(1)Do not discuss or exchange bidding-related information, such as participant details, successful bidders, bid volumes, or bid amounts, with other bidders in advance of competitive bidding.

(2)Do not exchange or discuss information about prices, production volumes, sales volumes, inventory levels, or shipment volumes with competing businesses.

(3)Do not participate in meetings to discuss such matters.

(1)Do not unreasonably refuse to commence transactions with or discontinue transactions with specific businesses.

(2)Do not make it a condition of doing business that the counterparty exclude our company's or our affiliates' competitors from being potential business counterparties.

(3)Do not impede business activities by unfairly soliciting or hiring personnel from other businesses.

(4)Do not force suppliers doing business with our company to purchase our products.

(5)Do not force purchases by directly or indirectly indicating that future delivery will be affected if products are not purchased.

(6)Do not include contract provisions stating that only our company has the right to interpret the contract in the event of disputes over its interpretation.

(7)Do not require our company's instructions or approval regarding the appointment, dismissal, or change of executives and employees, or disadvantage those who do not comply.

(8)Do not require partner companies or subcontractors to obtain our company's prior approval when supplying products to other companies.

(1)When selecting an affiliate as a business partner, conduct thorough market research and follow reasonable comparison and review procedures.

(2)When transacting with affiliates, do not trade at significantly lower or higher prices than would apply in standard transactions.

(3)Do not include affiliates who have no substantial or minimal role in the transaction stages unnecessarily.

(1)Do not accept quotations that include cost-related information, such as material costs and labor costs, from subcontractors.

(2)Do not reduce unit prices by a uniform percentage compared to existing unit prices without legitimate reasons.

(3)Do not conduct additional negotiations for amounts lower than the lowest bid amount in competitive bidding.

(1)Do not request commencement of work via email, verbally, or by phone before delivering the contract.

(2)Prepare and deliver a contract that specifies the legally required information, including the contract amount, delivery deadline, and payment terms, before work commencement.

(3)If subject to the subcontracting payment linkage system, a mandatory conclusion of a linkage contract (or a non-linkage agreement) with the subcontractor is required, and payment adjustment procedures must be implemented promptly according to the linkage contract when raw material prices change.

(4)Do not include contract clauses that are unilaterally favorable to our company, such as clauses that transfer liability for damages.

(5)Do not unilaterally change the contents of already concluded contracts or cancel contracts without legitimate reasons.

(1)Do not terminate or cancel contracts for reasons not attributable to the subcontractor.

(2)Do not demand submission of management information from subcontractors without legitimate reasons.

(3)Do not request technical data without legitimate reasons, such as those required for inspection purposes.

(4)When requesting technical data from subcontractors, verify whether there are legitimate reasons, and if so, issue our standard technical data request form and conclude a confidentiality agreement in advance.

(5)Manage technical data received from subcontractors separately from our company's technical data, and discard or return the technical data when the usage period specified in the technical data request expires.

(1)Do not pay subcontracting fees more than 60 days after receipt of the deliverables due to our internal circumstances, such as delayed account changes.

(2)If payment is delayed, you are required to pay late payment interest under the Subcontracting Law.

(3)Do not reduce subcontracting payments due to our financial circumstances.

(4)Even if unit price reductions are agreed with subcontractors for legitimate reasons, do not retroactively apply the changed unit prices to periods before the agreement date.

(5)Verify whether the raw material price fluctuation rates meet the adjustment requirements at each adjustment date, as specified in the linkage agreements, and adjust payments accordingly using the linkage formula once the adjustment requirements are met.

• (1)If you intend to provide cash, cash equivalents, or other valuables, you must confirm the following matters and obtain prior approval from the Compliance Team.
  • Provision of cash, cash equivalents, or other valuables is, in principle, not permitted.
  • However, condolence or congratulatory expenses may be provided only within an appropriate amount permitted under the laws, culture, and social norms of the relevant country (prior Compliance approval request process required).
• (2)If you intend to provide gifts (souvenirs), benefits, hospitality, donations, etc., you must confirm the following matters and obtain prior approval from the Compliance Team.
  • Whether the recipient or requester is a domestic or foreign public official
  • Whether there is a contractual basis or legitimate business purpose for the provision
  • Whether the provision falls within the scope permitted under the laws, culture, and social norms of the recipient’s country
  • Whether the recipient has received such benefits from the Company excessively or repeatedly
  • Whether there is any concern that the provision may be perceived as being provided in expectation of obtain or retain business, secure an improper advantage, or influence official duties or decision-making

• (1)When selecting or entering into a contract with Third Parties such as representatives, agents, or JV partners, the Company must conduct “Third-Party Due Diligence” and undergo Compliance review in accordance with the Company’s anti-bribery law compliance guidelines.
• (2)Information related to the investigation and evaluation of Third Parties, particularly evidence demonstrating that compensation to be paid to the stakeholder is reasonable and proportionate to the scope and nature of the services, must be documented and retained.
• (3)Confirm whether the contract with the stakeholder includes appropriate “anti-bribery and anti-corruption provisions” (the Company’s standard anti-bribery and anti-corruption provisions).
  In particular, confirm whether the following matters are included.
  • A representation that the stakeholder has complied with anti-bribery laws and regulations and will continue to do so
  • The Company’s right to rescind or terminate the contract in the event of a violation of anti-bribery laws and regulations

• (1)Confirm whether the counterparty is a public official or equivalent person.
  • Confirm whether the person falls under any relevant category, such as public officials, heads and employees of public service-related organizations and institutions, heads and faculty members of schools, executives and employees of school corporations, or representatives and employees of media companies.
  • If it is unclear whether the person falls under the above categories, request confirmation from the Compliance Team.
• (2)Confirm whether the receipt of money, valuables, etc. is exceptionally permitted (in principle, such provision is not allowed).
  • Money, valuables, etc. provided for smooth performance of duties, social courtesy, ceremonial purposes, or mutual aid purposes (Subparagraph 2)
    • In the case of Subparagraph 2, items are not automatically permitted merely because they fall within the value limits of KRW 50,000 for meals, KRW 50,000 for gifts, and KRW 100,000 for congratulatory or condolence expenses. A comprehensive assessment must be made based on factors such as the relationship between the public official or equivalent person and the provider, the existence of a personal relationship, the circumstances and timing of receipt, and the degree of closeness in connection with official duties.
  • Money, valuables, etc. provided based on a legitimate legal basis or authority (Subparagraph 3)
    • To fall under Subparagraph 3, there must be a basis or authority for providing the money, valuables, etc., and such authority must be legitimate.
  • Money, valuables, etc. ordinarily and uniformly provided at an official event (Subparagraph 6)
    • Whether an event qualifies as an official event must be determined comprehensively by considering factors such as its direct relevance to the Company’s business, the relationship between the participants and the purpose and content of the event, the openness of the eligible participants, whether the event is publicly disclosed, and whether internal approval exists for the operation of the event, including cost-bearing arrangements. Whether the provision is within an ordinary scope must be determined comprehensively by considering factors such as similar types of events, the venue and purpose of the event, the scope and status of participants, the host’s internal standards, and the host’s capacity to bear costs. Provision limited to a specific individual or group, rather than being uniformly provided, is not considered uniform provision.
  • Souvenirs or promotional items distributed to an unspecified number of persons (Subparagraph 7)
    • “An unspecified number of persons” refers not merely to the number of recipients, but to the randomness of selection in which recipients are not specifically identified. Whether an item qualifies as a souvenir or promotional item must be determined comprehensively by considering factors such as whether the Company’s logo or name is displayed, the purpose of production, value, and quantity.