Fair Trade eNtoB

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Fair Trade Compliance Program, CP

Compliance program

The CP, or self-regulatory Compliance Program, is an initiative designed and managed by a business to ensure strict adherence to fair trade laws. This comprehensive system facilitates the internal framework of education and supervision.

Guidelines for the Implementation of the self-regulatory Compliance Program Fair Trade Counseling and Reporting Center

Rationale Behind the Implementation of CP

The fundamental objective of our CP is to construct an internal compliance framework that periodically identifies and eradicates any business practices infringing upon fair trade laws. In doing so, we aim to safeguard our employees internally while externally fostering an atmosphere of fairness and freedom in competition, thereby advancing our pursuit of sustainable business operations.

Eight Central Tenets of CP

The primary objective of establishing an internal compliance system and systematically eliminating non-compliant business practices is to provide our employees with a secure working environment. Moreover, we aim to stimulate a business landscape conducive to free and fair competition, reinforcing our commitment to sustainable management.

Leadership's Commitment to and Support for Self-Regulatory Compliance

-Our CEO publicizes their unwavering commitment to fair trade, offering robust support to the CP's implementation.

Designation of a Compliance Officer

-Our board of directors, the organization's highest decision-making body, appoints a dedicated compliance officer.

-This role is responsible for ensuring the CP's effective operation.

Development and Utilization of the Self-Regulatory Compliance Manual

-We have crafted a comprehensive manual that outlines the CP's standards, procedures, and pertinent fair trade laws.

Systematic and Regular Execution of Self-Regulatory Compliance Training

- We deliver regular training sessions for employees, covering the CP's standards, procedures, and the importance of compliance with fair trade regulations.

Disciplinary Actions for Employees Violating Fair Trade Regulations

- Employees found violating the regulations are disciplined based on the severity of their infractions, as per our internal rules.

Establishment of an Internal Surveillance System

- We have built a robust supervision system that prevents violations and reports to the board of directors.

Evaluation of Effectiveness and Implementation of Improvement Measures

- We conduct regular audits, assessments, and enhancements of the CP's standards, procedures, and operations.

Formation and Execution of CP Standards and Procedures

- We have set up standards and procedures that promote adherence to fair trade regulations.

CP Implementation Progress

Year/Month	Progress
2011.10	Announcement of CP (Compliance Program) Introduction (Announcement by CEO Park Jong-sik)
2011.10	Formulation of the 'Self-Regulatory Compliance Program Implementation Guidelines'
2011.12	Establishment of 'Internal Audit Rules'
2012.06	Distribution of the Foreign Corrupt Practices Act (FCPA) Compliance Guidelines
2013.12	Development of a Verification System for Identifying the Representative of Companies Bidding on the Same IP
2014.06	Created a comprehensive fair trade compliance manual across 25 companies in the POSCO Group
2015.01	Awarded the '2014 Corporate Ethics and Fair Trade Model Headquarters Recognition
2017.07	Operated the 'Clean eNtoB' platform
2019.02	Provided guidelines for the 'Conflict of Interest Prevention'
2019.06	Instituted the discretionary contract pre-audit mechanism
2021.04	Expanded the implementation of the discretionary contract pre-audit system
2021.05	Launched the 'Good Friend' program
2021.10	Revised the 'Fair Trade Compliance Program Operating Guidelines'
2021.11	Formulated the 'Fair Trade Compliance Manual'
2022.07	Appointed the Fair Trade Compliance Manager's Board
2022.08	Instated the Compliance Manager and the Compliance Council Members
2022.09	The CEO participated in the 'Self-Driven Linkage Payment System Agreement Ceremony'
2022.11	The CEO received the Prime Minister's Award for Mutual Growth Cooperation
2022.12	Comprehensively revised the 'Fair Trade Compliance Manual'
2022.05	Newly opened the 'Fair Trade and Collusion Report Center' on the website
2023.06	Implemented the 'Bid-rigging Self-inspection Checklist'

Progress of CP Operational Elements

From 2011 onward, eNtoB has steadfastly put into action the tenets of the self-regulatory Compliance Program (CP).

Initiatives Undertaken	Results of the self-regulatory Compliance Program
1. Proclamation of CEO's Commitment to Self-Regulation	- The CEO, in October 2011, formally endorsed the 'CP' Voicing “an intention to promote transparent and equitable corporate conduct by elevating our ethical business practices via the deployment of the self-regulatory Compliance Program.” - All employees have pledged to adhere to self-regulatory compliance - CEO’s remarks at the May 2022 Executive Meeting “Given the escalating standards due to the introduction and enhancement of various regulations, it's imperative that all responsible personnel ensure no aspect of the law's requirements is overlooked through vigilant attention and appropriate system support.” - ’CEO's remarks at the September 2022 Executive Meeting "I urge those in managerial positions to scrutinize their respective responsibilities for any risks pertaining to the Fair Trade Compliance Program and initiate corrective measures as needed." - CEO's remarks at the March 2023 Executive Meeting "Our aim is to secure the top rating in the administration of the Fair Trade Compliance Program (CP). As we strive to fortify our ESG management, all employees must be well-versed in fair trade regulations to avoid violations, considering it's a basic necessity our company needs to meet." - CEO's remarks at the April 2023 Executive Meeting "As a company, we are committed to fostering the highest caliber of procurement professionals within the POSCO Group. Cultivating purchasing expertise necessitates more than just mastery of procurement tasks—it also calls for the development of ethical sensibilities. As such, I encourage formulating, sharing, and discussing an education plan geared towards nurturing exceptional employees rooted in unwavering ethics."
2. Designation of a Compliance Officer	-The Board of Directors' resolution led to the appointment of the Compliance Manager in July 2022.
3. Compilation and Dissemination of a Self-Regulatory Compliance Handbook	- In November 2011, we pioneered creating and distributing a manual outlining Fair Trade Compliance. - In September 2012, we launched a unified manual applicable to all entities within the POSCO Group. - The Fair Trade Compliance Manual underwent revisions in November 2021. - December 2022 saw the inaugural launch of a mobile app for autonomous Fair Trade compliance checks. - In December 2022, the Fair Trade Compliance Manual was revised.
4. Management of a Self-Regulatory Compliance Training Program	- Regular educational sessions on fair trade principles are conducted for every operational division. - Fair Trade education is delivered at all levels, spanning executives, appointees, and new hires. - Both E-learning courses ("Simplifying Fair Trade") and offline Fair Trade training are offered. - Launched an internal blog on fair trade to disseminate information on the latest violation cases and recent trends in fair trade. - Conducted small groups and distributed education under the supervision of the Fair Trade Practice Leader.
5. Disciplinary Measures for Employees Contravening Fair Trade Rules	- Penalties are stipulated and enforced based on the severity of unlawful actions. - Rapid disciplinary actions are initiated against transgressors of the law.
6. Development of an Internal Oversight Framework	- An autonomous inspection system is facilitated by employing a self-checklist for Fair Trade. - A system for preliminary task consultation with the Compliance Officer and dedicated departments is in place.
7. Appraisal of Efficacy and Implementation of Corrective Measures	- Following assessments and audits of CP norms, procedures, and operations, we drive forward necessary enhancements.
8. Formulation and Application of CP Standards and Procedures	- Operational guidelines for the self-regulatory Compliance Program were instituted in October 2011. - In October 2021, we comprehensively updated these operational guidelines. - Amended the Fair Trade Compliance Program Operating Guidelines in November 2022.

Self-Regulatory Compliance Council

The Self-Regulatory Compliance Council conducts in-depth discussions on crucial issues concerning the investigation and punitive actions related to Fair Trade transgressions and provides essential recommendations and advice.

- Committee members engage in quarterly routine meetings and participate in ad hoc sessions as required while fostering Fair Trade education within their respective groups.

-Each group's committee members pinpoint a Fair Trade Practice Leader to secure the effective functioning of the Self-Regulatory Compliance Council.

Operation Status of CP Initiatives

November
2022 Second assembly of the Self-Regulatory Compliance Council, alongside the fourth congregation of the Fair Trade Implementation Leaders Council

October
2022 Third gathering of the Fair Trade Implementation Leaders Council

September
2022 Second convening of the Fair Trade Implementation Leaders Council

August
2022 Inaugural meetings of both the Self-Regulatory Compliance Council and the Fair Trade Implementation Leaders Council

June
2022 Formation of the Self-Regulatory Compliance Council

May
2022 A declaration of self-regulatory compliance commitment by the CEO

January
2021 Hosted an organization-wide fair trade self-regulatory compliance pledge ceremony

January
2020 Initiation of self-regulatory compliance commitment practice

June
2011 Creation and dissemination of the Self-Regulatory Compliance Manual across all POSCO Group corporations

Fair Trade Self-Regulatory Compliance Manual

In June 2011, eNtoB crafted and distributed the Fair Trade Self-Regulatory Compliance Manual to all employees. The manual underwent a revision in September 2012 to incorporate amended legislation and practical examples, thereby enhancing its active usage across the POSCO Group.