윤리경영

Fair Trade

The Fair Trade Compliance Program (CP) is an independently established and operated internal compliance system in order to comply with fair trade-related regulations on their own. By presenting clear standards of conduct related to fair trade to employees, the company has been operating a compliance program since 2002 to prevent violations of fair trade-related laws in advance and to ensure corporate transparency.

Implementation Requirements for CP
(8 Essential Elements and Compliance Council)

1
Establishment and implementation of CP standards and procedures
2
Commitment and support for compliance from the CEO
3
Appointment of a compliance officer responsible for CP operations
4
Creation and utilization of a compliance manual
5
Continuous and systematic compliance training

6
Establishment of an internal monitoring system
7
Sanctions for employees who violate fair trade-related regulations
8
Effectiveness evaluation and corrective actions
9
Operation of the Compliance Council

CP Operational Status

Compliance Program (CP)

To prevent violations of fair trade-related regulations and ensure corporate transparency, POSCO has been operating the Compliance Program since 2002.

Compliance Manual and Training

POSCO publishes the ‘Fair Trade Compliance Manual’ to assist employees in complying with fair trade-related regulations.
The manual is regularly updated to incorporate the latest legal amendments. Furthermore, a compliance manual mobile app has been developed and is being operated to enhance accessibility for employees.

Self-Inspection System and Council

We conduct risk inspections for legal violations using the Fair Trade Self-Inspection Checklist, led by operational departments.
Additionally, we have established a Compliance Council composed of relevant department heads and have selected action leaders for each department to ensure the effective operation of the Fair Trade Compliance Program.

Overview

The Fair Trade Compliance Program (CP) refers to an internal compliance system that a company establishes and operates independently to ensure compliance with fair trade-related regulations.

To provide employees with clear guidelines on fair trade-related conduct, prevent violations of fair trade-related regulations in advance, and ensure corporate transparency, the company has been operating the Compliance Program since 2002.

Fair Trade Compliance Program Operating Guidelines

1. Scope of Application

These guidelines apply to all employees and all business activities related to fair trade. Employees are required to comply with fair trade-related regulations.

2. Core Principles of the Guidelines

Establishment and Implementation of CP Standards and Procedures: Establish and implement necessary standards and procedures to ensure that all affiliated employees clearly understand and comply with fair trade-related regulations in their work.
CEO’s Commitment and Support for Compliance: The CEO will express a commitment to fair trade compliance through a message and conduct the Fair Trade Compliance Pledge annually.
Appointment of a Compliance Officer Responsible for CP Operations: A fair trade compliance officer will be appointed based on the resolution of the board of directors.
Creation and Utilization of Compliance Manuals: Fair Trade Compliance Manuals will be periodically distributed for various sectors, including marketing, purchasing, and large conglomerates.
Continuous and Systematic Compliance Training: Conduct regular fair trade training for operational departments such as purchasing and sales, and provide fair trade training by hierarchy for new employees and managers. Additionally, operate e-learning courses such as “Learning Fair Trade Anew".
Establishment of an Internal Monitoring System: Report CP operational performance and plans to the board of directors and operate internal and external fair trade consultation and reporting centers. Additionally, provide advisory and consultation services and conduct thematic inspections of vulnerable areas concurrently.
Sanctions for Employees Violating Fair Trade Regulations: Enforce punishment regulations following the verification of illegal activities and promptly take disciplinary actions against those who violate the law.
Effectiveness Evaluation and Corrective Actions: Conduct inspections and evaluations of the program’s standards, procedures, and operations, and implement corrective actions accordingly. (Reference) Achieved an AA rating in the Fair Trade Commission CP Rating Evaluation for the years 2006-2012 and 2021-2023
Operation of the Compliance Council: Establish a Compliance Council composed of department heads from relevant areas such as marketing and purchasing.

Compliance Manual

In 1996, POSCO published the Fair Trade Practice Manual to provide employees with a code of conduct for compliance with the Fair Trade Act. A revised edition was issued in 2001 to incorporate amendments to the Fair Trade Act. In 2004 and 2005, recent legal amendments, case decisions, and Q&A sections were added to create the “Fair Trade Compliance Manual for the Subcontracting Sector,” “Fair Trade Compliance Manual for the Unfair Trade Practices Sector,” and “Fair Trade Compliance Manual for Large Conglomerates” for practical use in departments. In 2007 and 2008, POSCO released the “Fair Trade Compliance Action Guideline for the Marketing Sector” and the “Fair Trade Compliance Action Guideline for the Purchasing Sector.”

In 2015, to enhance user convenience, the manuals for the marketing and purchasing sectors were each integrated and published. In 2016, the “Fair Trade Compliance Manual for Large Conglomerates” was revised. In 2020, the manuals for the marketing, purchasing, and conglomerate sectors were updated, and the “Overseas Subsidiaries CP Manual” was published for the first time.

In 2023, POSCO further innovated by integrating an interactive AI service, ChatGPT, into the Fair Trade Compliance Manuals, creating the new Fair Trade GPT.

Fair Trade Training

POSCO provides customized fair trade training, both online and offline, for its domestic and overseas subsidiaries.

For the sales and purchasing sectors, as well as for managers, general employees, and new employees, POSCO conducts separate group training sessions categorized by sector and hierarchy, both regularly and as needed. Additionally, an e-learning training program is available for online access at any time.

Additionally, through regular legal affairs councils for overseas subsidiaries, POSCO provides major compliance guidelines and actively works to prevent related risks.

Self-Inspection System

POSCO conducts fair trade self-inspections using checklists for each sector. This self-inspection process is the most effective method to identify and prevent fair trade violations in advance, ensuring the practical operation of the Fair Trade Compliance Program.

The Fair Trade Self-Inspection Checklist is included in compliance manuals to help employees prevent the risk of legal violations in advance. Additionally, to facilitate self-inspections without inconvenience during fieldwork or business trips, the company has developed and distributed a smartphone application.

Compliance Council

A. Compliance Council

Purpose of Operation
Composition and Roles

B. Fair Trade Action Leaders

Purpose of Operation
Roles