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Sustainability Management (ESG)

Compliance Report

Purpose of Reporting Operation

In order to enhance business transparency and establish an ethical corporate culture, the Company receives reports on corruption related to external stakeholders such as accounts, taking unfair advantage or causing losses to the Company.

Corruption Type subject to Reporting

  • Acceptance of money or entertainment, and financial transactions
  • Preferential treatment of and equity investment in accounts
  • Embezzlement of public money, theft, and seeking personal profit
  • Sideline/side job and gambling
  • Act of leaking the information and manpower of the Company
  • Other cases (corruption, insolvency, violation of internal accounting management regulations, etc.)

Whistleblower Protection Regulations

Article 1 (Purpose)
This regulationaims to set forth the matters necessary to protect whistleblowers inside the Company to efficiently carry out ethical management of Seondo Electric Co., Ltd. (hereinafter referred to as the “Company”).
Article 2 (Corruption)
Corruption that is subject to reporting refers to any act that violates the Company's ethical management guidelines.
Article 3 (Employees and the Management)
Employees who can be the subject or subject to reporting refer to all members of the Company, and the management includes the CEO and internal accounting manager of the Company, as well as executives who have been delegated responsibility and authority. However, if the auditor is involved in the actual business of the Company, he/she is regarded as the management.
Article 4 (Receipt of Report)
When any employee becomes aware of the corrupt act stipulated in Article 2, the employee may report it to the Ethical Management Committee (hereinafter referred to as the “Committee”).
Article 5 (Corruption by theManagement)
In the event that employees are aware of corrupt practices of the management of the Company, or are coerced or proposed to commit corrupt acts while performing their duties, they must report it to the Committee without any delay.
Article 6 (Reporter's Duty of Good Faith)
If the reporter knew or could have known that the contents of the report were false, he/she is not protected by this regulation.
Article 7 (Reporting Method)
A person who wishes to report corruption shall write in a written document stating the reporter's personal information and the purpose and reason for the report, and present the subject of the report and evidence of the corruption.
Article 8 (Anonymous Report)
①With respect to the reported matters received, the Committee may confirm the following matters against the reporter.
1.Matters necessary for specifying the contents of the report, such as the personal information of the reporter and the purpose of the report
2.Matters concerning whether the contents of the report were false or whether there was a violation of Article 5 of this regulation
②The Committee may request the reporter to submit necessary data to the extent necessary to verify the authenticity of the matters in Paragraph 1.
③The Committee may request an investigative agency to investigate on the reported matters received if necessary.
④If there is a need for an investigation for criminal punishment and prosecution for a corruption act reported to the Committee, it shall be reported to the prosecution in the name of the Committee.
Article 9 (Guarantee of Status)
①Anyone who makes a report pursuant to this regulation or submits a statement or other data related thereto shall not be subjected to any disadvantage in status or discrimination in working conditions for matters other than the act attributable to the reporter.
②If anyone has suffered or is expected to suffer disadvantages in status or discrimination in terms of working conditions because of reporting, he/she may request the Committee to take measures to guarantee his or her status, such as restoration of the disadvantageous disposition to the original state, job transfer, suspension of disciplinary action, and other necessary measures.
③If anyone suffers economic or administrative disadvantages, such as cancellation of licensing etc., or cancellation of contract due to reporting, he/she may request the Committee to take necessary measures, such as temporarily remaining in effect of licensing, contract, etc., for restoration or correction.
④If there is a request under Paragraph 2 or 3, the Committee shall initiate an investigation.
⑤The Committee may conduct an investigation pursuant to Paragraph 4 in the following ways:
1.Demand to appear and hear statements or submit statements to the requester or reference witness;
2.Request for submission of data deemed related to the investigation to the requester, reference witness, or external related company, etc.;
3.Inquiry of facts or information recognized as relevant to the investigation to the requester, reference witness, or external related company, etc.; or
4.A person who receives requests, inquiries, and measures under each subparagraph of Paragraph 5 shall faithfully respond to them.
⑥As a result of the investigation, when the report is recognized as valid, the Committee shall reflect it according to the punishment provisions of the personnel management regulations.
Article 10 (Personal Protection, etc.)
①The Committee shall not reveal the identity of the reporter to others without the consent of the reporter, nor conduct an act of implying it.
②The reporter may request the Committee to take personal protection measures if there is concern about the safety of himself/herself, his/her relatives or a third party unrelated to the report due to reporting. In this case, the Committee shall hold a meeting related to the request for personal protection measures to find an appropriate method.
Article 11 (Liability Reduction and Reward)
①If a report is made pursuant to this regulation, and the related corruption of a reporter is discovered, the punishment of the reporter can be reduced or exempted.
②If the contents of the report are serious and significantly bring property benefits to the Company, prevent losses, or promote the public interest of the Company as a whole, a reward may be recommended to the person who made the report according to the Company's internal award regulations.
③If a report is made in accordance with this regulation, it shall not be regarded as a violation of the obligation to observe confidentiality.
④Any reporter of a corruption act may apply to the Committee for payment of compensation when reporting under this regulation directly results in the recovery or increase of the Company's income or the cost reduction of the Company, or when the relevant legal relationship is established. In this case, compensation includes expenses incurred in restoring the case to its original condition for the disadvantageous disposition.
However, compensation may be reduced or not paid for matters that are naturally reported in relation to his/her duties.
⑤The application for compensation pursuant to Paragraph 4 shall be made within six months from the date on which it is known that the legal relationship regarding the recovery of the Company's income or the cost reduction of the Company has been established.
⑥The Committee may form a separate Compensation Deliberation Committee to discuss the said compensation, if necessary.
Article 12 (Decision on Payment of Compensation, etc.)
①When there is an application for payment of compensation pursuant to Article 11 (4), the Committee shall decide whether or not to pay and the amount to be paid within 90 days from the date of application unless there is a special reason.
②When the decision to pay the compensation pursuant to Paragraph 1 is made, the Committee shall immediately notify the applicant of it. The same shall apply even if the decision to pay compensation is dismissed.
Article 13 (Disclosure of Whistleblower Protection System)
The Whistleblower Protection Regulation shall be perused through public notice and circulation so that all employees of the Company may be familiar with them, and keep them in the Company.
Article 14 (Change of the Regulation)
If there is a reason for change in this regulation, the Committee shall change it through a separate meeting and report it to the board of directors.
Article 15 (Commencement of Effect)
This regulation shall take effect from xx yy, 20zz.
Article 16 (Retroactive Effect)
A person who makes a report pursuant to this regulation may also report matters prior to the commencement date of this regulation.