The Corporate Audit Office reports key ethical management issues and outcomes to top management. To ensure independence, it also submits biannual reports on ethical management activities to the Audit Committee under the Board of Directors.

POSCO was the first Korean company to publish a Code of Conduct in 1993 and later formalized it as the Code of Ethics in 2003, placing ethics at the heart of its management philosophy. In 2024, we introduced a new ethical management system aimed at expanding the scope of ethics beyond individual behavior—fostering mutual empathy among all stakeholders, including employees, partners, and local communities—and cultivating an ethical culture befitting a global leader.

POSCO implements the following processes to integrate ethical management into the daily work and behavior of all executives and employees. These processes are designed to identify unethical conduct and proactively prevent its recurrence.

POSCO maintains 12 ethical management standards and policies—comprising five regulations and seven practice guidelines—including the Code of Ethics, Audit Committee Operating Regulations, and Internal Audit Guidelines. The Corporate Audit Office is responsible for managing these regulations and guidelines and conducting periodic reviews to ensure their adequacy.

POSCO promotes ethical awareness and practice by collecting annual ethics pledges from all executives and employees at each worksite and by providing regular training and awareness campaigns. Since 2024, we have additionally required an executive ethics pledge and have held Ethics Dialogues at least once a year, where each executive engages in open discussion with their team on ethical management.

POSCO provides both online and offline training programs to all executives and employees, across domestic and international sites.
“Understanding POSCO’s Ethical Management” is a mandatory e-learning course based on real-world counseling and audit cases, required for all executives and employees. We also run monthly ethical management campaigns that offer practical guidance on resolving ethical dilemmas and addressing workplace harassment. These materials are distributed throughout the Group. Upon request from customer-facing and procurement departments, we also deliver tailored training sessions based on actual unethical conduct cases to help reduce workplace risks. To support global operations, we share English-language campaign content with our overseas subsidiaries.

We regularly conduct ethics training sessions and surveys for employees to assess the level of ethical practices and proactively detect unethical behavior.

POSCO runs a reporting center where employees can report unethical behavior and human dignity violations. Our Corporate Audit Office handles unethical behavior reports, while the Human Rights Center manages reports concerning human respect violations. Both oversee the entire process, from receipt of a report to follow-up actions, and makes sure that every case is investigated. In 2023, we expanded our language input services from Korean and English to include Chinese, Spanish, Vietnamese, and Turkic languages. This expansion allows global employees in our overseas operations to submit reports in their native language.

Any stakeholder can seek consultation or submit reports. We strictly prohibit any actions that could reveal their identity during the consultation and reporting process. Furthermore, employees of the Internal Audit Department take the Auditor Security Pledge at the beginning of each year to ensure the identity of users is protected. The operating procedures for report investigation, including ensuring the confidentiality of reports, are set forth as guidelines in Chapter 3 of the Public Interest Whistleblower Protection Act, which is applicable to private companies (Guidelines for Rewarding and Providing Immunity for Reports on Unethical Behavior).

In addition, POSCO is fostering a transparent corporate culture by requiring employees to record and manage solicitations received from third parties in the Clean POSCO System.

In 2024, a total of 418 reports of unethical behavior were received and processed through the Reporting Center.

POSCO maintains a “zero tolerance” policy against the four major types of unethical behavior: bribery, embezzlement, sexual ethics violation, and information manipulation. Violations of our ethics code are met with appropriate punishment. We strictly prohibit any acts that could reveal the identity of whistleblowers and have established a clear framework for enforcing penalties. The Corporate Audit Office, our dedicated audit organization, requires its executives and employees to submit an Electronic Pledge to Protect the Identity of Whistleblowers at the start of each year.

POSCO supports the establishment of ethical management infrastructure to promote mutual growth with business partners and advance ESG practices among SMEs. Since 2020, we have assisted 32 companies in laying the groundwork for ethical management by helping them adopt ethical regulations and systems, establish unethical conduct reporting centers, conduct ethics education campaigns, and offer counseling on ethical dilemmas. Following these efforts, we re-assessed the ethical standards of our suppliers to evaluate progress and provided feedback to help them voluntarily develop and implement future improvement plans. We also work to prevent unethical risks and violations of respect for human dignity by helping small and/or newly-established subsidiaries build ethical management systems in alignment with our corporate philosophy of “doing the right thing in the right way.”