SUSTAINABILITY
Governance
responsibilities Composition and
operation of Board Ethical management
/ Law-abiding management Protection of
Shareholder’s Rights
Control
Standards Anti-bribery
management
system Ethical
Management
FAQ Law-abiding
Management
- Purpose
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To enact and implement law-abiding control standards in order to promote the fair and transparent execution of jobs and to secure the sound development of the company and confidence of customers by complying with laws and regulations
- Base Laws
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Article 542-13 of the Commercial Act and Article 3 of the Enforcement Degree of the Commercial Act
- Major Contents
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- Understand the entire system of laes and regulations for operation of the company business
- Self-inspection of compliance with the laws and regulations by all executives and employees
- Prevent illegal acts in advance
- Systematically respond to various legal risks
- Operate law-abiding education and training programs
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Q.
In the recent holiday, our team leader gave the team members a gift certificate that he received from one of our subcontractor partners.I don’t know which one that is, but since it is a gift from my superior I feel uneasy to refuse it. Would it be ok to receive it.
A. If your team leader received the gift certificates from a subcontractor partner and then distributed those among his team members, we can say that first, he violated the Code of Conduct. However, the team members who received it is also regarded as violating the Code and therefore both should report to the Audit Team. -
Q.
When we hold a company event, such as company track meet and hiking, we sometimes receive supporting donation (prizes, alcohol and non-alcohol beverage etc.) from our subcontractors. Is it a violation of the Code of Conduct?
A. Receiving any form of supporting donation from subcontractor partners is a violation of the Code of Conduct. The right to way to deal with supporting donation is to explain to the giver the purpose of our ethical management and return it. We need to establish a new culture to hold the company events more modestly within the budget, and refrain from burdening the subcontractor partners by informing them of the events intentionally for such donation. -
Q.
My uncle was hired by one of our subcontractors, which I am in charge of. We often come across with each other at work, and when that happens, he tends to request to change the design or raise the unit prices. What should I do?
A. If you think you cannot carry your tasks in a fair manner due to the situation, you should talk to your team leader or Audit Team about the matter and follow their advice accordingly. -
Q.
After finishing the special task in the field or at night overtime, we went out for team dinner to promote the amenity among the team members or to enjoy the sense of fulfilment.In such case, what should be the proper way to handle the expenses?
A. You should obtain the approval of the Department Manager on the expenses. If the expenses are within the budget range, it is ok.
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Q.
Is it not a violation receiving something else than cash?
A. Anything that has a value enough to influence the recipient on his/her task performance, that is considered as bribe. In other words, bribe is not only money, things and property gain, but also any and all gain, whether tangible and intangible, that can satisfy the needs and desires of the recipient (e.g. A person in charge of the company’s human resources had the subject of promotion give joint guarantee for his/her own bank loan.) -
Q.
Is donation to public institutions money or gift certificates that we receive from the subcontractor(s) a violation of the Code of Practice?
A. If the money or certificate was illegal reward or unjust profit, it is. In other words, spending unjust profits for public donation or company dinner, even if not for yourself or your family, is also a violation of the Code. -
Q.
If I return the money or valuables later, after I first received it, is it a violation of the Code of Ethical Conduct?
A. If you received the money or valuables thinking to keep it for yourself, it is a violation even if you return it later to the giver. Some examples are putting the money or valuables into your pocket or keeping it in your desk drawer or bank account, and then returning it to the giver later. However, if you later find out that the person left the money or valuables for you, without telling you, and if you report it to your superior or Audit Team as soon as you are aware of that, it is not a violation. -
Q.
Is receiving a gift as a social custom ok?
A. Even if the gift in issue is a social custom, if that involves some work or quid pro quo, or if the value exceeds what is generally accepted as a social custom, such as high-priced goods or entertainment, that will be considered as bribe. -
Q.
Is it allowed to receive some fruits or produce/livestock products from a partnership company as a holiday gift?
A. If you are a person in charge of handing that specific partner company and in the superior position that can influence the work-related decision making concerning that company, it is hard to interpret that the other side sent you the gift just for amity. Therefore, you should not receive it. If it is hard for you to refuse it directly, consult your superior or report to the Audit Team. (Valuables or gift of less than 30,000 WON worth is acceptable) -
Q.
At the end of year, we, as an annual event, invite the client companies’ representatives to the company and holds the ‘End-of-the-Year Celebration Meeting’ and give them gifts. In this case, is giving high-priced gift (200,000-300,000 won value) not a violation of the Code of Practice?
A. There are some special anniversaries of the company and occasions where we should prepare a gift of relatively high values, inserted Dongbu logo in it, depending on the guests’ position. In such cases, you can proceed as long as you get the authorization of the company. -
Q.
Q. When a foreign buyer visited us at work, he brought a bottle of liquor (over 50,000 Won-value). May I accept it?
A. You need to explain to him the ethical management policy and purposes of our company and politely refuse it. If you accepted it due to the difficult circumstances, you should thank him but report to the Audit Team. -
Q.
When the employees get promoted, we often receive plant pots from the partner companies. Does it contradict the Code of Ethical Conduct?
A. The employees are not allowed to receive goods of values exceeding the ordinary gifts from the partner companies. However, flower plants, flower baskets, or congratulatory telegrams are acceptable.That said, if there are too many pots or pots of exceeding values are not allowed to take. In such case, you need to refuse or return them. If the sender is not available at the moment or it is difficult to return the goods back to the sender, report to the Audit Team. -
Q.
If a team leader gives his team member(s) a gift certificate as present, is it a violation of the Code of Ethical Conduct?
A. Superiors may give gifts to their junior staff. However, if the gifts are purchased not by themselves, but the company asset or through our partner companies, it violates the Code. Junior staff’s giving a gift of gift certificates to his/her superior(s) is prohibited in any cases. -
Q.
At the end of the year, the team leader gave me the corporate credit card and asked to purchase and send a dried-yellow-corvine gift set (over 150,000 Won worth) to a VIP client on behalf of the company.What should I do?
A. In principle, providing valuables to the partner companies is prohibited. Even if that was your superior’s order and the expected recipient is one of our VIP clients, high-priced gift giving harms the traditional custom and the public morals, as well as contradicts our Code of Practical Conduct. So, please consult your team leader and change it to a lesser-value gift, such as general promo. product. -
Q.
I received a tribute payment of over 100,000 Won from a company relating to our project. How should I deal with the matter?
A. As social customs, we are rather generous in applying the rules for family events; nevertheless, the tribute should not exceed 30,000 Won and over-30,000 Won tribute must be returned to the offerer immediately as it may influence the parties’ fair performance of the task. -
Q.
I was invited to an year-end event of one of our partner companies and won a lottery prize of 2 round trip plane tickets to Jeju Island, along with 400,000 Won accommodation fees. What if I was the only person who won that prize at the event?
A. You should not take the prize. Even if they made it a lottery format, the prize exceeds the usual level of gifts and thus violates the Code of Practical Conduct. -
Q.
We had dinner with a person from one of our very important business partners. After that, the person hinted that he would like us to buy him rounds of drink, so my superior and I discussed and brought him to a bar with entertainment.Is there anything we should have not done?
A. It seems a treatment beyond an ordinary level. Consult your superior and discuss whether it is necessary to treat him with entertainment bar. Then, explain to the person the purpose and policy of our ethical management and refuse the request. -
Q.
I had a meal with a person related to my job duties and we played a card game after that. If I got a lot of money as I won the game, against my will, is it accepting bribery?
A. You should not exchange money or valuables, whether directly or indirectly, through card games with other work-related persons, in the first place. If absolutely necessary, regardless of the amount, you should return it to the other side. -
Q.
Let say, I visited one of our partner companies for inspection related to apparatus purchase. The company offered me dinner and considering what we had, it seemed to have cost more than 70,000 Won per person.What should I do?
A. As you know, we provide our employees with travel allowances including meals, for ordinary business operation. So, try to pay for your own meal, and if possible, think in advance of a restaurant and the costs per person within a normal, ordinary range, in case the other side would treat you. -
Q.
I am often invited to dinner by the partner company and drink after that, at a bar or even nightclub sometimes. If I accept the offer, would it violate the Code of Practical Conduct?
A. We understand that it is not always easy to decline the partner companies’ offer of treatment. However, we still encourage you to do so in a polite way, and remind you that we should never receive entertainment of high price. Even if the partner companies pay for it as their business expenses, it would still influence your work for them, and is probably intended for such effect. -
Q.
I have known an employee of a partner company for a long time on business. As we have known each other for many years now, we have become close on personal levels.He gave me a coupon for airline tickets to Jeju Island the other day and suggested to go on a family vacation together this summer, with both of our families. How should I respond to this?
A. The other side might have offered it genuinely for friendship, but while he deals with Dongbu account, you both should be careful not to mix professional with private action. If each party, you and the other side, pays for one’s own travel expenses, that would be, of course, fine. -
Q.
My closest high school alumnus is running a company that supplies to our company. We sometimes have dinner together and go for family picnics.In those occasions, my friend pays the expensive more often than I do, and I wonder if that would be a problem.
A. Since it is a case that your high school friend has a business relationship with us, if you are in a position that may involve the supply process at any stage, it should be better that you pay for your own expenses. You can probably explain our policy of ethical management and the Code of Practical Conduct to your friend without damaging the relationship. -
Q.
A partner company supplied to us and then invited me to dinner for expressing appreciation. I declined it. Then, a few days later I came across with their employees at a restaurant where I myself was having dinner with my colleagues, and found out that one of them paid our dinner and left before we finished. In this case, how should I handle the situation?
A. You should return the portion that you should have paid on your own to that person. And advise the partner company that you appreciate their favor, but in order to comply with our Code of Practice you had no choice but to return the favor. -
Q.
A friend of mine from high school works at our partner company, and I work at a department that has nothing to do with that company.There was a high school reunion where both of us attended, and we went to a bar after the reunion and he paid the drinks. Is this a violation of the Code of Practical Conduct?
A. Normal and usual level payment would be fine. However, excessive amount of payment must indicate his expectation of you to favor his account at the relevant department. Thus, you should pay for your own expenses. -
Q.
Would it violate the Code of Practice borrowing money from a friend, personally, who runs one of our partner companies?
A. Borrowing money with a normal and ordinary interest rate would be fine, if necessary. The point is not whether you are friends to each other, but whether there could be a favorable treatment towards that person/his company because of your personal relationship with each other. -
Q.
To which extent is provision of entertainment and treatment allowed?
A. In general, it should be less than 30,000 WON-value (one time per person). The range of entertainment or treatment includes various types’ leisure opportunities, such as meals, drinks, recreation, and cultural performance or concerts. -
Q.
For smooth communication and cooperation with a partner company, we take turns to pay the meals. For example, if we pay this time, the other side pays the next time, and then us again and so on. Is this too a violation of the Code or Practice?
A. As long as you keep both, that is receiving and offering the meal, under 30,000 Won limit, that should be fine. -
Q.
The partner company requested my business travel schedule, so I sent a copy. On the very day of my business travel, their staff came to fetch me by car at Gimpo Int’l Airport from Ansan.Is this case also a violation of the Code of Practice?
A. In our culture and tradition, making your guest feel welcome and at home is a virtue. So, their coming to the airport by car to fetch does not amount to an ethical violation. However, if you request it to the partner company and press them in any manner, it would be a violation. -
Q.
If a junior staff notifies the work-related personnel or partner companies of his/her superior’s family occasion without authorization of the superior, would it be a violation of the Code of Practice?
A. The Code of Practice restricts expressly notifying the work-related personnel of one’s own family events. Notifying on behalf of one’s superior who has the family event, is also a violation of the Code. -
Q.
I did not notify the partner company and work-related personnel of my family event, but the person attended the ceremony and paid 100,000 Won tribute. What should I do?
A. If a work-related person knew about your family matter through other people, attended the ceremony and provided condolences or congratulation, it would be difficult to refuse it in practice. However, if the payment excesses the standard, you should return it immediately. -
Q.
My wife does house-to-house sales as a sideline and asks me to post the introduction of that business and product description in our company e-board. Is it ok?
A. The electric board of the company is a tool to share necessary information of the company among the employees, so you should not post your or your relatives’ business for the purpose of advertisement or personal gain.
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Q.
I sent an internal report to a few our employees as I thought they would need it, and one of them leaked it. In this case, am I responsible for that, too?
A. If you sent the report to the relevant personnel for a specific work reference, you would not be held accountable. However, if you sent it to a person who has nothing to do with that work and the unlawful disclosure occurred, you would be held responsible. -
Q.
I received a request to lecture about the topics of investment, technology development and the future plan of the company, from another company or gov’t institute. I personally think that would be a good opportunity to promote our company. Your advice?
A. The company’s information exempted to disclosure must be protected as confidential. For any disclosure or provision of the company information at outside meetings, lecture, or seminar, you should first obtain the official authorization of the company.
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Q.
When we use the company budget or supplies, what is the prohibited use not directly related to the work, concretely?
A. An example is you meet your high school friends, have a good time at an entertainment establishment with them, and then treat the payment as work expenses. Another example is you bring the company supplies to your home and give those to your children for their school supplies.
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Q.
My superior insults me by his words and behavior too often. How should I handle the situation?
A. The best way is to talk to the person and try to solve the matter through conversation. But if nothing changes, contact the Audit Team and request help.
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Q.
My wife who has a sales business as a sideline asks me to introduce some of my colleagues to her. What should I do?
A. After the daily work, you and your wife can meet your colleagues or any other person through your introduction outside the company. However, you and/or your wife should not do a side job, including product introduction, recommendation, or product promotion, inside the company and during your work.
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Q.
In case of whistle-blowing, if the whistle-blower’s identification is disclosed in the course of investigation, how is the person protected?
A. The identification of the reporter will be kept confidential. However, in case it is disclosed, the HR will make a necessary arrangement to protect him/her against any harm, in consideration of the person’s own request as well. -
Q.
The company makes internal report mandatory, but if one does so, there is always a risk of causing conflicts with one’s superior or colleagues. What is the company’s solution to this?
A. The company will protect the identification of the reporter strictly, prevent any conflicts among our members, and take care of the reporter so that he/she would not suffer any disadvantages. Any illegal matters of the company should be solved quickly before it becomes a bigger problem since that is the way to protect the concerned parties, including the company. -
Q.
I wanted to make an official report to the company concerning an environment-related accident, or violation of relevant laws, but my superior tries to understate or hide it considering the image and reputation of the company. What should I do in this case?
A. If that the company attempts to understate or cover up the relevant facts becomes known to the public, Dongbu’s image of eco-friendly corporation will be damaged significantly. Therefore, if your superior tries to understate or hide the matter, you must report it to the Audit Team. -
Q.
Even if we understand that a certain behavior would contradict the Code of Ethics (Code of Conduct and Practice incl.), it is practically impossible for a junior employee to refuse his/her superior’s order.If a junior obeys the superior’s order, is he/she also subject to punishment?
A. If a junior employee carries out an act that contradicts the Code of Ethics (Code of Conduct and Code of Practice incl.), both his/her superior who ordered him/her to do it, and the junior employee who simply followed the order will be held responsible. Thus, even if your superior orders you to commit a violation, you decline and report to the Audit Team. -
Q.
What if a violation committed before the Code of Ethics (Code of Conduct, and Code of Practice incl.) was announced becomes a problem?
A. The company will take no count of the past matter in general. However, if the results of the relevant conduct still influence the present situation, the person who committed such violation should resolve the matter voluntarily, as quickly as possible to minimize the effect.
Law-abiding main activities in 2022
| Division | Date of Activities | Main contents of Activities | Inspection results |
|---|---|---|---|
| Ordinary compliance support | Year-round | Litigation management and legal advice | Accepted |
| Year-round | Reviewing contracts (contracts, agreements, etc.) | Accepted | |
| Year-round | Responding to FTC or mediation agencies | Accepted | |
| Year-round | In-house compliance education | Accepted | |
| Inspection of compliance, etc. | Year-round | Supporting compliance activities | Accepted |
Status of administrative agency sanction in 2022
| Agency name | Financial supervisory authorities | Federal Trade Commission | Tax authorities | Other Administrative Agencies |
|---|---|---|---|---|
| Contents | None | None | None | None |