Code of Ethics
Management based on
ethics and trust
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1.0 Overview1.1 Purpose of the Code of EthicsThis Code of Ethics sets forth ethical standards that employees of GnCenergy (hereinafter the "Company") shall observe, which serve as standards for behavioral norms and value judgments for all employees in their work performance and daily lives.1.1.1The Company pursues a "corporate culture of trust based on ethical standards" as its highest corporate value. All executives and employees shall uphold this corporate value with pride and responsibility as members of the Company to elevate their own character and establish trust in the Company.1.1.2All executives and employees shall recognize the dignity and responsibility required as members of the Company not only in official duties but also in their personal lives, and shall conduct themselves accordingly.1.1.3The following is the core code of the ethics required by the company:(a) Think honestly(b) Be warm-hearted(c) Judge fairly(d) Act sincerely(e) Keep a peaceful conscience1.2 Definitions of Terms1.2.1 Personnel CommitteeThe Personnel Committee shall consist of the Chief Executive Officer, responsible executives, and the Head of the Human Resources Team.1.2.2 CopyrightCopyright refers to the exclusive and proprietary rights to creative works that express human thoughts or emotions.1.2.3 E-CommunicationsE-Communications refers to the creation, reception, storage, viewing, transmission, or downloading of messages, information, and data in electronic form, including email, voicemail, fax, internet/intranet/extranet systems, telephone, video transmission, and file transmission.1.2.4 Conflict of InterestA conflict of interest refers to the conflict between the private interests of an individual employee and the interests pursued by the duties assigned to that individual1.2.5 Public Relations and BroadcastingAs the department responsible for media relations, public relations, and broadcast media-related affairs, the Planning Manager of the Planning and Management Division currently performs these duties.1.2.6 AuditAn audit refers to a special investigation conducted on related companies or participants when there is concern that executives or employees of the Company or other companies involved in the Company’s business may be in violation of applicable laws or regulations.
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2.0 Basic Ethics and Procedures
2.1 Responsibilities of Executives and Employees
2.1.1 Preventive Measures
2.1.1.1
All executives and employees shall comply with the laws of the Republic of Korea and the applicable local laws in accordance with their employment conditions, and shall perform their duties in compliance with this Code of Ethics and the Company’s internal regulations.
2.1.1.2
Each individual is responsible for understanding and becoming familiar with this Code, and all executives and employees shall make efforts to do so. Failure to recognize or understand the Code shall not exempt any individual from responsibility.
2.1.1.3
Executives and employees shall advise one another on violations of the code of ethics and help correct or improve them. When they find it difficult to make a judgment on their own, they shall immediately consult or report to their supervisor or the Head of the HR Team.
2.1.1.4
If an ethical issue not specified in this Code arises, it shall be resolved through consultation with the relevant team leader, department head, executive officer, or the Head of the Human Resources Team.
2.1.2 Violations and Enforcement
Any executive or employee who violates the law or fails to comply with this Code of Ethics and internal regulations shall be subject to disciplinary action, including dismissal.
2.1.3 Reporting Violations
All executives and employees shall report to their department head or the Head of the HR Team any employees who violate or are likely to violate these Regulations and Company Policy, including negligence in duty, illegal acts, misconduct, or misappropriation of Company assets.
2.1.4 General Ethical Standards
The standards described in this Code satisfy the following general ethical principles:
(a) Compliance with laws and regulations
(b) Honesty and trustworthiness
(c) Personal development and improvement of quality of life
(d) Enhancement of the interests of the Company and its customers
(e) Responsibility
(f) Accuracy
(g) Respect for the authority and dignity of internal and external parties
(h) Protection of confidential Company and customer information
(i) Avoidance of actual or potential conflicts of interest
(j) Prohibition on using Company assets or information for personal gain
(k) Prohibition of inappropriate conduct that may damage the Company’s reputation
2.2 Responsibilities of the Company
2.2.1
The Company is responsible for distributing this Code internally so that all executives and employees may become familiar with it.
2.2.2
Team Leaders and Department Heads shall regularly review these Regulations with their subordinate employees to ensure that these regulations are continuously implemented.
2.2.3
Managers, including department heads and executives, shall periodically supervise whether the operations of their departments are being conducted in compliance with this Code.
2.2.4
Department heads and executives shall create a work environment in which open communication can take place freely.
2.2.5
Department Heads and Executives shall be responsible for their scope of supervision among the Company's responsibilities.
2.3 Personnel Committee
2.3.1
The Personnel Committee shall provide advice upon request from other departments or individual executives and employees.
2.3.2
The Head of the Human Resources Team shall be responsible for reporting on the ethics program to the Personnel Committee, including violations of the Code of Ethics by executives and employees and the outcomes thereof.
2.3.3
The Personnel Committee shall supervise the ongoing compliance with this Code through a continuous management system and shall carry out follow-up measures, including revisions to related regulations.
2.3.4
The Personnel Committee shall plan and implement training and education programs for executives and employees to ensure compliance with this Code, and shall report regularly (once a year) to the Chief Executive Officer.
2.3.5
The Personnel Committee shall become involved in problem-solving upon the instruction of the Chief Executive Officer or at the request of executives and employees.
2.3.6
The Personnel Committee shall investigate violations through private interviews with the employee concerned and shall instruct all related parties to maintain confidentiality regarding the matter.
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3.0 Detailed Standards
3.1 Obligation of Accurate Records
3.1.1
Executives and employees shall provide accurate and truthful records and reports, including work hours, work details, expenses, work-related materials, and other work-related activities.
3.1.2
Company records shall be audited, and accounting records shall be managed in accordance with generally accepted accounting principles.
3.1.3
The act of altering or intentionally omitting information from records, or creating or reporting information that misleads the facts, is not allowed.
3.2 Confidential and Proprietary Information
3.2.1
All executives and employees shall maintain the confidentiality of all tangible and intangible assets, including confidential and proprietary information of customers and business partners.
3.2.2
Confidential and proprietary materials shall not be disclosed or revealed without prior written approval in accordance with internal regulations.
3.2.3
Executives and employees shall store and protect information under their responsibility and shall not access, use, or delete unauthorized materials.
3.2.4
Business-related information shall not be used for the benefit of executives and employees personally or for the benefit of related third parties.
3.2.5
Employees intending to resign shall not copy or possess any books or materials containing the Company’s confidential or proprietary information for any reason.
Violation of this provision may result in civil and criminal liability.
3.3 Copyright
3.3.1
Copyrights for documents, programs, articles, architecture-related works, and any other works of any form created during employment belong to the Company, and shall not be republished, distributed, or published without the Company's permission.
3.4 Use of Software
3.4.1
Software used by the Company either belongs to the Company or is copyrighted by other specialized companies, and its use is restricted under license agreements; therefore, the software shall not be copied or distributed without authorization.
3.4.2
Software purchased by the Company shall not be installed or used on personal computers except where permitted under the software license.
3.5 Electronic Communications
3.5.1
The Company’s communication network is installed to facilitate business communication within the Company or with external third parties related to business, to support the professional development of employees through the provision of prompt and accurate information, and to improve business efficiency.
3.5.2
Electronic systems and communications are Company-owned assets.
3.5.3 The Company prohibits the following uses of the e-communication system:
3.5.3.1
Using communication systems to intentionally provoke dissatisfaction or maliciously receive, store, review, solicit, transmit, or download information.
3.5.3.2
Engaging in acts that infringe upon or attack others based on gender, race, religion, nationality, physical or mental disability, skin color, age, or sexual orientation.
3.5.3.3
Using communication systems to send personal attacks, defamatory or contemptuous messages, or to announce unauthorized Company positions.
3.5.3.4
Using communication systems in violation of another person’s trademark, copyright, or proprietary rights.
3.5.3.5
Unauthorized use or misappropriation of confidential information belonging to the Company or others.
3.5.3.6
Using electronic communication systems for purposes contrary to the Company’s interests, causing conflicts of interest, or for unrelated personal purposes.
3.5.3.7
Using communication systems to directly or indirectly participate in or engage in gambling activities.
3.5.3.8 Misuse of E-mail and Voicemail
(a) Accessing, recording, copying, distributing, or listening to another person’s e-mail or voicemail without authorization
(b) Sending junk mail, defamatory messages, chain letters, prank messages, or advertisements
3.5.3.9
Unauthorized access to another person’s mail, files, passwords, or electronic information, or disclosure of related information.
3.5.4 Use of the Internet
3.5.4.1 Basic Guidelines
(a) All executives and employees shall not use the internet or PCs for personal purposes during working hours.
(b) Personal use is permitted before or after working hours and during lunch breaks or other non-working hours.
3.5.4.2 Business Use of the Internet
(a) Business use of groupware and related systems
(b) Searching technical data and information for business purposes
(c) Reserving or purchasing goods and services for business purposes
(d) Providing services to clients
(e) Accessing the Company’s official website
(f) Communicating with external parties to maintain business relationships
(g) Checking personal e-mail within a limited scope
(h) Viewing internet news and major events within a limited scope
(i) Reviewing economic trends and work-related information
3.5.4.3 Personal Use of PCs/Internet
(a) Chatting unrelated to work
(b) Playing games
(c) Using PCs or the internet for personal asset management, events, entertainment, private reservations, or purchases
(d) Responding to e-mails related to humor, games, quizzes, or surveys
3.5.4.4 Prohibited Activities
(a) Participation in political propaganda
(b) Side businesses for personal profit
(c) Accessing illegal or obscene websites under domestic law
(d) Responding to the media without prior approval from the public relations and broadcasting department
(e) Excessive transmission or downloading of data that interferes with business operations or security
3.6 Rules During Working Hours
3.6.1 Prohibited Conduct During Working Hours
(a) Violating the Company dress code
(b) Inappropriate language or behavior
(c) Disturbing or harassing others
(d) Unauthorized tardiness or early departure
(e) Failure to report leave, sick leave, or emergencies
(f) Leaving the work area without approval
(g) Bringing outsiders into the workplace without approval
(h) Smoking outside designated smoking areas
(i) Reading newspapers or magazines unrelated to work
(j) Excessive personal phone calls
(k) Frequent or excessive smoking
(l) Interrupting work for personal errands
(m) Excessive private socializing among employees
(n) Sleeping during working hours
3.6.2 The following behaviors or acts are always prohibited regardless of working hours.
(a) Sharing illegal or obscene information
(b) Entering or working while intoxicated
(c) Failure to comply with safety rules, guidelines, and procedures
Violations of the above provisions may result in disciplinary action under the relevant provisions of the Code of Ethics.
3.7 Conflict of Interest
3.7.1
The Company trusts that employees faithfully fulfill their responsibilities to the Company.
3.7.2
This Code provides general standards to prevent conflicts between employees’ official responsibilities and personal interests.
3.7.3
Anyone who has doubts about the standards shall first discuss them with their team leader.
3.7.4 The following are situations that may involve conflict of interests. To present such a situation, employees shall consult with their department head or HR manager in advance.
(a) Performing duties related to one’s own interests or those of relatives
(b) Receiving money, entertainment, or benefits from business partners or contractors
(c) Engaging in external activities conflicting with Company interests
(d) Receiving gifts, entertainment, or rebates
(e) Engaging in personal activities or secondary employment during working hours
(f) Using business-acquired information for personal gain
(g) Transferring or lending Company assets or leased property
(h) Selling or purchasing Company goods outside approved procedures
3.8 Acceptance of Money, Gifts, and Entertainment
3.8.1
All executives and employees are prohibited from receiving money, gifts, or entertainment from entities that currently have, compete for, or seek future business relationships with the Company.
3.8.2 Provision of Gifts and Entertainment
3.8.2.1
The Company’s customer value is based on providing high-quality products, competitive pricing, and excellent services.
3.8.2.2
Therefore, obtaining profit by providing gifts, entertainment, conveniences, etc. (hereinafter "entertainment") is not the Company’s policy, and prior approval shall be obtained from the Business Manager for entertainment.
3.8.2.3
Any related questions shall be directed to the Head of the relevant Department or the Head of the HR Team.
3.8.3 Acceptance of Money and Entertainment
3.8.3.1
Receiving money, gifts, or entertainment directly or indirectly from individuals or organizations that may influence business decisions is prohibited.
3.8.3.2 Exceptions
(a) Meals and beverages provided at a customary level
(b) Small promotional items such as pens or calendars
(c) Prohibition of unauthorized lodging or travel expenses
3.9 Employment Policies
3.9.1 Equal Employment Opportunity
3.9.1.1
Equal employment opportunities shall be provided based on individual ability regardless of race, skin color, religion, gender, sexual orientation, nationality, age, or physical or mental disability.
3.9.1.2
The equal employment opportunity policy applies to all employment policies, including recruitment, promotion, assignment, training, compensation, retirement, and welfare benefits.
3.9.2 Abuse
To provide employees with a work environment free from unfair abuse, the Company shall prohibit any form of abuse and take appropriate disciplinary action against employees who violate this regulation.
3.10 Audits
3.10.1
All executives and employees shall cooperate with internal and external audits determined by the Company.
3.10.2
Audited parties shall actively cooperate with investigations and provide relevant materials.
3.10.3
The Personnel Committee may conduct audits periodically or as needed and shall report the results to top management.
3.11 Right of Investigation
3.11.1
The Company may conduct investigations and take legal action against executives and employees who interfere with or harm Company operations.
3.11.2
The above provisions shall also apply to the theft of the Company’s property, including intellectual property rights, or theft of the property of employees or visitors, as well as acts of possessing illegal or harmful items such as narcotics, alcohol, or firearms.
3.12 Public Media
3.12.1
The Company shall respond to media, broadcasting, and public relations outlets in accordance with company policies and ethical standards. The head of the management department shall obtain approval from the CEO to respond to relevant media, and contact, announcements, and replies to the media shall be made through the head of the management department.
3.12.2
Any employee who receives an interview request from public media or a request for a statement or response from media personnel shall immediately notify the head of the management department through the head of the relevant department.
3.13 Discipline and Penalties
3.13.1
All executives and employees shall familiarize themselves with the standards set forth in these regulations.
3.13.2
Appropriate disciplinary measures shall be taken against employees who violate these regulations.
3.13.3
The Personnel Committee or the Head of the Human Resources Team may immediately initiate or delegate an investigation upon discovering or receiving a report of a violation.
3.13.4
Based on statements of violation by the accused and relevant parties, disciplinary measures shall be determined according to the severity of the violation. The HR Committee has the final authority and responsibility for interpreting and applying these Regulations in specific situations where issues arise.
3.13.5 Types of Disciplinary Actions
(a) Dismissal
(b) Referral for criminal or civil litigation
(c) Compensation for damages
(d) Demotion
(e) Suspension
(f) Salary reduction
(g) Reprimand