Code of Conduct and Ethical Principles

Compliance with Laws, Regulations and Internal Rules

All Company Employees are required to perform their duties in full observance of the applicable laws and/or regulations and as well as internal rules.

For this purpose, it is essential to

-   Familiarize with laws and regulations applicable to the businesses as well as their purposes, and pay attention to developments (new laws, revisions, etc.) in laws and regulations.

-   Evaluate whether industry practices, business practices, and internal practices are in accordance with expectations of society.

-  Pay attention not only to domestic laws and regulations, but also to international rules and foreign laws and regulations that might be applied to the business.

- In relationships with the customers, business partners, agents and other stakeholders, not only comply with laws, regulations and internal rules, but also act in good faith in accordance with social norms and generally applicable ethical standards.


Respect for Human Rights and Fair Dealing

Respect for human rights is essential in every aspect of business activities of the Company. All Employees are required to conduct themselves with mutual respect for all persons and shall not practice discrimination against anyone for any reason whatsoever.

For this purpose, it is essential to

-   Understand and comply with laws and regulations, internal rules regarding respect and protection of human rights related to the business of the Company.

-   Respect diversity of all people in every aspect of business activities of the Company and always interact with other people with respect and dignity, and never discriminate unfairly based on race, religion, color of skin, ethnicity, creed, nationality, gender, disability, or any other reason.

-   Never be involved in activities contrary to human rights such as forced labor, child labor, human trafficking, etc.

-   Comply with laws and regulations concerning equality of employment opportunities and adopt fair and impartial employment practices.

Each Employee shall endeavor to deal fairly and in good faith with Company’s customers, shareholders, employees, suppliers, regulators, business partners, competitors and others. No Employee shall take unfair advantage of anyone through manipulation, intimidation, coercion, concealment, abuse of privileged or confidential information, misrepresentation, fraudulent behavior or any other unfair dealing practice.

 

Healthy and Safe Working Environment 

Providing and promoting a healthy and safe working environment, in which Employees, contractors, and related third parties may have peace of mind and demonstrate their abilities fully without any concerns that threaten their mental or physical safety, is principle.

For this purpose, it is essential to

-   Understand and comply with labor-related laws, regulations and internal rules.

-  Never allow any harassment such as bullying, violent behavior, intimidation, sexual harassment or abuse of authority whether physical or mental both inside and outside the Company.

 

Protection of Company Assets

The assets of the Company, including information, materials, supplies, time, intellectual property, software, hardware and facilities, among other property, are valuable resources owned, licensed or otherwise belonging to the Company. Company assets should be protected and should only be used for the business activities of the Company. All Company Employees must take reasonable measures to prevent damage to and theft or misuse of Company property. The personal use of Company assets without permission is prohibited.

Compliance with applicable policies governing the use of Company assets as may be adopted from time to time, including but not limited to policies governing the use of Company email, internet access, and network security is required by each Company Employee. 

For this purpose, it is essential to

- Use Company assets including information, materials, supplies, time, intellectual property, software, hardware and facilities, among other property, are valuable resources owned, licensed or otherwise belonging to the Company only for the Company’s business activities, and never allow fraudulent use, personal use, theft, waste and damage in regard to them.

-   Never post any comments or information that would adversely affect the Company’s reputation on the Internet or through social media, etc.

 

Proper Document Creation and Management

The Company shall properly create and manage documents, and data, etc. related to transactions and operations of the Company in accordance with laws, regulations and internal rules.

For this purpose, it is essential to

-   Create accurately and store documents, emails, and data, etc. including records of all transactions of the Company, business records, based on facts, and always store such materials in accordance with related laws, regulations and internal rules.

-   Discard properly documents, emails, and data that have passed the storage period prescribed by laws and regulations and internal rules particularly by the Personal Data Storage and Destruction Policy.

 

Fair and Free Competition

It is principle to construct and maintain a sincere relationship with customers, competitors, and outsourcing partners, etc., and pursue fair and free competition. No Company Employee shall enter into with a competitor any agreement or understanding, express or implied, to “unreasonably restrain trade” in any product or service.

While the Company supports participation in certain industry trade associations, those attending trade association meetings should not, in formal or informal sessions, discuss or exchange information on any of the topics listed above or any competitively-sensitive practice.

For this purpose, it is essential to

-   Comply with antitrust and fair competition laws and regulations.

-   Obtain prices, sales conditions, cost and profit, etc. relating to products and services in an appropriate way and never share competitive information with the competitors or give any hints about them.

-   Never collaborate with competitors to engage in unfair practices such as:

·       agreement on prices and selling conditions of products and services, specific rates, coverage terms or forms;

·       assignment of markets, or elimination of specific companies, etc. from the market, explicitly or implicitly;

·       establishing underwriting guidelines/practices;

·       setting payments for outside vendors, such as repair shops, third party administrators, etc.;

·       allocating customers;

·       withdrawing from a territory/line of business;

·       providing only certain coverage to an insured or group of insured;

·       refusing to write business for an insured or group of insured;

·       appointing or terminating an agent, or changing the terms or conditions of the appointment (including commissions);

-   Never act to abuse a superior position in relation to outsourcing parties;

-   Never conduct unjust bidding transactions; and

-   Never post any comments or information that would lead to slandering of other companies on the Internet or through social media, etc.

 

Prohibition of Bribery

To contribute to the maintenance and development of an orderly free competitive market, promotion of fair business activities with high ethical sense and not engaging in bribery is fundamental.

For this purpose, it is essential to

-   Keep a professional relationship and deal at arms’ length with such other persons and/or organizations who are interested in the activities conducted by the Company or who are known to have commercial interests in business that is carried out by the Company (interested parties), strictly refrain from any conduct and/or relationship with these persons that may be perceived or construed as socially and/or professionally unacceptable.

-   Strictly refrain from presenting or accepting any entertainment or gift offers, which are beyond the generally accepted business practices.

Employees are prohibited from providing cash, gifts, entertainment, business opportunities, offers of employment or anything of value to government officials or employees or members of their families without prior written approval from their superior. Should any individual solicit any gift or other payment, such solicitation must be immediately reported to the Internal Control and Compliance Department.

 

Gifts & Entertainment

Refuse any “personal” gift or present, which is sent to the name of the employee beyond what is explicitly approved by the Company.

The maximum amount of the acceptable gifts and presents such as gifts datebooks, notebooks, calendars, pens, chocolate, candy, flower is determined and announced on yearly basis by the Human Resources Department. The gifts and presents, which are “personal” or with an amount exceeding the pre-determined level shall be returned with an e-mail of thanks to the sender by explaining this related Policy of the Company.

All the Employees shall be strictly prohibited from engaging in the following conduct with any interested parties for any reason whatsoever:

-   Providing or accepting any benefit (money, commercial or otherwise), which is not compliant with the amount stated in the Discipline Procedure;

-   As explained above, providing or accepting any entertainment and/or gifts (whether such entertainment and/or gifts are provided or accepted free of charge or at a subsidized rate of charge) beyond acceptable and common business practice;

-   Encouraging any other Employee or any interested party to do such action prohibited above; and

-   Any conduct which does not fall within acceptable and common business practice.

 

Charitable Activities

The Company is committed to maintaining goodwill and to being a good civic neighbor. The Employees are encouraged to serve on non-profit boards and in other volunteer capacities. However, if an Employee serves in any capacity with a non-for-profit organization, such person may not represent either the Company or the organization in any transactions between them.

 

Prohibition of Conflict of Interest

Under situations, where the interests of Employees conflict with the interests of the Company, in accordance with related laws, regulations and internal rules, the interests of the Company shall be taken into consideration. All Employees should clearly segregate between their professional and private matters. Employees must not take advantage of their jobs and/or positions in the Company for their personal benefit. Business decisions and dealings must be based on the best interest of the Company, and not be motivated by personal considerations or relationships. 

Before making any investment, accepting any position or benefits, participating in any transaction or business arrangement or otherwise acting in a manner that creates or appears to create a conflict of interest, Employees must make full disclosure of all facts and circumstances to, and obtain the prior written approval of their superior.  

For this purpose, it is essential to

-   Avoid taking any action or become a part of action that may be contrary to or conflict with the Company’s and the Shareholders’ interests.

-   Never use corporate position, Company assets including confidential information, etc., or business opportunities obtained in business for personal profit.

-   Never engage in activities that compete with the Company's businesses or profits or be employed as an officer or employee of a company or organization that competes with the Company while employed by the Company, and never prioritize employment of, or other transactions with, his/her relatives or acquaintances.

 

Protection and Management of Personal and Confidential Information

The Company will comply with the rules stipulated in related laws and regulations with regard to the collection, processing, and protection of personal data, confidential information, and trade secrets obtained or disclosed as a consequence of the activities of the Company.

The Company is committed to respecting the privacy and data protection rights of all those from whom it may collect data, in accordance with the Company’s Personal Data Protection and Confidentiality Policy, data protection procedures, shareholder’s policies and procedures and other applicable laws, regulations and rules.  

For this purpose, it is essential to

-  Only use business confidential information and personal information on executives, Employees, customers, etc. within agreed purpose and scope and never disclose such information outside the Company unless permitted to do so by laws and regulations.

-   Comply with relevant domestic and foreign privacy laws and regulations, such as obtaining the consent of the individual when required.

-   Use and manage information communications equipment such as mobile phones and PCs properly according to internal rules.

-   Return all confidential information, communication devices, IDs, etc. at the time of termination of employment relationship with the Company, and never use or disclose confidential information obtained during employment even after ceasing employment relationship with the Company.

 

Protection of Intellectual Property

The intellectual property possessed by the Company shall be protected, and intellectual property of third parties shall not be infringed.

For this purpose, it is essential to

Never use, duplicate, or sell in relation to patent rights, copyrights, trademark rights, know-how or confidential information possessed by the Company or third parties about business, technology, etc. with disregard to the laws and regulations.

 

Prohibition of Insider Trading

Information about any publicly-listed affiliate of a Company or its third-party service providers that is not generally available to the public and that could affect the market price of the securities of that company that are traded on a stock exchange is considered “insider information”. Trading securities on the basis of insider information is a criminal offense in many countries where the Company or its shareholder operate and is strictly prohibited by the Company.  

For this purpose, it is essential to

-  Manage strictly nonpublic information about the Company and other companies, etc., and never buy or sell securities such as stocks issued by them based on such information and share or tip inside information to others or encourage trading based on such information.

 

Elimination of Organized Crime Forces

In accordance with the aim of maintaining public confidence, contribution to social safety and having a sound corporate management, the Company takes the necessary measures to fulfill the responsibility incumbent upon the Company in the fight against organized crime forces and activities.

For this purpose, it is essential to

-   Confirm that customers and business partners are not organized crime forces, and if there is any suspicion at all, always strive to refuse the transaction and end the business relationship.

-    Refuse firmly demands or pressures from organized crime forces as an organization.

 

Prevention of Money Laundering and Terrorist Financing

The Company takes the necessary measures to ensure that the Company’s products and services are not used to transfer proceeds from crime, or to finance terrorism or the proliferation of weapons of mass destruction. 

For this purpose, it is essential to

-   Conduct the appropriate due diligence of counterparties to confirm that there are no suspicions about customers or transactions based on requirements of laws, regulations and internal rules, and degree of risk when starting and continuing business relationships with customers and contractors.

-   Promptly notify the authorities in accordance with the procedures stipulated by laws, regulations and internal rules, if we recognize a situation of suspected money laundering, etc.

-   Never engage in transactions with persons subject to economic sanctions or organizations with which they are involved.

-   Report any suspicious activities relating to transactions with third parties that may indicate potential money laundering activity.

-   Complete all Company required training regarding anti-money laundering and terrorist financing.


Disclosure of Crimes

Any employee who has ever been convicted of a crime involving dishonesty or breach of trust must promptly report the conviction to the General Counsel and Internal Control and Compliance Department, and Human Resources Department. If an employee is unsure whether a felony conviction involves a breach of trust or dishonesty, the employee must seek guidance from the General Counsel and Internal Control and Compliance Department. If in doubt, the employee should report the doubt to the General Counsel and Internal Control and Compliance Department.

In the event an employee has been convicted of a felony involving a breach of trust or dishonesty, his or her employment will be reviewed in accordance with the Discipline Procedure by the Disciplinary Committee.


Appropriate Political Activities

The Company shall conduct fair business activities while maintaining an appropriate relationship with politics. In addition, the Employees should clarify the distinction between public and private regarding personal political activities.

 

Appropriate Financial Reporting, Tax Processing Based on Laws and Regulations

It is the Company’s policy to make full, fair, accurate, timely and understandable disclosure in compliance with all applicable laws and regulations in all reports and documents that the Company files with, or submits to, applicable insurance and other regulatory authorities as well as in all other public communications made by the Company and to improve tax compliance in accordance with tax related laws and regulations. For this reason, accuracy and transparency of financial reporting is critical. All books and records of the Company must be kept in such a way as to fully and fairly reflect the Company’s transactions. Compliance with applicable accounting principles and systems of accounting controls is required at all times. 

For this purpose, it is essential to

-    Perform appropriate accounting in accordance with applicable standards and internal rules for all transactions and events that occurred.

-   Disclose financial information such as on finances and performance of the Company in a fair and equitable manner in accordance with related laws, regulations and internal rules.

-    Conduct appropriate tax payments and tax ordinances in accordance with the tax laws and the related laws and regulations.


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