Sustainability Report

정책

Policy

Code of Ethics

Ethical Principles

1. Roles and Responsibilities of All Members

  • We comply with relevant laws and company regulations and guidelines wherever POSCO conducts business globally.
  • We maintain our dignity as employees and strive to uphold the corporate reputation.
  • We take responsibility for practicing ethical behavior and do our utmost to establish an ethical culture.
  • If we become aware that a situation or behavior, whether involving ourselves or others, violates or has the potential to violate the code of ethics, we promptly report it or seek consultation with a supervisor or the department responsible for ethical management.
  • We actively cooperate with the department responsible for ethical management in investigations of cases with potential violations of the code of ethics.
  • We never engage in retaliatory actions against whistleblowers or participants in investigations of ethical violations.
  • We understand that if we violate the code of ethics, request others to violate the code of ethics, do not cooperate in the reporting and investigation of ethical violations, or engage in retaliatory actions against whistleblowers or participants in investigations, we may face corresponding disciplinary action. We understand that the zero tolerance principle applies specifically to the four major unethical behaviors: bribery, embezzlement, information manipulation, and sexual ethics violations.
View Full Text of Ethical Principles Ethics Charter Code of Conduct Practice Guidelines

Anti-Corruption Compliance Guidelines

Chapter 1 General Provisions
Article 1 Purpose
POSCO is committed to adhering to the highest global legal and ethical standards in conducting business worldwide. The purpose of the POSCO Anti-Corruption Compliance Guidelines is to ensure that POSCO employees, as well as POSCO’s group companies, agents, and business partners, comply with global anti-corruption laws and standards.
Chapter 2 Business Procedures

Article 2 Global Anti-Corruption Compliance
POSCO employees are responsible for complying with all global anti-corruption laws and standards. Major global anti-corruption laws and standards include the US FCPA (Foreign Corrupt Practices Act), the UK Bribery Act, the OECD Anti-Bribery Convention, and the UN Global Compact. The FCPA prohibits US stock exchange-listed companies from bribing foreign officials and establishes requirements for accurate bookkeeping, management, and internal controls related to accounting. The UK Bribery Act prohibits UK companies and companies doing business in the UK from bribing foreign officials and business partners. The OECD Anti-Bribery Convention is the first international convention to criminalize the bribery of foreign officials. The Republic of Korea has enacted and implemented the “Act on Combating Bribery of Foreign Public Officials in International Business Transactions” to comply with this convention. The UN Global Compact sets forth guidelines for corporate responses to all forms of corruption, including bribery.

POSCO employees must comply with global anti-corruption laws and standards, as well as local anti-corruption laws in the regions where they conduct business. In the Republic of Korea, these include the Criminal Act, the Act on the Aggravated Punishment of Specific Crimes, the Act on the Aggravated Punishment of Specific Economic Crimes, and the Improper Solicitation and Graft Act. Even if an action is taken based on social or business practices, it cannot be exempt from liability if it violates global anti-corruption laws, standards, or local laws. In the event of a conflict between global anti-corruption laws, standards, local laws, and POSCO’s anti-corruption compliance guidelines, the strictest standards will be followed.

View Full Text of Anti-Corruption Compliance Guidelines

Ethical Principles

1. Roles and responsibilities of all employees

  • We comply with relevant laws and company regulations and guidelines anywhere in the world where POSCO conducts business.
  • We endeavor to maintain our dignity as employees and protect our corporate reputation.
  • We make our best efforts to establish an ethical culture by taking responsibility for practicing ethical behavior.
  • We report to or consult an authority figure or the department in charge of ethical management1) immediately upon becoming aware of the fact that a situation faced or an action performed by us or another person violates or is likely to violate the Code of Ethics.
  • We fully cooperate with investigations conducted by the department in charge of ethical management regarding matters that are likely to violate the Code of Ethics.
  • We do not retaliate against informants or individuals who participate in an investigation in relation to Code of Ethics violations.
  • We are aware of the fact that by violating the Code of Ethics, soliciting another person to violate the Code of Ethics, failing to report a Code of Ethics violation or cooperate with an investigation, or taking retaliatory action against an informant or individual participating in an investigation, we may become subject to disciplinary action as appropriate. In particular, we are aware that there is zero tolerance for the four major ethical violations2) : acceptance of bribery, misappropriation, fabrication of information, and sexual misconduct.
1) In accordance with guidelines on roles and responsibilities
2) Acceptance of bribery: Accepting money or goods beyond a socially acceptable amount from a stakeholder
Misappropriation: Taking unlawful possession of company funds or assets
Fabrication of information: Falsifying, concealing, or distributing business-related information in a manner that contradicts the truth
Sexual misconduct: Conduct that causes distress through sexual harassment or sexual assault

2. Special responsibilities of executives and authority figures

Executives and authority figures have the responsibility to set an example of ethical compliance and prevent ethical misconduct among staff members. To this end, they must be aware of the following principles and put them to practice:
  • When the company’s profits and ethics are in conflict, you have a duty to prioritize ethics in your operational and administrative decision making.
  • You must exemplify ethical conduct in your work and fulfill your duty as an internal and external role model.
  • You must train and guide staff members to understand the provisions of the Code of Ethics and Practice Guidelines and the importance of compliance.
  • You must routinely examine your teams for ethical misconduct and proactively prevent unethical behavior that is likely to occur by identifying the causes, improving processes, and taking other measures.
  • You must foster an organizational atmosphere that promotes and supports ethically correct behavior where staff members can speak up without worrying about adverse action.
  • You must report to or consult the department in charge of ethical management immediately upon becoming aware of the fact that a staff member has violated the Code of Ethics.
  • You have unlimited liability for any ethical misconduct you have engaged in, and supervisory liability for the ethical misconduct of a subordinate employee.

Ethics Charter

POSCO Group aspires to become a trusted and respected enterprise by deeply understanding that ethical management is the greatest value we must uphold in order to co-exist and co-prosper with our many stakeholders as a member of society.

Members of the POSCO family1) must comply with laws and ethics based on the ethical management philosophy of “doing the right thing in the right way,” while also seeking to achieve Integrity, Respect, and Mutual Empathy and establishing an ethical corporate culture in business activities that cover all the basics and comply with the rules.

At the employee level, we must pursue individual growth and company success by achieving a work-life balance, and create a positive work environment by establishing a corporate culture of mutual respect. We must fulfill our duty to respect everyone as human beings and to respect the human rights universally pursued by human society.

For our customers, we must understand that our future depends on customer trust and success. We must respect the customer voice at all times and create value that promotes customer prosperity.

For our shareholders, we must enhance shareholder value by making fair profits through transparent decision making and efficient business activity.

With our business partners, we must establish a fair trading system based on mutual trust and strengthen our corporate ecosystem in which we co-exist with our business partners through mutual growth.

At the community level, we must contribute to the development of society by fulfilling our duties and obligations. We must be deeply aware of the importance of environmental issues and do our best to protect the environment in all of our business activities.

POSCO family members must always be aware of the fact that our actions are directly linked to our self-respect as well as corporate value and reputation. We pledge to comply with the Code of Conduct and to ensure that ethics and integrity are at the heart of our culture and business operations.

July 2024

1) All employees of POSCO and its subsidiaries

Code of Conduct

1. Compliance with basic ethics and relevant laws

We do not seek personal gain.

  • We do not put work-related pressure, issue instructions, or solicit favors that conflict with company interests in order to seek personal gain or undue gain for another person.
  • All company funds and assets must only be used for work-related purposes and cannot be used to promote personal interests in any manner.
  • We respect the political rights and preferences of individuals while maintaining the political neutrality of the workplace. We do not use company funds, personnel, facilities, etc. for political purposes.

We protect company information and assets.

  • We understand the importance of the company’s confidential information and intellectual property and keep them well protected.
  • We do not distort information or distribute false information.

We practice fair competition and trading.

  • We establish fair and transparent trading procedures in accordance with international standards and national fair trade laws. To maintain a fair trading system, we comply with domestic and foreign anti-corruption laws and standards including the UN Convention Against Corruption, the FCPA, the Act on Combating Bribery of Foreign Public Officials in International Business Transactions, and the Improper Solicitation and Graft Act.
  • We do not force business partners or suppliers to agree to unreasonable working conditions or engage in disadvantageous activities.

2. Developing a culture of trust and human respect

We foster a wholesome organizational culture.

  • We pursue both personal growth and company success by achieving a work-life balance.
  • Employees create an organizational atmosphere of mutual cooperation through open communication based on trust.

We provide equal opportunities.

  • We provide equal employment opportunities to all individuals with the required skills and qualifications.
  • We provide equal opportunities for skill development and self-improvement. Individuals are remunerated in an appropriate manner based on fair evaluations of their skills and achievements.
  • We foster a wholesome organizational atmosphere that celebrates employees who create meaningful outcomes regardless of their regional, academic, or other background.

We protect and respect human rights.

  • We support the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and other internationally recognized human rights standards. We endeavor to avoid infringing human rights in the process of conducting business activities.
  • We respect each employee as an individual. We do not engage in acts that may defame an employee or undermine human dignity such as verbal or physical abuse, bullying, and intimidation.
  • We ensure proper working conditions by maintaining reasonable working hours and ensuring that no work is performed involuntarily by emotional or physical force.
  • We do not discriminate against individuals on the grounds of ethnicity, nationality, gender, age, academic background, religion, regional background, disability, marital status, or sexual identity.

3. Realizing customer value

We commit to customer satisfaction.

  • We listen to and respect customer voice.
  • We welcome our customer’s valid requests and thoughtful suggestions, and prioritize to incorporate them to our business activities.

We create customer value.

  • We fulfill customer needs and expectations by providing the best products through technological advancement.
  • We respect our customer’s culture and customs.

We build customer trust.

  • Customer safety and well-being are given utmost consideration in our business activities. Products or services that may pose a threat to safety and health are not offered.
  • We protect customer information and provide customers with accurate and timely information.

4. Good faith towards investors

We fulfill our obligations to investors.

  • We strive to increase corporate value and shareholder value at the same time by creating profit through transparent decision making and efficient business activities.
  • We respect shareholder’s fair suggestions and endeavor to build mutual trust.

We communicate transparently with investors.

  • We provide key business information in a timely, fair, and faithful manner to facilitate investor decision making
  • Our financial information is calculated through suitable processes and controls based on accurate transaction figures. All financial documents are prepared in accordance with “Generally Accepted Accounting Principles.”

5. Co-prosperity with suppliers

We build mutual trust with suppliers.

  • We ensure fairness in our dealings with our suppliers through mutual respect and equal partnerships.
  • Vendors are required to demonstrate a sense of responsibility before they are chosen as a supplier. We support our suppliers to maintain compliance with laws and regulations associated with workplace safety, employee human rights, and fair trade.

We pursue co-prosperity with suppliers.

  • We seek mutual gains by sharing our outcomes with our suppliers.
  • We support our suppliers to provide high quality products and services through effective communication and mutual cooperation.
  • We aim to develop partnerships with our suppliers by providing fair opportunities and ensuring equitable terms of trade.

6. Social and environmental responsibility

We contribute to the development of the nation and society.

  • We strive to create and maintain stable jobs and to fulfill tax obligations.
  • We actively participate in volunteering, disaster relief, and other activities to serve the community. We contribute to the sound development of society through our pro bono involvement in such fields as culture, arts, sports, and academia.
  • We endeavor to build community trust in our company by providing support to improve the quality of life of local residents and strengthen the joys of life.

We commit to environmental protection and ecosystem conservation.

  • We are deeply aware of the importance of environmental issues. We comply with domestic and foreign environment-related laws and strive to improve the environmental impact at all stages of the product life cycle including development, production, and use.
  • We do our best to minimize pollutant emissions by introducing environmentally friendly production processes and by adopting the best available technologies to prevent environmental pollution.
  • We endeavor to restore natural ecosystems and conserve biodiversity by making efficient use of natural resources and byproducts.

Practice Guidelines

Chapter 1. General Provisions

Article 1 (Purpose)

The purpose of these Practice Guidelines is to provide a frame of reference for making decisions and taking action in ethical dilemma situations that may arise during the course of work so that POSCO employees understand and apply the Code of Ethics correctly.

Article 2 (Scope)

These Guidelines apply to the Company and all employees.

Article 3 (Principle of Application)

Employees shall make decisions and take action based on the Code of Ethics and these Practice Guidelines when faced with an ethical dilemma situation in relation to work.

However, if a frame of reference is not clearly prescribed herein, employees shall make decisions and take action according to the following decision-making principles. Employees who are not confident in their judgment shall consult the leader of the organization or the department in charge of ethical management and act accordingly.

  • Lawfulness: Is my action likely to be interpreted as a violation of the law, rules, regulations or company Codes?
  • Transparency: Can I disclose my decision-making process and the relevant details?
  • Rationality: Am I making the best possible choice for the company and individuals?

Chapter 2. The Code of Ethics in Practice

1. Restrictions on the provision and acceptance of valuables

  • “Valuables” means money (cash, gift certificates, vouchers, etc.), goods, and other articles that may bring about financial gain.
  • Valuables shall not be provided to or solicited or accepted from stakeholders1) for any reason.
    However, exceptions shall be made in the following circumstances:
    - Marketing or promotional gifts valued at or less than KRW 50,000 or up to KRW 150,000 for agricultural, marine, and processed goods (including ornamental plants)
    - Memorabilia bearing the company logo of a stakeholder and memorabilia routinely offered to attendees at stakeholder-organized events, not exceeding KRW 50,000
  • Employees shall not solicit or accept gifts from foreign entities during international business trips.
  • Valuables that are unanticipated and accepted due to unavoidable circumstances shall be returned, or if this is impracticable, report to the department in charge of ethical management.
  • Employees who earn income (e.g., lecture fees) from external speaking opportunities using his/her work-related knowledge or position at POSCO shall donate 50% of the earnings.
1) 1) Stakeholder: Employees or clients, suppliers, enterprises, business partners, domestic or foreign public institutions, and international organizations (including affiliated employees) that may directly or indirectly affect or be affected by rights and interests in relation to one’s duties

2. Principles and restrictions concerning hospitality

  • “Hospitality” means various activities that facilitate business-related gatherings and interactions, such as meals, social drinks, golf, performances, and entertainment.
  • Hospitality in excess of KRW 100,000 per person shall not be offered to or accepted from stakeholders. If it is necessary to offer or accept hospitality in excess of KRW 100,000 per person in relation to work, prior approval shall be obtained from the head of the department. Hospitality in excess of KRW 100,000 per person that has been offered or accepted due to unavoidable circumstances shall be reported to the department in charge of ethical management
  • Food worth up to KRW 30,000 per person may be provided to public officials, journalists, teachers, and other persons subject to the Improper Solicitation and Graft Act to facilitate work execution or for social, ceremonial, or other legitimate purposes
  • Hospitality at an entertainment and drinks venue that offers services of a sexual nature is prohibited regardless of cost.

3. Principles and restrictions concerning convenience

  • “Convenience” means benefits such as transportation, accommodation facilities, sightseeing, event support, etc. provided by or to a stakeholder.
  • The provision or acceptance of transportation, accommodation facilities, or other convenience beyond a generally acceptable level2) is prohibited. However, this shall not include conveniences routinely provided to all attendees at an event, etc
  • A convenience in excess of the permitted range that has been offered or accepted due to unavoidable circumstances shall be reported to the department in charge of ethical management.
2) “Generally acceptable level” means a level that satisfies the following requirements:
  1. The benefit is at an acceptable level based on reasonable common sense and social norms, is justifiable when disclosed, in no way affects the fair handling of affairs, and does not pose a burden on either party.
  2. The benefit is appropriate not only in terms of cost but also with respect to the location, purpose, method, count, frequency, timing, recipient, content, and social ethics and conventions (customs).
  3. There is no reciprocity regardless of amount.
  4. The benefit complies with the Improper Solicitation and Graft Act and other relevant domestic and foreign laws. In the event of a conflict in the interpretation of laws, the higher-order law shall take precedence.
  5. The generally acceptable level may vary depending on factors such as the exact circumstances, nature of the work, and job position.

4. Principles and restrictions concerning congratulatory and condolence money

  • Employees shall not notify stakeholders of their own family events or those of their colleagues. Informing a stakeholder through a third party shall be construed as a notification made by the employee concerned.
  • However, employees may inform each other of their family events. Use of the Company’s congratulations and condolences channel is advised. For the purpose of family event announcements, the scope of relatives shall be limited to immediate family members, namely the parents (or grandparents if the parents are already deceased) and children of employees and their spouses. Congratulations and condolence money between employees shall be at a generally acceptable level.
  • The maximum limit for congratulations or condolence money paid to an external stakeholder shall be KRW 100,000, including floral wreaths or arrangements. However, congratulations or condolence money paid to a person subject to the Improper Solicitation and Graft Act shall not exceed KRW 50,000, excluding floral wreaths or arrangements.
  • Congratulations and condolence money from external stakeholders shall not be accepted under any circumstance. Congratulations or condolence money that has been accepted due to unavoidable circumstances shall be returned or donated to the department in charge of ethical management.
  • Employees shall submit the relevant information, such as proof of return of congratulations or condolence money accepted from a stakeholder, when requested by the department in charge of ethical management.
  • Condolence flowers from stakeholders shall not be accepted, and those that are accepted due to unavoidable circumstances shall not be displayed.

5. Restrictions concerning solicitations and recommendations

  • Employees shall not make solicitations or recommendations through an internal acquaintance or an external party regarding the following. If an employee has received a solicitation or recommendation, he/she shall register it in the “Clean POSCO System.”
    - Requests for preferential treatment regarding various contracts, such as equipment/materials purchases
    - Requests for favorable and preferential treatment regarding personnel decisions such as hiring, promotions, rewards and punishments, and transfer of positions
    - Requests for excessive convenience, preferential treatment, etc. outside of usual procedures
    - Requests to neglect management and supervision tasks such as inspections and tests .
  • Employees shall not unlawfully solicit favors directly or through a third party in relation to duties subject to the Improper Solicitation and Graft Act.

6. Restrictions concerning monetary transactions

  • Employees shall not engage in cash loans, loan guarantees, name lending, or other monetary transactions with stakeholders.
  • An employee who has engaged in a monetary transaction with a stakeholder due to a personal connection shall report it to the department in charge of ethical management.

7. Restrictions concerning event sponsorship

  • Sponsorships from stakeholders shall not be accepted for events funded by the Company, such as department events or club activities.
  • The acceptance of vehicles, venues, services, or other conveniences required for an event shall be construed as acceptance of sponsorships.
  • A sponsorship that has been accepted due to unavoidable circumstances shall be reported to the department in charge of ethical management.

8. Principles concerning the use and protection of Company assets

  • The Company’s budget resources, such as meeting expenses and operating expenses, shall be used as intended by the budget and in accordance with legal requirements, and shall not be used for personal purposes.
  • As a general rule, business expenses shall be paid with a Company card.
  • In addition to the budget, all tangible and intangible assets, including Company supplies and facilities, shall be used for work-related purposes only. Ongoing efforts shall be made to protect assets by periodically reviewing asset classification and protection measures.
  • Employee information (telephone numbers, email addresses, etc.) is also considered Company assets and shall not be used for personal purposes.

9. Principles concerning information protection

  • Important or confidential Company information shall be strictly protected and controlled.
  • Important information shall be relayed to the intended recipient immediately upon recognition.
  • The falsification, concealment, or distortion of work-related information or the reporting or distribution of incorrect information shall be regarded as fabrication of information.
  • Employees shall manage internal Company information acquired during the course of work according to the security level, and shall not use the information for personal purposes.

10. Fair trade regulations and building mutual trust with suppliers

  • Employees shall comply with international standards and national laws and regulations concerning fair trade to ensure fair competition in domestic and international markets and refrain from engaging in unfair trade practices such as colluding with competitors regarding production, prices, bidding and market segmentation.
  • Employees shall fulfill their social responsibility by refraining from using a position of power against a client or supplier to make demands or unlawful requests.
  • Employees shall respect the rights and property of others, including intellectual property rights, and shall not infringe upon them to create business or generate profit.
  • The information acquired from a supplier shall be strictly protected as stipulated in relevant laws and regulations and contract terms.
  • Employees shall support suppliers to comply with laws and regulations concerning fair trade and ESG.

11. Principles concerning the prevention of conflicts of interest

  • “Conflict of interest” means a situation where a personal relationship with an employee of a supplier has an improper influence on an employee’s work performance.
  • Employees shall not engage in unfair trade practices such as signing unlawful private contracts, making high-price purchases, tunneling work, or leaking trade information to give preferential treatment to a certain individual or corporation.
  • Employees shall prevent conflicts of interest by strictly denying improper requests from a supplier’s employee with whom there is a personal connection, including former employees.
  • Employees shall not make unofficial contact with a supplier’s employee with whom there is a personal connection, and shall report any unintentional contact to the head of the department or the department in charge of ethical management.
  • Employees shall not attend gatherings of former employees without the Company’s approval.
  • Where an employee has a personal connection to a supplier’s employee, he/ she shall consult the head of the department or ethics officer and adjust his/her duties, etc. accordingly.
  • When the head of the department recognizes a work-related conflict of interest involving himself/herself or a staff member, he/she shall adjust the relevant duties or otherwise take action to avoid the conflict of interest. If it is impracticable to avoid the conflict of interest due to the nature of the work, he/she shall consult the department in charge of ethical management.
  • Retired employees shall also prevent conflicts of interest with POSCO and its business entities.

12. Developing an organizational culture of human respect

  • Employees shall not engage in verbal, physical, or visual behavior that may offend others, such as the use of profanities, verbal abuse, physical abuse, or sexual harassment that violates the human rights of an individual.
  • Violations of human respect may be subject to disciplinary action in accordance with the relevant regulations.
  • Employees shall respect each other’s privacy and shall not slander or undermine others or disclose personal information.
  • Employees shall comply with national labor laws and international standards, including working conditions for minors and minimum working age requirements.
  • Safety rules shall be strictly observed, and any risks identified shall be addressed appropriately.

Chapter 3. Reporting Unethical Conduct and Rewards and Sanctions

1. Reporting obligations and confidentiality

  • Employees who recognize the fact that he/she or someone else has violated the Code of Ethics or these Guidelines shall actively protect the Company and employees from unethical practices by reporting to or consulting the head of the department or the department in charge of ethical management as quickly and conveniently as possible. However, violations of human respect shall be reported to the department in charge of ethical management without delay.
  • Executives and department heads shall report to and consult the department in charge of ethical management immediately upon being informed of a violation of the Code of Ethics by a staff member, and shall not downplay or conceal the incident.
  • The department in charge of ethical management may conduct a fact check of the reported incident if necessary, and the employees concerned shall actively cooperate.
  • Employees shall not take adverse action against, or disclose the identity of, an informant or whistleblower.
  • Where it is likely that an informant or whistleblower may be subject to adverse action in terms of employment, a change of position or other personnel measures shall be taken if so desired by the informant.
  • If an employee becomes aware of the fact that an incident has been reported, either by chance or during the course of work, he/she shall keep it confidential or face disciplinary action.

2. Rewards and sanctions (disciplinary action)

  • The Company may award part of the clawback resulting from an ethical misconduct investigation to the informant as compensation in accordance with the relevant regulations.
  • The compensation criteria shall be in accordance with the guidelines on compensation and indemnity for informants of ethical misconduct and other relevant regulations.
  • The Company shall firmly reprimand employees who violate the Code of Ethics and Practice Guidelines in accordance with the relevant regulations.
  • The Company may restrict Company access and business to employees who have been dismissed after violating the Code of Ethics.

3. Reporting of violations and protection of informants

  • Employees who become aware of a violation of the Code of Ethics or these Practice Guidelines shall actively protect the Company and employees from the violation by reporting it to the head of the organization or department or the department in charge of ethical management for timely resolution.
  • Employees are not subject to any disadvantage for legitimate reporting.
  • The counseling and reporting channels are as follows.
    ※ Unethical counseling and reporting channels
    - Phone(only in Korean): 080 – 577 – 6262 (Ethical Dilemma Consultation)
    080 – 390 – 3366 (Non-ethics Reporting Center)
    - Online: POSCO Homepage > Contact Us >> Ethics dilemma counseling / Unethical reporting center
    -E-mail : ethics@posco.com

    ※ Consultation and reporting channels for violations of respect for human beings
    - Phone(only in Korean) : 080 – 390 – 8585
    - Online: Home page > Contact Us >> Consultation and reporting on bullying and sexual harassment in the workplace
    - E-mail : humanrights@posco.com

윤리원칙범 실천지침 전문

윤리 실천과 준법

글로벌 기업으로서 기본에 철저하고 원칙을 지키는 경영 활동을 통해 법과 윤리를 준수함으로써 윤리적 기업문화를 정착합니다.
포스코를 지원하거나 대리하는 직원 및 제3자는 FCPA 및 기타 해당 반부패 법률을 반드시 준수해야 합니다.
  1. 금품은 금전(현금, 상품권, 이용권 등), 물품 등 경제적 이익을 가져올 수 있는 것을 뜻합니다.
  2. 예외로 정한 사항을 제외하고는 어떠한 명목으로도 이해관계자1)에게 금품을 제공하거나 요구 또는 받아서는 안 됩니다.
  3. 해외출장 시 해외법인으로부터 선물을 요구 또는 받아서는 안 됩니다.
  4. 인지하지 못한 상태에서 불가피하게 금품을 받은 경우에는 반환하여야 하며 반환이 곤란한 경우에는 정도경영실에 신고하여야 합니다.
1) 이해관계자: 임직원, 고객사, 협력사/공급사, 지역사회, 주주/투자자 등
접대
  • 접대는 식사, 술자리, 골프, 공연, 오락 등 비즈니스로 인한 인적모임과 교류를 위해 이루어지는 다양한 활동을 뜻합니다.
  • 이해관계자와 인당 10만원을 초과하는 접대는 주고받을 수 없습니다. 업무와 관련하여 인당 10만원을 초과하는 접대를 주고받아야 하는 경우에는 사전에 부서장의 승인을 받아야 합니다. 불가피하게 10만원 을 초과하는 접대를 주고받은 경우에는 지체없이 정도경영실에 신고해야 합니다. 단, 공무원, 언론인, 교직원 등 청탁금지법 적용대상자에 대해서는 원활한 직무수행, 사교·의례 등 정당한 목적이 인정되는 경우에 한해 청탁금지법이 허용하는 범위 내에서 인당 3만원 이하의 음식물을 제공할 수 있습니다.
  • 금액에 관계없이 도우미가 있는 유흥주점에서의 접대는 금지합니다.
편의
  • 편의는 교통수단, 숙박시설, 관광, 행사지원 등의 수혜를 제공하거나 받는 것을 뜻합니다.
  • 통상적 수준을 초과하는 교통수단, 숙박시설 등의 편의를 주고받아서는 안 됩니다. 다만, 행사 등에서 모든 참석자에게 일반적으로 제공되는 편의는 제외합니다.
  • 불가피하게 허용된 범위를 초과하는 편의를 주고받은 경우에는 지체없이
경조금
  • 본인 또는 동료에게 발생한 경조사를 이해관계자에게 알려서는 안 되며, 제3자를 통해 알리는 것도 본인의 통지행위로 간주합니다.
  • 직원간 경조사 안내는 사내 경조사 게시란을 이용하고, 개별 사내메일 및 안내장(청첩장 및 부고장) 발송등에 의한 안내를 금합니다. 경조사 안내 시 친족의 범위는 직계가족인 직원 본인 및 배우자의 승중, 부모, 자녀로 제한합니다.
  • 임직원 간 경조금은 사회 관례상 통상적 수준인 5만원을 권장합니다.
  • 외부 이해관계자에게 경조금을 제공하는 경우 5만원 이내를 권장하되, 이를 대신하는 10만원 한도 내의 화환/조화는 허용합니다. 단, 청탁금지법 적용대상자에 대해서는 청탁금지법에 따릅니다.
  • 임직원은 정도경영실이 요구하는 경우 이해관계자로부터 받은 경조금의 반환실적 등 관련 자료를 제출하여야 합니다.
청탁/추천
  • 사내 지인 또는 외부인을 통해 다음 사항에 대한 청탁/추천을 하지 않으며, 청탁/추천을 받은 경우 회사의 ‘클린 포스코 시스템’에 등록하여야 합니다.
    • 설비/자재 구매 및 각종 계약에 대한 특혜 요청
    • 채용, 승진, 상벌, 보직 이동 등 각종 인사에 있어서 우대 및 특혜 요청
    • 통상적인 절차를 벗어난 과도한 편의, 특혜 제공 등 우대 요청
    • 점검 및 검수 등 관리, 감독 업무를 소홀히 하도록 요청
  • 청탁금지법에 열거된 대상 직무와 관련하여 직접 또는 제3자를 통하여 부정청탁을 해서는 안 됩니다.
금전 거래
  • 이해관계자와 금전대차, 대출보증, 부동산 임대차 등 금전거래를 해서는 안 됩니다.
  • 사적인 친분으로 이해관계자와 불가피하게 금전거래를 한 경우에는 정도경영실에 신고하여야 합니다.
행사 찬조
  • 부서 단위 행사 또는 동호인 활동 등 회사가 지원하는 행사 시 이해관계자로부터 찬조금품을 받아서는 안 됩니다.
  • 행사에 필요한 차량, 장소, 용역 등 편의를 제공받은 것도 찬조금품을 받은 것으로 간주합니다.
  • 불가피하게 행사 찬조를 받은 경우에는 정도경영실에 신고하여야 합니다.
예산 재원의 부당사용
  • 회의비, 업무추진비 등 회사의 예산 재원을 사적인 용도로 사용해서는 안 됩니다.
  • 경비 집행 시 법인카드 사용을 원칙으로 하며, 예산의 목적과 법이 정하는 기준에 맞게 사용하여야 합니다.
정보 및 자산의 보호
  • 회사의 비공개 정보나 중요한 정보를 철저히 보호하여야 합니다.
  • 중요한 정보는 인지하는 즉시 업무에 필요한 사람에게 전달합니다.
  • 정보를 왜곡하거나 허위사실을 유포하지 않습니다.
  • 회사의 비품, 시설 등을 회사업무와 직접 관련 없는 용도에 사용하지 않습니다.
  • 정보를 그 목적 또는 용도 이외의 부정한 방법으로 이용, 유출, 누설하지 않습니다.
  • 정보를 권한 없이 지득, 보관하게 된 경우 지체없이 폐기하는 등 관련 법령 및 내부 규정이 정하는 기준에 맞게 처리합니다.
공정거래
  • 국제기준 및 국가별 공정거래 관련 법규를 준수함으로써 경쟁사와 생산, 가격, 입찰, 시장 분할 등에 관한 담합 등 불공정거래 행위, 부당공동행위를 하지 않으며 시장에서 공정하게 경쟁합니다.
  • 우월적 지위를 이용하여 어떠한 형태의 대가나 부당한 요구를 고객과 거래회사에 하지 않습니다.
  • 지식재산권을 포함하여 타인의 권리와 재산을 존중하고 이를 침해해서 거래나 이득을 취하지 않습니다.
  • 경쟁사 정보를 포함한 기업 정보는 정당한 방법을 통해서만 취득하고 활용합니다.
이해충돌 방지
  • 이해충돌이란 임직원이 업무를 수행할 때 거래 관계사 임직원 등과 사적 이해관계가 관련되어 공정한 직무수행이 저해되거나 저해될 우려가 있는 경우를 뜻합니다.
  • 퇴직 임직원을 포함한 사적 이해관계가 있는 거래 관계사 임직원의 부적절한 요청사항은 철저히 배제하여 이해충돌을 방지합니다.
  • 회사의 승인을 받지 않은 퇴직 임직원 모임에는 참석하지 않습니다.
  • 퇴직 임직원 모임은 퇴임 후에 가입하고, 현재 가입된 경우 부서 상급자에게 보고 및 탈퇴합니다.
  • 사적 이해관계를 이유로 특정 개인, 법인 등을 우대하여 부당한 수의계약 체결, 고가 구매, 물량 몰아주기, 거래정보 사전유출 등의 불공정 거래를 하지 않습니다.
  • 퇴직 후에도 포스코 및 포스코 그룹사와의 이해 충돌을 방지합니다.

임직원의 일과 삶의 조화

일과 삶의 균형을 통해 개인의 성장과 회사의 발전을 추구하며 상호 존중하는 기업문화의 정착을 통해 행 복하게 일하는 일터를 조성합니다.
일과 삶의 균형 추구
  • 임직원의 생활 여건 안정에 도움이 되는 복리후생 제공 등을 통해 삶의 질 향상을 도모합니다.
  • 임직원이 개인의 비전을 달성하도록 지원하고 시간, 장소, 방법 등에서 유연하게 업무를 수행할 수 있도록 합니다.
교육과 성장의 기회 제공
  • 창의적으로 일할 수 있는 근로환경과 제도를 마련합니다.
  • 직원이 능력과 자질을 개발하여 최고의 역량을 지닌 인재가 될 수 있도록 역량향상과 자기개발 교육을 지원합니다.
공정한 평가 및 보상
  • 회사는 임직원 개인의 역량과 성과에 기반한 공정한 평가를 실시하고 이를 체계적으로 반영하여 적절한 보상이 이루어지도록 합니다.
건전한 조직문화 구성
  • 임직원은 열린 의사소통을 통해 개방적인 기업문화를 지향합니다.
  • 임직원은 조직 간의 벽을 없애고 상호 협력하는 조직 분위기를 조성합니다.

고객가치 창출과 신뢰확보 실천지침

고객의 신뢰와 성공이 우리의 미래임을 인식하여 고객의 의견을 항상 존중하고, 고객을 이해하며 고객의 발전에 도움이 되는 가치를 창출합니다.
고객만족 실현
  • 고객의 소리를 경청하고 존중하는 고객 중심의 업무를 수행합니다.
  • 고객의 정당한 요구와 합리적인 제안을 적극적으로 수용합니다.
고객가치 창출
  • 지속적인 기술개발을 통해 최상의 제품을 제공함으로써 고객의 니즈에 부응합니다.
  • 임직원은 국내외 시장현황을 파악하고 고객의 문화와 관습을 존중하는 서비스 마인드를 함양합니다.
고객신뢰 확보
  • 경영활동에서 고객의 안전과 건강을 충분히 고려하여 고객의 안전과 건강에 위협이 되는 제품과 서비스를 제공하지 않습니다.
  • 고객의 정보를 보호하며 정보보호에 관한 법규와 규정을 준수합니다.
  • 고객에게 정확한 정보를 적기에 제공합니다.

국가와 사회에 대한 공헌 (기업시민의 자세)

글로벌 기업시민으로서의 책임과 의무를 다함으로써 국가와 사회발전에 기여합니다.
기업시민으로서의
역할과 자세
  • 현지국의 법규와 규정, 지역사회 문화와 전통을 존중하고 국가사회와의 공동 발전을 위해 노력합니다.
  • 국가사회와 관련이 있는 경영활동 과정에서 이해관계자의 참여를 통해 의사소통할 수 있도록 노력합니다.
  • 거래회사가 국가사회 발전을 위한 활동에 참여하도록 노력합니다.
국가와 사회
발전에 기여
  • 회사는 안정적인 일자리 창출과 유지, 성실한 세금 납부를 통해 지역사회에서의 의무를 다합니다.
  • 자원봉사, 재난구호 등 사회봉사활동에 적극 참여하고 문화, 예술, 스포츠, 학문 등 각 분야에서의 공익활동을 전개합니다.
  • 지역주민의 삶의 질을 향상하고 행복한 삶을 누릴 수 있도록 지원합니다.

환경 보호와 생태계 보전

환경경영 체계를 구축하고 환경 리스크 대응 역량을 강화하며 열린 의사소통을 통해 친환경 경영을 수행합니다.
환경경영 체계 구축
  • 환경경영체계를 효과적으로 운영하여 환경경영 목표를 달성할 수 있도록 기업활동이 환경에 미치는 영향과 리스크를 평가하고, 환경경영 실적을 체계적으로 관리 분석합니다.
  • 다양한 이해관계자와 성과 및 이슈를 공유하고 환경보존 활동을 함께 수행합니다.
  • 거래회사와 환경보호가 기업의 기본적인 사회적 책무임에 대한 공감대를 형성하고, 환경보호에 관한 법규와 규정을 준수하도록 지원합니다.
  • 거래회사가 제품의 생산과 서비스의 제공에 있어 공공의 보건과 안전을 지키는 한편, 지역사회 환경과 천연자원에 미치는 부정적인 효과를 최소화하도록 지원합니다.
환경법규 준수,
환경영향개선
  • 환경법규를 준수하고 제품의 개발과 생산, 사용 등의 전 과정에서 환경영향 개선을 위해 노력합니다.
  • 친환경생산 공정 도입과 환경오염 방지 최적기술 적용으로 오염물질 배출을 최소화합니다.
기후변화 대응
  • 화석연·원료 사용량을 저감하고 에너지 효율 향상을 통해 온실가스 배출을 감축하기 위해 노력합니다.
  • 저탄소 혁신기술 개발을 통해 경쟁력을 강화합니다.
환경과 생태계 보호
  • 천연자원, 부산물 등을 효율적으로 활용하여 자연 생태계의 복원과 생물 다양성 보전을 위해 노력합니다.

인권의 보호와 존중

인권을 존중하고 관련 국제 기준을 지지하며 자유, 안전, 삶의 질적 향상을 통해 모든 이해관계자의 인간의 존엄성을 확립합니다.
인권 관련
국제기준의 존중
  • 세계인권선언, UN 기업과 인권에 관한 이행원칙, UN글로벌콤팩트 10대 원칙, OECD 다국적기업 가이드 라인, 국제노동기구(ILO) 핵심 협약 등 국제적으로 통용되는 인권 관련 국제기준을 존중하고 지지합니다.
  • 명확한 인권보호 정책과 체계를 확립하고 경영활동 과정에서 인권을 침해하지 않도록 노력합니다.
  • 거래회사가 인권 관련 국제기준에서 요구하는 인권규정을 준수하고 직원의 인권을 보호하며 공정하게 대우하도록 지원합니다.
인권존중을 위한
실사 의무
  • 인권을 침해하거나 불만을 초래하는 경영활동에 대해서는 필요시 실사를 실시할 수 있습니다.
  • 실사 결과 회사의 경영활동으로 인해 인권을 침해하거나 불만을 초래했다고 판단되는 경우에는 합리적 해결책을 모색합니다.
  • 인권과 관련된 활동 내용과 결과에 대해 관련 이해관계자들과 의사 소통합니다.
임직원 보호
  • 개인의 인권을 침해하는 성희롱 행위를 포함하여, 다른 사람에게 불쾌감을 주는 언어적, 육체적, 시각적 행동을 하지 않습니다.
  • 임직원 개개인의 사생활을 존중하며 타인에 대한 비방이나 음해 등을 하지 않으며, 개인 정보를 유출하지 않습니다.
  • 정신적, 육체적 강요에 의해 비자발적으로 수행되는 업무가 발생하지 않도록 합니다.
  • 미성년자의 노동조건과 최저 노동의 연령기준은 국가별 노동법과 국제기준을 준수합니다.
  • 안전수칙을 철저히 준수하고 발견된 위험 요소에 대해서는 적절한 조치를 취합니다.
존중과 평등
  • 인종, 국적, 성, 연령, 학벌, 종교, 지역, 장애, 결혼 여부, 성 정체성 등을 이유로 어떠한 차별이나 괴롭힘을 금지합니다.
  • 직무 자격 요건과 능력을 갖추고 있는 경우에는 고용에 있어 평등하게 기회를 제공합니다.
  • 다양한 문화적 차이를 존중하여 근로환경을 유지합니다.
적법한
고용조건 보장
  • 임직원이 제기한 인권 문제에 대해서는 회사의 고충처리 제도를 이용하여 신속하고 적극적으로 조치합니다.
  • 인간의 존엄을 유지할 수 있는 생활을 영위할 수 있도록 적정한 근로시간 유지 등 고용조건을 보장합니다.
지역사회의
인권 존중 노력
  • 회사의 경영활동으로 인하여 지역사회에서 인권을 침해당한 경우 의견을 수렴하고 인권 문제가 해결될 수 있도록 노력합니다.

Anti-corruption Compliance Guidelines

Chapter I. General Provisions

Article 1. Objective

POSCO seeks to observe the highest legal and ethical standards in conducting business in all areas around the world. The objective of these Anti-corruption Compliance Guidelines is to ensure that global anti-corruption laws and standards are being complied with by not only POSCO employees, but also POSCO Group companies, agents, and counterparties.

Chapter II. Procedures

Article 2. Global Anti-Corruption Standards

POSCO employees shall observe legal and ethical standards regarding global anti-corruption set out in the Foreign Corrupt Practices Act of 1977 (FCPA) (United States), the Bribery Act of 2010 (United Kingdom), the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Convention) and the UN Global Compact. The FCPA prohibits any company, US or non-US, listed on a national securities exchange in the United States from giving bribes to any non-US foreign government officials and requires the bookkeeping of accurate records and implementation of adequate internal controls. Considering that POSCO is listed on the New York Stock Exchange (NYSE), it must abide by the FCPA.
The Bribery Act prohibits UK companies and any non-UK entities doing business in the UK from giving bribes to any non-UK, foreign civil servants and business partners outside the UK. The OECD AntiBribery Convention is the first international convention to criminalize bribery to foreign government officials. In Korea, the Act on Combating Bribery of Foreign Public Officials in International Business Transactions was enacted and implemented to execute the OECD Convention. The UN Global Compact regulates all forms of corruption of corporate entities.
POSCO employees not only shall observe the global anti-corruption laws and standards but also the local anti-corruption laws and regulations of the countries where they do business. For instance, in the Korea, some of the local laws and regulations include the Criminal Code, the Act on the Aggravated Punishment of Specific Crimes, the Act on the Aggravated Punishment of Specific Economic Crimes, and Anti-Graft Act, among others. An act committed as a social or business customary practice, if in violation of the global anti-corruption laws and standards or local laws, will not be exempt. On the other hand, if there is a conflict or inconsistency between the global anti-corruption laws, standards, local laws and the Anti-Corruption Compliance Guidelines, the strictest standards shall prevail.

Article 3. Prohibition and Restrictions on Hospitality and Convenience

General principles
No POSCO employees shall provide or receive anything of value as convenience to or from any stakeholder, including foreign or local government officials, counterparts, with the intention of wrongdoing to obtain or retain any business benefits. In this regard, ‘anything of value' shall include, but is not limited to:
  • Securities, real estate, meals, gifts, golf
  • Expenses of transportation, accommodation, etc.
  • Any rights to use or receive discounts on products or services
  • Any political contributions
  • Any transfer or exemption of liabilities, employment, privileges, or any other tangible or intangible economic benefits
PROVIDED, HOWEVER, THAT it may be permitted to provide or receive a generally accepted hospitality or convenience if it is necessary to conduct the ordinary business for sales promotion, execution of a contract or promotion of mutual business understandings, etc., when the following conditions are met:
  • The level of business hospitality and convenience is reasonable and legitimate.
  • The business hospitality and convenience should not be offered frequently within a given time period.
  • Relevant expenditure details shall be accurately reflected in the Company's books and must comply with the Company’s internal regulations in relation to other procedures.
Meals, gifts, etc
When POSCO employees provide any meal or gift to a stakeholder as a gesture of goodwill or courtesy or to promote social relationship, they must comply with the following:
  • The meal or gift is provided only at necessary points of time with a clear cause and is not provided frequently within a given time period.
  • Matters concerning business hospitality, including meals, shall be subject to the Company’s Code of Ethics, and in the case of public officials who are subject to Anti-Graft Act, relevant laws must be followed.
Convenience
Whenever POSCO employees provide any convenience to a stakeholder, they must comply with the following.
  • Employees shall not provide or receive convenience such as transportation, accommodation, etc. beyond a generally accepted level, except where a convenience is provided generally and equally to all attendees of an event.
  • The convenience shall be of a reasonable level and shall be directly or indirectly related to sales promotion, demonstration or explanation, execution of a contract or performance of obligations thereunder, etc.
  • The convenience shall not provided to anyone other than the stakeholders themselves (friends, etc.)
  • Any costs incurred by the convenience should not paid to the stakeholders, but should be paid directly to the service providers, such as airlines and hotels.

Article 4. Prohibition and Restrictions on Express Fee

No POSCO officer and employee shall make any express fee to any domestic and foreign government officials to gain favor. Express fees are a relatively small amount, and is provided or intended to be provided to a government official who is involved in daily routine work, in order to expedite a legitimate business decision or other transaction, which may include:
  • Receipt and processing administrative documents, such as visa issuance
  • Customs clearance, and loading or unloading of products related to logistics, etc.
  • Opening a telephone line or providing supply of electricity or water

Article 5. Agents and Joint Ventures

Agents
An agent is a person who handles matters such as contract awarding, customs clearance, license approval, and tax affairs on behalf of a company. Global anti-corruption laws and standards such as the FCPA, prohibit an agent from making any payment of money or providing any valuables to a stakeholder, including foreign or local government officials, and counterparties on behalf of the company with a fraudulent intent. Therefore, while working with an agent, one should exercise their duties and responsibilities in a manner that ensures that there is no violation of any global anti-corruption laws and standards. Before signing a contract with an agent, the following should be considered: if any of the following applies, the final decision on whether to sign a contract with the agent shall be made based via Agent Contract Checklist.
  • Whether an agent has a past or present record of improper business practices (e.g., actual or alleged incidence of giving or receiving bribery or other corrupt practices)
  • Whether an agent is related to a former and current public official (e.g., recommendation of an agent by a public official, stake-holding by a public official)
  • Whether an agent requests an unusual or complicated method of payment (e.g., advance payment, third party payment)
  • Whether information provided by the agent is incomplete or inaccurate
When entering into a contract with an agent, the following must be expressed in the contract:
  • Agent’s roles and responsibilities in complying with the global anti-corruption laws and standards
  • Criteria for computing the agent's remuneration and method of payment
  • Right of the Company to terminate a contract with the agent in the event that the agent violates global anti-corruption laws and standards
  • Right of the Company to conduct an investigation where there is a reasonable concern that the agent may violate the global anti-corruption laws and standards. After executing a contract with an agent, POSCO employees will manage that the agent complies with the global anti-corruption laws and standards, and upon finding of a violation, shall report immediately to the Corporate Audit Office, so that the Company can take any appropriate measures, such as rectifying the violation or terminating the contract with the agent. On the other hand, whenever there is any question or concern with regard to the violation of global anti-corruption laws and standards in an agency contract, please contact the Corporate Audit Office.
Joint ventures Under the global anti-corruption laws and standards, such as the FCPA, joint venture companies or joint venture partners are prohibited from making any payment of money or providing anything of value with fraudulent intentions to any stakeholders, including but not limited to, domestic/foreign government officials and counterparties, and hence, the laws and regulations applicable to agents also apply to joint venture businesses.
Miscellaneous The Anti-Corruption Compliance Guidelines that apply to agents may be used vis-à-vis counterparties, including, but not limited to suppliers and customers, mutatis mutandis based on mutual understanding.

Article 6. Accounting Records and Management

Global anti-corruption laws and standards strictly stipulate that it is necessary to keep a system of accounting controls to record and monitor all business transactions in order to ensure that they are accurately recorded.
Therefore, POSCO employees shall keep and properly account for invoices, receipts, and other related payment documents that arise from the business, and any possession of expenditures or assets which is not listed in the books of the Company is strictly prohibited. In addition to maintaining the books and records, all businesses must be carried out as per the following via the Company’s internal accounting management system:
  • All transactional expenses and costs shall be executed only after approval by a person with proper authority.
  • All transactions shall be recorded as per the accounting standards and approved from a person with proper authority.
  • The Company’s assets shall be utilized only upon approval from a person with proper authority.
  • A due diligence on the Company’s assets will be conducted periodically.

Article 7. Anti-Corruption Compliance Training

POSCO employees shall implement and attend anti-corruption compliance training sessions under the guidance of the Corporate Audit Office, and submit records of attendance to the Corporate Audit Office.

Article 8. Whistleblowing and Protection for Whistleblowers

POSCO employees shall report to the Corporate Audit Office when they learn or have a reason to believe that any violation of the global anti-corruption laws and standards or the Anti-Corruption Compliance Guidelines has occurred.
The Company shall fully protect whistleblowers who report any violation of global anti-corruption laws and standards or the Anti-Corruption Compliance Guidelines to the Corporate Audit Office, and strictly prohibit disclosure of the whistleblower’s identity, and retaliation against or search for the whistleblower, and shall not subject the whistleblower to any type of disadvantages, such as in relation to the whistleblower’s employment relationships with POSCO.

Article 9. Reward and Punishment

POSCO may reward its employees who have contributed to achieving the objectives of the AntiCorruption Compliance Guidelines as per the relevant regulations of reward and punishment. POSCO may take disciplinary actions against its employees who violate the global anti-corruption laws and standards and the Anti-Corruption Compliance Guidelines as per the rules of employment and the rules of reward and punishment, and such disciplinary actions may include dismissal, suspension, salary reduction, reprimand, etc.
On the other hand, POSCO will not be responsible for any fine or cost, etc. if a civil or criminal penalty is imposed on its employees for violation of the global anti-corruption laws and standards.