such actions ultimately pose significant risks to both the organization and individuals.

While setting challenging goals, the process must always be conducted within legal boundaries, without exception.

Second, we must all share the same mindset and work together to follow the ‘right path.’ An ethical organization cannot be built by the efforts of just one individual; it requires the collective commitment of everyone. When we all strive to move just a little further in the right direction, our collective efforts will enable Hyundai Steel to grow into a more transparent and trusted “sustainable company.”

Third, results achieved through violations of the law cannot be considered legitimate achievements. Any attempts or activities that violate the law will not be recognized as achievements, and strict accountability will be enforced on the employees involved.
I urge you to assess legal violation risks in all decision-making processes and ensure that operations are conducted in a fair and compliant manner.

Dear employees, we must embody the values of maintaining ‘right thoughts and actions’ and consistently choosing ‘ethical standards and processes’ in every situation.

Although we expect challenging business conditions to persist in the coming year, I am confident that if we all uphold the right values and ethical behavior, we will be able to overcome the crisis and lay the foundation for growth.

As the year comes to a close, I hope you fill the remaining days with good health and rewarding experiences. 12/13/2024
Gang-hyeon Seo, CEO and President of Hyundai Steel

Ethics and Compliance management system

In order to reflect the strong commitment of the management to ethical compliance management and to achieve daily compliance, we have established and operate an organization across the company.

CEO and board of directors

Responsible for overseeing compliance control and the operation of the Fair Trade Compliance Program.

Person in charge
Compliance Support Officer
Appointed under the Commercial Act, responsible for operating
compliance standards and procedures.
Compliance Program Manager
Delegated by the CEO to exercise full authority over fair trade
compliance activities. (Currently, the Compliance Support Officer also
serves as the Compliance Program Manager.)
Compliance Team
Supports the Compliance Support Officer (Compliance Program
Manager) in tasks such as training and audits.
Relevant organization
Compliance Management Committee
Composed of executives from each division, responsible for reviewing
and approving plans and performance related to ethics and compliance
management.
CP Council
Consists of key department leaders, responsible for implementing
compliance activities focused on critical risk areas. (Risk Assessment →
Monitoring & Improvement → Horizontal Deployment)
Compliance Support Officer
Appointed among department heads to promote ethics and compliance
management at the operational level.

Purpose

Hyundai Steel aims to be a global company that contributes to humanity’s dreams with creative thinking and a relentless dive to overcome challenges. As the practice of ethical management is the keystone of such a goal, Hyundai Steel has amended its Ethics Charter and Code of Conduct to become a reliable partner for diverse stakeholders and increase value for our customers. All members of Hyundai Steel should comply with this Ethics Charter and Code of Conduct.

Coverage

This Ethics Charter and Code of Conduct applies to Hyundai Steel, including production and sales corporate bodies at home and abroad, subsidiaries, and the executives and employees of Hyundai Steel should act in accordance with this Ethics Charter and Code of Conduct when dealing with suppliers and sales/service organizations. Executives and employees who work for organizations covered under the scope of this Ethics Charter and Code of Conduct should comply with local laws and perform their duties in accordance with the Ethics Charter and Code of Conduct. Moreover, all stakeholders holding contractual relationships with Hyundai Steel, hereinafter referred to as the “Company”, should respect the content and spirit of this Ethics Charter and Code of Conduct. All persons and organizations who fall under the scope of this document shall perform their duties in accordance with the regulations, policies and rules that guide this Ethics Charter and Code of Conduct. Where this Ethics Charter and Code of Conduct, and related regulations, policies and rules contradict local laws, the local laws shall prevail. In such cases, the Company may amend this document to reflect local legal and industrial obligations, and if necessary, may specifically establish detailed policies in response.

Five guiding principles at Hyundai Steel

  • 1. We shall perform our duties based on clear and transparent standards, and do our utmost to fulfill our responsibilities with integrity.
  • 2. We shall compete fairly in the market and conduct business ethically with parties that engage in contractual relationships with us.
  • 3. We shall provide safe products, exceptional services and accurate information, and we rigorously protect personal information to increase customer value.
  • 4. We shall respect our members as independent individuals, and to this end, we provide fair working conditions and safe working environments.
  • 5. We shall contribute to sustainable development by fulfilling our social & environmental responsibilities as a member of society, so that diverse stakeholders may prosper together in harmony.

Code of conduct

We shall perform our duties based on clear and transparent standards, and do our utmost to fulfill our responsibilities with integrity.

Bribery
We shall not receive any form, monetary or non-monetary, of illegal or unethical benefits and *bribery from our stakeholders, nor do we provide or promise thereof. *Bribery refers to all forms of benefits that provide or are provided for monetary or non-monetary purposes, including money, services, entertainment, gifts, donations, sponsorship, preferential treatment, provision of conveniences, and etc.
Improper solicitation
We prohibit improper solicitation externally between executive and employees and stakeholders, as well as internally between executives and employees.
Conflicts of interest
In cases where conflicts of interests between the Company and individuals are unavoidable, we act in the best interests of the Company and our customers, within the scope allowed by the law.
Insider trading
We shall not leak insider secrets, knowledge or *informationx obtained either directly or indirectly in the course of employment, nor use such illicit gains for the purpose of pursuing individual interest. *Insider trading involves in abusing a company’s secrets, knowledge, sales information, organizational information such as a merger and acquisition, stock price information, and internal decision-making
Workplace ethics
Executives and employees shall do their utmost to fulfill their responsibilities in the course of employment, regardless of time or place, and use the Company’s assets and facilities only for the purposes of fulfilling their duties.
Abuse of power
We shall not abuse our power or status to exert undue influence or pursue illicit benefits for the Company or individuals.
Documentation & reporting
We shall not create misleading documents by hiding, reducing, exaggerating or falsifying information, nor shall we report such documents or share them with internal and external stakeholders.

We shall compete in the market fairly and conduct business ethically with parties that engage in contractual relationships with us.

Anti-trust
We shall not engage in activities that would disrupt fair competition through the pursuit of unfair transactions, such as abusing our market dominance or trading position.
Collusion
We shall not engage in activities with other businesses that would restrict fair competition in terms of the prices, volume, area and terms of products and services, including, but not limited to, price fixing, bid rigging, or improper market allocation.
Unfair competition
We shall not improperly obtain information from competitors, partners, or any other organizations, nor use or disclose information obtained illicitly by the Company or third parties.
Money laundering
We shall not engage in money-laundering activities involving customers, partners, suppliers, or other organizations and individuals.
Intellectual property
We shall protect the trade secrets of suppliers in engaged in contractual relationships with the Company, and shall not infringe on the intellectual property rights of other companies or individuals.
Tax compliance
For transparent and fair compliance with our tax obligations, we shall comply with the tax laws of each and every country where we have business operations, and shall not avoid legitimate tax obligations.
Procurement
We shall seek fair and mutually beneficial relationships with our suppliers, and will not engage in unfair competition.

We shall provide safe products, exceptional services and accurate information, and we rigorously protect personal information to increase customer value.

Customer safety
We shall not make decisions that compromise customer safety, covering all processes from research and development, to raw material procurement, manufacturing, sales and distribution, and after-sales service.
Product/Service quality
We shall not engage in any activities that would compromise the quality standards necessary to provide our customers with exceptional quality products and services in a stable manner.
Complete information
We shall help our customers make informed decisions by providing them with correct and useful information regarding our products and services, and shall not provide falsified or exaggerated information.
Privacy protection
We shall comply with the laws and regulations applicable to protecting customers’ personal information, and shall not engage in activities that would illicitly infringe upon their rights to data privacy.
Customer communication
We shall listen carefully to customers’ feedback on our products and services, and are committed to accepting reasonable demands and recommendations in this respect.
Product/Service accessibility
We shall take any appropriate measures necessary to prevent discrimination against customers who are treated unfairly in terms of access to our products and services based on gender, age, disability, language, etc.
Product liability
We are committed to providing any information necessary to prevent damages and risks to customers, and shall implement appropriate measures to ensure the safety and quality of our products and services.

We shall respect our members as independent individuals, and to this end, we provide fair working conditions and safe working environments.

Human rights
We respect executives and employees as independent individuals, and shall take affirmative action to respect the human rights universally pursed by society.
Child labor and forced labor
We shall comply with the labor laws of the countries where we have business operations, and ban child labor and forced labor in workplace.
Discrimination
We forbid discrimination against executives and employees based on nationality, place of birth, race, gender, age, culture, religion, disability, education, political affiliation, personal tastes, or any other factors.
Equal opportunity
We shall provide executives and employees with equal opportunities for training and capacity development, assess them fairly based on performance, and give them fair compensation.
Harassment
We ban any and all activities, online and offline, that may insult or damage human dignity, such as verbal abuse, sexual harassment, mental or physical coercion, corporal punishment, ostracization, and threats.
Safety and Health
We are committed to taking all measures necessary to ensure the safety and well-being of our executives and employees, and to maintain working environments safe from occupational accidents, injuries, disasters, disease and contagion.
Work-Life balance
We shall endeavor to provide a working environment that promotes work-life balance for our executives and employees.

We shall contribute to sustainable development by fulfilling our social & environmental responsibilities as a member of society, so that diverse stakeholders may prosper together in harmony.

Sustainable development
Through our management decision-making processes, we shall endeavor to fulfill our responsibilities concerning the sustainable development goals (SDGs), with the aim of ending the environmental and social problems facing humanity.
Environment
환We understand that the environment is an invaluable asset to be preserved for future generations, and are committed to implementing responsible actions to minimize any negative impacts on the environment in all management areas.
Philanthropy
We are committed to identifying the social problems facing our society and humanity, and to finding solutions for these issues.
Stakeholder engagement
By proactively identifying stakeholders who may impact, or be impacted by, the company’s decision-making, we are committed to communicating and taking action with regard to important matters concerning sustainability.
Contribution and sponsorship
We shall comply with all internal standards and rules relevant to fairly processing charitable donations and sponsorships, and ban donations and sponsorships of a political nature.
Shareholder value
We shall promote corporate and shareholder value by implementing sustainable management practices.
Information disclosure
We shall make financial and non-financial information publicly available, in accordance with all applicable laws and regulations.

Ethics and Compliance programs

Pre-approval & reporting system

Monitors potential violations of fair trade regulations through a proactive review and reporting process.

Preventive pre-inspection

Annual audits by a dedicated compliance team, with findings reported to the board at least twice a year.

  • Preventing violations related to collusion, unfair trade practices, subcontracting, and trade secrets.
  • Evaluating the effectiveness of the compliance program and gathering Voice of Employees (VOE).

Policy development & update

Regular establishment and revision of policies such as Compliance Control Standards, Compliance Support Regulations, and Fair Trade Compliance Guidelines.

Employee training

To emphasize the importance of ethics and compliance management, various training sessions are conducted that include topics such as workplace ethics, fair trade, subcontracting, and trade secrets.

  • Basic Training: Conducting basic training for all employees
  • Intensive Training: Conducting in-depth training for employees in key departments, considering each area of work
  • Special Training: Fostering awareness and leadership in ethics and compliance for managers or executives
  • On-the-Spot Training: Conducting additional training for those who violate the law and for individuals who have not completed training

Providing guidance

Providing various ethics and compliance guides through IT systems (newsletters, fair trade compliance manuals, text message services, checklists, etc.)

Ethics and compliance campaign

Promoting a culture of ethics and compliance through the creation of ethics and compliance pledges by all employees (regular and non-regular) and various compliance campaigns

Actions against violating employees

Establishing preventive measures to avoid recurrence, along with disciplinary actions and training, in accordance with internal standards.

Effectiveness evaluation

Evaluating the effectiveness of the ethics and compliance program and reporting the results to the Board of Directors at least once a year.

Legal risk assessment

Categorizing major legal violations such as fair trade, subcontracting, and prevention of unfair competition, and analyzing their likelihood and impact to reflect them in the operation of the ethics and compliance program.

Contact Information for Whistle Blowing/Grievance

Hyundai Steel operates a consultation and reporting channel for ethical issues to establish a culture of ethics and compliance management. Submitted matters can only be viewed by the submitter and the responsible personnel, and the company protects the whistleblower through confidentiality, identity protection, and liability exemption.

Cyber Audit Office

Report
Email
compliance@hyundai-steel.com
Phone
031-510-2114
Mail
Hyundai Steel Compliance Support Team, 9th floor, The GreitsPangyo, 117 BundangNaegok-ro, Bundang-gu, Seongnam City,
Gyeonggi-do, Korea (13529)