• ① We shall respect our customers' diverse opinions and will make efforts to create value for our customers.
• ② We shall make efforts to be able to provide the best products and services needed by our customers.
• ③ We shall protect our customers' assets and information at the same level with the assets and information of our company.

• ① We will do our best to raise the value of our stocks with faithful business operation through creativity and innovation.
• ② We shall respect a shareholder's legitimate request and proposal and share the business performance with our shareholders.
• ③ We shall comply with the laws and regulations and the principles related to business administration and shall maintain and provide financial condition and business performance transparently.

• ① The officers and employees shall thoroughly comply with the internal and external regulations and the applicable laws and regulations.
• ② The officers and employees shall respect each other and shall foster an atmosphere enabling them to work voluntarily and enthusiastically.
• ③ We shall make efforts to strengthen individual competitiveness and shall maintain our honor and dignity.

• ① We shall make efforts to provide the partner companies with equal opportunity and do business with them fairly so that we benefit from each other.
• ② We shall not make any wrongful request or receive any money and valuables or entertainment using our superior status.

• ① As a member of our community, we shall comply with the laws and regulations of our community and respect its tradition and culture.
• ② We shall contribute to the development of our society by actively participating in the corporate philanthropic activities suiting to the characteristics of the community.

The meanings of the terms used in this regulation are as follows:

• ① "Public officials, etc." refer to a public official or its related organization or group who has a direct or indirect interest in the management activities of the company, that falls under any of the following categories.
  • 1. A public servant pursuant to the National Civil Service Act or the Local Public Servants Act, and a person who has been recognized as a public servant in terms of qualifications, appointment, education and training, service, remuneration, and security of status in accordance with other laws thereof
  • 2. Public Institutions pursuant to the Article 3.2 of the Public Officials Ethics Act and the head of the institution and its officers and employees pursuant to the Article 4 of the Act on the Operation of Public Officials Related Organizations.
  • 3. Principals and faculty members of schools and executives and employees of educational corporations established in accordance with the Elementary and Secondary Education Act, the Higher Education Act, the Early Childhood Education Act, and other laws and regulations.
  • 4. Representatives and their executives and employees of media companies pursuant to Article 2, paragraph 12 of the Act on Media Arbitration and Relief for Damages.
  • 5. Spouses of public officials, etc.
  • 6. Foreign public officials, etc.
    • A. A person engaged in legislative, administrative, or judicial affairs of a foreign government.
    • B. A person who is delegated by a foreign government to carry out official duties.
    • C. A person who performs public functions in a foreign country and who is engaged in the work of a public body or public institution in accordance with laws and regulations in order to carry out official duties.
    • D. A person who performs public functions in a foreign country and who is an executive or an employee of companies in which the foreign government has invested more than half of the paid-up capital or exercise substantial control over the overall operations.
    • E. A person who performs the work of a public international organization.
  • 7. External organizations, corporations, associations, etc.
  • 8. NGO(Local Environmental Organizations), etc.
  • 9. Others equivalent to the above
• ② "Money and valuables, etc." refer to anything which falls under each of the following subparagraphs:
  • 1. All types property benefits such as money, marketable securities, real property, articles, hotel coupons, membership, admission tickets, discount coupons, invitation tickets, admission tickets and right to use real estate, etc.
  • 2. Provision of entertainment with foods, alcoholic drinks, gold, etc. or convenience such as transportation and lodging
  • 3. All other tangible or intangible economic benefits such as cancellation of debts, provision of employment, and provision of interest
• ③ The "Improper Solicitation Prohibition Act" refers to the Improper Solicitation and Graft Act.
• ④ "Specific Financial Information Act" means the Act on the Reporting and Use of Specific Financial Transaction Information.
• ⑤ “Money laundering” refers to the following acts as defined in Article2, No.5 of the Specific Financial Information Act.
  • 1. Criminal acts under Article 3 of the 「Act on the Regulation and Punishment, etc. of Concealment of Criminal Proceeds」
  • 2. Criminal acts under Article 7 of the 「Act on Special Cases Concerning the Prevention of Illegal Traffic in Narcotics」
  • 3. The purpose of committing a crime under Article 3 of the Punishment of Tax Offenders Act, Article 270 of the Customs Act, Article 102 of the Framework Act on Local Taxes, or Article 8 of the Act on the Aggravated Punishment of Specific Crimes, or tax payable in accordance with the Tax Act (“Local Tax”) Acts of disguising facts about the acquisition, disposition, or cause of occurrence of property or concealing the property for the purpose of evading local taxes under the Framework Act.
• ⑥ "Anti-money laundering system" is a system designed to detect and prevent illegal money laundering conducted domestically and internationally. As a legal and institutional device, it refers to a comprehensive management system that links the judicial system, financial system, and international cooperation.
• ⑦ "Department in charge of ethics" refers to the department to which the personnel in charge of ethical management of our company belong.

• ① The officers and employees shall not provide, promise or offer any type of money and valuables to any public officials and their spouses directly and indirectly regardless of whether or not related to the business or under any pretext such as donation, sponsorship or gift in principle.
• ② The officers and employees shall not provide public officials with any monetary compensation exceeding the limits specified by the Enforcement Decree of the Improper Solicitation and Graft Act as an honorarium for a lecture, presentation, or contribution related to his/her duties at a training course, promotional event, forum, seminar, public hearing, or any other meeting.

• ① Money and valuables, etc. of which the value is within the following scope, in the form of food and beverages, congratulatory or condolence money, gifts, etc. offered for purposes of facilitating performance of duties, social relationships, rituals, or aid
  • ① Foods
  • ② Congratulatory or condolence money (Contribution to wedding expenses or funeral expenses)
  • ③ Gifts
• ② The officers and employees should check whether the scope of provision allowed under other laws and regulations or standards is applicable and the procedure of provision in advance and they can ask about this to the department in charge of ethics.

• ① The officers and employees shall not gain improper interest or let another person gain improper interest using their position.
• ② The officers and employees shall not use or let others use the name of the company or their position for personal interest out of the scope of their job duties.
• ③ The officers and employees shall not receive money and valuables from a person related to his job duties.

• ① If an employee becomes aware of a violation or attempted violation of this regulation, he/she must immediately report it to the ethics department.
• ② The ethics department shall review the contents of the report to determine whether the report is in violation of the Anti-Graft Act, and if it is determined that the report is in violation of the Anti-Graft Act, it shall report it to the CEO.

• ① Executives and/or employees may be subject to disciplinary action in accordance with the Personnel Regulations if they violate relevant laws such as the Anti-Graft Act or this regulation, or if they do not take reasonable measures to prevent a violation after discovering it.
• ② In the event that an executive or employee is subject to a fine or a fine for violating related laws, such as the Anti-Graft Act, the company shall not be held liable on behalf of the executive and/or employee, and the employee may not be compensated for the fine, fine, or other damages from the company.

• (1) The officers and employees shall comply with the code of ethics and the laws and company rule related to the business activities.
• (2) The officers and employees shall assume their job duties with a clear understanding of their roles and shall be responsible for the results.
• (3) The officers and employees shall respect and be considerate to each other.
• (4) When an officer or employee or another officer or employee has violated or has been forced to violate the code of ethics, the pertinent officer in charge of ethical management shall report this to the affiliated department (henceforth referred to as "the department in charge of ethics") without delay.
• (5) The officers and employees shall act giving priority to the interests of the company and when the proprietary interest is put in conflict as prescribed in each of the following subparagraphs, they shall report this to the department in charge of ethics:
  • • An act by which an officer or employee concludes a contract or has a transaction with the company directly or through a third party
  • • An act intended to obtain a personal interest using the assets or information of the company for personal purpose
  • • An act exercising influence upon an officer or employee or a partner company such as requesting a special favor in personnel matter and provision of convenience
  • • An act giving or receiving money and valuables or entertainment between an officer or employee and a partner company
• (6) The officers and employees shall not engage in any of the following misconduct in the performance of their duties:
  • • offering, giving, receiving or soliciting, directly or indirectly, anything of value to influence improperly the actions of a public official or any person.
  • • any act or omission, including a misrepresentation, that intentionally or recklessly misleads, or attempts to mislead, any person or entity to obtain a financial or other benefit or to avoid an obligation.
  • • any arrangement between two or more parties designed to achieve an improper purpose such as, for example, by exchanging information of another participant in the procurement process or contract execution, or agreeing on the terms and conditions of the transaction such as price or production volume.
  • • impairing or harming, or threatening to impair or harm, directly or indirectly, any third party or the property of the third party to influence improperly the actions of any person or entity.
  • • An act of intentionally destroying, falsifying, altering, or concealing evidence important to the investigation or making false statements to investigators, and/or, threatening, harassing or intimidating a third party to prevent them from disclosing knowledge of matters related to the investigation or proceeding with the investigation, in order to significantly impede the investigation by the competent agencies regarding the above allegations of misconduct.

• (1) The management information and important information of the company shall be protected and they shall not be disclosed externally without a prior approval. The customers' information and the information related to a partner company shall be protected and the laws and regulations related to information protection shall be observed.
• (2) The assets of the company shall be protected and shall be used only for the designated purposes.
• (3) The intellectual property rights of the company such as patent rights, trademark rights and copyrights shall be protected actively.

• (1) When it is not clear whether this guideline has been violated or not while conducting one's job duties, the officer or employee shall take care of this after having a consultation with the department in charge of ethics.
• (2) When you get to know that an officer or employee of our company or a partner company has violated this guideline, you shall report this to the head of your department or the department in charge of ethics.
• (3) The head of the department in charge of ethics can recommend a disciplinary action against the pertinent officer or employee to the human resource committee.

• (1) The organizational unit in charge of the operation of the code of ethics and conduct and the practice guidelines shall be the department in charge of ethics.
• (2) The education for the officers and employees shall be conducted periodically and a disciplinary action can be taken against an employee who has committed an unethical act.
• (3) In the event that the occurrence or threat of violation of relevant laws and regulations or this guideline is suspected, the Company shall preserve all documents of the Company related to such violations, take measures not to destroy, alter, or conceal any such documents, and shall actively cooperate with the investigation by the authorities authorized to investigate such as the government.

• (1) The company shall not give any disadvantage in terms of position or any discrimination in working conditions due to such reasons as an informant's legitimate tip-off and related statement and submission of materials.
• (2) When an informant has been disadvantaged, the department in charge of ethics shall examine the matter and establish and implement a disciplinary action and a measure for the prevention of recurrence.
• (3) The person in charge of ethics shall keep the informant's identity and the information tipped off confidential so that they are not disclosed.

• (1) Reward

  A person who has contributed to the ethical business activities of the company, or if an informant’s tip-off or report is confirmed to be true, the CEO may pay compensation to the informant or take preferential measures in personnel management such as transfer or promotion. The level and procedure of reward shall be determined in accordance with the Personnel Regulations(R-60-GA-01) of the company.

• (2) Disciplinary action

  A person who has committed an act in violation of the code of ethics and conduct can be disciplined and the matters concerning disciplinary action including level of disciplinary action shall be determined in accordance with the related regulation of the company.

• 1. Sinmungo: https://www.lotteinnovate.com/cscenter/sinmungo
• 2. e-mail: innovate_ethics@lotte.net
• 3. Phone number: 02-2626-6699
• 4. Address: 179, Gasan digital 2-ro, Geumcheon-gu, Seoul, Republic of Korea (Department in charge of ethics)

• ① Code of ethics and conduct
• ② Integrity practice regulation