Guidelines for the Practice of the Code of Ethics

  • Fair Execution of the Duty

    • All members of the company must understand their roles with a mindset of a good manager in performing their duties and faithfully comply with the relevant laws and regulations, procedures and guidelines of the company.
    • All members of the company clearly recognize the authority and responsibilities given to them and make decisions in accordance with the company’s goals, anticipate and manage possible risks resulting from their decisions and actions, and have a sense of responsibility for the problems that arise.
    • All members of the company shall never cover up any violation of the related rules and regulations, procedures or guidelines of the company in connection with the performance of their own or other members of the company.
    • If an accident involving the roles or the duties of their own or any of the members of the company has occurred or is likely to occur, it shall be reported immediately to the head of the department or the head of the division (hereinafter referred to as the “Senior Member(s)”) and the Senior Member shall report it to the Secretary Office.
    • All members of the company shall refuse any orders from the Senior Members, which are contrary to the relevant laws or regulations, procedures, and guidelines of the company, and if any, report to the Secretary Office if deemed necessary.
    • All of the accounting filing within the company shall be expedited and accurately kept in accordance with generally accepted accounting principles and internal regulations, and shall be disclosed regularly. Any conducts such as false records, record forgery, falsification, and/or damaging of the records shall never be tolerated.

    Responsibilities and Obligations to Customers

    • All members of the company should recognize the ‘Customer-Oriented Management’ as the company’s foremost value and strive to provide the best financial services for the customers, and all duties for the customers should be performed transparently and fairly.
    • Any personal information of the customers should be kept strictly confidential and should never be used for the personal benefit of any members of the company.

    Sales Activities and Guidelines for Customer Treatment

    • The Five ‘Must’s and Five ‘Must-Not’s Movements shall be strictly complied during sales activities as below
        The Five 'Must's
      1. 1. When a customer opens an account especially a gifts/options account, an ID check or reference check should be carried out thoroughly and the execution procedure should be strictly complied.
      2. 2. When a customer opens an account for high risk transactions, such as futures, options and credit transactions, the customer should be issued a manual, explained in details and requested to confirm in writing.
      3. 3. Appropriate investment guidelines shall be suggested in view of the customer’s asset condition, purpose of investments, investment experience and knowledge.
      4. 4. We will accept transactional entrustment from valid customers only and if a third person is designated as the rightful person or an agent of that customer, a clear intention of delegation shall be submitted and checked in writing.
      5. 5. When a transaction is established, it shall be notified without delay in accordance with the agreed method.
        The Five 'Must-Not's
      1. 1. We, the company or any members of the company, neither will fill out or sign on behalf of the customer on any documents or vouchers related to customers’ accounts, nor store or keep the customers’ belongings such as transactional seals, security card or account booklets.
      2. 2. We, the company or any members of the company, will not guarantee any profit or loss (including compensation for loss or return on asset) in writing such as a memo, warranty or agreement to any customers.
      3. 3. We, the company or any members of the company, will not violate the related laws or engage in illegitimate business practices such as arbitrary purchases and sales, illegal entrusting trading, prepayments, or initiation fees.
      4. 4. We, the company or any members of the company, will not accept unfair trading or false orders that are clearly non-compliant or in default, such as market price manipulation and use of undisclosed information.
      5. 5. We, the company or any members of the company, will not allow non-employees or unqualified persons to engage in investment counseling or business activities and will not use unfair and undeserved titles (e.g., director, head, deputy, etc.) that may cause misunderstanding.
    • The company or any members of the company shall not make any misleading actions such as spreading unconfirmed rumors or false information, and do not intentionally cover up or manipulate data.
    • When a communication with a customer takes place over the phone and if an answer cannot be given right away due to no relevant knowledge or other unavoidable reasons, it shall be handed over to another member who can provide an answer correctly and accurately.
    • All customers should always be treated in sincere and courteous manners and all members should contain relevant financial knowledge through continuous education so the consultation to customers can be trusted.

    Mutual Respect among Members and Departments of the Company

    • Respect the privacy of each member and do not engage in verbal, physical, or visual actions that offend each other.
    • Do not form factions or discriminate any members of the company based on academic background, religion, gender, region of origin, age, marital status, political views, social status, and physical disabilities, nor create sense of discord in private or public, through citing academic ties, origin, and affiliated departments.
    • All departments and their respective tasks are interdependent, with no difference in their importance and contribution. The goal is to create a working environment of mutual respect and trust in which interdepartmental supremacy is rejected among members.
    • The company or any members of the company shall not make false or exaggerated reports for the benefit of an individual or a department, nor shall intentionally omit, conceal, or monopolize important information.

    Protection of the Company Asset

    • In the event that an important and urgent situation has occurred or is likely to occur regarding the asset of the company, it shall be reported promptly and appropriate measures and procedures shall be taken in accordance with the company’s internal reporting system.
    • The company’s CI and all assets shall be used for legitimate purposes only and prohibited from being used for personal use or interest without due cause.
    • The internet connection using an in-house LAN should be used for job performing purposes only, and inappropriate use such as unhealthy chatting, gambling, and access to obscene sites shall be prohibited.
    • The cost of meetings in which are out of job specifications shall be at own expense.

    Prohibition of Internal Information and Security Maintenance

    • The company’s operation, performance, strategies, on-going projects, business partnerships, customer relations, information about executives and other members, and any type of undisclosed information externally shall be used only within the scope of normal on-duty activities and shall not be leaked outside the company.
    • If a third party wishes to obtain confidential information about the company’s internal affairs or it seems that its actions are suspicious, it should be notified and reported to the Senior Members and the Secretary Office immediately.
    • Control third-party access to offices and computers and prevent leakage of job-related documents, memos, photocopies, and faxes to third party.
    • Do not make copies of documents or files containing important information more than needed.
    • Do not mention about sensitive matters or confidential matters related to jobs in public places such as elevators, hallways, restaurants, toilets, or public transportation.
    • Do not disclose any confidential information about the company to family members, relatives, and friends.
    • Information obtained in connection with a job during employment shall not be provided or used by others for personal gain after retirement.

    Domestic and Foreign Public Relations Policy and Media Relations

    • Information relating to the company shall be disclosed to the press and publicized only by authorized personnel within the company.
    • If a third party requests for company information in which only certain members have access to, such information shall not be provided and the designated employees shall be informed.
    • Any members of the company should not engage in any act that encourage distrust within the organization such as the creation or distribution of false rumors, or hindering a healthy organizational atmosphere.

    Conflict among the Interested Parties

    • Avoid situations in which personal interests may conflict with the interests of the company, and if potential conflicts of interests are expected, it should be shared with the Senior Members or the Secretary Office in advance.
    • Personal investments in targets that are likely to affect or affect job performance should be avoided. If the investment decision was made prior to being employed, it should be notified and reported to the Senior Members of the Secretary Office.
    • In the event of financial conflicts of interests between a member, family, relative or acquaintance-owned assets and the company owned assets, it shall be reported to the Secretary Office.
    • If a member of the company performs their job against a company that has direct or indirect interests with the member’s family, relatives, and acquaintances, the member shall report them to the Secretary Office.

    Prohibition of Accepting Unfair Benefits

    • Under no circumstances should the unfair benefits of bribery, entertainment or convenience be provided by stakeholders, including personal family affairs, holidays, etc., that could impair the fairness of the job performances. Exceptions shall be made in the case of meals or support for family affairs within commonly acceptable level.
    • The benefits of bribery, entertainment or convenience above commonly acceptable level shall not be provided to relevant agencies or interested parties.

    Prohibition of Accepting Unfair Benefits among Members of the Company

    • The unfair benefits of bribery, entertainment or convenience shall not be provided and accepted among members of the company. However, the exception is made to the extent accepted by the norms of the society when it comes to birthdays, support for family affairs, and promoting teamwork purposes.
    • Do not engage in unnecessary formalities in relation to promotions, department transfers, etc.
    • It is strictly prohibited among members of the company of money loan, feneration, or joint/mutual guarantee.

    A Ban on Misuse of the Titles or Positions

    • No post-retirement job guarantee is promised or required by stakeholders who have come to know during employment
    • Do not engage in business contracts personally or transactions such as renting assets or monetary loans with interested parties.
    • No Senior Members require or instruct their subordinates for monetary favors or personal chores.

    Prevention of Sexual Harassment and Improper Working Atmosphere

    • Sexual harassment, including actions and expressions, shall be avoided regardless of inside and outside the work.
    • Do not force others to drink, sing, dance, etc. at a company meal.
    • No sexual evaluation or metaphor is used against co-workers on their body and avoid unnecessary sexual contacts (physical contact).
    • Make no remarks emphasizing fixed gender roles.
    • Except in cases that are inevitable due to the role or job, it should be prohibited from drinking alcohol during working hours and excessively after work that could disrupt the job performance on the following day.

    Prevention of Money Laundering

    • Pay extra attention not to get the company or any members of the company involved in the process of money laundering and any suspicious transactions related to money laundering shall be reported by the prescribed procedures and methods.

    Social Work

    • All members of the company should take the lead in social work voluntarily as exemplary members of the society.
  • Self-Reporting

    • In the event that the benefits of bribery, entertainment or convenience out of commonly acceptable level are inevitably received by the interested parties in connection with the job or on-going projects, a report of any of the mentioned, regardless of whether it is returned or not, shall be prepared and reported to the Secretary Office within three days from the date of receipt.
    • When providing monetary benefits to the counterparty, comply with Chapter 5, Providing and Receiving Assets-related benefits of “Regulations on the Operation and Business of Financial Investment Companies” published by Korea Financial Investment Association

    Voluntary Return

    • In principle, if a bribe is received from a stakeholder, it should be returned to the provider, and if any sort of hospitality or convenience has been received, the as much corresponding due should be returned to the provider in money.
    • The return shall take place under the name of the person received, and all of the proof or evidence (any receipt, deposit slip, or other return evidence) of the return should be attached to the report to the Secretary Office. If it is deemed rude to return the money directly or it is not possible to return anonymously, the received items shall be enclosed to the report to the Secretary Office.
    • In the event that there is a concern of decay, deterioration, and damage due to the passage of time, the person shall donate to the social welfare facility in the name of the provider and report it to the Secretary Office attaching the evidence of the donation.
    • the Secretary Office shall regularly report to the Ethical Management Committee the status of managing and handling reports of bribery, entertainment or convenience.
  • Violations to be Reported

    • Any violation of the company’s Code of Ethics and the Code of Conducts.
    • Any act of ordering or forcing a violation.
    • An act of penalizing a whistleblower of any violation.
    • Any other act that may cause damage or loss to the company financially or reputational.

    A Whistleblower

    • Any member of the company who found the violations.
    • Customers, traders, or employees of the partners who have found or suffered from violations.
    • Members of the company, customers, traders, or employees of the partners who are disadvantaged for reporting violations.

    Reporting Methods/Procedures

    • Those who voluntarily report violations can freely do so through various methods such as through the main website, mail, email, phone calls or direct visits, regardless of format.
    • the Secretary Office posts the report of the violation on the company’s website.
    • The report of the violation shall be made clearly that it includes the names of the violator and the related parties and any witness or evidence shall be presented with the specific circumstances.

    Processing of a Report

    • the Secretary Office shall set up and operate a processing office that accepts and processes reports of violations with designated members exclusively responsible for the job.
    • the Secretary Office shall directly investigate the reported matters or request an investigation to the in-house investigating department, and the designated department shall notify the Secretary Office of the findings.
    • the Secretary Office shall report the violation to the Ethical Management Committee if the investigation confirms that the violation is true and the case is serious.
    • The Ethical Management Committee deliberates on the details of the Secretary Office’s report and cooperates with the Human Resources to take follow-up disciplinary actions according to the gravity of the violation.
    • If the details of the report are confirmed to be false and the whistleblower is supposed to have known or knew about it, it shall be reported back to the Ethical Management Committee according to the gravity of the issue and the Human Resources shall follow up with the disciplinary actions for the whistleblower.
    • the Secretary Office shall notify the whistleblower of the results of the investigation and handling of the case. However, it may not be notified if it is deemed unnecessary for the interests of the company.

    Protecting the Whistleblowers and Securing their Identity

    • The company shall keep confidential about the identity of the whistleblower and shall prevent them from any disadvantage caused by reporting, making statements, or providing information.
    • In the event of a divulgence of classified information, the Secretary Office may investigate the circumstances and report the results to the Ethical Management Committee and suggest disciplinary actions against the divulger.
    • If the whistleblower makes a request to transfer departments or change positions or roles in order to avoid any inconvenience or disadvantages caused by reporting, all possible measures shall be taken in respect of the whistleblower.
    • If the whistleblower is disadvantaged by the reporting process of the violation, the Secretary Office may require the relevant departments to help and restore the whistleblower’s original state within the company.
    • The company shall provide the same level of protection measures and security for those who have cooperated through any part of the investigation process.

    Recognitions and awards for whistleblowers

    • The company may exceptionally make a mitigation or exemption of disciplinary actions for those who voluntarily report their own faults and violations.
    • The Ethical Management Committee may propose a corresponding reward to the whistleblower if the report of the violation results in a significant contribution to the company, such as prevention of illegal activities, cost reduction, and mitigation of management risk.