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Ethics and Compliance Standards

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Hyundai Engineering System of Norms for Ethics and Compliance

Hyundai Engineering ethical standards
Ethical standards
Ethics charter (7 articles)
Declaratory basic ethical policies
Code of conduct (6 chapters, 20 articles)
Criteria for practical value judgment
Guidelines(20 articles)
Specific guidelines for ethical behavior

   *Rules of Basic Business Ethics, Rules of compliance with Anti-corruption Laws, and so on

Charter of Ethics and Compliance

  • 01

    We shall perform work responsibly based on honesty and good faith, and shall establish the organizational culture of mutual respect and trust.

  • 02

    We shall improve the value of the corporation through transparent and efficient management, and shall strive to maximize the shareholders’ interests.

  • 03

    We shall comply with domestic and foreign laws for prevention of corruption, and shall neither improperly solicit any public officials, interested parties, and etc. nor provide any financial benefits, such as money, goods, and etc.

  • 04

    We shall regard customer satisfaction as the highest priority, and shall provide the goods and services of the highest quality as desired by the customers.

  • 05

    We shall establish fair and transparent trading order with the partner companies, and shall strengthen the partnership to pursue mutual growth.

  • 06

    We shall respect competitors, comply with commercial laws and customs, and pursue fair and free competition.

  • 07

    We shall strive for sustainable development as an environmentally friendly corporation, and shall contribute to the preservation of the earth and the prosperity of the human race.

  • 08

    We shall fulfill the corporate social responsibility by complying with laws and contributing to the state and the public interest of the society.

Code of Ethics and Compliance

  • Hyundai Engineering Company (HEC) shall establish the system of norms for ethics and compliance to implement the globalization-oriented values of “customer first,” bold implementation, communication and cooperation, and respect for talent based on the philosophy to create a new future through ingenious thinking and continuously pioneering new frontiers, realizing the dream of the human race.


    The system of norms for ethics and compliance shall apply to all the business areas in which HEC operates. Based on the system of norms for ethics and compliance, HEC shall become a socially responsible corporation that practices sustainable management based on value-based management, safety and environment management, talent management, partnership management, and community commitment, increasing the happiness of the human race, and a global engineering company, creating future with the best technology.


    All the officers and employees at all the business sites of HEC shall respect ethics and laws, and shall comply with the Code of Ethics and Compliance (the “Code”) which is established to practice the management that serves in the role of a corporation and social responsibility. Further, such officers and employees shall communicate the Code to the officers and employees of the partner companies, and shall encourage the officers and employees of the partner companies to comply with the Code.

  • [ Article 1 General principles ]

    1. The officers and employees shall share the company’s management ideology, objectives, and core values, and shall establish ethical corporate culture through value judgment in accordance with the principles of lawfulness, transparency, and fairness.

    2. The officers and employees shall provide guidelines and continuous education for strengthening the ethical awareness based on which a sound and transparent corporate management culture may be established in the company.

    [ Article 2 Contribution to state and society ]

    1. The officers and employees shall strive to create jobs continuously and pay taxes honestly, thereby contributing to the development of the state’s economy.

    2. The officers and employees shall have an interest in the local and environmental issues the society faces, and shall take the lead in the campaigns and various community service activities to resolve such issues.

    [ Article 3 Protection of shareholders’ interests ]

    1. The officers and employees shall maintain sound financial structure by continuously discovering sources of growth and operating the business portfolio in a balanced manner, thereby advancing the shareholders’ interests and values of such interests.

    2. The officers and employees shall strengthen internal management and risk management, and shall quickly provide to the shareholders transparent management information, thereby establishing relationships based on mutual trust.

    [ Article 4 Customer satisfaction ]

    1. The officers and employees shall always listen to the voice of the customers and actively embrace the customers’ justified demands and rational suggestions for the customers’ satisfaction.

    2. The officers and employees shall provide the products and services of the highest quality that meet the customers’ needs.

    [ Article 5 Talent development ]

    1. The officers and employees shall respect and support the basic human rights, and the right to pursuit of happiness, of each officer and employee.

    2. The officers and employees shall establish the environment for health and safety of the officers and employees, and shall execute creative training appropriate for the job responsibilities and aptitude, thereby enabling promotion of self-realization and growth of value.

    [ Article 6 Mutual growth ]

    1. The officers and employees shall promote co-existence with the partner companies, and shall nurture and support the partner companies.

    2. The officers and employees shall provide equal opportunities to all the partner companies, select the partner companies in accordance with objective procedures, and aim for fair transactions with the partner companies.

    [ Article 7 Corporate culture ]

    1. For establishing the corporate culture for mutual respect and of goodwill, the officers and employees shall not engage in discriminatory and inappropriate words or actions.

    2. The officers and employees shall maintain political impartiality in terms of work, thereby ensuring separation of business and state.

    3. The officers and employees shall perform work honestly and transparently, and shall not engage in any acts that are in conflict with the interests of the company.

    4. For fair performance of work, the officers and employees shall not engage in any acts that may influence the work, such as the financial transactions with the interested persons, dealing in securities, equity investment, business operation, and etc.

  • [ Article 8 General principles ]

    1. The officers and employees shall comply with domestic and foreign laws, as well as internationally recognized declarations, conventions, covenants, treaties, and etc.

    2. The officers and employees shall comply with the laws relating to construction, such as the Framework Act on the Construction Industry, the Occupational Safety and Health Act, the Fair Transactions in Subcontracting Act, and etc., thereby promoting solid advancement of the domestic construction industry.

    3. The officers and employees shall comply with the manuals, rules, guidelines, regulations, and etc. as set forth by the company with relations to the performance of work.

    [ Article 9 Prevention of corruption ]

    1. The officers and employees in performing work shall not improperly solicit (or receive solicitation) or provide (or receive), promise, or declare intent with relations to money, goods, entertainment, or other tangible or intangible economic benefits (“money, goods, and etc.”) to public officials or interested persons (or from interested persons) for any reasons.

    2. In case of performing work in association with third parties or in case the third parties perform work by the delegation of the company, the officers and employees shall pay sufficient attention to ensure that the third parties do not violate domestic and foreign anti-corruption laws, conventions, and etc.

    [ Article 10 Fair trade ]

    1. The acts that may harm fair competition, such as unfair trade practices, abuse of the market-controlling position, improper internal transactions, improper collective actions, and etc., shall be eradicated, thereby complying with the free-market economic order.

    2. The officers and employees shall respect the competitors, and shall not take profit from the acts of unfair competition against the competitors.

    3. The officers and employees shall not engage in the improper acts of indication and advertising that may deceive or mislead consumers.

    [ Article 11 Partner companies ]

    1. The officers and employees shall not engage in unfair transactions and improper acts that are based on the advantageous position, thereby strengthening the partnership with the partner companies for mutual development.

    2. The officers and employees shall not engage in the acts that improperly use, or disclose, the information and technology of the partner companies, thereby causing damage on the sales activities of the partner companies.

    [ Article 12 Work environment ]

    1. The company shall set forth the standards for the lawful working conditions, thereby ensuring and improving the basic life of the officers and employees.

    2. The company shall establish solid labor relations based on mutual trust and smooth communication.

    [ Article 13 Accounting management ]

    1. The financial records and accounting books relating to the management activities of the company shall be transparently and accurately recorded and managed in accordance with the Commercial Act, tax laws, Act on External Audit of Stock Companies, international financial reporting standards, and etc.

    2. The budget, funds, and expenses (the “budget”) shall be rationally fixed in accordance with the set objectives and standards. Further, they shall be efficiently executed through fair and transparent procedures in accordance with the set rules.

    3. In case of incurring expenses of the company, the expenses shall be honestly evidenced and stored in accordance with the relevant facts.

    4. As set forth by the laws, the important information in terms of the management of the company and the company information shall be publicly disclosed in good faith.

    [ Article 14 Information security ]

    1. The information in terms of the technology and management of the company, and other equivalent information, (the “important information”) shall be managed as trade secrets. The officers and employees shall strive towards maintaining security.

    2. The officers and employees shall not engage in any acts, such as using, or disclosing to the third parties, the important information of the company acquired directly and indirectly through the performance of work, without prior approval during or after the employment.

    3. In case of lecturing on and disclosing at the lectures or seminars outside the company, or providing to other organizations, the internal information of the company, the officers and employees shall obtain approval through the official procedure.

    [ Article 15 Customer information ]

    1. The purpose of processing the customer information shall be made clear, and the minimum customer information within the scope that is necessary for such purpose shall be lawfully and properly collected.

    2. The customer information shall be processed and used as fit within the scope that is necessary for the purpose of processing the customer information.

    3. The customer information shall be safely protected and managed in view of the possibility that the right of the subject of the information would be infringed and the level of risk.

    [ Article 16 Safety, health, and environment ]

    1. The safety, health, and environment standards that meet the international standards shall be established, and the voluntary inspection system shall be maintained. The risk on business and environmental impact shall be identified in advance for removing the risk factors.

    2. The management system to improve the achievement in safety, health, and environment shall be established and implemented, and shall be periodically reviewed and improved for preventing accidents.

    [ Article 17 Quality assurance ]

    1. The highest quality and service the customers demand shall be provided through continuous research and development.

    2. The quality management system shall be established and implemented for providing the products and services that meet the standards of the International Organization for Standardization.

  • [ Article 18 System of norms ]

    1. The Charter of Ethics and Compliance (the “Charter”), Code of Ethics and Compliance, and Rules of Ethics and Compliance shall collectively be called the system of norms for ethics and compliance.

    2. The Code, as the principle realizing the declaration of the Charter, shall stipulate the rights and obligations of the officers and employees on ethics and compliance.

    3. The internal rules containing the provisions on compliance shall be called the Rules of Ethics and Compliance (the “Rules”), and the specific standards of conduct relating to the provisions of the Code shall follow the Rules of Ethics and Compliance under Annex 1.

    [ Article 19 Interpretation, establishment, and amendment of norms ]

    1. In case of conflicts between, or lack of clarity in the interpretation of, the Code and the Rules, the relevant laws shall govern. In case the relevant laws are insufficient, the court precedents, administrative agencies’ decisions, and interpretation by the Compliance Team shall govern in the respective order.

    2. The Rules are administered by each of the relevant divisions as set forth under Annex 1. The relevant divisions shall consult with the Compliance Team in case of establishing or amending the Rules for systematic and uniform operation of the system of norms for ethics and compliance.

    3. The Compliance Team may present opinions, or recommend corrections, relating to ethics and compliance to the above-mentioned divisions.

    [ Article 20 Operation of organization ]

    1. The Compliance Team shall be established under the Legal Affairs Office to construct the company-wide organization system that can actually put into practice ethics and compliance. Each department shall appoint a “Compliance Manager,” and each team, site, and branch shall appoint a “Compliance Staff.”

    2. The Compliance Team shall establish, as well as generally implement and manage, the overall policies that are necessary for voluntary compliance activities on ethics and compliance.

    3. The Compliance Team, Compliance Manager, and Compliance Staff shall hold regular meetings every quarter to check the current status of ethics and compliance at the company and to discuss the plan for improvement.

    [ Article 21 Covenant to practice ]

    All officers and employees shall sign the Covenant to Practice Ethics and Compliance under Annex 2 as a declaration to become familiar with the Code and put it into practice.

    [ Article 22 Reporting procedure ]
    1. 1. The officers or employees who violate this Code or Rules, or identify the violation of another, shall immediately report through the following channel.
      1. a. Offline channel: Audit Office or Compliance Team
      2. b. Online channel: Cyber Audit Office (https://audit.hec.co.kr/)
      3. c. Phone: 02-2134-1299 (Audit Office) or 02-2134-1760 (Compliance Team)
      4. d. Fax: 02-2038-6443 (Audit Office) or 02-2038-6447 (Compliance Team)
      5. e. Mail: Audit Office or Compliance Team, 75, Yulgok-ro, Jongno-gu, Seoul
    2. 2. The Audit Office shall notify the reporting person the result of the report submitted through the above channel.
    3. 3. All the information, such as the personal information of the reporting person, reported information, and result of processing the report, shall be strictly protected, and the reporting person shall not suffer any disadvantage from the report.
    [ Article 23 Discipline and reward procedure ]

    1. The officers or employees who violate the Code, abet and aid the third parties, or fail to act while being aware of such violation may be subject to discipline pursuant to the internal rules.

    2. The officers or employees who comply with the Code in performing work and contribute to the company’s ethics and compliance activities may be rewarded.

    3. In case the act of the person who violated the Code caused tangible or intangible damage to the company, such person may assume civil or criminal liability pursuant to the laws separately from the disciplinary measures of the company.

  • [ 1. Effective date ]
    The Code shall be effective from September 1, 2017.
    [ 2. Interim measures ]
    As for the violations of the Code that occurred prior to the effective date, the Code of Practice and Guidelines on Conduct shall govern.
  • Code of Ethics and Compliance Rules of Ethics and Compliance
    Article 7 Corporate culture Rules of Basic Business Ethics
    Article 9 Prevention of corruption Rules of Compliance with Anti-corruption Laws
    Article 10 Fair trade Operating Rules of Voluntary Fair Trade Compliance Program
    Article 11 Partner companies Four Action Items for Compliance with Subcontractor Laws
    Rules of Subcontractor Management (Domestic)
    Rules of Subcontractor Management (International)
    Rules of Subcontractor Management (Engineering)
    Rules of Partner Company Management
    Article 14 Information security Information Protection Business Manual
    Rules of Information Security Management
    Article 15 Customer information Rules of Personal Information Management
    Article 16 Safety, health, and environment Safety and Health Business Manual Rules of Safety and Health Management
    Environment Business Manual Rules of Environment Management
    Article 17 Quality assurance Quality Business Manual Rules of Quality Standards and Objectives Management
  • HEC Covenant to Practice Ethics and Compliance


    I sufficiently read and have become familiar with the company’s Charter of Ethics and Compliance and Code of Ethics and Compliance. I commit to actively participate in ethical management and legal compliance as sought by the company and to faithfully comply with the following.


    1. I will respect and comply with domestic and foreign ethics and laws. I will not engage in any acts in bad faith under any circumstances.


    2. I will always bear in mind the company’s norms of ethics and compliance, including the Charter of Ethics and Compliance, Code of Ethics and Compliance, and Rules of Ethics and Compliance for compliance in performing the assigned work.


    3. I will not demand to, or receive from, the interested persons, such as the officers and employees, customers, competitors, suppliers, affiliates, partner companies, related organizations, and domestic or foreign public officials, who may directly or indirectly influence the rights or interests in performing work any money, entertainment, convenience, and etc. I will also not solicit from, or provide to, such interested persons any money, entertainment, convenience, and etc.


    4. I will not directly or indirectly engage in financial transactions (e.g., loan, guarantee, and etc.), dealing in securities, equity investment, business operation, or any other equivalent acts with the interested persons.


    5. I will not use the company’s tangible or intangible assets for private purposes. Further, I will not abuse the job position or authorities to gain improper profits or disclose the information that may affect the interests of the company.


    2017.   .   .


    [] Hyundai Engineering Company


    Name: [] (signature)


Rules of Ethics and Compliance

  • Title
    1 Rules of Basic Business Ethics
    2 Rules of Compliance with Anti-corruption Laws
    3 Operating Rules of Voluntary Fair Trade Compliance Program
    4 Four Action Items for Compliance with Subcontractor Laws
    5 Rules of Subcontractor Management (Domestic)
    6 Rules of Subcontractor Management (International)
    7 Rules of Subcontractor Management (Engineering)
    8 Rules of Partner Company Management
    9 Information Protection Business Manual
    10 Rules of Information Security Management
    11 Rules of Personal Information Management
    12 Safety and Health Business Manual
    13 Rules of Safety and Health Management
    14 Environment Business Manual
    15 Rules of Environment Management
    16 Quality Business Manual
    17 Rules of Quality Standards and Objectives Management
  • [ 1.0 PURPOSE OF ESTABLISHMENT ]

    Hyundai Engineering Company (the “company”) imposes on all officers and employees the duty to engage in ethical value judgment and conduct through the Charter of Ethics and Compliance and the Code of Ethics and Compliance.

    The Rules of Basic Business Ethics (the “Rules of Ethics”) aim to establish a highly ethical value system for good faith performance of the company’s vision and business policies in domestic and international performance of work by the officers and employees of the companies. The Rules also aim to set practicable standards to always adhere to the honest and fair positions based on pride and self-esteem while maintaining the dignity of the individual and the reputation of the company.

    [ 2.0 SCOPE OF APPLICATION ]

    The Rules of Ethics apply to the company, domestic and international corporations, subsidiaries, and sites on which the company exercises control (collectively the “companies”), as well as all the officers and employees thereof.

    [ 3.0 BASIC PRINCIPLES ]

    3.1 The officers and employees shall comply with the Code of Ethics and Compliance, and shall faithfully perform the work assigned to each by the business policies of the company.

    3.2 The officers and employees shall perform the duty of care and lead the ethical corporate culture based on honesty and trust.

    3.3 The officers and employees shall practice the basic good manners necessary for office life, and shall strive for promoting smooth communication and cooperation for business among colleagues, divisions, partner companies, and other interested parties.

    3.4 The officers and employees shall be free from stereotypes, always seek novelty, and have a sense of ownership to actively manage problem-solving.

    3.5 The officers and employees shall safeguard reputation and dignity as a member of the company, and shall not engage in the acts injurious to public morals.

    3.6 The officers and employees with relations to performance of work shall maintain integrity and transparency for the prevention of corruption, such as rejecting improper solicitations and etc.

    [ 4.0 SPECIFIC PRACTICE GUIDELINES ]

    4.1 Duty to establish sound organizational culture

    4.1.1 The officers and employees shall not use the job position or responsibility to engage in the words and actions that cause the other to feel a sense of humiliation or disgust, and shall not engage in the acts that harm solid relationships with colleagues, such as financial dealings, violence, improper instructions, personal instructions, and etc.

    4.1.2 The officers and employees shall not form factions that cause disharmony, or private organizations, within the organization.

    4.1.3 The officers and employees shall respect diversity of individuals and care for each other to establish the environment for autonomous and creative work.

    4.1.4 The officers and employees shall not discriminate based on race, nationality, gender, educational background, age, and regionalism, and etc., and shall provide equal opportunities in case of being prepared with the qualification and capacities for the work.

    4.1.5 The officers and employees shall not have the private life, such as gambling, adultery, and pyramid scheme, and etc., affect the performance of work or damage the reputation of the company.

    4.1.6 The officers and employees of the company shall not give to, or receive from, each other any money and goods with relations to work.


    4.2 Duty of Good Faith

    4.2.1 The officers and employees shall always have responsibility for the assigned work and process the work in a careful, quick, and accurate manner.

    4.2.2 The officers and employees shall not engage in the acts that are in conflict with the interests of the company.

    4.2.3 The officers and employees shall not be absent from, or leave, the workplace without permission of the company.

    4.2.4 The officers and employees shall not engage in the acts that are contrary to the rules of the company or the proper instructions of the seniors.

    4.2.5 The officers and employees shall not use relationships, such as family connections, regional connections, school connections, religions, and etc., to engage in unfair performance of work.

    4.2.6 The officers and employees shall not engage in the second job activities for profit-making purpose, dual employment, or establishment and operation of a separate company that may interfere with the work without permission of the company.

    4.2.7 The officers and employees shall not engage in the acts unrelated to the work, such as stock investing, online shopping, gaming, excessive messaging, and etc., during the work hours.


    4.3 Duty to Maintain Dignity

    4.3.1 The officers and employees shall maintain dignity of oneself and the company through polite and proper speech and behavior.

    4.3.2 The officers and employees shall strive for cleanliness and safety management relevant to the prevention of theft and fire at the workplace (e.g., office, site, and etc.).

    4.3.3 The officers and employees shall maintain neat dress code by wearing set uniform and gear.

    4.3.4 The officers and employees shall not engage in improper or unlawful acts that may give rise to criminal prosecution.


    4.4 Duty to Maintain Political Impartiality

    4.4.1 The officers and employees shall ensure separation of business and state, and shall reject all irregularities.

    4.4.2 The officers and employees shall respect the individuals’ political rights and ideas, yet shall maintain political impartiality with relations to the performance of work.

    4.4.3 The officers and employees shall not use the funds, human resources, facilities, and etc. of the company for political purposes.

    4.4.4 The officers and employees shall not provide money and goods, such as illegal donation and etc.


    4.5 Prohibition of Abuse of Job Position and Responsibility

    4.5.1 The officers and employees shall strictly keep the public and private matters separate in all work activities.

    4.5.2 The officers and employees shall not improperly use the job position and responsibility to engage in the following acts:

    1) the act of directly or indirectly acquiring shares of the partner company in one’s own name, or under the name of family or relatives, or of investing or acquiring assets jointly with the interested parties;

    2) the act of practically owning the partner company in one’s own name or under the name of family or relatives; and

    3) the act of working as the officer or employee of the partner company using one’s own name, or under the name of family or relatives, or practically performing the work of the relevant partner company.

    4.5.3 The officers and employees shall not use the internal information of the company that was acquired through the job position and responsibility, or directly or indirectly made known with relations to the performance of work, to engage in the following acts:

    1) the act of providing undisclosed internal information of the company to the third party and receive a price or of directly using the information to improperly gain profit, such as stock investing, and etc.; and

    2) the act of providing to another, or using, the intellectual property, information, technology, and etc. acquired with relations to work for gaining personal profit after retirement.

    4.5.4 The officers and employees shall engage in transactions with the partner companies, and etc., at arm’s length, and shall not engage in improper acts that use the advantageous position in any forms.


    4.6 Prohibition and Prevention of Sexual Harassment

    4.6.1 The officers and employees shall not, using the position at the workplace or with relations to other officers or employees, engage in the speech and behavior deemed sexual harassment as set forth below:

    1) the act of physical contact, such as kissing, hugging, and etc.;

    2) the act of touching certain body parts, such as breasts, buttocks, and etc.;

    3) the act of forcing massage or caress;

    4) the act of obscene joking or obscene or vulgar speech (including phone calls);

    5) the act of sexual figure of speech or evaluation of outward appearance;

    6) the act of asking about sexual conduct or intentionally spreading information of sexual nature;

    7) the act of forcing or coercing sexual relationships;

    8) the act of making another sit in the next place against his or her will and forcing to pour drinks at business dinners and etc.;

    9) the act of posting or showing obscene photographs, pictures, drawings, publications, and etc. (including via internet, facsimile, and etc.);

    10) the act of intentionally exposing or touching certain body parts, relating to sex, of oneself; and

    11) other speech and behavior recognized to trigger sexual shame under social norms.

    4.6.2 The officers and employees shall complete the company-wide training relating to prevention of sexual harassment which is carried out based on the Equal Employment Opportunity and Work-Family Balance Assistance Act.


    4.7 Prohibition of Forgery and Falsification of Documents and of False Reports

    4.7.1 The officers and employees shall accurately and honestly record all documents and figures based on the basic facts, and shall not forge or falsify to be contrary to the facts for the purpose of using such documents and figures.

    4.7.2 The officers and employees shall not use forged or falsified documents or figures.

    4.7.3 The officers and employees shall not falsely report to be contrary to the facts for the purpose of exaggerating the outcome in performing work.


    4.8 Prohibition of Use of Company’s Assets for Other Purposes and Etc.

    4.8.1 The company’s assets are distinguished between tangible assets, such as vehicles, computers, land, buildings, facilities (e.g., machineries), raw and subsidiary materials, office fixtures, documents, goods (e.g., equipment), and intangible assets, such as management information, technological information, customer information, systems, blueprints, know-hows, other trade secrets, and etc., and collectively called the “company’s assets.”

    4.8.2 The officers and employees shall not use in the manner contrary to the original purpose, or embezzle, the company’s assets, and shall prepare in advance for the company’s assets to not be sold, lost, misused, stolen, transferred, or discharged.

    4.8.3 The officers and employees shall not arbitrarily engage in external transfer, or sale, of the company’s assets except in case of having obtained approval by the lawful procedures.

    4.8.4 The company’s electronic network shall be used for performing work or the approved purposes only, and shall not be misused for the purposes of the second job, or promotion of work, of oneself or the third party.

    4.8.5 The company’s budget shall not be arbitrarily converted, or withdrawn, and used without permission for other purposes, such as using the remaining budget for unnecessary spending; using entertainment expenses, meeting expenses, division operating expenses, business trip expenses, corporate card, and etc. for personal purposes; and etc.

    [ 5.0 INTERNAL INSPECTION ]

    The Compliance Team may regularly or irregularly inspect whether the officers and employees of the company are in compliance with the Rules of Ethics. The officers and employees of the company shall cooperate with regards to such inspections.

    [ 6.0 EFFECTIVE DATE ]

    The Rules of Ethics shall be effective as of September 1, 2017.

  • [ 1.0 PURPOSE OF ESTABLISHMENT ]

    Hyundai Engineering Company (“Hyundai Engineering”) imposes on all the officers and employees the duty to engage in ethical value judgment and conduct with regards to the job responsibilities through the norms for ethics and compliance. The officers and employees of Hyundai Engineering assume the duty to strictly adhere to the domestic and foreign anti-corruption laws and international conventions relating to anti-corruption (the “Domestic and Foreign Anti-corruption Laws”) in performing the work of the company not only domestically but also in various parts of the world.

    The Rules of Compliance with Anti-Corruption Laws (the “Rules of Compliance”) aim to set standards for making judgments on specific acts and for carrying out work in order to comply with the norms for ethics and compliance of Hyundai Engineering, as well as the Domestic and Foreign Anti-corruption Laws.

    [ 2.0 DEFINITIONS ]

    The definitions of each word referred to in the Rules of Compliance are as follows.

    2.1 “Company” refers to Hyundai Engineering, as well as domestic and international corporations, branch offices, and sites on which Hyundai Engineering exercises control.

    2.2 “Interested parties” refer to those engaging in transactions for the work of the company regardless of the title, including the business enterprises that provide articles or services to the company for efficient performance of the work of the company, such as partner companies, consultants, agents, and retail stores, as well as individuals, joint venture partners of the company, partners participating in consortia, representatives, and etc.

    2.3 “Representatives” refer to the interested parties that directly or indirectly perform work with public officials and etc.

    2.4 “Purpose to obtain improper business benefits” refer to the purposes including all cases for securing business benefits or avoiding business losses by improper methods, not proper competitions, such as exercising influence on the purchasing process of the owner to win projects, execute agreements, avoid taxes or fines, acquire exceptions with regards to regulations or crackdowns.

    2.5 “Economic benefits” refer to all tangible or intangible benefits provided in various forms such as money, goods, and etc., gifts, souvenirs, entertainment, invitation to events and provision of conveniences, and congratulatory and condolence money, goods, and etc., as well as promotional benefits, travel expenses, donations, provision of discounts, political contribution, acquisition or repayment of debts, commission on agreement, job placement, and etc.

    2.6 “Public officials and etc.” refer to (i) domestic and foreign public officials, (ii) heads, officers, and employees of organizations and agencies related to public service; and domestically to (iii) heads and faculty members of schools of each level and officers and employees of educational foundations, and (iv) representatives, officers, and employees of press organizations.

    2.7 “Domestic and foreign public officials” refer to domestic or foreign (i) officers and employees of central or federal governments (i.e., governments divisions, government agencies, or government institutions), as well as officers and employees of local governments and official representatives of governments, (ii) officers and employees of state-owned enterprises, public enterprises, public institutions, or state-invested enterprises (iii) officers and employees of public international organizations (e.g., International Monetary Fund, World Bank, World Trade Organization, Organization for Economic Co-operation and Development, and etc.), (iv) politicians, employees of political parties, and executive nominees, and (v) those who are delegated government affairs.

    2.8 “Money, goods, and etc.” refer to the following.

    1) Money: cash, foreign currency, and etc.

    2) Money equivalents: checks, promissory notes, savings certificates, bonds, gift certificates, securities, and etc.

    3) Gifts: articles, meal vouchers, memberships, accommodation vouchers, admission tickets, discount coupons, and etc.

    4) Other economic benefits: repayment of debts, guarantees, payments of loan interests, provision of movables or properties at no or low cost, and etc.

    2.9 “Entertainment” refers to the act of assuming or imposing the costs incurred from dining, drinking, entertainment, sports (e.g., golf and etc.), and etc.

    2.10 “Souvenirs” refer to the articles either uniformly provided by the sponsors of official events to the participants for proper business purposes, such as promotion of products and services or strengthening of relationships; or the articles to be distributed to many and unspecified persons or the articles displaying the company logo; these include promotional articles, free gifts, and samples.

    2.11 “Convenience” refers to providing economic benefits other than money, goods, and etc. or entertainment, such as transportation, accommodation, meals, tours, invitation to events, reservation, and etc., to the participants at reasonable level for hosting meetings or events for business purposes such as promotion of products, strengthening of relationships, and etc.

    2.12 “Customary level” refers to the level that satisfies each of the following requirements.

    1) The level that can be understood by universally valid and sound reason, that can be proven legitimate when disclosed, that does not have any effect on carrying out work from a fair position, and that does not impose any burden on each other;

    2) The level that is appropriate in terms of the amount, place, purpose, method, number of times, frequency, timing, counterparty, nature of reward, societal ethics, and customs (i.e., conventions), and etc.;

    3) Without any expectation of reciprocity regardless of the amount; and

    4) Not prohibited by laws.

    [ 3.0 SCOPE OF APPLICATION ]

    The Rules of Compliance apply to the company and all the officers and employees thereof.

    [ 4.0 BASIC PRINCIPLES ]

    4.1 The officers and employees shall understand and adhere to the Rules of Compliance, as well as the domestic and foreign anti-corruption laws.

    1) Various domestic anti-corruption laws (see Exhibit 3 for details)

    A. Article 129, 130, 133, and 357 of the Criminal Act

    B. Article 2 to 4 of the Act on the Aggravated Punishment, Etc. of Specific Crimes

    C. Article 6 of the Act on the Aggravated Punishment, Etc. of Specific Economic Crimes

    D. Improper Solicitation and Graft Act

    E. Act on Combating Bribery of Foreign Public Officials in International Business Transactions

    F. Other laws regulating acts of corruption

    2) International anti-corruption conventions

    A. OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (“OECD Anti-Bribery Convention”)

    B. United Nations Convention against Corruption

    C. Other international conventions regulating acts of corruption

    3) All foreign anti-corruption laws that may apply with relations to the performance of the work

    A. US Foreign Corrupt Practices Act (FCPA)

    B. UK Bribery Act

    C. Other laws of the states in which the business is carried out

    4.2 Default prohibition of improper solicitation and provision or receipt of money, goods, and etc.

    1) Regardless of whether there is any expectation of reciprocity, the amount, and etc., improper solicitation shall not be made directly or through third parties for purposes of obtaining improper benefits, and provision of money, goods, and etc., as well as entertainment, souvenirs, conveniences, and other economic benefits (“money, goods, and others”) shall not be suggested, promised, or made with relations to the public officials in connection with their duties.

    2) Regardless of whether there is any expectation of reciprocity, the amount, and etc., improper solicitation shall not be received directly or through third parties for the purpose of obtaining improper benefits, and receipt of money, goods, and etc., entertainment, souvenirs, conveniences, and other economic benefits shall not be demanded, promised, or made from the interested parties in connection with their duties.

    3) It should be noted that the provision of improper economic benefits to the public officials and etc. may be subject to stricter penalties in accordance with the laws of the relevant states.

    4.3 Standard and interpretation of the Rules of Compliance

    1) The determination as to whether the Rules of Compliance are adhered to shall be made from the objective third party’s position, not by the individual’s subjective determination. The determination shall be made by comprehensively considering all circumstances, such as the job responsibilities of the person receiving benefits, the personal relationship between the persons providing and receiving benefits, the extent of the benefits, the circumstances and timing of receiving benefits, and etc.

    2) In case whether the act of providing economic benefit in individual case may be exceptionally permissible is unclear or its legitimacy is questionable, the officers and employees shall consult with the Compliance Team in advance.

    4.4 The Rules of Compliance take priority over other internal rules with relations to the acts of corruption that may arise from the work of the company.

    [ 5.0 EXCEPTIONS ]

    5.1 Provision to domestic public officials and etc.

    5.1.1 Improper solicitation

    Notwithstanding Article 4.2, the following shall not be considered improper solicitation.

    1) Where demanding particular action such as relief or settlement of infringement on rights in accordance with the procedures or methods prescribed by any acts, subordinate statutes, or standards or suggesting or proposing enactment, amendment, or rescission of any acts, subordinate statutes, or standards relevant thereto;

    2) Where publicly demanding a public official and etc. to take a particular action;

    3) Where requesting or demanding a public institution to complete a certain duty within a statutory deadline, or asking confirmation or inquiring about the progress or outcome thereof;

    4) Where requesting or demanding confirmation or certification for a certain duty or juristic relations;

    5) Where requesting for explanation or interpretation of any acts and subordinate statutes, systems, procedures, and etc. related to duties through inquiry or consultation; and

    6) Any other acts deemed to be in accordance with social norms.


    5.1.2 Provision of money, goods, and etc.

    Notwithstanding Article 4.2, the following shall not be considered the money, goods, and etc. of which provision is prohibited.

    1) Money, goods, and etc. of which value is within the limit specified in the following table in the form of food and drink, congratulatory and condolence money, gifts, and etc. offered for purposes of facilitating performance of duties, social intercourse, rituals, or aid;

    Type Limit of value
    A Food and drink Meals, refreshments, alcoholic beverages, drinks, and other equivalents consumed by public officials and etc. together with the provider 30,000 won
    B Congratulatory and condolence money Various money gifts such as congratulatory and condolence money and etc.; wreaths and condolence flowers in place of the money gifts; and other equivalents 50,000 won
    C Gifts All articles or securities and other equivalents besides money and the food/drink under A 50,000 won

    (1) The limit of value for food and drink, congratulatory and condolence money, and gifts shall be the total amount of the applicable items under each category.

    (2) In case of having provided food and drink, together with gifts, the value shall be aggregated. In this case, the limit of value shall be 50,000 won, not exceeding each of the limits of value for food and drink or for gifts.

    (3) In case of having provided food and drink, together with congratulatory and condolence money, and in case of having provided congratulatory and condolence money, together with gifts, the value shall be aggregated respectively. In this case, the limit of value shall be 100,000 won, not exceeding each of the limits of value for food and drink, congratulatory and condolence money, and gifts.

    (4) In case of having provided food and drink, together with congratulatory and condolence money, as well as gifts, the value shall be aggregated. In this case, the limit of the value shall be 100,000 won, not exceeding each of the limits of value for food and drink, congratulatory and condolence money, and gifts.


    2) Money, goods, and etc. offered from legitimate sources of right such as payments of debts (excluding donations) incurred in private transactions;

    3) Money, goods, and etc. offered by relatives of public officials and etc.;

    4) Money, goods, and etc. offered by employees' mutual aid societies, clubs, alumni associations, hometown associations, friendship clubs, religious groups, social organizations, etc., related to public officials and etc. to their members in accordance with the rules prescribed by respective organizations; and money, goods, and etc. offered by those who have long-term and continuous relationships with public officials and etc., such as members of the aforementioned groups, to the public officials and etc. who are in need due to diseases, disasters, and etc.;

    5) Money, goods, and etc., provided uniformly in a normally accepted range by organizers of official events with relations to the duties of public officials and etc. to all participants in the form of transportation, accommodation, food and drink, and etc.;

    6) Souvenirs, promotional goods, and etc. to be distributed to many and unspecified persons, or awards or prizes given in contests or lotteries; and

    7) Money, goods, and etc. permitted by other Acts, subordinate statutes, standards, or social norms.


    5.2 Provision to foreign public officials and etc.

    In the following cases in which there is no purpose to obtain improper business benefits in light of the amount, place, purpose, method, number of times, frequency, timing, counterparty, nature of reward, societal ethics, and customs; and there is no concern of misunderstanding as having improper purposes under the laws, culture, and social norms of the relevant country, money, goods, and etc. may be provided within the permitted scope in the relevant country.

    1) From the position of the objective third party, there is no possibility of misunderstanding that the money, goods, and etc. are provided to the persons who are able to make decisions that incur direct benefits or losses to the company at the time such decisions are imminent in order to exercise improper influence on such decisions.

    2) The money, goods, and etc. are not provided to the excessive extent or amount beyond the purpose to the recipient.

    3) The value of the money, goods, and etc. provided is not excessive in light of the job title of the recipient of the money, goods, and etc.

    4) The money, goods, and etc. are not provided to the external third parties, such as the spouse or family of the persons related to work, other than the persons related to work, such as the counterparty to the transaction.

    5) The internal rules of the organization, and the laws of the country, to which the recipient of the money, goods, and etc. belongs do not prohibit the receipt of the relevant money, goods, and etc.

    6) The money, goods, and etc. provided do not raise issues of public policy.


    5.3 Receipt from interested parties and etc.

    1) In case interested parties provide money, goods, and etc., the officers and employees shall respectfully decline on the site.

    2) In case it was deemed impossible or impolite to return money, goods, and etc. at the time of the receipt, or in case of receiving money, goods, and etc. without personal knowledge, the money, goods, and etc. shall be respectfully returned to the provider as soon as possible.

    3) As for the exceptional reasons for which the officers and employees may receive money, goods, and etc. from interested parties, the terms set forth under 5.1 shall apply.

    4) In case it is difficult to determine whether the money, goods, and etc. received are covered under the exceptional reasons under the above terms of 3), the officers and employees may inquire to the Compliance Team.

    5) In case the officers and employees were obliged to receive money, goods, and etc. even though they were not covered under the exceptional reasons for which the officers and employees may receive money, goods, and etc. from interested parties, the officers and employees shall report to the Compliance Team within three business days from the date of the receipt of the money, goods, and etc. in accordance with the form for report on receipt of gift under Exhibit 1.

    6) The Compliance Team having received the report shall enter the information to the register for management of gifts under Exhibit 2, and shall proceed as follows.

    A. Recommend return in case it is possible to return to the provider; or

    B. Transfer to the Management Planning Team in case it is impossible or inappropriate to return to the provider.

    7) The head of the Management Planning Team shall manage and maintain the money, goods, and etc. transferred from the Compliance Team by contributing to the local community such as donating to social welfare facilities or religious organizations.


    5.4 Special cases relating to interested parties

    1) Financing, purchase at low price, and sale at high price

    A. The officers and employees shall not accept any offers of leasing assets or providing guarantees from the interested parties for convenience or profits for themselves, their family and relatives regardless of the amount.

    B. The officers and employees shall not take profit by improperly purchasing any movables or properties owned by interested parties at no cost or a price lower than the market price or by improperly selling any movables or properties owned by themselves or their family to interested parties at a price higher than the market price.

    2) Guarantees for loans

    When lending, the officers and employees shall neither demand guarantees to interested parties nor accept offers of guarantees from interested parties regardless of lending agencies and amounts.

    3) Loans

    The officers and employees shall not engage in the acts of borrowing or lending money with interested parties regardless of the amount.

    4) Guarantees for future (e.g., job placement, promise to execute agreements, and etc.)

    The officers and employees shall neither demand to, nor accept offers from, interested parties job placements, promises to execute agreements, or any equivalent forms of promises after retirement. Further, the officers and employees shall neither demand to, nor accept offers from, interested parties promises securing any benefits, such as execution of promises, after retirement to, or accept offers from, interested parties.

    [ 6.0 REPRESENTATIVES ]

    6.1 In performing the work of the company through representatives, appropriate measures shall be taken to ensure that the representatives do not offer, promise, or provide economic benefits, such as money, goods, and etc. to public officials and etc. directly or through third parties for the purpose of obtaining improper business benefits.

    6.2 If the officers and employees knew or could have known violations of anti-corruption laws by representatives based on the circumstances, yet failed to take appropriate measures to prevent such acts, the company and the relevant officers and employees may assume civil and criminal liability for the violations by the representatives. In order to reduce such risks, the officers and employees shall adhere to the following guidelines relating to representatives when appointing representatives or executing agreements with agents.

    6.2.1 Due Diligence

    1) In case of appointing representatives with relations to the work of the company, due diligence shall be conducted to verify whether the representatives are appropriate companies (or individuals) to engage in transactions with the company.

    2) The information relating to due diligence, particularly the evidence to prove that the compensation to be paid to representatives are at reasonable level corresponding to the relevant scope and nature of work, shall be documented and preserved.

    6.2.2 Execution of agreements

    When executing agreements relating to the work of the company with representatives, the following information relating to prevention of corruption shall be reflected.

    1) Affirmation of past and future compliance with anti-corruption laws;

    2) In case of violation of the above provision, the company may conduct relevant investigation; and

    3) In case of violation of anti-corruption laws or failure to cooperate with the investigation of the company, the company is entitled to revoke or terminate the agreement.

    6.2.3 Follow-up measures

    The officers and employees in charge of representatives shall regularly check whether the representatives are adhering to the terms relating to anti-corruption that are specified in the agreements, and shall preserve the result.

    [ 7.0 TRAINING AND CONSULTATION ]

    7.1 The officers and employees shall receive training relating to anti-corruption policies that are carried out by the company annually or more. The training may be carried out in writing, in person or online.

    7.2 In case there are concerns of violations of the Rules of Compliance, the officers and employees shall inquire to the Compliance Team.

    [ 8.0 REPORTING AND PROCESSING OF VIOLATIONS ]

    8.1 The officers and employees who violate domestic or foreign anti-corruption laws, or the Rules of Compliance, or refuse the relevant investigation of the company, in the process of performing work shall be disciplined in accordance with the Rules of Employment.

    8.2 The officers and employees, when having found violations of domestic or foreign anti-corruption laws, or the Rules of Compliance, shall report to the supervisor and the Compliance Team without delay. The officers and employees may report violations via online reporting form on the reporting channel of the company (http://audit.hec.co.kr), email, phone, and etc.

    8.3 The officers and employees having received reports from the employees shall rapidly communicate the reported information to the Compliance Team.

    8.4 The company, as well as the officers and employees, shall strictly maintain confidentiality of the processing of all reports and the personal information of the reporting persons, and shall ensure that the reporting persons do not suffer any disadvantage due to the reports.

    [ 9.0 INTERNAL INSPECTION ]

    9.1 The Compliance Team may regularly or irregularly inspect whether the officers and employees are adhering to the Rules of Compliance. The officers and employees shall cooperate with regards to such inspections.

    [ 10.0 EFFECTIVE DATE ]

    10.1 The Rules of Compliance shall be effective in part as of January 2, 2017.

    10.2 The Rules of Compliance shall be amended as of October 1, 2017


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