POSCO GYRTECH

Upholding the core values of integrity, fairness, and honesty remains our unwavering commitment as we endeavor to craft a corporate reputation worthy of trust from all stakeholders. To that end, the POSCO Group initiated a code of conduct in 2003, setting ethical benchmarks for every employee. By 2014, this commitment deepened as the United Nations human rights and respect principles were seamlessly integrated into our code. Most recently, in our continuous drive for business innovation with ethics at its core, we refined these standards, further fortifying our code of conduct.

This journey stands as a testament to our dedication to the POSCO Group's rich heritage, a legacy cemented by our predecessors' sacrifices and our founding members' tireless efforts.

• 1. POSCO GYR-TECH employees must comply with all relevant laws and regulations wherever we operate in the world.
• 2. POSCO GYR-TECH Employees must behave with dignity and try to maintain the reputation of the company.
• 3. Employees must demonstrate honesty, fairness, and credibility when conducting all businesses and developing business relations.
• 4. Employees must not engage in actions that may cause any conflict of interest.
• 5. Employees must not discriminate against other employees or stakeholders on the basis of race, nationality, gender, disability or religion and must appreciate each individual’s dignity and diversity.
• 6. Employees must seek to create a safe workplace and to protect the environment.
• 7. Employees must make their utmost efforts to create an ethical culture by taking responsibility for their behavior and embracing ethical practices.

• 1. Understanding and compliance with the Code of Ethics
  • - Be familiar with all the content in the Code of Ethics and follow it faithfully.
  • - Consult with the head of the department or the Right Path Management Office in situations that are likely to violate the Code of Ethics before making a decision.
  • - For any case of unethical conduct in which you are involved, you will be held responsible for the outcome.
  
  
• 2. Reporting and counseling for unethical behavior
  • - If you become aware of your own actions or actions of others that are in breach of the Code of Ethics, you must immediately report to or consult with the head of the department or the Right Path Management Office.
  • - You must be aware of different ways to report or seek consultation about actions that violate the Code of Ethics.
  
  
• 3. Role and responsibilities of leaders

  A leader of a team or a department must play an essential role in enhancing the competitiveness of the company by preventing and eliminating unethical behavior through compliance.

  
  

  (1) Decision making

  In case the company’s interest conflicts with ethics, you are obliged to make decisions based on ethics

  (2) Management responsibilities

  When the management engages in unethical behavior, they take full responsibility for their actions. They also take responsibility for any unethical conduct of their junior employees.

  (3) Execution of business

  Abide by the law. Do not pursue private interests, but do your best to create corporate value. Do not participate in corrupt dealings.

  (4) Exclusion for solicitation

  Eliminate all solicitations and any exercise of influence in business deals in connection with outsiders will be excluded.

  (5) Respect for human beings

  Eradicate actions that undermine respect for other people, such as sexual harassment and/or verbal abuse.

  (6) Ethical Practices

  Take the initiative in running Ethical Practice Programs to ensure that the culture of ethical practice is improved to the highest global level.

  
  

  Leaders must prevent any unethical behaviors from their team members, and in case an employee does breach the ethics policy, they must take the following actions.

  
  

  (1) Ethics education and counseling

  • - Provide ethics education and counseling to the employee.
  • - Ensure that they fully understand the importance of complying to Code of Ethics and ethical practices.

  (2) Management responsibilities

  • - For unethical behavior that occurs repeatedly, identify the cause of and improve the process to perform actions that eradicate such behavior.
  • - Upon receiving a report that an employee in your team or department has violated the Code of Ethics, report to or consult with the Righteous Management Office.

Employees who violate the Code of Ethics may be subject to penalties including dismissal pursuant to the relevant regulations. A zero-tolerance policy is applied for bribery, embezzlement, manipulation of information and sexual misconduct.

• Actions subject to penalties
  • - Actions in a breach of the Code of Ethics, or demanding other people to violate the code.
  • - Failure to immediately provide notification of any violations or suspected violation that you have learned of.
  • - In case you do not cooperate with the investigation by Righteous Management Office on a possible violation case.
  • - In case of retaliation against other employees who have reported an ethical management issue.