Code of ethics - Ethical management - ESG

Obligation to follow the code of ethics

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

Roles and responsibilities of employees

All employees must fully understand and faithfully comply with all aspects of the code of ethics, and comply with domestic and international anti-corruption laws as a member of a global company.

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 ESG team 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 the 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 ESG team.

- You must be aware of different ways to report or seek consultation about actions that violate the code of ethics.

Roles 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 ethics-based decisions.
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. Preventing conflicts of interests
Prevent conflicts of interest with any private interested party who is working for a trading partner and make an effort to eradicate unfair business practices of providing business favors for private interests.
7. Ethical practices
Make the utmost effort to fulfill all the above roles and responsibilities to ensure that POSCO’s ethical practices are on par with the highest global level.

Leaders must prevent any unethical behaviors of 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 employees.

- Ensure that they fully understand the importance of complying with the code of ethics and ethical practices.
2. Measures to prevent unethical behavior

- For unethical behavior that occurs repeatedly, identify the cause 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.

Penalties for a breach of the code of ethics

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 breach of the code of ethics, or that demand 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 ESG team on a possible violation case.

- In case of retaliation against other employees who have reported an ethical management issue.

Ethical practices and Compliance

As a global company, the Company establishes an ethical corporate culture by complying with the laws and ethics through management activities that adhere strictly to the basics and principles.

1. Money and valuables

- Money and valuables refer to money (e.g., cash, gift cards, vouchers) and goods that can bring economic benefit.

- You must not provide, request, or accept money or valuables from stakeholders* for any reason. However, exceptions are made in the following cases.

· Gifts for promotional purposes that cost KRW 50,000 or less. However, agricultural and fishery products and processed products (including flowers) that cost up to KRW 100,000 are allowed.

· Gifts displaying a stakeholder's company logo that do not exceed KRW 50,000, and gifts given to all attendees in general at events organized by stakeholders are allowed.
*Stakeholders: Employees, customers, trading partners, affiliates, partner companies, public agencies in Korea and abroad, and international organizations (including their employees) who may affect or be affected directly and indirectly in terms of their authority and benefit by the duties you perform.

- You must not request or receive gifts from overseas offices when traveling abroad for business purposes.

- If you have received money or valuables without being aware of this, you must return them, and if it is difficult to do so, you must report the matter to the Righteous Management Office.
2. Entertainment

- Entertainment refers to various activities for the purpose of business meetings and exchanges, such as meals, drinking, golf rounds, enjoying a performance, and other forms of amusement.

- You must not provide or accept entertainment to/from stakeholders that exceeds KRW 100,000 per person. However, in case you have to provide or accept entertainment that exceeds KRW 100,000 per person in relation to your work, you need to seek approval from the department head in advance. In case you provided or accepted entertainment that exceeds KRW 100,000, you must report it to the Righteous Management Office. For those subject to the Improper Solicitation and Graft Act, such as public officers, journalists, and school personnel, you may provide meals that don’t exceed KRW 30,000 per person for legitimate purposes only that are recognized as they are for the smooth progress of a given task, social reasons or formality.

- You are prohibited from offering entertainment in bars that offer hostess or host services regardless of the price.
3. Hospitality

- Hospitality refers to offering or accepting services including transportation, accommodation, tourism, and/or event support.

- You must not provide or receive hospitality services including transportation and/or accommodation that exceed general standards. However, hospitality services provided in general to all participants in events are excluded.

- If the expense exceeds the permitted amount due to inevitable circumstances, it must be reported to the Righteous Management Office.
4. Congratulations and condolences allowance

- You must not notify stakeholders of your own or of a colleague’s congratulatory or condolatory events; notifying them of these events through a third party is also considered as being a notification from you.

- You must use a company forum to provide any notifications of congratulatory or condolatory events; you must not provide information of these events by using your company mail or sending an invitation card (wedding invitations and obituaries). When providing information about congratulatory or condolatory events, the scope of relatives is limited to your immediate family: your parents, parents-in-law, grand parents, grand parents-in-law, and your children.

- A general standard of KRW 50,000 is recommended for expenditure for congratulations or condolences between employees.

- No more than KRW 100,000 can be provided to stakeholders as a congratulations or condolences allowance, which includes the price of standing spray arrangements and flowers. However, congratulations or condolences allowances for those subject to the Improper Solicitation And Graft Act must not exceed KRW 50,000 excluding the price of standing spray arrangements and flowers.

- You must never receive a congratulations or condolences allowance from stakeholders outside the company under any circumstances. If you have inevitably received a congratulations or condolences allowance from stakeholders outside the company, you must return the money or deposit the money to the Righteous Management Office.

- When requested by the Righteous Management Office, executives and employees must submit relevant materials, such as a record of returned allowances received from stakeholders.

- You must not accept congratulations or condolence flowers from stakeholders. If you have accepted them due to unavoidable circumstances, you must not display them.

- Executives and employees must not hold extravagant weddings in luxury hotels, etc.
5. Solicitation and recommendation

- Do not make any solicitation or recommendation related to the following through an acquaintance within the company or an outsider. If you receive any such solicitation or recommendation, you must report the case to the Righteous Management Office.

· Any request for preferential treatment regarding equipment/material purchase, and various contracts.

· Any requests for preferential treatment for personnel matters including employment, promotions, rewards, penalties, and new appointments.

· Any requests for excessive preferential treatment that goes beyond normal practices.

· Any requests to neglect management and supervision tasks, such as inspections and examinations.

- You must not make any illicit solicitation directly or through a third party regarding tasks subject to the Improper Solicitation And Graft Act.
6. Pecuniary transactions

- You must not be involved in any pecuniary transactions with stakeholders, such as lending money, offering loan guarantees, and/or leasing real estate.

- If you engage in pecuniary transactions with a stakeholder due to unavoidable reasons, you must report the case to the Righteous Management Office.
7. Event contributions

- You must not accept any event contributions or donations from stakeholders in events sponsored by the Company, such as department events or club activities.

- If you use a vehicle / venue / service provided by a stakeholder for your convenience, you are deemed as having accepted donations or contributions.

- If you receive these donations or contributions in inevitable circumstances, you must report it to the Righteous Management Office.
8. Unfair use of company budget

- You must not use the Company budget, such as budget allocated to meetings and project implementation, for personal purposes.

- For business expenses, you must use a corporate card; the card must be used only to serve the purpose, pursuant to relevant laws.
9. Protection of information and properties

- You must strictly safeguard confidential or other important information.

- If important information becomes known to you, you must inform the person in charge of it.

- You must not manipulate information or disseminate false information.

- You must not use any of the Company’s equipment or facilities for purposes that are not directly related to work.
10. Fair trade

- You must comply with international standards, laws and regulations related to fair trade in order to not engage in unfair trade practices, including collusion related to production, price, bidding and market sharing, etc; you must compete in the market in a fair manner.

- You must not take advantage of a superior position to demand any form of rewards or other unreasonable gains from customers or companies you are trading with.

- You must respect the rights and properties of others, including intellectual properties, and not violate them to win in a trade or gain profit.

- Corporate information including that of competitors must be acquired and used by fair means.
11. Preventing conflicts of interests

- Conflict of interest refers to situations where employees of a company you are dealing with have personal interests with you, which has a negative impact on the performance of your duties.

- You must completely exclude inappropriate requests from employees of companies you are dealing with if they have private interests with you. The same applies to retired POSCO executives and employees.

- Do not make unofficial contact with employees of companies you are dealing with if they have private interests with you. In case you have contacted them unintentionally, report it to the senior officer in your department or the Ethics Officer at the Righteous Management Office.

- Do not attend meetings of retired POSCO executives and employees that are not approved by the Company.

- Do not join a group for retired POSCO executives and employees before you retire. If you are already a member, report to a senior officer in your department and leave the group.

- If you have private interests with executives and employees of companies you are dealing with, consult your senior or the Ethics Officer, and follow the actions to be taken, such as job reassignment.

- Do not engage in unfair trade, including the signing of an unfair private contract, purchasing products at a higher price, favoring certain companies in biddings, and leaking of trade information in advance by giving preference to a specific individual or a company for reasons of private interest.

- Prevent conflicts of interest with POSCO Holdings and companies even after retirement.

Work-life balance

The Company seeks the development of both individuals and the Company through work-life balance. The Company creates a happy workplace by establishing a corporate culture of respect towards one another.

1. Pursuit of work-life balance

- We promote improved quality of life by offering welfare benefits that help stabilize the living conditions of employees.

- We support employees to achieve their goals and assist them to work flexibly in terms of time, place, and way of working.
2. Provision of opportunities for education and growth

- We create a work environment and system that promote creative thinking.

- We support employees with training programs to improve their capabilities and foster self-development.
3. Fair assessment and compensation

- The Company conducts fair assessment based on the capabilities and performance of each employee and reflects this systematically to ensure the provision of appropriate compensation.
4. Creating a healthy corporate culture

- Employees seek an open corporate culture though communication.

- Employees remove barriers between organizations and create a culture of cooperation.

Creating customer value and securing trust

Recognizing that customer trust and success is our future, we respect customer opinions at all times, understand customers, and create value that promotes their development.

1. Realization of customer satisfaction

- We listen carefully to the voice of the customers and conduct our duties in a customer-centric fashion.

- We readily accept legitimate customer requests and reasonable suggestions.
2. Creation of customer value

- We meet customer needs by providing the best products through continuous technological development.

- Our employees understand the market trends in Korea and abroad, and develop a service mindset that respects each customer’s culture and customs.
3. Securing customer trust

- We certainly consider customer safety and health, and don’t provide products or services that threaten it.

- We protect each customer’s information and comply with the laws and regulations regarding information protection.

- We provide accurate information to customers in a timely manner.

Duty of good faith to investors

We maximize investor value by making profit on the basis of transparent decision making and efficient management activities.

1. Pursuit of increased shareholder value

- We make profit on the basis of transparent decision making and efficient management activities and enhance both corporate and shareholder value.
2. Fair provision of investor information

- We do not provide information that may affect the investment decisions of shareholders to only some shareholders, or offer select information.

- We do not directly trade stocks or securities using inside information acquired at work, or solicit trade to others.
3. Calculation and provision of transparent financial information

- Financial information must be calculated using an appropriate process or control based on precise trade facts.

- Financial reports must be made according to generally recognized accounting standards.

- A sufficient amount of correct management information must be provided to help investors make investment decisions based on free will and responsibility.

Building mutually beneficial relations with business partners

We must establish a fair business order based on mutual trust and build a corporate ecosystem in which we coexist and develop with our stakeholders.

1. Building mutual trust

- We must ensure that we do business fairly with an equivalent relationship with partners on the basis of mutual respect.

- We protect information acquired from doing business with our partners according to the relevant laws, regulations, and provisions in contracts.

- We support our business partners in observing fair trade laws and regulations.
2. Shared prosperity with business partners

- We share accomplishments with our business partners and pursue shared prosperity.

- We support our business partners to provide high-quality products and services through smooth communication and cooperation.

- We offer equal opportunities and ensure reasonable business requirements for our business partners to develop relationships into companionships.
3. Supporting the continued development of business partners

- We offer technical and financial support to our business partners to help them build a stable supply chain.

- We expand the scope of our growth partners for the comprehensive prosperity of the entire business ecosystem.

Contribution to the country and society

We fulfill our responsibility and duty as a corporate citizen to contribute to national and social development.

1. Our role and attitude as a corporate citizen

- We strive to achieve mutual development with local communities and respect their local laws, regulations, culture and customs.

- We strive to communicate with stakeholders by involving them in our management activities that are related with the local society.

- We strive to support our business partners to participate in the activities aimed at the development of the local society.
2. Commitment to the country and society

- The Company fulfills its duty in the local community by creating and maintaining jobs and by faithfully paying taxes.

- The Company participates in charities including volunteer activities and disaster relief, and engages in pro bono activities in different areas, such as culture, art, sports, and academia.

- The Company assists local residents in improving their quality of life.

Preservation of the environment and the ecosystem

We build a sustainable management system, strengthen our capabilities to respond to environmental risks and implement sustainable management through open communication.

1. Building a sustainable management system

- We operate an efficient, sustainable management system to evaluate the impact and risk of our activities, and to manage and analyze our sustainable management performance systemically, in order to, ultimately, reach our sustainability goals.

- We share accomplishments and issues with various stakeholders and engage in sustainability activities together.

- We form a consensus with partners regarding environment protection as a social obligation, and support them to comply with environment laws and regulations.

- We assist our business partners to safeguard public health and safety when producing products or services. At the same time, we help them minimize any negative impact on local environments and natural resources.
2. Compliance with environmental laws and improvement in environmental impact

- We abide by environmental laws and try to improve the impact on the environment in all processes, including development, production, and use of products.

- We minimize emissions of harmful substances by introducing environmentally friendly process and applying the optimum technology that prevents environmental pollution.
3. Response to climate change

- We strive to reduce greenhouse gas emissions by using fewer fossil fuels or raw fossil materials and by improving energy efficiency.

- We strengthen our competitiveness by developing innovative low-carbon technology.
4. Protection of the environment and the ecosystem

- Through the efficient use of natural resources and by-products, we work to restore the natural ecosystem and preserve biodiversity.

Protection and respect for human rights

We uphold human rights, endorse international human rights standards, and establish human dignity of all stakeholders through the enhancement of freedom, safety, and quality of life.

1. Respect for international human rights standards

- We respect and support the internationally accepted human rights standards, such as the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN Global Compact, and the OECD Guidelines for Multinational Enterprises.

- We have established clear human rights policies and systems and strive not to violate human rights in the course of our management activities.

- We support our business partners to observe human rights-related regulations as required by international human rights standards. We help them protect the human rights of their employees, and treat them fairly.
2. Obligation to perform due diligence to respect human rights

- We may conduct due diligence as needed for management activities that violate human rights or cause complaints.

- We seek reasonable solutions if, as a result of due diligence, the Company is considered to have violated human rights during the course of its management activities.

- We communicate with stakeholders regarding the results of human rights-related activities.
3. Protecting executives and employees

- Company executives and employees do not engage in verbal, physical, or visual behavior that is offensive to others, including sexual harassment, which infringes on the human rights of an individual.

- We respect the privacy of our individual employees. We do not slander others nor leak personal data.

- We prevent people from working involuntarily due to mental or physical coercion.

- We observe the labor laws of each country we operate in as well as the international standards for employment and the minimum age of employment for minors.

- We strictly follow safety rules and take appropriate measures for all risks identified.
4. Respect and equality

- We do not discriminate or harass people on the basis of race, nationality, gender, age, academic background, religion, region, disabilities, marriage status, gender identity or any other reason.

- We provide equal employment opportunities to people who meet the job qualifications.

- We maintain the work environment by respecting various cultural differences.
5. Guarantee of legal and humane employment requirements

- We take prompt action on human rights issues raised by our employees through our complaints support system.

- We guarantee employment requirements, including appropriate working hours, so that our employees can live a life of dignity that is worthy of a human being.
6. Efforts to respect human rights in the community

- In case a human rights violation in the community is committed in the course of the Company’s management activities, we gather opinions and take appropriate measures to resolve any said human rights issues.