Ethics/Compliance
POSCO has ingrained an ethical corporate culture rooted in the ethical management philosophy of “Doing the right thing in the right way.” We strive to not only comply with laws and ethical standards but also adhere strictly to the basics and uphold principles through our business activities. Reflecting evolving social expectations, we have established a new ethical management system at the level of a leading global company. Moving forward, we will continue to act based on the core values of ethical management: Integrity, Respect, and Mutual Empathy in all our endeavors.
Integrity: Our decisions and actions are transparent and honest.
Respect: We treat everyone with dignity and fairness, grounded in mutual respect and consideration.
Mutual Empathy: Through interactions with stakeholders, we consider and understand others’ perspectives, fostering a more cooperative and inclusive culture.
Integrity: Our decisions and actions are transparent and honest.
Respect: We treat everyone with dignity and fairness, grounded in mutual respect and consideration.
Mutual Empathy: Through interactions with stakeholders, we consider and understand others’ perspectives, fostering a more cooperative and inclusive culture.
Ethical Management System
Since establishing and announcing the ‘Code of Ethics’for corporate ethics practice in 2003, POSCO has made ethics the highest priority in its management and has operated a systematic ethical management compliance system for over 20 years.
The company executes its ethical management tasks through the Corporate Audit Office, which operates directly under the CEO. The Corporate Audit Office is involved in various ethical practice activities, such as establishing and supporting the operation of ethical management policies for domestic subsidiaries, overseas subsidiaries, and partners; providing customized ethics training and conducting campaigns by rank and job category; and auditing violations of human dignity and unethical conduct.
Key issues and performance in ethical management are reported to top management and, to ensure independence, are also regularly reported twice a year to the Audit Committee under the Board of Directors.
The company executes its ethical management tasks through the Corporate Audit Office, which operates directly under the CEO. The Corporate Audit Office is involved in various ethical practice activities, such as establishing and supporting the operation of ethical management policies for domestic subsidiaries, overseas subsidiaries, and partners; providing customized ethics training and conducting campaigns by rank and job category; and auditing violations of human dignity and unethical conduct.
Key issues and performance in ethical management are reported to top management and, to ensure independence, are also regularly reported twice a year to the Audit Committee under the Board of Directors.
Ethical Management Process
POSCO operates the following process to ensure that ethical management is embedded in the daily activities and work of all employees. Through the detection and prevention of unethical behavior in everyday life, we strive to make ethical practices an integral part of our daily routine.
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Ethical Policies and
Process Operation
- Establish and revise the code of ethics and practice guidelines, develop governance structures, and formulate strategies.
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Unethical
Risk Prevention Activities
- Conduct ethics pledges for all employees, provide customized on/offline training, and run ethical management campaigns.
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Unethical Behavior
Diagnosis and Action
- Manage risks of unethical behavior and human dignity violations detected through executive and managerial ethics sessions and ongoing surveys. Handle reports of unethical behavior through audits and implement follow-up measures.
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Change Management
- Improve unethical practices and reduce waste through audits. Support ethical management activities for subsidiaries and partners.
Standardization of Ethical Standards and Policies
Ethical management standards and policies include a total of 11 items, comprising the code of ethics, Audit Committee operating regulations, and internal audit guidelines (5 company regulations and 6 business guidelines). The Corporate Audit Office, as the department responsible for these regulations and guidelines, periodically conducts adequacy reviews.
Ethical Management Standards Operating Framework
Ethics Training
We develop and operate online and offline training programs, providing training for all domestic and international employees. Our mandatory e-learning course, “Understanding POSCO’s Ethical Management,” centers on ethical management consultations and audit cases, allowing all employees to complete it online. Moreover, we run monthly ethical management campaigns to ensure that all employees can easily understand how to handle ethical dilemmas and prevent and address bullying, sharing the materials across group companies.
We provide advanced training focused on unethical case studies at the request of customer-facing and purchasing departments, aiming to prevent unethical risks that may arise in field operations. Additionally, we prepare English campaign materials and distribute them to overseas subsidiaries, contributing to the education of locally hired employees (Global Staff).
Online
- Mandatory e-learning training (Understanding POSCO’s Ethical Management / Workplace Sexual Harassment Prevention Training)
- Company-wide posting of ethical management campaigns (focusing on unethical behavior, bullying, sexual harassment, and prevention of abuse of power)
- Sharing ethical management campaigns through the GIH (Global Information Hub) system
Offline
- Training programs by hierarchy/position : Training for newly appointed executives/managerial position holders/resident reps, training for new/experienced/intern employees, training for overseas employees, etc.
- Department-specific specialized training : Advanced training focused on case studies for external-facing departments including the Raw Materials Office, the Investment Engineering Office, the Marketing Division, etc.
- Special training on sexual ethics : Focused on long-tenured employees, this training covers compliance with sexual ethics (31 sessions with external experts invited)
- Executives and managers receive annual training through the PIUM program
Ethical Diagnosis and Actions
Surveys
To assess the level of ethical practice among employees and to detect unethical behavior early, we regularly conduct ethics sessions and surveys for all employees.
| Ethics Sessions for Executives | Assess the ethical management mindset of executives (annually) |
|---|---|
| Ethics Sessions for Managers | Enhance the ethical leadership of managers (annually) |
| Ethical Risk Detection Survey | Monitor the status of unethical business practices and violations of human dignity (such as sexual harassment and bullying) (monthly) |
Operation of the Reporting Center
We maintain a reporting center where employees can report unethical behavior and violations of human dignity at any time.
Stakeholders can also seek consultation and file reports. When employees receive solicitations, they are required to record and manage the details in the ‘Clean POSCO System,’ fostering a transparent corporate culture. In 2023, a total of 420 reports of unethical behavior were received and processed.
Stakeholders can also seek consultation and file reports. When employees receive solicitations, they are required to record and manage the details in the ‘Clean POSCO System,’ fostering a transparent corporate culture. In 2023, a total of 420 reports of unethical behavior were received and processed.
Number of Unethical Reports Received
Reporting Process
| Unethical Behavior Consultation and Reporting | Fact-Finding Investigation | Conclusion of Investigation and Request for Action | Notification of Action Results | Follow-Up Management |
|---|---|---|---|---|
| Website reporting center, email, phone, etc | Consultation and investigation with the complainant, respondent, and third parties (confidentiality and non-retaliation agreement signed) | Internal review of investigation results to determine the conclusion, request for administrative and personnel action | Inform the complainant of the investigation results | Recurrence prevention education, monitoring |
Actions Against Unethical Behavior
POSCO adheres to the Zero Tolerance Principle for the four major unethical behaviors: bribery, embezzlement, sexual ethics violations, and information manipulation. Violations of ethical standards are always met with appropriate punishment. POSCO prohibits any actions that could disclose the identity of whistleblowers and has codified a system for punishing such violations. Employees of the Corporate Audit Office, the audit organization, make an electronic pledge for whistleblower protection at the beginning of each year, ensuring the utmost protection of whistleblower identities.
Change Management
To foster win-win partnerships and ESG management among SMEs, we support the establishment of ethical management infrastructure.
From 2020 to the present, we have assisted a total of 32 companies in implementing ethical regulations and systems, establishing unethical behavior reporting centers, providing ethics training campaigns, and offering ethical dilemma consultations. This support helps partners build a foundation for independently practicing ethical management.
Additionally, following the support activities, we reassessed the ethical standards of our partners to confirm their improvement and provided feedback. This process enables partners to voluntarily establish and implement future development plans. Furthermore, through support activities focused on building ethical management infrastructure and compliance for small-sized and newly established business companies, we have prevented violations of human dignity and mitigated unethical risks.
From 2020 to the present, we have assisted a total of 32 companies in implementing ethical regulations and systems, establishing unethical behavior reporting centers, providing ethics training campaigns, and offering ethical dilemma consultations. This support helps partners build a foundation for independently practicing ethical management.
Additionally, following the support activities, we reassessed the ethical standards of our partners to confirm their improvement and provided feedback. This process enables partners to voluntarily establish and implement future development plans. Furthermore, through support activities focused on building ethical management infrastructure and compliance for small-sized and newly established business companies, we have prevented violations of human dignity and mitigated unethical risks.
Support for Building Ethical Management Infrastructure for Partners
| Step 1 | Step 2 | Step 3 |
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Major Achievements in Establishing Ethical Management Infrastructure for Business Companies (Comprehensive)
| Category | Major Improvements | Completion |
|---|---|---|
| Regulations | Revised and updated company regulations, including the code of ethics and bullying/sexual harassment prevention guidelines | By May 2023 |
| Management’s Declaration | Held an ethical management pledge event | By June 2023 |
| CEO Message and Employee Ethics Pledge | By June 2023 | |
| Organization and System | Inspected the grievance handling process and established operational standards | By June 2023 |
| Introduced and informed about the reporting system/channel, and inspected the solicitation prevention process | By July 2023 | |
| Implemented the unethical behavior inspection app and human dignity survey (ethics session) | By August 2023 | |
| Practical Activities | Conducted monthly ethics training and campaign activities for managers and employees | Monthly in 2023 |
| Conducted the no-gift campaign and operated a gift return center | By September 2023 |
Ethics Training Completion Rate
We are offering the company-wide mandatory course ‘Understanding POSCO’s Ethical Management (e-learning)’ with the aim of having all employees complete it.
| Metric | Unit | 2020 | 2021 | 2022 | 2023 | 2024 Goal |
|---|---|---|---|---|---|---|
| Ethics Training Completion Rate | % | 99.9 | 100 | 100 | 100 | 100 |
| Metric | Ethics Training Completion Rate |
|---|---|
| Unit | % |
| 2020 | 99.9 |
| 2021 | 100 |
| 2022 | 100 |
| 2023 | 100 |
| 2024 Goal | 100 |