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Ethics & Compliance

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Ethics & Compliance

POSCO Group's ethical management is based on our corprate philosophy of "doing the right thing in the right way.

POSCO Group has remarkable growth with the mission to assist national advancemnet. In the process, we have engaged in a relentless search to identify waht is right for our country and business. We must charge ourselves with the trust of the people and a stronger belief in ourselves to drive us forward and navigate the future.At this juncture, I would like to share with you the new way forward in our ethical management. First, ‘my’ actions and decisions should always represent ‘integrity'. We shall not seek personal interests at work and all decisions shall be made with the highest standard of justice and righteousness.Second, we shall practice the value of ‘respect’ for ‘others’. We shall protect the human rights of our co-workers and everyone with whom we interact in our business activities, embrace diversity, and treat each other with fairness.Third, let us exercise ‘mutual empathy’ as a means to extend the boundaries that frame ‘we/us‘. We can develop and grow together through mutual trust by paying attention to the voices of our stakeholders and by respecting the perspectives and rights of diverse populations.POSCO Group will step up our efforts to being a trusted leader in the global market through ethical management.

Reporting Unethical Behaviors

Submit any irregularities (such as bribery, embezzlement, and improper entertaining) involving POSCO MC Materials employees.

Report

Reporting Abuse of Power

Report any instances of verbal or physical abuse experienced by POSCO MC Materials employees.

Report

Reporting Workplace Harassment and Sexual Harassment

Report if you have been subject to workplace harassment or sexual harassment.

Report

Ethics Charter
POSCO Group aspires to become a trusted and respected enterprise by deeply understanding that ethical management is the greatest value we must uphold in order to co-exist and co-prosper with our many stakeholders as a member of society

Members of the POSCO family must comply with laws and ethics based on the ethical management philosophy of "doing the right thing in the right way." while also seeking to achieve Intergrity, Respect, and Mutual Empathy and establishing an ethical corporate culture in business activities that cover all the basics and comply with the rules.

For our customers, we must understand that our furture depends on customer trust and success. We must repect the customer voice at all times and create value that promotes customer prosperity.

At the employee level, we must pursue individual growth and company success by achieving a work-life balance, and create a positive work environment by establishing a corporate culture of mutual respect. We must fulfill our duty to respect everyone as human beings and to respect the human rights universally pursued by human society.

For our customers, we must understand that our future depends on customer trust and success.We must respect the customer voice at all times and create value that promotes customer prosperity.

For our shareholders, we must enhance shareholder value by making fair profits through transparent decision making and efficient business activity.

With our business partners, we must establish a fair trading system based on mutual trust and strengthen our corporate ecosystem in which we co-exist with our business partners through mutual growth.

At the community level, we must contribute to the development of society by fulfilling our duties and obligations. We must be deeply aware of the importance of environmental issues and do our best to protect the environment in all of our business activities.

POSCO family members must always be aware of the fact that our actions are directly linked to our self-respect as well as corporate value and reputation. We pledge to comply with the Code of Conduct and to ensure that ethics and integrity are at the heart of our culture and business operations.
Ethical Principles

Roles and responsibilities of all employees

Executives and authority figures have the responsibility to set an example of ethical compliance and prevent ethical misconduct among staff members. To this end, they must be aware of the following principles and put them to practice:
  • We comply with relevant laws and company regulations and guidelines anywhere in the world where POSCO MC Materials conducts business.
  • We endeavor to maintain our dignity as employees and protect our corporate reputation.
  • We make our best efforts to establish an ethical culture by taking responsibility for practicing ethical behavior.
  • We report to or consult an authority figure or the department in charge of ethical management immediately upon bocoming aware of the fact that a situation faced or an action performed by us or another person violates or is likely to violate the Code of Ethics
  • We fully cooperate with investigations conducted by the department in charge of ethical management regarding matters that are likely to violate the Code of Ethics.
  • We do not retaliate against informants or individuals who participate in an investigation in relation to Code of Ethics violations.
  • We are aware of the fact that by violating the Code of Ethics, soliciting another person to violate the Code of Ethics, failing to report a Code of Ethics violation or cooperate with an investigation, or taking retaliatory action against an informant or individual participating in an investigation, we may become subject to disciplinary action as appropriate.In particular, we are aware that there is zero tolerance for the four major ethical violations: acceptance of bribery, misappropriation, fabrication of information, and sexual misconduct.

Specail responsibilities of executives and authority figures

Executives and authority figures have the responsibility to set an example of ethical compliance and prevent ethical misconduct among staff members. To this end, they must be aware of the following principles and put them to practice

  • When the company’s profits and ethics are in conflict, you have a duty to prioritize ethics in your operational and administrative decision making
  • You must exemplify ethical conduct in your work and fulfill your duty as an internal and external role model.
  • You must train and guide staff members to understand the provisions of the Code of Ethics and Practice Guidelines and the importance of compliance.
  • You must routinely examine your teams for ethical misconduct and proactively prevent unethical behavior that is likely to occur by identifying the causes, improving processes, and taking other measures.
  • You must foster an organizational atmosphere that promotes and supports ethically correct behavior where staff members can speak up without worrying about adverse action.
  • You must report to or consult the department in charge of ethical management immediately upon becoming aware of the fact that a staff member has violated the Code of Ethics.
  • You have unlimited liability for any ethical misconduct you have engaged in, and supervisory liability for the ethical misconduct of a subordinate employee.
Code of Conduct


Purpose
To create a corporate culture where ‘solicitation does not take root’ by recording and managing all recommendation and solicitation contents.
Preemptive Measure against Unethical Behaviors
  • - Employees who receive solicitations have the justification to refuse them by registering them.
  • - Those who make solicitations experience the psychological burden of leaving a solicitation record, leading to a preventive effect against future unjust solicitations.
Practicing the Whistleblower Spirit
  • - Employees who receive solicitations foster a transparent and honest atmosphere within the company by registering the solicitation contents conscientiously.
  • - By considering the registration of a solicitation as a voluntary report, we protect virtuous employees from future issues or liabilities that may arise.
Operating Procedures
Registration Subject
All employees involved in the recommendation/solicitation process, including those who receive or relay the recommendation/solicitation, and those who handle the tasks.
Registration Method
Employees who receive recommendations/solicitations register the content truthfully and without modification, based on the principle of "5W1H".
Registration Timing
Register the relevant content in the system within 24 hours of the occurrence of recommendation/solicitation. However, extensions are possible in special circumstances such as meetings or business trips.
Processing Procedures for Recommendation/Solicitation Registration
  • 1. After an employee receives a recommendation/solicitation, they register the solicitor and the content in the system.
  • 2. The relevant department receives and verifies the registration.
  • 3. After verifying the content, the results are reported to the relevant department.
  • 4. If necessary, the relevant department conducts a detailed investigation, diagnoses the issue, and takes action if problems arise.
Interpretation of Solicitation
Solicitation encapsulates any form of communication wherein the solicitor seeks to sway an employee's role performance or decision-making to serve their own or another's interests.
Evaluation Standards for Integrity Influencing Job Execution and Decision-Making
Solicitation takes place when an individual seeks to sway an employee's professional performance or decision-making for their own or another's advantage through any communication form.
Extent of Recommendations/Solicitation Registration
  • - The Clean POSCO Group System was established to proactively prevent unethical conduct resulting from solicitations. Consequently, we've broadened the solicitation scope beyond legal bounds to incorporate any expression that might undermine impartiality.
  • - In cases where it's unclear whether an action is a solicitation or routine business, the guideline is to register the entirety of the content in the system without determining the solicitation.
  • - Any employee who has knowledge of a recommendation or solicitation but fails to register it may face stern disciplinary action.
Activities Requiring Documentation as Recommendations/Solicitations
  • - Requests for preferential treatment concerning the acquisition of equipment/materials and various contracts.
  • - Requests for advantages and special privileges relating to personnel matters such as recruitment, promotion, rewards/punishments, and job relocation.
  • - The provision of extraordinary convenience or special favors that go beyond standard procedures.
  • - Requests to neglect management/supervisory duties such as inspections and quality control.
  • - Instances where a solicitation is withdrawn immediately after a refusal is communicated.
  • - Instances of visiting field departments, purchasing departments, or meeting with relevant employees without registering in the procurement system.
  • - Instances of personal visits to field departments, purchasing departments even after registering in the procurement system.
Actions Not Necessitating Documentation as Recommendations/Solicitations
  • - Cooperation through official directives and typical work instructions from superiors. However, if these directives are perceived to violate rules, they should be recorded.
  • - Simple requests for confirmation, inquiries, or complaints intended to facilitate the duties of associated departments or agencies.
Handling of Recommendation/Solicitation Registration
The outcomes of recommendations/solicitations are independently managed by associated departments like Human Resources and Procurement, and measures may be taken against implicated employees and firms.