DONGSEO MECHATRONICS CO., LTD.

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ETHICS

Behavior guides for the code of ethics

1. Objectives

To secure the frame of voluntary compliance and the ethical decision making for employees with respect to the code of ethics, Dongseo Mechatronics hereby enacts the behavior guides for the code of ethics. Employees must perfectly abide by the behavior guides for the code of ethics regardless of in private or public life. The behavior guides for the code of ethics aim to define necessary items for decision making and behavior criteria and reporting procedures for ethical problems that employees are faced with in their daily life with relation to the fulfillment of the code of ethics.

2. Terminology

ㆍMoney : Cash, check and security, or gifts or souvenirs and so on.
ㆍService : Receipt of meals, drinks, sports or entertainment.
ㆍConvenience : Supports for transportation, accommodation, events and other non money or service related bribery.
ㆍReporter : A person who is responsible for reporting the fact of money receiving and so on.
ㆍManager : A person whos has the position to comprehensively manage employees of the department.
ㆍInterested party : It refers to corporate, group or natural person whose rights are affected by the decision making or action of employee directly related to the business.
ㆍSocially acceptable level : When an ordinary person with good common sense makes a decision, it should be acceptable. It is the level at which one can fairly process business without burdens. It is less than 50K won per person and even in special cases, no more than 100 K won per person.

3. Responsibilities and roles of employees

ㆍEvery employee must be fully familiar with the code of ethics and the behavior guides and comply with them fully.
ㆍfailure to comply with the code of ethics or the behavior guide is not exempted from the responsibilities even if you were not aware of it if there is a question or conflict of ethical issues, then ask the ethical management department and act according to the interpretation results.

4. Responsibilities and roles of managers

ㆍManagers must provide full supports and management to ensure that members and interested parties can correctly understand and fully comply with the code of ethics and the behavior guides.
ㆍThrough fair and clean decision making and actions, we will become the role models of code of ethics and behavior guides.

5. Awards and violation penalties

ㆍIf there is a person who contributed to achievement of the goals in the guide, the company can provide them with compensation or awards accordingly.
ㆍIf the guide is violated and their actions are subject to penalty according to the HR rules of the company, then their responsibilities will be asked.

6. Unethical activity report

Internal report
ㆍIf there is a person who contributed to achievement of the goals in the guide, the company can provide them with compensation or awards accordingly.
ㆍIf the guide is violated and their actions are subject to penalty according to the HR rules of the company, then their responsibilities will be asked.

Voluntary report
ㆍIf an employee participated in unethical actions against their wills or they regret the past wrongdoings and voluntarily report it to the ethical management department or manager then they can be exempted from the punishment.
ㆍIn case of voluntary reporting, the manager should notify the ethical management department.
ㆍThe company should maintain confidentiality of internal reports so that reporters are not subject to any kind of disadvantages.

External interested party report
ㆍIf externally interested party such as customer, affiliate and partner company reports unethical behaviors of the employee then it should be processed according to the internal reporting procedures and the results should be notified to the reporter.

7. Interpretation

ㆍStandards for reporting unethical actions such as bribery from interested parties and rewarding reporters should be separately defined.
ㆍStandards for reporting unethical actions such as bribery from interested parties and rewarding reporters should be separately defined.

8. Degradation of customer values

Cases

ㆍFailure to keep the promises to customers
ㆍSales of products by deceiving customers
ㆍActions to ignore fair requests or opinions of customers

Behavior guides
ㆍEmployees must set the first priority in keeping the promises to customers. - If not possible to keep it, then get consent from them ahead of time.
ㆍDo not show false or exaggerated ads to customers.
ㆍAlways accept fair requests or opinions of customers.
ㆍIf there is customer complaint, then apologize politely and resolve it immediately. ㆍTo quickly respond to customer's requests, always have the professional and accurate knowledge about your business.

9. Leakage of customer information

Cases

ㆍAcquisition or leakage of customer information without going through a fair process
ㆍAbandonment or private use of customer information

Behavior guides
ㆍCustomer’s personal information, trade information and so on should never be leaked to others except for those allowed by the laws and regulations.
ㆍWithout consent from the customer, do not provide or send it to others vis tel, fax email and so on.
ㆍEmployees should never accept requests for leaking customer information through personal relations.
ㆍMust prepare perfect protection measures against every customer information according to the laws, company rules and regulations.
ㆍDo not use others name/password to access the company DB in efforts to steal the customer information.
ㆍDo not leave the document with customer information unattended for a long time on the desk or leave the PC with customer information on for a long time. Do not let other easily see the personal information.
ㆍDo not make backup copies of papers, disks containing customer information when not needed.

10. Money, gift, service received

Cases

ㆍReceiving money, gift or service from customers
ㆍUnauthorized use of customer property

Behavior guides
ㆍDo not receive money, gift or service directly or indirectly from customers or encourage or ignore it.
ㆍIf the above request is received, then turn it down politely.
ㆍBut if case of exception is made for souvenirs such as gifts with company logos of the client distributed at the client’s event.
ㆍIf received without recognition, it should be immediately returned.

11. Financial transactions

Cases

ㆍSuperior asking form loans or loan guarantee to subordinates by taking advantages of their positions
ㆍSubordinates giving money to their superiors when they go on business trip or transfer to other departments
ㆍAct of providing excessive condolence or gift money for other employee’s events.

Behavior guides
ㆍregardless of whether interests are received, financial transactions among employees are prohibited.
ㆍEmployees are never allowed provide guarantees for loans.
ㆍBut simple award plate or gift acceptable according to the social norm can be allowed.
ㆍCondolence or anniversary money exchanged between employees should be based on free wills. According to the mutual help foundation, the amount should be acceptable as accepted by the social norm.

12. Sexual harassment

Cases

ㆍActions to make others feel sexual embarrassment, disgust or fear and so on.
ㆍSexual eyesight, condemn, joke, obscenity, physical contact and so on

Behavior guides
ㆍDo not make others feel sexually embarrassment, disgust, fear or cause sexual eyesight, condemn, obscenity, or physical contact.
ㆍDo not ask other colleagues to dance or pour drinks at the group dining out and so on.
ㆍDo not comment on other’s physicals or make analogy.
ㆍAvoid unnecessary physical contacts and do not use language that emphasizes fixation of roles of each sex(because you are a woman and man)
ㆍRespect other’s will expression to reject sexual harassment

13. Embezzlement and misuse of company funds

Cases

ㆍTemporary use or acquisition of profits or company funds ㆍUse of corporate card for private use.

Behavior guides
ㆍPrivate use of profits or company funds is always prohibited regardless of amount or reasons.
ㆍProfits and public funds must be managed in a company bank account.
ㆍProfits should be declared as profits immediately and expenditures should be accompanied with evidence perfectly.
ㆍDo not falsely demand company budget for your private use.
ㆍDo not buy private items and services by using corporate cards, company's security stocks and so on.
ㆍConsidering excessive amount or losses to the company, it is possible to file a criminal lawsuit.
ㆍMisuse is assumed to be embezzlement until it is fully restored.
ㆍIn case of disciplinary actions, it is excluded from deduction.

14. Private use and damage of company property

Cases

ㆍIllegal external discharge or private use of company products(service) fixed asset, items and consumables.
ㆍDoing personal stuff during the official business hours
ㆍA transfer or lending of company property to yourself or third parties without going through the standard procedures
ㆍAction to cause damages to the company property.

Behavior guides
ㆍThe company property must be used for public purposes of the company only.
ㆍClarify the usage and scope of purchase for ads materials(promotion) and do not use them for private purposes.
ㆍIf you obtain some times for free during your trade relations, then register it in ‘Clean-365 center’ so that that can be used for the community’s poor people and so on.
ㆍExcept for when needed for the business, do not access the harmful site or non business site from the company PC.
ㆍDo not engage in activities such as chatting, stock trade, gambling, illegal video distribution which are not relevant to the job.
ㆍBusiness hours are managed as the company property and it should never be used for hobbies, religious activities and other personal stuff.
ㆍIf unavoidable, then you must get approval from the department manager.
ㆍWhen you transfer, or lend the company property to the outside, the follow the procedures. ㆍHandle the company property carefully.

15. Leakage of company information

Cases

ㆍAction to leak the company information such as business plans, management information and so on.
ㆍAction to leak the data that can damage the company reputation or cause losses of profits.

Behavior guides
ㆍCompany information such as long term business plans, product development and sales strategies should never be leaked to the outside. If it happens, it is assumed as a serious attempt to damage the company.
ㆍDo not every hurt the company reputation or degrade the organization culture by distributing rumors, false information and so on.
ㆍThe company information should be used for the approved goals only and not for the private purposes.
ㆍMaterials sent to external organization such as news media, academic and so on should be approved by the department manager.
ㆍAfter the retirement, do not leak the company information to a third party or use it for private purposes.
ㆍEvery data should be managed according to the internal security rules.

16. Duplicate jobs or positions

Cases

ㆍHaving a position at another company at the same time.
ㆍDoig other company jobs at the same time without approval from the company.

Behavior guides
ㆍDo not hold a position at other company at the same time. Do not work for other company at the same time.
ㆍBut it is possible if pre approval is received from the company.
ㆍEmployee cannot have another job without consent from the company.
ㆍDraw a clear line between private and public matters so do not engage in activities that conflicts with the interest of the company.