Code of Ethics

1. Objectives

The purpose of the Code of Ethics Guide is to stipulate specific provisions needed to implement the purport of the Code of Ethics for SKC employees.

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2. Target

All employees of SKC and firms under the control of SKC shall understand and observe the Code of Ethics and Code of Ethics Guide.

For any inquiry about the Code of Ethics and Code of Ethics Guide contact the leader of the organization or Ethical Management Department.

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3. Employees’ basic obligations

3.1. Basic ethics for employees

All SKC employees shall fulfill their duties and take responsibility for the results based on the principle of

good faith.

All SKC employees clearly understand their roles and understand and observe the Code of Ethics and related regulations.

If any of the employees violates the Code of Ethics, sees the other person violating it, or is forced to violate it, such incident shall be reported to the Company immediately.

3.2. Ban on practices under conflict of interests

In the event of conflict of interest when fulfilling their duties, employees shall take the Company’s interest prior to others.

All employees shall make their best efforts to avoid any conflict of interest with the Company. If the conflict occurs, it shall be reported to the Company.

Examples of conflict of interest

A) Employees enter into an agreement or engage in business with the Company directly or through a third party;

B) Any financial conflict of interest or involvement of rights/obligations with the Company’s rival or contractual party directly or indirectly;

C) Misappropriation for personal benefits by taking advantage of the Company’s assets or information;

D) Exerting unfair influence on vendors by taking advantage of their job position such as special consideration for a job position and any special benefits;

E) Engaging in a side job which may have a negative influence on the fulfillment of obligations at work; or

F) Acquisition of the partner’s stocks in an unfair fashion

3.3. Anti-bribery and corruption

All employees shall fulfill all management activities in an open and transparent manner. They are prohibited from getting special treatment or benefit from contractual or related parties regardless of the relevance with the job.

If any special treatment or benefit is obtained regardless of your intentions, you shall return it immediately or report it to the Company.

However, to preserve a decent and sound relationship meals or gifts which are permitted under the current laws and business practices are acceptable.

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4. Protection of the Company’s assets

4.1. Physical properties

Employees are prohibited of using the Company’s assets for personal purposes or transfer or lease them to a third party without getting approval from the Company.

The Company’s budget shall be used according to the designated purpose. Processes shall be recorded in accordance with accounting standards and procedures.

If a loss occurs in (or there is a possibility of loss of) the Company’s assets, it shall be reported to the Company immediately, and any necessary actions to prevent such loss shall be taken.

4.2. Intellectual property

The Company’s internal management information shall not be disclosed to the outside without getting approval in advance.

Client information shall not be provided to third parties in an illegal fashion. In addition, Employees shall not engage in any unfair or illegal practices which can harm a client’s interests.

The Company’s intellectual property rights such as patent, copyright trademark are actively protected.

The Company’s secret information shall be kept confidential according to related laws and regulations. To disclose it to the outside, approval shall be obtained in advance in accordance with related procedures.

Other companies’ intellectual property rights shall also be protected. In particular, the use of illegal software is strictly prohibited.

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5. Observance of related laws and the Company’s management policies

All business management activities in the Republic of Korea and abroad shall be implemented in accordance with local laws and regulations and business practices. All transactions shall be performed in accordance with related laws and bylaws under free competition principle.

Accounting information shall be recorded accurately according to related laws, business accounting standards and bylaws. Any falsification or misstatement of accounting information is strictly banned.

Management information on interested parties shall be disclosed in a fair and transparent fashion in accordance with related laws and bylaws.

Any falsification or misstatement (e.g., concealment, exaggeration/omission, delay) of management information is prohibited.

Product quality and safety management shall observe related laws and meet the client’s requirements. Product performance and risk-related information shall be disclosed as is. Safety, health & environment-related domestic and international laws and international conventions shall be observed. In addition, employees shall be active in creating safe work environments and participating in environmental protection activities.

In accordance with the Improper Solicitation and Graft Act, it is prohibited requesting special treatment or benefits (or any promise to provide such benefit) to related parties such as government officials.

Domestic and international laws relating to anti-corruption such as Foreign Corrupt Practice Act (the U.S.), Bribery Act (the U.K.) and Act on Preventing Bribery of Foreign Public Officials in International Business Transactions shall be strictly observed.

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6. Work handling procedures

6.1. Department

The department relating to the operation of the Code of Ethics and Code of Ethics Guide for employees shall be the Management Efficiency Team (Ethics management team).

Said ethical management organization shall get advices from employees, perform guidance and education on employees and properly punish those who violate such rules.

6.2. Protection of whistleblowers

The employee who recognizes the violation of the Code of Ethics or Code of Ethics Guide shall report it to the department leader or Ethical Management Department immediately.

The Company shall not treat the whistleblower in an inappropriate manner at work for his/her fair reporting, related statements or submission of data.

During the whistleblowing investigation, those who cooperate shall be protected as equally as the whistleblower.

In the event of any unfair treatment, the whistleblower may request proper protection such as corrections or job relocation to the Ethical Management Department. Then, the Ethical Management Department shall investigate the case, take proper actions and establish a plan to prevent the recurrence of such incident including punishment of the responsible parties. The whistleblowing investigator shall keep the related information confidential to protect the whistleblower.

Any person who violates the said whistleblower protection provision (e.g., retaliation such as disadvantage in personnel, disclosure of the whistleblower’s identity or leak of the related information, and order to find the whistleblower) shall be punished in accordance with related regulations.

6.3. Investigation guideline for the protection of whistleblower

The investigator shall perform the investigation by taking the protection of the whistleblower as a top priority and must observe the following:

A) The investigator shall not leak or imply any information regarding whistleblowing without getting approval from the whistleblower.

B) All whistleblowing-related data are open to authorized persons only and kept confidential. Paper documents acquired by mail or fax shall be kept in a separate place and locked properly.

C) Any leak of whistleblower’s information obtained during the investigation shall be punished in accordance with related laws. If one of the following events occurs, however, an exception can be made:

- A matter which can cause serious accident or discontinuance of business; or - Serious corruption, leak or falsification of the Company’s secret, press release, etc.

D) The Ethical Management Department Manager is liable to educate and manage the security management guidelines regarding whistleblowing-related investigation.

6.4. Consultation / Reported to

For inquiry or consultation regarding the Code of Ethics and Code of Ethics Guide, refer to the contact information below. Reporting can be made by email, phone, mail or in person regardless of its format.

Block B, The K Twin Towers, 50 Jongro 1-gil, Jongro-gu, Seoul, South Korea, Ethical Management Manager, Management Efficiency Team (Ethics management team)