Tongsuh Petrochemical Corporation

Creating for Tomorrow

“Contribute to the Life and Living of People around the World”

Compliance Management Implementation System

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Item	Decision-making body	Responsibility
Decisions to activate policies and standards of conduct	Executive Meeting	Based on the deliberation, decide whether to activate or deactivate the Business Ethics Policy and Standards of Conduct.
Proposal of a plan to activate the standards of conduct and measures against violations	General Affairs Team	Submit a proposal to activate the policy and standards of conduct at the Executive Meeting. Submit a proposal for measures against violations to the Personnel Committee.
Implementation of education, dissemination and auditing	Each department	Conduct audits on training, dissemination, and compliance with Business Ethics Policies and Standards of Conduct.

Standards of Conduct on Compliance

Rules on Business Activities
Rules on Individual Activity
Rules on Operating Internal Notification System

Environmental conservation, product safety, security disaster prevention, labor stability, hygiene and health	RC activities are the basis of our business activities, primarily focusing on environmental preservation, product safety, security disaster prevention, occupational safety, hygiene, health, and social communication. It is essential to constantly improve through business activities to deal with environmental conservation, such as preventing global warming, securing biodiversity, forming a circular society, and managing chemical substances. In addition, full consideration must be given to human health and safety, including post-disposal treatment, when providing products or services. In addition, security and disaster prevention, occupational safety, hygiene, and health must also be ensured in daily business activities. The company encourages thorough implementation by adopting 『RC Policy』, 『RC Management Rules』, 『Process Safety Management (PSM) Rules』, 『Product Liability (PL) Management Rules』, 『Environmental (ISO 14001) Management Rules』, etc. In addition to complying with these in-house regulations, we must always pay attention to environmental conservation, human safety, and health in our daily activities.
Harmony with the local community	Businesses have roles and responsibilities as citizens in the local community. We will fulfill our commitments, recognizing that it is a vital mission as a member of the region to fully comprehend the culture and customs of the area, both at home and abroad, and to contribute to regional development.
Disclosure of information and communication with society	The company will always maintain healthy relationship by disclosing information and assertively pursuing communication activities with the entire society including the interested parties such as customers, stockholders and employees, etc. Regarding disclosure of information, the company will pursue fairness, equity and accuracy in corporate information while putting in efforts to disclose informaiton as quickly as possible at the same time. In addition, regarding communication activities, the company will continually buildup relationship based on trust through efforts for bidirectional communication with interested parties and society, and, moreover, promote understanding of the company as well as strive to increase the corporate value.
Compliance with economic laws, etc	For companies to provide better quality and affordable products and services to society through competition, it is necessary to ensure fair and free competition between suppliers. We strive to secure fair and free competition by complying with the 『Monopoly Regulation and Fair Trade Act』 and 『Fair Transactions in Subcontracting Act』. In addition, concerning the export of strategic materials, etc., we do our best to to prevent suspicious actions by others complying with internal regulations such as the 『Regulations on the Management of Voluntary Export of Strategic Materials』.
Sound and appropriate business relationships	In relation to stakeholders, it is prohibited to provide or receive products or services that violate public morals or exceed common sense or widely-accepted social norms. In particular, departments responsible for goods and services shall not accept holiday gifts or congratulations from stakeholders. In addition, we should refrain from passing the burden of costs on to stakeholders.
Respect for intellectual property rights	We protect the company's intellectual property rights, such as patent and utility model rights, and respect the intellectual property rights of others. Using such intellectual property rights without the right holder's consent may result in a prohibition and demand for compensation for damages from the right holder, which should be taken seriously.
Protection of information assets	The information acquired through on-the-job tasks is the company's property. By using such information competently, we seek to perform our work efficiently and enhance our competitiveness. Sufficient consideration is required to prevent information leakage because compromised valuable information may lead to diminished asset value and loss of business opportunities unless protected confidential from outside the company. All employees shall handle information appropriately complying with internal regulations such as Trade Secret Management Regulations. We must not use the company's information system for any purpose other than work or access websites that provide sexist contents. In addition, enterprise information systems, including our computers, are interconnected through networks, and inappropriate use of an information system by one person can lead to the threat of information leakage in the company. Thus, special attention is required.

Rules on Business Activities

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Item	Responsible department	Relevant laws	Internal regulations
Environmental conservation Product safety Security disaster prevention Occupational safety, hygiene and health	Environment Team, Safety Team	Environmental safety-related laws, such as the Industrial Safety and Health Act, Water Quality and Air Quality Management Control Act, etc.	RC policy and related regulations PSM related regulations ISO 14001 related regulations
Communication with the company Provision of information to customers, employees, and shareholders Security disaster prevention Occupational safety, hygiene, and health	General Affairs Team		Business Ethics Policy and Standards of Conduct Rules of Employment
Entertainment	Entertainment		Business Ethics Policy and Standards of Conduct Internal Audit Regulations(draft)
Compliance with economic laws	Sales Team 1	Monopoly Regulation and Fair Trade Act	Internal Audit Regulations(draft) Regulations on the Management of Voluntary Export of Strategic Materials
	Sales Team 2	Foreign Trade Act
	Purchasing Team	Fair Transactions in Subcontracting Act
Protection of information assets	General Affairs Team, Accounting Team	Unfair Competition Prevention and Trade Secret Protection Act	Trade Secret Management Regulations

Compliance with regulations	Values change as society and times evolve. The company has made these value standards into regulations and manuals as much as possible, and employees should clearly understand prohibited matters by law and internal regulations and strive to comply with them.
Elimination of discrimination	We must respect individuals' basic human rights and diversity, not discriminate on the basis of nationality, ancestry, race, ethnicity, religion, gender, ideology, age, physical characteristics, sexual orientation and gender identity, employment status, form of contract, etc., nor condone such discrimination as company policy.
Prohibition of sexual harassment, etc.	Our employees must maintain a workplace free of unlawful harassment, whether moral, sexual harassment, physical or psychological, etc., and our employees must not condone such words or deeds.
Liability for violating the Sexual Harassment Policy	When an employee commits an act such as sexual harassment, he or she is subject to punishment. In addition, a higher-ranking person who neglects appropriate management actions, such as condoning the act, may also be liable.
Counseling response	Do not hesitate to report and seek counseling (Ulsan: responsible manager, General Affairs Team, Seoul: responsible manager, Management Team) when sexual harassment has been committed. In addition, when consulting, the persons concerned should be fully aware of privacy. The company responds to the facts faithfully and strictly, and strive to erdicate unfair acts such as sexual harassment and to prevent a recurrence.
Implementation of fair accounting practice	Accounting should be based on facts. In case of violating related laws or internal regulations, the violator is subject to punishment as the subject of false accounting, and a higher-level manager who neglects appropriate management actions may also be held accountable.
Prohibition of outside work	No member shall be employed by another company or engage in work for purposes contrary to the company's interests while enrolled in the company without the company's approval.
Abolition of pretentious formalities	In principle, the company prohibits gifts during holidays and year-ends in the company. Exchanging gifts within the company for the sake of doing it is not only pretentious but also can create an adverse atmosphere. All employees shall strive to develop and maintain a healthy environment considering these circumstances.

Rules on Individual Activity

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Item	Responsible department	Relevant laws	Internal regulations
Elimination of discrimination	General Affairs Team	Labor Standards Act Act on Prohibition of Age Discrimination in Employment and Elderly Employment Promotion Act on the Prohibition of Discrimination against Persons with Disabilities, Remedy against Infringement of Their Rights, etc. Equal Employment Opportunity and Work-Family Balance Assistance Act	Business Ethics Policy and Standards of Conduct
Prohibition of sexual harassment	General Affairs Team	Labor Standards Act Equal Employment Opportunity and Work-Family Balance Assistance Act	Business Ethics Policy and Standards of Conduct Rules of Employment against Sexual Harassment
Implementation of fair accounting practices	Accounting Team, Management Team	Various tax laws General Corporate Accounting Standards	Accounting-related regulations Internal Audit Regulations (draft)
Prohibition of outside work	General Affairs Team	Civil Law Commercial Law	Rules of Employment

Subject of notification	Subjects of the internal notification system include all individuals working in the company (executive officers, employees, contract workers, dispatched workers, part-time jobs, etc.).
Notified matters	The notified matters of the internal notification system are for acts that violate internal regulations, such as laws and the rules of employment, by organizations or individuals in the company and acts suspected of violating. In addition, notices intended for framing, retaliating, or gaining one's unjust interest may be regarded as violations and may be subject to disciplinary action.
Means of notification and filing	A notification shall be made to the in-house HR director by letter.(Plan for Internet submissions will be reviewed in the future) In addition, both real names and anonymous notifications are validly accepted. General affairs director : tspc7600@tspc.co.kr
Handling notification details	The notified details are investigated by the General Affairs Team or an appropriately organized response team(structured by HR director). If an illegal act or violation of regulations is determined after the investigation, corresponding measures shall be taken. In addition, the General Affairs Team or the corresponding response team shall notify the real name informant of the results of the investigation and the corresponding countermeasures.
Protection of the notifier, etc.	No adverse action shall be taken against the notifier for the notification. If a disadvantageous disposition is confirmed, the disadvantageous process should be ceased, and the person who took the disadvantageous disposition and the responsible person of the relevant organization are subject to disciplinary accountability. In addition, the name of the notifier and the notification details are treated with confidentiality. In particular, the notifier's name is not disclosed to anyone other than the person concerned.

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