POSCO’s Legal Affairs Office is led by the Fair Trade Compliance Officer, who is appointed by the Board of Directors and regularly reports to the Board on the operation of the Fair Trade Compliance Program(CP). To enhance the effectiveness of our Fair Trade compliance framework, we operate the Compliance Council, comprising department heads from functions closely related to fair trade, as well as the Fair Trade Practice Leader system, which provides working-level support for the CP.

The Fair Trade Compliance Program (CP) is an internal compliance system that companies establish and operate on a voluntary basis to ensure adherence to fair trade laws and regulations. Since 2002, POSCO has operated the CP to proactively prevent violations of fair trade regulations by equipping executives and employees with clear standards of conduct, while also reinforcing corporate transparency.

Since adopting the Fair Trade Compliance Program (CP) in 2002, POSCO has established a Fair Trade compliance framework centered on prevention, detection, and response to effectively manage compliance risks. In line with the Korea Fair Trade Commission(KFTC) guidelines, we have implemented the eight core elements of the CP and established the Compliance Council, both of which are actively operated as part of our compliance management system.

POSCO publishes the Fair Trade Compliance Guidebook to support executives and employees in complying with fair trade laws and regulations. We regularly update the Guidebook to reflect the latest legal developments and offer a mobile application and e-book version to enhance accessibility.

POSCO conducts risk assessments for potential legal violations through the Fair Trade Self-Inspection Checklist, led by relevant operating departments. POSCO also operates the Compliance Council, which comprises department heads from functions related to fair trade. In addition, POSCO designates Fair Trade Practice Leader for each department to support the operation of the Fair Trade Compliance Program.

POSCO has established and operates a tailored fair trade training system for its domestic and overseas subsidiaries, delivering training through both online and offline channels. We conduct regular and ad hoc group training sessions tailored to key business functions, including sales and procurement, as well as to employees at different levels and roles. In addition, we operate an ongoing e-learning program. Furthermore, we provide compliance guidance to overseas subsidiaries and proactively prevent fair trade risks that may arise in the course of global business operations.

POSCO systematically identifies, assesses, and manages fair trade risks in accordance with its Compliance Control Standards and Fair Trade Compliance Program (CP) Operating Guidelines. Key risks are identified through periodic compliance reviews and risk assessments, and in high-risk areas, corrective and preventive measures are proactively implemented along with targeted training and compliance monitoring.

The effectiveness of the CP is also regularly evaluated using indicators such as employee awareness and the effectiveness of preventive measures. The results are reflected in the following year's action plan, supporting the continuous management of fair trade risks.

POSCO maintains the Fair Trade Counseling and Reporting Center on an ongoing basis to offer consultation on fair trade issues and to receive reports of suspected unfair trade practices. The reporting channel is open to all individuals, and all reports are handled with strict confidentiality.