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.

    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.