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Receipt of reward(money or other valuables) from interested parties

Basic Principles

  • 1. Rewards from interested parties are to be refused at all times regardless of reasons.
  • 2. Must report in accordance with the reporting procedures when rewards are received due to unavoidable circumstances.

Guidelines for Procedures

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  • 1. Receipt of Money (money or gift including securities)
    Classification Examples Basic Principle(s) Remarks
    Money cash, check and other securities Prohibited  
    Gift golf pass, health club pass, gift certificates, admission tickets, goods, etc. (also includes other promotions and benefits of discounts) Prohibited from Receiving gifts regardless of amount Promotions and benefits of discounts are allowed when offered to all with the supervisor's approval
    Congratulatory & Condolatory Gift Congratulatory & condolatory money or goods (flowers, rings for babies’ first year birthday, etc.) Prohibited Intentional notification prohibited
    Defrayment of Cost Reception cost, company dinner expense and other personal expenses (Leaving burden upon the interested parties with such cost) Prohibited Return after the fact in cases of unavoidable circumstances
  • 2. Entertainment Treat and Reception
    Classification Examples Basic Principle(s) Remarks
    Meal   Exceeding limit prohibited Limit: under 50,000 won per person under 300,000 won in total / meal
    Unsound Places Expensive drinking places, pubs, night clubs, steam house, massage parlor, high class sauna and other deluxe and luxurious entertainment locations Prohibited  
    Recreation Entertainments such as card game (‘Go-Stop’), Casino, etc. Prohibited  
    Sport golf, ski Prohibited
    • - Excludes official gatherings approved by the company
    • - Prohibits gathering for reception with interested parties
  • 3. Conveniences and Accommodations
    Classification Examples Basic Principle(s) Remarks
    Business Trip Support

    Transportation benefits (tickets for train / airplane / bus, vehicle support, etc.)

    Board and lodging accommodations (lodging, dining support, etc.)

    Fair cost to be paid Pay fair cost when using accommodations provided by interested parties for efficiency in business affairs
    Personal Vacation Support Transportation and lodging benefits for personal vacation including tour guide Prohibited  
    Office Equipments Expense support for departmental moving and office equipment (clocks, mirrors, tissues, etc.) Prohibited Within the range of gifts allowed under unavoidable circumstances
    Sponsorship

    Support for internal events of departments (money, goods, transportation benefits, etc.)

    Invitational events for interested parties having no relation to business affairs (domestic / overseas seminars)

    Prohibited Unless with prior consent of the company, invitation and participation of interested parties are prohibited
  • 4. Loan (Movable and Immovable Estates), Debt Redemption, Guarantee and Money Loan
    Classification Examples Basic Principle(s) Remarks
    Lease/Buying/Selling
    • - Lease, security selection, gratuitous receipt, bargain, purchase of properties such as movable & immovable estates of interested parties
    • - Costly sale of personal assets of employees
    Prohibited For the purposes of personal conveniences and profit
    Payment of debts Settlement or redemption of personal debt such as credit cards, credits, advanced money Prohibited  
    Guarantee Demand or request for guarantee on loan Prohibited Regardless of any form of loan from financial institutions
    Money Lending & Loaning Lending or loaning money from or to interested parties / paying or receiving of interest from such transactions Prohibited  
  • 5. Guarantee of Future (promise of employment opportunity, promise from contracts)
    Classification Examples Basic Principle(s) Remarks
    Employment Opportunity Receiving guarantee of employment from interested parties upon retirement, promise for employment opportunities Prohibited  
    Promise from Contracts Contracting of transaction promised upon retirement Prohibited  

1. Basic Principles

  • (1) Rewards from interested parties are to be refused at all times regardless of reasons.
  • (2) Must report in accordance with the reporting procedures when rewards are received due to unavoidable circumstances.
  • (3) Even the families of employees of the company must not receive or request rewards from interested parties in relation to business affairs.

    Typical forms of rewards are as follows including acts recognized as obvious bribes.

    • - Receipt of money (money or gift including securities), entertainment and reception, offer of conveniences
    • - Loan (movable and immovable estates), debt redemption or guarantee and money loan
    • - Guarantee of future (employment or promise of employment upon retirement, promises from contracts on business transactions)

2. Form of Reward (money and other valuables) and Violation Possibility of Code of Ethics

  • (1) Direct Receipt

    Employees personally receive money and other valuables from interested parties Families, relatives, or friends accept money and other valuables from interested parties and deliver to employees

  • (2) Indirect Receipt
    • - Superiors receive money and other valuables from interested parties and then give to subordinates
    • - Subordinates receive money and other valuables from interested parties and then give to superiors
    • - Employees of equal rank exchange money and other valuables received from interested parties among themselves
  • (3) Violation Possibility of Code of Ethics

    Any case of receiving money and other valuables from interested parties either directly or indirectly is generally considered a violation of the code of ethics. However, when a subordinate does not recognize the source of the reward due to receiving it from his/her superior who accepted the reward from interested parties, only the superior is subject to the violation of the code of ethics.

3. Receipt of Money (money or gift including securities)

A. Applicable Deeds and Standard of Judgment

Classification Examples Basic Principle(s) Remarks
Money cash, check and other securities Prohibited  
Gift golf pass, health club pass, gift certificates, admission tickets, goods, etc. (also includes other promotions and benefits of discounts) Prohibited from Receiving gifts regardless of amount Promotions and benefits of discounts are allowed when offered to all with the supervisor's approval
Congratulatory & Condolatory Gift Congratulatory & condolatory money or goods (flowers, rings for babies’ first year birthday, etc.) Prohibited Intentional notification prohibited
Defrayment of Cost Reception cost, company dinner expense and other personal expenses (Leaving burden upon the interested parties with such cost) Prohibited Return after the fact in cases of unavoidable circumstances

B. Management Measures when Received Money (Guidelines for Procedures)

  • (1) Must not receive money from interested parties at any time regardless of reasons and must politely refuse or return when received.
  • (2) Must report when money is received in accordance with the "Report on Receipt of Money and other Valuables / Conveniences" and take following procedure.
    • - Remit money to the appropriate party or corresponding company in the name of the recipient along with proof of return.
    • - A letter stating reasons for remitting the money, gratitude for goodwill and request for avoidance of same incident, along with the copy of deposit slip in the name of a superior must be sent to the representative of the interested party.
    • - Result of the procedures such as the report, and copies of the letter and deposit slip must be submitted to the Ethics Bureau.

C. Management Measures when Gifts are Received (Guidelines for Procedures)

  • (1) Employees shall not accept gifts from stakeholders under any circumstances. If a stakeholder provides a gift, he/she must politely and promptly decline or return the gift.
  • (2) If employees receive gifts from stakeholders, report it in accordance with the reporting process by completing the “Declaration of Receiving Gifts/Money/Conveniences” form and must take one of the following actions depending on the gift type:
    • a. Returnable Goods (Non-perishable gift sets, liquor, etc.)
      • - Return the gift to stakeholder’s company enclosing a letter, express gratitude, and request that similar gifts should be avoided in the future. Designate a company executive as the sender and address it to the head of the stakeholder’s ompany. The results shall be reported to the Ethics Bureau.
    • b. Non-returnable Goods (Perishable gifts such as fish and meat)
      • - Donate the gift, under the name of the representative of the stakeholder’s company, to welfare facilities or religious organization, such as a nursing home or an orphanage. Additionally, employee shall request a copy of the Donation Acknowledgement Receipt specifying the amount / type of the gift.
      • - Then, send a Return Letter and a copy of Donation Acknowledgment Receipt received from the welfare facility or religious organization, express gratitude, and request that similar gifts be avoided in the future. Designate a company executive as the sender. The results shall be reported to the Ethics
  • (3) Benefiting from promotions or discounts shall be considered as gifts. However, provided that such benefit is available to anyone and that it does not exceed the “socially acceptable amounts”, employees may keep possession of the gift upon reporting it to his/her supervisor.
  • (4) Employees may keep customary gifts exchanged with overseas business partners for contracting or partnerships, provided that gifts are kept in the office or it is used for business purposes only.
    Upon receipt, employee must complete the ‘Declaration of Receiving Gifts/Money/Conveniences’ and submit the same to the Ethics Bureau.
  • (5) For cases that have not been covered by the code of Ethics, employees shall discuss with the Ethics Bureau in advance or take the most appropriate action and then report the details in accordance with the reporting process.

D. Management Measures for Congratulatory or Condolatory Gifts (Guidelines for Procedures)

  • (1) Employees shall not receive any congratulatory or condolence gifts from stakeholders under any circumstances. Employees shall either politely decline or return it to the stakeholder.
  • (2) Intentional notification of congratulatory or condolence events by the employee or the employees’ family and friends, thus pressuring stakeholders, can be accounted as receiving gifts, with regards to circumstances.
    • - Sending invitation notices(e-mail, mail, fax, etc.) to stakeholders is prohibited.
    • - Posting notices on bulletin boards or sites where stakeholders can access is not allowed.
    • - Openly informing congratulatory and condolence events by the concerned or other colleagues is forbidden.

E. Prohibition on Defrayment of Cost (act of burdening interested parties with expenses of entertainment or company dinner)

  • (1) Must not invite interested parties to dinner with business partners or within departments to burden the dinner expense or receive money in exchange of the receipt.
  • (2) When coincidently encounter interested parties at places of departmental dinner and the interested parties pay for the dinner expense in advance, must report the incident to the department head and return the cost to the interested parties after managing it as company expense.

4. Entertainment Treat and Reception

A. Applicable Deeds and Standard of Judgment

Classification Examples Basic Principle(s) Remarks
Meal   Exceeding limit prohibited Limit: under 50,000 won per person under 300,000 won in total / meal
Unsound Places Expensive drinking places, pubs, night clubs, steam house, massage parlor, high class sauna and other deluxe and luxurious entertainment locations Prohibited  
Recreation Entertainments such as card game (‘Go-Stop’), Casino, etc. Prohibited  
Sport golf, ski Prohibited
  • - Excludes official gatherings approved by the company
  • - Prohibits gathering for reception with interested parties

B. Management Measures for Entertainment Treat & Reception (Guidelines for Procedures)

  • (1) Meals for business purposes are allowed, with the supervisor's approval. Such permission is valid only if the amount is reasonable and not prohibited by business rules and regulations.
  • (2) If meals and entertainment exceed "socially acceptable amounts" and have the possibility of violating the Code of Ethics, employees shall not accept them, even for the purpose of business cooperation.
  • (3) Employees shall not receive invitations to expensive sporting events or tickets, paid by stakeholders, unless it is an official gathering approved by the company.
  • (4) If a stakeholder offers gifts and entertainment, employees shall file a "Declaration of Receiving Gifts/Money/Conveniences." However, reporting is unnecessary for meals under the "socially acceptable amount."
  • (5) When it is difficult to determine whether the gift is an ordinary business meal or a form of excessive meal/entertainment, employees shall consult with the Ethics Bureau in advance or take the most appropriate action and then report the details in accordance with the reporting process.

5. Conveniences and Accommodations

A. Applicable Deeds and Standard of Judgment

Classification Examples Basic Principle(s) Remarks
Business Trip Support

Transportation benefits (tickets for train / airplane / bus, vehicle support, etc.)

Board and lodging accommodations (lodging, dining support, etc.)

Fair cost to be paid Pay fair cost when using accommodations provided by interested parties for efficiency in business affairs
Personal Vacation Support Transportation and lodging benefits for personal vacation including tour guide Prohibited  
Office Equipments Expense support for departmental moving and office equipment (clocks, mirrors, tissues, etc.) Prohibited Within the range of gifts allowed under unavoidable circumstances
Sponsorship

Support for internal events of departments (money, goods, transportation benefits, etc.)

Invitational events for interested parties having no relation to business affairs (domestic / overseas seminars)

Prohibited Unless with prior consent of the company, invitation and participation of interested parties are prohibited

B. Management Measures for Business Trips or Personal Vacation Accommodations (Guidelines for Procedures)

  • (1) Regardless of purpose, employees must not request conveniences or accommodations or accept such proposals from the interested parties.
  • (2) However, receiving lodging, dining and transportation accommodations from the facility managed by interested parties for the purpose of training is an exception. Nevertheless, it is also limited to accommodations not prohibited by law or customs and is permissible when offered to all employees. Also, must acquire prior consent by specifying the content of accommodations. Different forms of accommodations other than that of the pre-approved ones must be paid in fair cost.
  • (3) If employees did not pay fair cost after receiving transportation and lodging accommodations, one must remit the cost to the supplier or the representative of the corresponding company to which the supplier belongs and report to the Ethics Bureau after acquiring an approval of an executive on the "Report on Receipt of Money, Valuables and Conveniences" and include a copy of deposit slip.

C. Management Measures when Office Equipment is Received (Guidelines for Procedures)

  • (1) Must not receive any kind of support (money or goods) from interested parties when moving to a different office or department.
  • (2) When notifying interested parties about moving to a different office or department as might be necessary for business affairs, must pay close attention not to burden the interested parties by clearly indicating refusal of any kind of goods.
  • (3) If the receipt of office equipment is unavoidable, acceptance of goods under 50,000 won (clocks, plants, mirror, tissues, etc.) is permissible but goods exceeding 50,000 won in cost must be returned.

D. Management Measures for Sponsorship Support (Guidelines for Procedures)

  • (1) Must not receive sponsorship support from interested parties in the form of money, goods or transportation for the company's events such as picnics, athletic events, workshops, etc.
  • (2) Notification of such events to interested parties in order to receive sponsorship support using the following methods is considered intentional.

    - Burdening by talking about events with interested parties or listing in the internal bulletin board visible to the interested parties/p>

    - Giving invitations for events to interested parties without prior consent of the company

  • (3) If it is necessary to invite interested parties to an event in accordance with the nature of the event, must acquire prior consent from the company and notify the interested parties that a congratulatory gift will not be accepted, relieving them from the burden of participation.
  • (4) When interested parties give money or goods exceeding 50,000 won, such gift must be returned promptly. However, if receipt of the gift is unavoidable or the goods are under 50,000 won, the person in charge of the event shall express gratitude to the interested parties along with an explanation of company regulations, to prevent further occurrence of the incident. Then, the incident must be reported to the Ethics Bureau
  • (5) For an event hosted by interested parties, it must be business related and participation is allowed only with prior consent of the company. Participants must avoid or refrain from situations if there is concern about the event progressing from business related to a possible change in accommodations or reception. Moreover, if an entertainment or reception occurred at the event other than the business purpose, the cost to the interested parties must be paid and reported to the Ethics Bureau in accordance with measures of management for entertainment and reception.

6. Loan (Movable and Immovable Estates), Debt Redemption, Guarantee and Money Loan

A. Applicable Deeds and Standard of Judgment

Classification Examples Basic Principle(s) Remarks
Lease/Buying/Selling
  • - Lease, security selection, gratuitous receipt, bargain, purchase of properties such as movable & immovable estates of interested parties
  • - Costly sale of personal assets of employees
Prohibited For the purposes of personal conveniences and profit
Payment of debts Settlement or redemption of personal debt such as credit cards, credits, advanced money Prohibited  
Guarantee Demand or request for guarantee on loan Prohibited Regardless of any form of loan from financial institutions
Money Lending & Loaning Lending or loaning money from or to interested parties / paying or receiving of interest from such transactions Prohibited  

B. Management Measures for Loan / Bargain Purchase / Costly Sale (Guidelines for Procedures)

  • (1) Personal transaction with stakeholders is prohibited in principle.
  • (2) Must not accept any kind of offer such as property leasing or securities from interested parties for the purpose of convenience or profit of employees and their families.
  • (3) Moreover, receiving movable or immovable estates without return compensation or acquiring gains from purchase estate at lower than normal cost are prohibited as such are considered as receipt of money.
  • (4) Acquiring gains from costly sale in comparison to the norm of movable or immovable estates owned by employees through interested parties, is also prohibited and is considered receipt of money as well.
  • (5) When you did not recognize stakeholders in advance or such personal transaction with stakeholders occurred unavoidably, you shall report the fact to ethics bureau by preparing the form, 『Declaration of Receiving Gifts/Money/Convenience』 according to the report procedure.

C. Management Measures for Debt Redemption and Guarantee on Loan (Guidelines for Procedures)

  • (1) Settlement: Must not request settlement or redemption of debt (credit card, credit, loan, etc.) of employees, families or subordinates or accept proposal of such settlement or redemption from interested parties.
  • (2) Guarantee on Loan: Must not request guarantee from interested parties when employee, family or subordinate is getting a loan (regardless of type of loan from financial institution or other place) or accept proposal of such guarantee on loan.
  • (3) Receiving settlement or guarantee on loan from interested parties for debt redemption is considered receipt of money regardless of reason.

D. Management Measures for Money Lending and Loaning (Guidelines for Procedures)

  • (1) Must not conduct lending or loaning of money between employees and families with interested parties.
  • (2) Not only the lending and loaning of money but also the acquirement or payment of interest from such is considered receipt of money regardless of reason.

7. Guarantee of Future (promise of employment opportunity, promise from contracts)

A. Applicable Deeds and Standard of Judgment

Classification Examples Basic Principle(s) Remarks
Employment Opportunity Receiving guarantee of employment from interested parties upon retirement, promise for employment opportunities Prohibited  
Promise from Contracts Contracting of transaction promised upon retirement Prohibited  

B. Guidelines for Procedures

  • (1) Employment or employment opportunity upon retirement: Must not request any form of guarantee of employment or employment opportunities upon retirement from interested parties or accept proposal of such.
  • (2) Promise on transaction contract: Must not request any form of benefits such as through transaction contracts upon retirement from interested parties or accept proposal of such.
  • (3) When proposal is received of employment guarantee or transaction contract from interested parties, must notify an executive and report to the Ethics Bureau.