■ Introduction
- This Code of Ethics states our ethical values and standards of conduct that every Innertron employee should follow and develop.
- Building a corporate image that is trusted by all stakeholders is a value we all need to pursue.
- Innertron established the Code of Ethics, which was introduced to all employees before 2019, in line with the intention of management innovation that puts ethics at the top of management values.
- This Code of Ethics consists of the introduction, the principles of ethical management that reflect employee compliance with ethical standards and responsibilities, and guidelines for ethical decision making.
All employees of Innertron must strictly comply with the ethical principles and put into practice the guidelines set forth in this Code of Ethics in all aspects of their work.
■ Ethical Principles
① Duty to comply with the Code
- Wherever Innertrons do business, they must comply with the applicable laws and regulations.
- Employees must endeavor to maintain the corporate reputation of Innertron.
- Employees must endeavor to satisfy customers, and work to develop and gain customer trust.
- Employees must be honest, fair, and trustworthy in all their work and interactions with the public.
- Employees must not engage in conflicting interests between themselves and the company.
- Employees must respect other employees and stakeholders, and there can be no discrimination based on race, nationality, gender, age, educational background, religion, location, disability, marital status, gender identity, etc.
- Employees should make efforts to create a safe workplace and to protect the environment.
- Employees should do their best to establish an ethical work culture by taking responsibility for and practicing ethical behavior.
② Employee Roles and Responsibilities
As a member of Innertron, employee must understand and put into practice all elements of the Code of Ethics and must comply with domestic and international laws and regulations related to anti-corruption.
■ Understand and comply with the Code
- Employees should be familiar with the contents of the Code of Ethics; claiming to not know the Code is never an excuse for an infringement of the Code.
- Employees should consult with their department head or management support team to make decisions about situations that conflict with the Code of Ethics.
- If an employee or another employee has acted unethically, there is a corresponding liability for that action.
■ Reporting Unethical Behavior
- If an employee or someone else has violated the Code of Ethics, one should immediately report or consult with the department head or management support team.
- Employees should be aware of the different ways in which they can report a violation of the Code.
▶ Leader Roles and Responsibilities
- Leaders play a pivotal role in enhancing the company's competitiveness by preventing and eradicating unethical conduct through ethical compliance.
▶ Decision making
- If there is a conflict between the company's interests and ethics, there is an obligation to make ethical decisions.
▶ Management responsibility
- In the event of unethical conduct, ultimately, leaders are responsible and take responsibility for managing the unethical behavior of subordinates.
▶ Performance
- Leaders strictly comply with laws and regulations, do not pursue private interests, do their best to uphold corporate values, and will not deal with corrupt stakeholders.
▶ Solicitation
- Leaders prohibit all solicitation and reject business influences from outsiders.
▶ Human respect
- Leaders endeavor to eradicate behaviors that hinder respect such as sexual harassment or verbal abuse in our organization.
Leaders should do the following to prevent the unethical behavior of employees and to respond to it when it occurs.
▶ Ethics Education and Counseling
- Ethics training and counseling should be provided to employees
- All employees should understand the importance of adhering to the Code and the practice of ethics.
■ Preventing Unethical Behavior
- In the case of habitually occurring ethics violations, fundamental prevention activities should be carried out by identifying the cause and improving the process.
- Employees should report or consult with the management support team immediately upon becoming aware of a violation of the Code.
③ Discipline for Violation of the Code
- Employees who violate the Code may be subject to disciplinary action, up to and including termination of employment, in accordance with the applicable regulations.
- In particular, there is a principle of zero tolerance for bribery, embezzlement, information manipulation, and violations of sexual ethics [1].
■ Disciplinary Behavior
Disciplinary action will be taken:
- If an employee violates the Code or asks someone to violate it;
- If an employee does not immediately notify your supervisor about a violation of the code of conduct, either known or suspected;
- If there is a failure to cooperate with the management support team investigation regarding issues that may violate the Code;
- And for retaliation against another employee for reporting an ethical management issue
[1] Items of monetary value: Receiving money and goods that are more than socially acceptable from stakeholders
Embezzlement: The illegal exploitation of company funds or property
Information manipulation: Acts of forgery, concealment, and dissemination of business information
Sexual Ethics Violation: Sexual activities that amount to sexual assault or harassment
■ Ethical Practices and Compliance
- We aim to establish an ethical corporate culture by complying with laws and practicing exemplary ethics through management activities that adhere to ethical global business practices.
① Monetary
- Items of monetary value and money (cash, gift certificates, use rights, etc.) are an economic gain.
- Employees shall not offer, demand, or receive anything of monetary value in any way from stakeholders.
[1]. However, the following cases are exceptions.
▶ Gifts for promotional purposes that do not exceed 50,000 won. However, the amount can go up to 100,000 won for agricultural, marine, and processed products (including flowers).
▶ Souvenirs with stakeholder company logos not exceeding 50,000 won and souvenirs normally offered to attendees at stakeholder-hosted events.
- If anything of monetary value is inadvertently received, it must be returned. If it is difficult to return, the gift should be reported to the management support team.
② Hospitality
- Hospitality can refer to a variety of activities during business gatherings and exchanges such as meals, drinks, golf games, performances, and entertainment.
- Stakeholders are prohibited from receiving a hospitality amount exceeding 100,000 won per person. If it is necessary to give and receive entertainment expenses in excess of 100,000 won per person in relation to work,
it must be approved in advance by the department head. If a hospitality amount exceeding 100,000 won is inadvertently accepted, it must be reported to the management support team. However, meals of less than
30,000 won per person may be provided to persons subject to the Anti-Solicitation Act, such as public officials, journalists, and faculty members, provided that the meal is provided for a legitimate purpose such as recognition
of work performance or for social rituals.
- Regardless of the amount, entertainment in entertainment venues with a sexual component is prohibited.
③ Convenience
- Convenience refers to providing or receiving benefits such as transportation, accommodation, tourism services, and support for events.
- The convenience of transportation, accommodations, etc., exceeding the normal level should not be given or received. However, accommodations provided to all attendees of an event, etc., are excluded.
- In the event of inadvertently giving or receiving accommodations in excess of the permitted range, the management support team must be informed.
④ Money Given as a Congratulatory Gift or Condolence
- Stakeholders shall not be informed of confrontations that occur between you and your colleagues; communicating issues through a third party is regarded as a notification by oneself.
- Personal messages may be posted on in-house bulletin boards, but personal mail such as invitations to weddings or obituaries shall not be sent through company channels.
- When discussing family events with colleagues, topics shall be limited to those concerning grandparents, parents, children, and spouse of the employee.
- It is recommended that a personal gift (including money) to celebrate or family events or offer a condolence between employees be less than 100,000 won.
- When providing monetary values as a congratulatory amount or condolence to external stakeholders, the limit shall be 300,000 won, including wreaths and flowers.
However, as stated in the Anti-Solicitation Act, the amount of money given as a congratulatory gift or condolence, excluding wreaths and flowers, shall not exceed 50,000 won.
⑤ Request / Recommendation
- The company shall not request / make recommendations about the following matters through internal coworkers or external acquaintances, and should report the requests or recommendations to the company's
management support team if requested.
▶ Requests for preferential treatment regarding equipment / materials and contracts.
▶ Requests for preferential treatment for personnel (recruitment, promotion, rewards, and transfers)
▶ Requests for preferential treatment (conveniences that exceed the normal range) or other preferential treatment outside of normal procedures
▶ Requests that management neglect due diligence in matters such as inspections
- No fraudulent solicitation shall be made directly or through a third party in relation to the duties as listed in the Anti-Solicitation Act.
⑥ Money Transaction
- Monetary transactions shall not be conducted with stakeholders, which includes items such as money loans, loan guarantees, or real estate leases.
- If a financial transaction is inevitably made with a stakeholder due to a personal relationship, it should be reported to the management support team.
⑦ Event Sponsorship
- If sponsored events such as departmental events or club activities are hosted by the company, it is prohibited to accept contributions from stakeholders.
- The conveniences of vehicles, places, services, etc., necessary for the event are also considered to have been received.
- If you inadvertently receive a convenience, you should report this to the management support team.
⑧ Unfair use of budgetary resources
- The company’s budget resources, such as meeting expenses and business operating expenses, should not be used for private purposes.
- In principle, corporate credit cards should only be used for expenses, and should be used in accordance with the purpose of the budget and the standards set by law.
⑨ Information and asset protection
- Employees must thoroughly protect the company's non-public information and important information.
- Important information must be immediately communicated to the people who need it.
- Information must not be distorted and false information must not be disseminated.
- The company's equipment and facilities may not be used for purposes not directly related to the company's business.
⑩ Fair trade
- As we comply with international standards and country-specific fair-trade laws, we do not engage in unfair trade practices such as collusion in production and pricing, bidding, and market division, and compete fairly in the market.
- Superior status must not be used to make unreasonable demands on or request payment from customers and trading companies.
- The rights and property of others, including intellectual property, must not be infringed upon, and unfair trade or gain is not permitted.
- Company information, including competitor information, may only be obtained and used in a legitimate manner.
■ Work-Life Balance for employees
- We have created a workplace with a corporate culture that respects individual growth and company development through a work-life balance.
① Pursuit of work-life balance
- We aim to improve quality of life by providing welfare benefits to help employees stabilize their living conditions.
- We support our employees in achieving their personal vision and to be flexible in work hours, workplace, work style.
② Training and growth opportunities
- We have established a work environment and a system where employees can work creatively.
- We support capacity-building and self-development education so that employees can develop their abilities and qualities to become the best.
③ Fair evaluation and reward
- The company conducts fair evaluations based on individual employee capabilities and performance, and systematically reflects them to ensure appropriate compensation.
④ Creating a Healthy Organizational Culture
- Employees should also pursue an approachable corporate culture through open communication.
- Employees create an organizational atmosphere that removes barriers and encourages cooperation with each other.
■ Creating customer value and securing trust
- Recognizing that our customers' trust and success are our future, we always respect their opinions, strive to understand our customers, and create value that will help them.
① Customer Satisfaction
- We perform customer-oriented work that listens to and respects the voice of customers.
- We actively accept the legitimate demands and reasonable requests of our customers.
② Customer Value Creation
- We respond to customer needs by providing the best products through our continuous technology development.
- Employees should work to develop service minds that understand domestic and international market conditions and respect customer cultures and customs.
③ Obtaining customer trust
- We do not provide products and services that threaten safety and health; the safety and health of customers must be taken into consideration by management.
- We protect customer information and comply with all applicable laws and regulations.
- We provide accurate information to customers in a timely manner.
■ Duty of Good Faith to Investors
- Maximize investor value by realizing legitimate benefits through transparent decision making and efficient management activities.
① Seeking to increase shareholder value
- We profit from transparent decision making and efficient management activities, and increase corporate value and shareholder value at the same time.
② Fair provision of investment information
- We do not provide information that may affect the investor’s judgment only to some of the investors, or screen the contents provided to them.
- Stocks or securities may not be traded using internally acquired information, nor should others be encouraged to do so.
③ Calculate and provide transparent financial information
- Financial information should be generated through appropriate processes and controls based on accurate trading facts.
- Generally, financial reporting is prepared in accordance with accepted accounting standards.
- Provide sufficient and accurate management information so that investors can make investment decisions freely and responsibly.
■ Establish a win-win relationship with trading companies
- We will establish a fair-trade order based on mutual trust and build a cooperative enterprise ecosystem through mutual growth with stakeholders.
① Mutual trust building
- Dealings with our trading companies must be carried out fairly, on a foundation of equality and mutual respect.
- Information obtained when dealing with trading companies is strictly protected in accordance with the relevant laws and contractual terms.
- It is our mandate to help trading companies comply with laws and regulations related to fair trade.
② Promotion of shared growth with trading companies
- Results shall be shared with trading companies for the purpose of mutual benefit.
- Smooth communication and mutual cooperation with trading companies ensure that trading companies can provide high-quality products and services.
- Partnerships shall be developed with trading companies by providing equal opportunities and ensuring reasonable terms and conditions.
③ Support for continuous development of trading companies
- Establish a stable supply chain through technical and financial support for trading companies.
- Expand the scope of shared growth with trading companies for a corporate ecosystem where everyone benefits.
■ Contribution to Country and Society
- Contribute to national and social development by fulfilling our responsibilities and duties as citizens.
① Role and attitude as a corporate citizen
- Respect local laws and regulations, the culture and traditions of local communities, and strive for shared development with the national community.
- Efforts should be made to communicate through stakeholder involvement in management activities related to society at a national level.
- Efforts will be made for trading companies to be able to participate in activities for the development of society at a national level.
② Contribute to national and social development
- We shall fulfill its obligations in the community by creating and maintaining stable jobs and paying taxes in good faith.
- We shall actively participate in social service activities such as volunteering and disaster relief, and promote public interest activities in various fields such as culture, arts, sports, and academics.
- We shall support local residents to improve their quality of life.
■ Environmental protection and ecosystem conservation
- We shall establish an environmental management system, strengthen its capacity to respond to environmental risks, and conduct eco-friendly management through open communication.
① Environmental Management System
- In order to effectively operate the environmental management system to achieve the environmental management goals, the company shall evaluate the impacts and risks of corporate activities on the environment and systematically analyze the performance of environmental management.
- We shall share performance and issues with various stakeholders, who will then carry out environmental conservation activities together.
- Trading companies and environmental protection form a consensus on the company's basic social responsibilities and support compliance with environmental laws and regulations.
- We shall help trading companies ensure public health and safety in the production and service of products, while minimizing negative impacts on the community environment and natural resources.
② Compliance with environmental laws and lessening environmental impact
- We shall comply with environmental regulations and strive to lessen environmental impact in all processes of product development, production, and use.
- We shall minimize pollutant emissions by introducing eco-friendly production processes and applying optimal technologies to prevent environmental pollution.
③ Response to climate change
- Efforts will be made to reduce greenhouse gas emissions by reducing fossil fuel and raw material consumption and improving energy efficiency.
- We shall strengthen its competitiveness through the development of low carbon technology and innovation.
④ Environment and ecosystem protection
- Efforts will be made to restore natural ecosystems and preserve biodiversity by efficiently utilizing natural resources and by-products.
■ Protection and respect of human rights
- We shall respect human rights, uphold relevant international standards, and preserve human dignity for all stakeholders through freedom, security, and quality of life.
① Respect for international human rights standards
- We respect and support internationally accepted standards on human rights, including the Universal Declaration of Human Rights, the UN Principles for Business and Human Rights, the UN Global Compact, and the OECD Guidelines for Multinational Enterprises.
- We have established a clear human rights protection policy and system, and never infringe on human rights in the course of conducting business.
- We support trading companies who comply with human rights regulations as required by international standards on human rights, and we protect the human rights of our employees and treat them fairly.
② Due diligence for respect for human rights
- Due diligence may be conducted on management activities that infringe on human rights or cause complaints.
- If due diligence determines that the company's management activities have violated human rights or caused dissatisfaction, reasonable solutions shall be sought.
- Communicate with relevant stakeholders on the content and results of activities related to human rights.
③ Employee protection
- No one shall be permitted to engage in verbal, physical, or visual acts that are offensive to others, including sexual harassment that violates a person's human rights.
- We respect the privacy of our employees, and will not slander or demean others, nor will we disclose personal information.
- We will ensure that involuntary work does not occur by mental or physical coercion.
- The working conditions for minors and the minimum age standard for being employed shall comply with national labor laws and international standards.
- All safety rules shall be thoroughly observed and appropriate action shall be taken for any hazards found.
④ Respect and equality
- No discrimination or harassment based on race, nationality, gender, age, educational background, religion, region, disability, marital status or gender identity shall be tolerated.
- Equal opportunities for employment shall be provided where job qualifications and competencies are met.
- We will maintain a harmonious working environment by respecting cultural differences.
⑤ Guarantee of legal and human employment conditions
- We will respond promptly to human rights issues raised by employees using the company's grievance mechanism.
- We will ensure employment conditions, such as maintaining appropriate working hours, shall be observed so that human dignity is maintained.
⑥ Respect for Human Rights in the Community
- If human rights are violated in the local community due to the company's management activities, we will collect opinions and try to resolve any human rights issues.
[1] Stakeholders: Employees and customers, clients, trading companies, affiliates, partners, the domestic and international public, and international organizations
(including their employees) who may be directly or indirectly affected or affected by their rights or interests in relation to their work.
① Compliance with the Code of Ethics
- The Code of Ethics should be used to assess conduct, and should be faithfully followed.
- Management of the Code of Ethics is conducted by the management support team, and detailed operation shall be carried out by the department responsible for management in each area [1].
- Separate standards may be set when necessary for the efficient operation of the Code of Ethics.
② Responsibilities of executives and department heads
- Executives and department heads should conduct training and consultations from time to time so that their employees fully understand the Code.
- Executives and department heads should take appropriate precautions to ensure that employees do not violate the Code.
③ Duty to report and confidentiality
- If an employee finds out that the Code of Ethics has been violated, the incident should be reported to the management support team in the fastest and most convenient way.
- Executives and department heads should report to the management support team immediately after receiving reports of violations of the Code of Ethics.
- The management support team can check facts when necessary, and the related employees must cooperate.
- Related employees shall not penalize or disclose the identities of the person who reported the incident.
- If the reporter and the complainant are likely to be disadvantaged in their work position, personnel actions such as a change of position should be implemented according to their wishes.
- Related employees must not reveal sensitive information, even if they accidentally find out a report has been made; if information is revealed, this employee may be subject to disciplinary punishment.
- Operational standards for reporting and compensation for unethical behavior regarding the receipt of money from stakeholders, etc., shall be determined separately.
④ Awards and Discipline
- We may reward or give appropriate compensation to employees who are devoted to achieving the purpose of the Code of Ethics according to the relevant regulations.
- We shall implement strict remedies for employees who violate the Code of Ethics.
- We may restrict employees who have violated the Code from entry to the company and may prohibit transactions by retired employees who violated the Code.
⑤ Ethics Committee
- We may establish and operate an Ethics Committee to report, deliberate, and resolve important ethical matters. The operating standards shall be determined separately.
⑥ Interpretation
- Any violation of this Code of Ethics by family, relatives, acquaintances, etc. who use the name of the employee shall be regarded an act of the employee.
- If there is any issue that is not specified in the Code of Ethics or there is a dispute in the interpretation, contact the management support team and follow their suggestions or guidance.
⑦ Revision
- If necessary, the management support team shall revise the Code of Ethics, but the matters deemed important by the head of the management support team shall be revised with the approval of the CEO.
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