GS Power

Ethical Management

We are increasingly recognizing the importance of transparent management through recent cases of domestic and international companies' failures and internal transactions.

Transparent and ethical management is now established as a global standard driven not by choice but by the demands of the times.
Especially for GS Power, as a national strategic industry contributing to the public interest, the need for corporate ethics enhancement is even more profound.

To effectively adapt to the rapidly changing business environment, GS Power introduced the Voluntary Compliance Program under the CEO's Voluntary Compliance Management Policy on July 18, 2003. The company has established a framework for ethical management by formulating and implementing voluntary compliance regulations, ethical norms, and ethical practice guidelines.

In line with the implementation of this Voluntary Compliance Program, GS Power has appointed the CFO as the Voluntary Compliance Officer and conducts regular CCP (Compliance and Code of Conduct) education.

Furthermore, the company has also established an internal reporting hotline to allow all employees and executives to report various violations related to their work. This is part of our efforts to facilitate the early detection and resolution of violations and to prevent their recurrence in the future. Moreover, GS Power has established an internal audit system to handle post-discovery measures for violations and related actions, among other activities, in pursuit of voluntary compliance management.

GS Power will continue to work diligently under the framework of ethical management to earn the trust of all stakeholders, including customers. The company is committed to ongoing efforts to become a top-tier company in the 21st century.

GS Power CEO 유 재 영

: The purpose of these regulations is to establish the structure and scope of duties for the operational body responsible for the systematic and efficient performance of the Voluntary Compliance Officer's responsibilities at GS Power Co., Ltd.

2.1. All employees and executives of the company must perform their duties with the care of a prudent manager, understand their roles, and faithfully adhere to relevant laws, company policies, regulations, procedures, and guidelines. When requested by the Voluntary Compliance Officer, employees must submit a Voluntary Compliance Commitment Pledge related to their work and compliance with the law.
2.2. All employees and executives of the company must recognize that ignorance of relevant laws, company policies, regulations, processes, and guidelines is not a valid excuse for any violations. If they have questions or concerns, or if there is a risk of violation, they must contact their leader or the Voluntary Compliance Officer.

3.1. "Corporate Compliance Officer" refers to the person responsible for overseeing the efficient execution of the company's compliance activities.
3.2. "Compliance Activities" refer to activities aimed at ensuring the compliance with relevant laws, company policies, regulations, processes, and guidelines in the execution of the company's overall business operations. These activities encourage compliance, check, investigate, and monitor violations, and take corrective and improvement measures accordingly.
3.3. "Unit Head" refers to the head of a department or a unit within an organization, responsible for overseeing compliance activities within the respective organization. They are accountable for the overall implementation of compliance activities within the organization and monitoring violations.
3.4. "Compliance Manual" refers to guidelines that establish the standards of behavior and value judgments that all employees and executives must adhere to for compliance with the compliance regulations.
"Whistleblower" refers to individuals who report violations or concerns of potential violations of relevant laws, company rules, and regulations through the company's voluntary compliance management procedures.
3.6. "Leader" collectively refers to organization heads, senior colleagues, superiors, mentors, and other senior personnel within the company.

4.1. The Corporate Compliance Officer shall establish and operate a system for the development, education, dissemination, monitoring, and supervision of all relevant systems necessary for the company's compliance activities. This includes ensuring that compliance activities within each organization are systematic and efficient.
4.2. When education related to compliance activities is deemed necessary, the Corporate Compliance Officer may develop training materials for the relevant departments and delegate the establishment and implementation of an education system to the Human Resources/External Cooperation Department./li>
4.3. Each department must consult with the Corporate Compliance Officer regarding the development of training materials, the establishment of an education system, and the implementation of education related to all company compliance systems.
4.4. All employees and executives who have completed compliance education in each department or unit must submit a certificate of completion to the Corporate Compliance Officer. The Corporate Compliance Officer must then retain this certificate with the care of a prudent manager.

5.1. The Corporate Compliance Officer may require all employees and executives to submit a personally signed Voluntary Compliance (Practice) Pledge at least once a year.
5.2. The Corporate Compliance Officer shall establish and operate an internal reporting system to effectively monitor and supervise violations of relevant laws and the voluntary compliance system.
5.3. If the Corporate Compliance Officer discovers that employees and executives' actions have violated relevant laws or the company's policies, regulations, procedures, or guidelines, they must report it to the CEO. If necessary, the Corporate Compliance Officer may request the Employee Disciplinary Committee to take disciplinary action against the employee and require appropriate measures within the organization. Furthermore, they must make every effort to prevent the recurrence of similar violations.
5.4 When deemed necessary, the Corporate Compliance Officer may seek assistance from external experts such as certified public accountants and lawyers to perform their duties related to the company's compliance activities.

6.1. Employees and executives have an obligation to report immediately to the Corporate Compliance Officer any matters related to violations of relevant laws or concerns about potential violations of relevant laws, company policies, regulations, procedures, and guidelines.
6.2 The Corporate Compliance Officer must promptly report the results of any investigations into reported matters to the CEO and take necessary actions regarding the reported violations.
6.3. If the Corporate Compliance Officer determines that the reported matter has significantly contributed to preventing illegal activities, reducing costs, or avoiding operational risks for the company, they may suggest appropriate rewards to the CEO for the reporting employee.
6.4. Employees and executives who report violations shall not suffer any personnel or economic disadvantages as a result of such reporting. The Corporate Compliance Officer receiving the report must protect the identity and related information of the whistleblower from being disclosed, with the care of a prudent manager.

7.1. The Corporate Compliance Officer may demand corrective actions and improvements from organizations where violations of company policies, regulations, procedures, and guidelines have occurred or are likely to occur.
7.2. The Corporate Compliance Officer may request disciplinary actions from the Employee Disciplinary Committee against individuals who have violated relevant laws or the company's policies, regulations, procedures, and guidelines.
7.3. Violators and their respective organizations who receive demands for corrective actions and improvements must establish and report a plan for addressing the corrective and improvement requirements to the Corporate Compliance Officer within one month from the date of the demand.
7.4. The Employee Disciplinary Committee must notify the Corporate Compliance Officer of the disciplinary results for cases requested by the Corporate Compliance Officer and other disciplinary matters deemed necessary in relation to the company's compliance activities.

8.1. The Corporate Compliance Officer must report the overall operational status of compliance activities to the CEO and the Board of Directors at least twice a year.
8.2. The Corporate Compliance Officer may request each organization to prepare the Unit Compliance Plan for the following year by the end of each year to establish the company's annual compliance activity plan.

Article 1 (Effective Date)
This regulation shall be effective from 18th July, 2003.
Article 2 (Abolition of Compliance Monitoring Regulation)
Upon the enforcement of this regulation, the previous Compliance Monitoring Regulation (established on June 28, 2001) shall be abolished.
Article 3 (Establishment of Ethical Norms)
In accordance with this regulation, the 'Ethical Norms' and 'Ethical Norms Practice Guidelines' shall be established as the Self-Compliance Guidelines.
Article 4 (Execution of Self-Compliance Regulation and Self-Compliance Guidelines)
To express their commitment to comply with the Self-Compliance Regulation and the Self-Compliance Guidelines, all current employees and executives as well as newly hired employees and executives shall be requested to sign the 'Self-Compliance Regulation and Self-Compliance Guidelines Commitment Form.'
Article 5. Comprehensive Revision of Self-Compliance Regulation (8th March 2011) The Self-Compliance Regulation has been comprehensively revised as of March 8, 2011, along with the integration of the 'Ethical Norms' and 'Ethical Norms Practice Guidelines.

: GS Power aims to grow as an Energy Frontier with the optimal business portfolio and maximum synergy in the Clean Energy Service sector, ensuring the highest competitiveness. Furthermore, the company strives to provide customers with excellent products and services, achieve coexistence and co-prosperity with cooperating companies and collaborators, offer fair opportunities and active support to employees and executives for their growth, maximize shareholder value through excellent management, pursue sustainable growth and development of the company and society through safe business operations, active environmental protection, and CSR activities. In all its management activities, GS Power upholds the values of universal human rights and coexistence of humanity.
To achieve these goals, GS Power establishes ethical norms that guide decision-making in management activities and the standards for employees and executives performance and commits to their practice.

2.1 Customer Satisfaction Management

The company realizes that customers are the foundation of our profitability and growth. By providing true value that customers desire, GS Power aims to achieve customer satisfaction.

2.1.1 Always respect customer opinions and consider them as the foremost criteria in the company's business activities.
2.1.2 Provide the best products and services that meet customer demands and expectations.
2.1.3 Highly value customer information and interests, and fulfill commitments to customers.

2.2 Coexistence and Co-prosperity with Cooperating companies

GS Power pursues mutual development through transparent and fair transactions that establish trust and cooperative relationships with its cooperating companies.

2.2.1 Provide cooperating companies with equal trading opportunities and ensure reasonable terms, fostering a collaborative relationship for mutual growth.
2.2.2 Engage in fair transactions with partner companies on an equal footing and refrain from any unfair practices through the use of a dominant position in any form.

2.3 Respect for employees and executives and Compliance with Basic Ethics

The company and employees and executives fulfill their obligations for mutual growth and development based on mutual trust and respect.

2.3.1 The company respects each employee or executive as an independent individual and ensures fair treatment based on their abilities and achievements, fostering an environment for self-realization.
2.3.2 Employees and executives show mutual respect and perform their duties fairly and transparently, distinguishing between work-related matters and personal affairs, in order to fulfill their assigned responsibilities.

2.4 Protection of Shareholder Interests

GS Power protects shareholder interests through efficient and transparent management activities that inspire trust for investment.

2.4.1 Protect shareholders' investment returns diligently by achieving sound profits through efficient management.
2.4.2 Respect shareholders' rights to know about the company and provide necessary information truthfully and in a timely manner.

2.5 Contribution to the Nation and Society

As corporate citizens, we respect national policies and regulations, fulfilling our social responsibilities.

2.5.1 The company contributes to the nation's development through continuous job creation and diligent tax payments.
2.5.2 Taking a leading role in creating a future where everyone is happy, the company strives for ongoing development in collaboration with the local community.
2.5.3 It adheres to all relevant regulations both domestically and internationally, including those related to free-market competition, political contributions, lobbying, economic benefits to public officials, and international trade controls related to exports and imports, as well as various laws and treaties related to anti-corruption and business conduct, while respecting commercial customs and cultures.
2.5.4 In all our business activities, the company upholds the values of freedom and equality, based on human dignity, and respects and supports universal human rights and the values of coexistence among humanity.

2.6 Emphasis on Environment, Health, and Safety Management

GS Power makes every effort to protect the environment and strives to maintain accident-free workplaces.

2.6.1 The company is committed to environmental protection by making every effort to prevent environmental pollution.
2.6.2 The company is committed to environmental protection by making every effort to prevent environmental pollution, and it simultaneously prioritizes the safety and well-being of its employees and executives, striving to maintain safe and pleasant, accident-free workplaces.

1. This Code of Ethics shall be effective from 18th July, 2004.
2. This Code of Ethics shall be revised and effective from 8th March, 2011. (Comprehensive Revision)
3. This Code of Ethics shall be revised to include Human Rights and Coexistence of Humanity and effective from October 21, 2011. (Specification of Human Rights and Coexistence)

: GS Power aims to provide guidelines for decision-making and behavior in ethical conflict situations that may arise during the course of work, to ensure that its employees and executives understand and practice the Code of Ethics correctly.

2.1 (Scope of Application) These guidelines apply to all stakeholders who have a relationship with the company, including employees and executives, customers, cooperating companies, shareholders, the government, and society at large.
2.2 (Principles of Ethical Decision-Making and Behavior) Employees and executives, during the course of their work, should use the Code of Ethics and these guidelines as a basis for judgment in situations involving ethical conflicts or conflicts of interest with the company. However, in cases where ethical standards are not explicitly defined in the Code of Ethics, decisions should be made based on the principles of legality, fairness, and transparency, which are the guiding principles of ethical management. If there is still uncertainty, employees must consult with the Corporate Compliance Officer on the matter.
- ㆍLegality: Is it in compliance with relevant laws and company regulations?
- ㆍFairness: Can all stakeholders empathize with the decision?
- ㆍTransparency: Is the decision open and honest, with nothing hidden or false, and can it be disclosed?
2.3 (Operation of Reporting System and Protection of Whistleblowers)
- 2.3.1 Employees and executives who become aware of violations of the Code of Ethics should promptly report or disclose such violations to their organization's leaders or the Corporate Compliance Officer to ensure the swift resolution of the issue, thereby actively protecting the company and employees and executives from harm.
- 2.3.2 The company operates a reporting system to facilitate reporting and disclosure.
- 2.3.3 The contents of reports are treated confidentially, and the identity and related information of the whistleblower are strictly protected. Whistleblowers will not face any adverse consequences as a result of their reports.
2.4 (Actions Against Violations) When an employees and executives of the company violates this regulation, appropriate actions will be taken in accordance with company policies.
(Exceptional Interpretation) In cases where matters are not explicitly covered by these guidelines or disputes arise in their interpretation, the interpretation of the Corporate Compliance Officer will be followed. If necessary, the Corporate Compliance Officer shall refer the matter to the Executive Committee for resolution.

Definitions
Title	Content
Leader	Colleagues within the same organization, including supervisors, senior employees, mentors, etc.
Duties	Repetitive and ongoing tasks performed directly or indirectly in the capacity of an employee
Stakeholders	All individuals, entities, or organizations, both internal and external, whose interests are affected by the actions or decisions of company employees and executives related to their work. Employees and executives within the same organizational unit, including superiors and subordinates, who have work-related interactions, also fall within the category of stakeholders.
Socially recognized	When the provider's purity, voluntariness, and lack of burden are recognized.
Inevitable circumstances	When it was delivered in one's absence and refusal was not possible, or when it was deemed impolite to refuse a favor, or when a fee through family members/relatives/friends is disclosed. Act of transferring of family members/relatives/friends are considered as one's own act of transferring.
Reporters	All employees and executives who have a duty to report any acceptance of money, gifts, or similar items, and the awareness of such actions.
Executives	Individuals with a rank of Executive director or higher.
Reporting/ Whistleblowing	Reporting: Employees should report according to the company's reporting system, but they must report to at least a team leader or higher. Whistleblowing: Employees must complete a whistleblower report form, obtain approval from a team leader or higher, and submit it to the Compliance Officer by the fifth working day.

Responsibilities and Authorities.
Organization	Responsibilities and Authorities
Employees and Executives	ㆍEmployees and executives must understand their roles and responsibilities and familiarize themselves with the company's code of ethics and related regulations. They should comply with guidelines and practice ethical management. ㆍIf an employee or executives or someone else violates the code of ethics or tries to force a violation, they must promptly report it to the compliance officer following the prescribed procedure. ㆍEmployees and executives are not exempt from personal responsibility, even if their actions are for the benefit of the company. They should recognize that not knowing the company's code of ethics or related regulations is not an excuse. If they have any doubts or concerns about potential violations, they should consult their leader or compliance officer. ㆍIf employees and executives are suspicions of wrongdoing related to the company's business or if the handling of tasks is not transparent, employees have a responsibility and obligation to prove that their work was conducted transparently. When requested by the compliance officer, employees and executives should fill out the self-compliance commitment form at least once a year and submit it to the company.
Leaders	ㆍLeaders should familiarize themselves with the code of ethics and guidelines, setting an example in all matters and providing guidance to ensure that members can adhere to the company's policies and work regulations. ㆍTo establish a fair trade order, leaders should establish work procedures and take necessary measures or provide support to ensure that decisions are not influenced by undue pressure or solicitation.

Chapter 1. Customer Satisfaction Management

1. Listening to Customer Feedback and Providing Honest Information
- 1.1 Recognize that customer evaluations are a measure of success and always listen to the voices of customers, incorporating their feedback into management.
- 1.2 Provide truthful information to customers and refrain from spreading false facts or providing false information.
- 1.3 Disclose important and relevant information to customers in a sincere manner, ensuring that they are informed of facts they should know or have a right to know.
2. Providing the Best Products and Services
To meet customer expectations and demands through technological development and quality improvement, all requirements of the company's quality management system must be complied with.
3. Customer Information and Interest Protection
- 3.1 Members handling customer information and interests must establish protective procedures and guidelines in accordance with relevant laws and company regulations to securely protect customer information. They must not use customer information without prior approval or disclose it without authorization.
- 3.2 It must refrain from engaging in unethical practices that could harm customer interests.
- 3.3 Promises made to customers, whether explicit or implicit, must be honored.
- 3.4 Promptly address legitimate requests from customers.
- 3.5 Quickly address all complaints related to products/services and customer information management received from customers.

Chapter 2. Coexistence and Co-prosperity with Cooperating Companies

Ensuring Fair Selection and Development of Cooperating companies
- 1.1 Ensure that all qualified companies have the opportunity to participate in cooperative company registration and selection.
- 1.2 Establish and adhere to a comprehensive system related to the [Cooperating Companies Selection Procedure] to enable the fair selection and registration of suppliers based on objective evaluation criteria.
- 1.3 Establish criteria for supporting and nurturing cooperating companies and develop long-term cooperative relationships through technical support and management guidance.
- 1.4 Strictly prohibit any requests or pressure based on special relationships such as blood ties, academic connections, or personal connections in relation to the selection and transactions with cooperating companies.
2. Maintaining Fair Trading Practices
- 2.1 All transactions must be conducted fairly on an equal footing, and no unfair practices that take advantage of a dominant position over cooperating companies are allowed.
  Practices such as unilaterally pushing products that cooperating companies do not intend to purchase.
  - 2.1.1 Unfair price adjustments without prior notice or consultation with cooperating companies.
  - 2.1.2 Refusing valid returns for justifiable reasons or unfairly refusing or delaying the receipt of ordered goods.
  - 2.1.3 Failing to fulfill legal obligations regarding payment terms, delayed interest payments, or other payment conditions.
  - 2.1.4 Unjustifiably discontinuing or significantly limiting the relationship with cooperating companies with no legitimate reasons.
  - 2.1.5 Engaging in any unfair trade practices prohibited by relevant laws and regulations governing fair trade.
  - 2.1.6 Unfairly utilizing information and technology obtained during transactions with cooperating companies without explicit prior approval, thereby obstructing the business activities of these cooperating companies.
- 2.2 Matters that could be interpreted as violations of fair trade-related regulations must be handled after sufficient consultation with the department responsible for fair trade to avoid making arbitrary decisions based on personal interpretations.

Chapter 3. Respect for Employees and Executives and Adherence to Fundamental Ethics

1. Respecting Employees and Executives
- 1.1 Nurturing Talents
  - 1.1.1 Have the necessary systems in place and actively support them to foster employees as autonomous and creative talents.
  - 1.1.2 Superiors have the determination to nurture their subordinates into challenging and resilient talents and provide necessary guidance and support, taking into consideration the subordinates' aptitude and potential.
- 1.2 Fair Treatment Based on Competence and Achievements
  - 1.2.1 Provide equal opportunities (such as education and job assignments) for employees to enhance their abilities and do not discriminate based on nationality, educational background, gender, disability, age, place of origin, or religion.
  - 1.2.2 Establish and publicly disclose clear evaluation criteria for competence and achievements and strictly adhering to them, promoting employees' self-development motivation and fostering a fair competitive environment.
  - 1.2.3 Reward employees differently based strictly on the differences in their qualifications and performance (achievements), without discrimination based on irrelevant factors.
- 1.3 Ensuring Free Expression of Sound Opinions
  Have necessary systems and create an atmosphere that allows employees and executives to freely suggest, propose, and express concerns.
- 1.4 Responsibility for Health and Safety
  - 1.4.1 Take necessary measures to ensure the health and safety of employees in the workplace.
  - 1.4.2 Take necessary safety precautions before conducting work for workplaces where hazardous materials or substances are present

2. Employees and Executives Adherence to Basic Ethics

2.1 Protection of Company Assets and Compliance with Laws and Regulations

2.1.1 In the event of an important or urgent situation involving company assets or the possibility thereof, promptly report it and take appropriate actions.
2.1.2 Respect and cherish company assets, including supplies, furniture, and facilities, and refrain from using them for personal gain.

2.1.3 Do not use the company's corporate cards and budgets for personal purposes. Expenditures must align with the purposes specified by the company and be accurately recorded in the accounting ledger.

Accounting ledger records
Guidelines for Company Expense Usage	- Do not patronize establishments that go against societal ethics. - Limit drinking and dining to a single round as a basic practice.

2.1.4 Actively protect intellectual property rights, business information, and technical data, including information assets, in accordance with security management regulations, ensuring that neither oneself nor others gain unfair advantages from their use. Also, ensure the equal protection of the intellectual property rights of others, particularly by refraining from using illegal software.
2.1.5 (Obligations of internal information handlers) Do not disclose information to individuals within the company, even if they are internal, without proper authorization before the company officially discloses such information.
2.1.6 Compliance with Company Regulations and Work Ethic
- 1) Adhere to company regulations, work procedures, and all other work-related guidelines.
- 2) Avoid job negligence, failure to fulfill managerial responsibilities with integrity, improper exercise of authority, and engaging in personal activities during working hours, as these actions may result in losses for the company.

2.2 Prohibition of Unethical Conduct in Job Performance
- 2.2.1 Prohibition of Receiving Economic Benefits from Stakeholders
  - 1) Do not accept or request any form of economic benefit (money, services, favors, etc.) from individuals or entities with whom the company has a stake if it could compromise the fairness of job performance.
  - 2) Do not accept or tolerate any bribes related to personnel and recruitment matters.
- 2.2.2 Prohibition of Wrongful Acts Using Position or Duties
  - 1) Do not promise or demand future employment from stakeholders related to their duties after retirement, During employment.
  - 2) Do not enter into personal business contracts or engage in transactions such as leasing assets or provide financial loans with stakeholders related to their duties.
  - 3) Superiors do not assign personal tasks or implicitly demand them from their organization or subordinates.
- 2.2.3 Honest and Fair Reporting and Refusal of Unfair Tasks
  - 1) Do not manipulate documents or provide false reports to deceive superiors and relevant departments with inaccurate information or figures.
  - 2) Superiors cannot instruct subordinates to perform tasks that do not comply with laws and company regulations, and subordinates have the right to refuse tasks that do not align with legal requirements and company regulations when instructed by superiors.
- 2.2.4 Respect Among Employees and Executivs and Maintenance of GS Power peoples's Dignity
  - 1) Employees and Executives should respect each other and maintain basic courtesy necessary for workplace etiquette, refraining from any form of unethical or immoral behavior that could damage the company's corporate image.
  - 2) Employees and Executives should not engage in any form of sexual harassment that infringes upon personal dignity and undermines the working atmosphere.
  - 3) Employees and Executives should avoid promoting or participating in any divisive actions within the organization, such as creating or spreading rumors, which could undermine a healthy working environment.
  - 4) Employees and Executives refrain from engaging in inappropriate practices among themselves, such as accepting or lending money, co-signing loans, or engaging in undue solicitation.
  - 5) In matters related to promotions, transfers, holidays, and the like, employees and executives should avoid engaging in ceremonial practices among themselves within the company, such as giving gifts, floral arrangements, celebrations, or sending congratulatory messages.
- 2.3 Avoidance of Conflicts of Interest with the Company
  - 2.3.1 Employees and executives shall not engage in businesses that directly or indirectly compete with the company.
  - 2.3.2 Employees and executives shall not involve themselves in the operations or investments of businesses or cooperating companies that have conflicts of interest with their assigned duties at the company without prior agreement.
  - 2.3.3 Employees shall not provide counseling, advice, or engage in dual employment with competing companies or cooperating companies that may conflict with the interests of the company.
  - 2.3.4 If there is a possibility of a conflict of interest with the company due to involvement or employment with external companies, employees and executives must report it to the company in advance and obtain approval.
    If such matters are discovered later and not reported, they will be subject to serious violations according to the regulations.
- 2.4 Self-Development Efforts
  - 2.4.1 Employees shall continuously strive for self-development to embody the company's ideal of talent.
  - 2.4.2 In addition to excelling in their assigned duties, employees shall cultivate a broad perspective and knowledge in various fields to contribute to the overall benefit of the company.

3. Guidelines for Accepting Monetary Benefits and Gifts - These guidelines are intended to establish specific provisions regarding [Chapter 3, Section 2, 2.2.1 Prohibition of Accepting Economic Benefits from Stakeholders].

3.1 Procedures
3.1.1 Basic Principles
- 1) If employees and executives receives money, gifts/hospitality, or any form of convenience from stakeholders, it can potentially influence normal decision-making processes. Therefore, in such cases, employees and executives should first politely decline these offerings.
- 2) In cases where employees and executives unavoidably receives money, gifts/hospitality, or economic conveniences related to their job from stakeholders, they must voluntarily report it and follow the procedures outlined below for post-receipt reporting and handling. Even if the fact of receiving money or gifts later comes to light, no punishment will be imposed for the reported cases. However, if the act constitutes a prohibited action, reporting and post-receipt handling alone will not exempt the employee from disciplinary actions.
- 3) All employees and executives must report to the company, following the voluntary compliance program, if they become aware that a colleague has received money/gifts, etc., and has not reported it in accordance with Voluntary Compliance Program.

3.1.2 Receipt of Gifts or Money

1) Prohibited Acts

Prohibited Acts
Content	Exampels	Type of Act
Receipt of Gifts or Money	Cash/ checks/ gift cards/ tickets/ goods	Prohibited (mandatory reporting for exceeding limits)
Receipt of Real Estate or Property	Real estate/ property/ business rights/ memberships/ property stakes	Prohibited
Debt Repayment on Behalf of Others	Credit card debt/ accounts receivable/ loan repayments
Borrowing money	Borrowing money
Low price purchase	Acquiring real estate or property at a price lower than the market value and effectively profiting from it
Indiscriminate notification of family events	Personally or by instructing/subordinating colleagues, sending wedding/funeral invitations indiscriminately to cooperating companies/agents, etc., through the distribution of wedding/funeral notices or through phone/fax notifications.

2)Subject to report: If receiving gifts in excess of 100,000 won per case, they must be reported and either returned or handled according to the reporting procedure. However, for gifts of 100,000 won or less, the reporting procedure can be skipped, and they may be returned.
3) Exceptions to Gift Receipt: The following items within the generally accepted societal norms are not considered as gift receipts:
- (1) Commemorative gifts/celebration money/gifts recognized as pure and voluntary by the provider, within the limit of 100,000 won, in accordance with social norms
- (2) Gifts provided publicly to employees and executives in difficult situations due to illness, disasters, etc.
- (3) Floral tributes received from external stakeholders upon promotion, transfer, or assumption of a new position in the company.
- 4) Reporting Procedure : Money or valuables received unavoidably will be handled as follows.
  - (1) General Procedure
    - A) The reporter must report the receipt of gifts by contacting the self-compliance manager via telephone or email, or by completing the "Gifts and Benefits Receipt Report" form and submitting it to the Voluntary Compliance Officer with attached details of the actions taken.
      If the Voluntary Compliance Officer is informed of the gift receipt by phone or email, they will handle it on behalf of the reporter.
    - B) The reporter may write a letter of cooperation for promoting a fair trading culture to the provider or the CEO of the provider's company and send it along with the returned items. Alternatively, they may enclose copies of the deposit receipt, returned goods receipt, and donation certificate.
    - C) If the appropriate recipient for the donation cannot be found or it is difficult to determine how to handle the situation, the reporter should contact the Voluntary Compliance Officer or seek their guidance.
  - (2) When Return Is Possible: In the case of cash, checks, gift cards, etc., they must be remitted/returned to the provider or the CEO of the provider's company if possible.
  - (3) When Return Is Not Possible
    - A) In cases where there is a risk of corruption/deterioration/damage or for reasons such as volume/weight that prevent return, the items must be donated in the name of the provider's affiliated company to social welfare facilities/religious organizations, etc.
    - B) In cases where corruption has already occurred and donation is not possible, dispose of the items immediately and report the reasons.
    - C) If the personal information of the provider is unknown, donate in the name of the company to social welfare facilities/religious organizations.
    - D) In the case of personal use: Convert to market value and donate in cash in the name of the provider's affiliated company to social welfare facilities/religious organizations.
    - E) High-value items or items unsuitable for donation to external organizations should be entrusted to the Voluntary Compliance Officer and processed under the instructions of the CEO.

3.1.3 Entertainment/Hospitality

1) Prohibited subjects

Prohibited subjects
Category	Prohibited subjects (Luxury Establishments)
Drinking	Room Salons/Entertainment Bars/Nightclubs
Entertainment	Casino
Unethical	Rest Areas/ Saunas/ Massage Parlors/ Decadent Barber Shops

2) Reporting subjects: Meals/Entertainment exceeding KRW 50,000 per person or KRW 200,000 per event
3) Reporting Procedure: When it is determined that receiving entertainment/hospitality is unavoidable, the following procedures shall be followed
- (1) The person who receives the offer of entertainment/hospitality shall report it in advance to a supervisor of a rank of team leader or higher, and the person receiving the report shall assess the necessity and instruct whether to attend.
- (2) When it is anticipated that the level of entertainment/hospitality exceeds the prescribed limit or that it will deviate into prohibited items, the attendees shall avoid it or take appropriate sanctions.
- (3) In the event that the reported matter falls under the reporting criteria after receiving entertainment/hospitality, the reporter shall send a letter requesting cooperation in promoting a fair culture to the provider or the CEO of the provider's affiliated company, attaching a copy to the "Entertainment/Hospitality Receipt Report," and report it to a Voluntary Compliance Officer after obtaining the approval of a supervisor of a rank of team leader or higher.
- (4) The reporting, both in advance and after the fact, shall be based on the highest-ranking participant.
4) Convenience Provision
- (1) Subjected Action
  Content Exampels Type of Act Business trip support When visiting an interested party's workplace or accompanying him/her to a business trip, the other party provides rail/air/bus tickets or accommodations. pay a fair price Vacation support Provision of rail/air/bus tickets, passenger vehicles, and accommodations for personal vacation Prohibited Future security Receiving guarantees regarding employment, job placement, prohibition on entering into business contracts, etc. Receipt of warranty Receive loan guarantee Borrowing movable/real estate The act of renting an asset or providing collateral
- (2) Reporting subjects: In case employees and executives have received economic convenience and have not paid legitimate compensation.
- (3) Reporting Procedure: In cases where transportation/accommodation convenience has been provided but legitimate compensation has not been paid, the recipient shall send a remittance to the provider or the CEO of the provider's affiliated company, attach a copy to the letter requesting cooperation in promoting a fair culture, and attach that copy to the "Gift/Convenience Receipt Report." After obtaining approval from a supervisor of a rank of team leader or higher, the recipient shall report it to the voluntary compliance manager.
5) Golf Expense Handling Guidelines
- (1) When Providing Golf Entertainment to External Stakeholders: Golf entertainment expenses may be processed for cases where golf is related to the company's business and is provided to external stakeholders. In such cases, employees and executives should not play golf during working hours, and if playing golf on a working day is unavoidable, prior written approval from the CEO must be obtained.
- (2) Golf among Company Employees: In principle, expenses related to golf among company employees and executives cannot be covered by company funds.
- However, in exceptional cases driven by organizational culture, such expenses may be processed as part of an executive's organizational activation budget with prior written approval from the CEO. In such cases, the approved golf application must be attached when preparing the expense report.
- (3) Receiving Golf Entertainment from External Stakeholders: Employees and executives should not accept golf entertainment from business-related stakeholders, regardless of cost sharing agreements. However, in situations where receiving golf entertainment is unavoidable, prior written approval from the CEO must be obtained.
6) Compilation and Reporting of Receipt of Benefits and Entertainment Situations: The Voluntary Compliance Officer compiles and reports the results of the receipt of gifts, entertainment, and benefits, on a quarterly basis, to the CEO.

Chapter 4. Protection of Shareholders' Interests

1. Sound Profit Realization and Enhancement of Corporate Value
- Maintain rational and transparent management activities and a sound financial structure to realize the sound interests of shareholders and receive fair evaluations of corporate value externally.
2. Transparency of Accounting System and Provision of Corporate Information
- 2.1 Accounting information is accurately recorded and maintained in accordance with generally accepted accounting principles, relevant regulations, and company regulations.
- 2.2 All management information of the company, including financial information, must accurately reflect relevant facts and transaction details to support proper decision-making by management and the board of directors.
- 2.3 Management information for shareholders and external stakeholders should be provided transparently and fairly in accordance with relevant regulations and company regulations.

Chapter 5. Contribution to the Nation and Society

1. Contribution to National and Social Development
- 1.1 Contribute to national development through sound profit generation, through continuous job creation, and diligent tax payments.
- 1.2 Provide equal employment opportunities to everyone, regardless of educational background, gender, place of origin, disabilities, or race, without discrimination.
- 1.3 Actively participate in sharing activities such as volunteering and donations, leading the development of an advanced sharing culture and contributing to the enhancement of the welfare of the citizens.
- 1.4 Make every effort to address the demands of local communities, actively engage in resolving them, and contribute to the formation of local communities through partnerships.
2. Respect for the Free Competitive Market Order
- 2.1 Comply with all regulations of the respective countries or regions where business activities are conducted and respect trade customs and cultures.
- 2.2 Do not engage in activities that harm the national economy, such as market manipulation or real estate speculation.
- 2.3 Pursue fair competition with competitors and do not unfairly infringe on the interests of competitors.
- 2.4 Obtain and utilize information fairly in accordance with regulations and trade customs.

Chapter 6. Environmental, Health, and Safety centric management

1. Environmental Management
- 1.1 Comply with domestic and international environmental laws and agreements, and establish and implement an environmental management system.
- 1.2 Make sufficient facility investments for environmental pollution prevention and engage in continuous and diverse improvement activities.
- 1.3 Promote active environmental protection activities in all areas of business activities, including manufacturing, distribution, and sales, through the development of environmentally friendly products and services.
2. Health and Safety Management
- 2.1 Conduct continuous health and safety improvement activities and accident prevention activities in all areas of management activities.
- 2.2 Comply with all health and safety regulations and transparently disclose health and safety information based on trust.
- 2.3 Implement health and safety improvement programs and training within the workplace, creating a safe and pleasant working environment.

1. These Ethical Guidelines for Practice shall be effective from 18th July, 2003.
2. These Ethical Guidelines for Practice shall be amended and effective from 8th March, 2011.
3. These Ethical Guidelines for Practice shall be amended and effective from 12th March, 2012 (Regulation of post-action sanctions for conflicts of interest by employees).

GS Power

ESG

Governance

Governance