POSCO INDONESIA

POSCO GROUP

Company

Ethics Standards

Preamble

This code of ethics establishes the ethical values and behavioral standards that must be preserved and developed by all POSCO Group employees by inheriting the foundational spirit of patriotism in steelmaking based on sacrifice and service while reflecting the new spirit of the times.

It is our unchanging value to establish a corporate image that can be trusted by all stakeholders with the highly prioritized value criteria of integrity, fairness, and honesty.

As a result, POSCO enacted the code of ethics in 2003 that must be adhered to by all employees, and explicitly included US Human Rights that proclaims support and respect for human life and dignity in 2014. At this time, POSCO has amended the code of ethics with tighter ethical standards according to the intent of management innovation that places the highest value on ethics in management.

This code of ethics consists of the preamble, followed by the principles of ethics that reflect compliance and responsibilities of employees regarding the code of ethics, and uphold guidelines that set the standard for ethical decision-making.

All employees of POSCO Group must strictly comply with the principles of ethics and uphold the guidelines set forth by this code of ethics in all aspects of business.

This is how we all can proudly preserve the credibility of POSCO as we know it today, built on the blood, sweat, and tears of our founding members.

Principles of Ethics

Duty of Compliance with the Code of Ethics

Role and Responsibility of Employees

Penalty for Violation of the Code of Ethics

Duty of Compliance with the Code of Ethics
  • We must comply with related rules and regulations in all areas of the world where POSCO is conducting business operations.
  • We must retain our dignity as POSCO employees and make efforts to maintain the company's reputation.
  • We must preserve integrity, fairness, and trust throughout all jobs and business relations.
  • We must not become engaged in activities in which there are conflicts of interests between the company and individuals.
  • We must not irrationally discriminate against other employees or stakeholders based on race, nationality, gender, age, educational background, religion, region, disability, marital status, and sexual orientation, and must respect the dignity and diversity of each individual.
  • We must make efforts to create a safe workplace and protect the environment.
  • We must be devoted to establishing an ethical culture by taking responsibility and upholding ethical conduct.
Role and Responsibility of Employees

Employees must understand and uphold all aspects of the code of ethics, and comply with domestic and international laws regarding anti-corruption as members of a global company.

  • Understanding and Complying with the Code of Ethics.
    • We must fully understand and faithfully comply with all aspects of the code of ethics.
    • Regarding situations in which there are conflicts concerning the code of ethics, decisions must be made after consulting with the department head or the Ethics Management Office.
    • We must take responsibility for unethical conduct.
  • Reporting and Consulting Unethical Conduct
    • If we find out that our own or others' behavior conflicts with the code of ethics, we must immediately report to and consult with the department head or the Righteous Management Office.
    • We must be aware of various methods to report or consult on cases in which there are conflicts over the code of ethics.
Role and Responsibility of the Leader

The leader must perform a key role in ensuring the competitiveness of the company by preventing and eradicating unethical conduct through ethical compliance.

  • Decision-making
    • The leader has the obligation to make decisions with ethics being the top priority whenever the company's benefits conflict with ethics.
  • Operational accountability
    • The leader possesses unlimited liability in unethical conduct, and must take supervisory responsibility in cases of unethical conduct by his or her subordinates.
  • Job performance
    • The leader strictly abides by the law and company regulations, and does not pursue private interests, is devoted to creating corporate values, and does not deal with corrupt stakeholders.
  • Elimination of favors and solicitations
    • The leader aims to eliminate all forms of favors and solicitations, and to eliminate business influence in relation to outsiders.
  • Respect for humans
    • The leader strives to eliminate conduct that negatively impacts respect for fellow humans, such as sexual harassment and verbal abuse in the organization.
  • Preventing Conflicts of Interest
    • I will prevent conflicts of interest with any private interested party who is working for a trading partner and make an effort to eradicate unfair business practices of providing business favors for my private interests.
  • Practical activities
    • I will make my utmost effort to play a role in raising the level of ethical practice to the highest level in the world by fulfilling the above roles and responsibilities.

The leader must prevent unethical conduct among members of the team and take the following measures in case of such conduct.

  • Training and counseling on ethics
    • The leader must provide training and counseling on ethics for relevant staff.
    • The leader must have relevant staff understand the importance of compliance with the code of conduct and practice of ethical conduct.
  • Precautions for unethical conduct
    • In cases where unethical conduct occurs habitually, the leader must isolate the cause, improve the process, and fundamentally take preventive measures.
    • The leader must report to or consult with the Righteous Management Office immediately after receiving a report that a member has violated the code of ethics.
Penalty for Violation of the Code of Ethics

Employees violating the code of ethics may receive certain penalties, including dismissal according to related regulations. In particular, the zero tolerance policy is applied to unethical conduct such as accepting bribes*, embezzlement*, fabrication of information*, and violation of sexual ethics*.

Conduct Subject to Penalty

  • If one has violated the code of ethics or demanded others to do so
  • If one has not immediately reported a violation of the code of ethics that he or she is aware of or is skeptical about
  • If one does not cooperate with the investigation of the Righteous Management Office regarding matters that may have violated the code of ethics
  • If one takes retaliatory action against other employees who reported an issue regarding ethical management
  • *Accepting bribes : Receiving money or valuables beyond social norms from stakeholders
  • *Embezzlement : Misappropriating corporate funds or assets illegally
  • *Fabrication of information : Falsification, concealment and dissemination of business information
  • *Violation of sexual ethics : Committing acts of sexual humiliation via sexual harassment or sexual assaults