A. If an act is in violation to the Code of Ethics or the guidelines for practice, not only the boss/supervisor/senior member who gave the order but also the subordinate/staff who followed the order shall be held accountable. Therefore, even it is an order to follow, you have to reject it and report it to the Secretary Office.

A. The company will thoroughly protect the whistleblowers’ identity to prevent such conflicts with their boss and colleagues in any way possible so they will not suffer any disadvantages. it is also desirable for violations and irregularities to be promptly reported before they develop into bigger problems.

A. Using corporate credit card for meeting acquaintances who are not related to the jobs and treat them as corporate expenses can be an example. Intentionally taking office supplies from the office is also an example.

A. If the budget for the meetings is spent for the necessary performance in connection with additional meetings and related overtime, it can be acceptable. However, in case of entertainment expenses, it should only be spent for the reception of outsiders, such as customers and clients in relation to the job or on-going projects.

A. The company information may not be used for any reasons other than job-accomplishing purposes. Since the ownership of the information obtained by any employees belongs to the company, leakage or private usage of any information, how trivial it may seem, is not only a violation but also subject to criminal charges for wrongdoing. In the event that documents, PCs, USBs, etc. are transferred to a location outside the company, it must be approved by the designated person in advance and the details of the transfer and import shall be thoroughly managed.

A. You will not be held responsible if it was sent to those who are related to the job as a reference, but if it is sent to a person who is not related to the job, you will be held responsible.

A. Under the Act on Real-name Financial Transactions and Confidentiality, the company shall never provide customer information such as securities trading history or account balance without receiving written consent or specific requests from the customers. However, providing information is allowed as an exception by taking the specified procedure for the following cases,
-in case needed for the inspection by the supervisory agency.
-in case of a court order or a warrant issued.
-In case a tax official presents an official document or request issued by the head of the relevant. department or the head of a local government.
-Under the request of the head of FSS, Stock Exchange, KOFIA, and KSFC.
-In case a written request is made based on the purpose of the investigation by the prosecutor.

A. A conflict of interest includes situations such as when a person is able to exert influence when getting the job done or making a decision or a person is unfairly to gain profit from using the information obtained from work. More specific examples are as follow;
- The act of contracting or making a transaction directly through personal business or a third party.
- The act of doing business with competitors or clients of the company through personal business.
- The act of being double-employed by the company and the related company without prior approval from the company.
- The act of establishing a monetary relationship with a client on a loan, a joint investment, a loan guarantee, a real estate or any asset.
- The act of personally receiving benefits or compensation from the clients of the company.
- The act of acquisition of the stocks or bonds of the clients.
- The act of an employee’s family or relatives doing business with the company or its clients
- The act of an employee unfairly profiting from the information obtained in course of job.
- The act of employees who handle investments and loans to venture firms, etc., make equity investments prior to the shares of the venture firm is traded normally in the stock market.

A. Even if a conflict can be handled internally, the following cases should be reported without delay:
1) Does it cause serious harm to the company and society?
2) If it is clear that something is wrong and not being fixed, either cases should be reported.

A. It does not matter if it is inevitable to borrow at normal interest rates. It is not about the personal relationship that matters, it is about giving or providing ‘comparative advantage’ to specific employees or any of the clients.

A. Any contract with a company owned by a relative or an acquaintance does not constitute a violation. However, it does constitute a violation of the company’s any negligence when evaluating candidates in order to register the relatives’ and acquaintances’ as clients during the process of selecting a client or executing unfair business through the leakage of bidding information or arbitrary contracts. In addition, giving direct or indirect orders or requests to do business with a company owned by your relative or acquaintance using your position is also in violation as well as getting any sort of monetary benefits from candidates whether or not is not owned by a relative or an acquaintance.

A. Depending on the company’s special anniversaries or social status of the guests, there are cases where expensive gifts are given with the company logo carved. In such cases, it is acceptable only if prior approval is obtained within the company.

A. Our company covers expenses for business trips and in result it can be a burden to the counterparty although it was given in a favorable manner. In conclusion, it must be rejected considering the fact that it can be a factor to influence the result.

A. If you are the person in charge who can influence the process of decision making for a business, it is difficult to say that any gifts from clients are just for friendship or amity. Therefore, we must explain in detail of the company’s code of ethics and practice guidelines and politely decline them. If you unavoidably accepted a gift, you should express your gratitude to the provider but at the same time, report it to the Secretary Office.

A. Under no circumstances should cash be provided or accepted.

A. It is an official event so it is acceptable.

A. If there is an offer for an after-dinner drink, it may be difficult to resist, but it should be politely declined, especially not to receive excessive or expensive hospitality. It does not only violate the guidelines but also affect the job performance for the following day.

A. Our code of ethics and code of conduct prohibits golfing with a business-connected client. Therefore, you must explain in details of the code of ethics and politely decline the offer.

A. Although it is acceptable if each player covers own expenses, it is advisable to refrain from doing so as it may affect future businesses.

A. The boss can give gifts to his/her subordinates for birthdays, supporting for family affairs, and promoting teamwork purposes. However, if the expense was covered by a client, it is a violation of the code of ethics. In addition, it is strictly prohibited whatsoever for subordinates to provide any benefits, such as bribery, entertainment or convenience, to their boss.

A. Although it would be difficult to refuse favors from a boss or colleague who we meet every day at work, the relationship may worsen, harm the work atmosphere, or disrupt the company’s performance as a whole if the borrower fails to pay back in time so it is not desirable to do so among the members. In particular, all acts of borrowing money from subordinates or demanding guarantees using their status shall not be carried out even if it is under the right interest terms or legal contracts.

A. It would be perfect if such matters are resolved through open communications, but if not, consult with the Secretary Office for assistance.

A. The followings constitute sexual harassments;
- The act of directly making obscene jokes or indirectly making obscene and sexual stories.
- The act of expressing excessive interest in other’s appearance or clothing and making sexual evaluations or comparisons
- The act of viewing pornographic sites online, posting obscene pictures and drawings and spreading them, etc.
- Kissing or hugging, hugging from behind, forcing a massage or a caress.
- Forced to serve or drink at a meal.
- The act of making unnecessary physical contacts.
- Emphasizing fixed gender roles, etc.

A. Although we have been continuously preparing standards for developing a healthy drinking culture from the past, we still lack them. The followings are just suggestions from the company, but as a good gesture of descent members of the company, please follow the below voluntarily.
- All business related or personal get-togethers and dinners should end in the first round.
- Avoid gathering and drinking in places where unnecessarily excessive expenses are incurred.
- Let’s stop the bomb-drinks culture.
- Let’s not recommend excessive drinking and ignore personal tolerance to alcohol.

A. It is NOT allowed. It is in violation of Section 2 “No unnecessary Formalities in relation to promotions, department transfers, etc.” of Article 13 「No Mutual Benefit Acceptance among Members」 of the code of ethics. the Secretary Office will release a list of items including potted plants (e.g., an orchid) could be exchanged between members in a near future, so please refrain from doing anything unnecessary. Please send your sincerity through phone calls or emails and those gifts should be returned to the Secretary Office.

A. It is NOT allowed. The members of company shall not receive any form of bribery, entertainment or convenience from the clients. However, exceptions can include light meals or small amount of money to help family affairs that do not affect any part of decision making process of on-going projects. Until now, it has been customary or norm of the society to give and receive gifts from clients in cases of promotions or transfers, but in order to take the initiative in the ethical management, we will not accept them in the future. Of course, congratulatory message, calls, and emails are fine. If you were not present when a gift arrived or have no way to return it by courier service, please report it to the Secretary Office for processing. If it is out of personal level such as new opening or relocation of a branch office, it shall be recognized as an exception, but it shall be within the acceptable range as much as possible, and if it exceeds that level, it shall be reported to the Secretary Office.

A. If it is not from a stakeholder or business related party, of course, it is allowed. It should be clearly identified that they are not stakeholders but simply acquaintances.

A. The office will handle them through internal auctions and use the proceeds for social contribution activities. if not disposed through in-house auction, the company will either use them for the public uses or make them available to an outside auction. As the internal auction is difficult for the branch offices, they can be utilized for the public uses or make them available to an outside auction according to the guidelines of the branch offices.