1. Purpose

This Code of Ethics Practice aims to define criteria for determining behavior so that employees can properly understand ethical problems faced during business activities, and to determine necessary procedures for reporting violations.

2. Application

This Code of Ethics applies to all employees of Hyundai Welding, whether they work in Korea or abroad. However, local laws and regulations will also be considered for employees working abroad.

3. Definition of Terms

1)Money and other valuables : All property benefits, such as money, securities, real estate, goods, accommodation, membership, admission, discounts, invitations, etc.

2)Stakeholders : People who are directly or indirectly related to the company's business and have a mutual impact on the decision-making of the company and its employees.

3)Superior status : Using a superior business status to gain an advantage over another party in a relationship.

4)Reporter : A person who reports or calms fraudulent transactions, illegal activities, and other unethical practices of employees or in accordance with the Code of Ethics.

1. Management of business information and creation of documents

1)Employees shall not use information acquired in the company for personal profit or disclose it to third parties.

2)Employees must not trade shares using internal information and must not provide confidential information to third parties that may affect stock prices without due process.

3)Employees shall prepare documents for business in accordance with the company's regulations, and must immediately report and modify documents in case of error.

2. Prohibition of request for job position

1)Employees shall not make unreasonable requests to the company and its interested companies by using their status, such as asking for employment of family members, relatives, or acquaintances.

2)Employees must not request the HR team for unfair personnel evaluations by using their status.

3)Employees shall not request any other person to make a request to the HR team for an unfair influence on their appointment, promotion, transfer, etc.

4)Employees shall not receive any guarantee of employment after retirement from interested parties.

5)If an employee receives a personnel request, he/she shall inform them that it is an illegal request and clearly indicate his/her intention of refusal.

3. Prohibition of Multiple Jobs and Concurrent Positions

1)Employees are prohibited from duplicate employment in other companies without prior approval from the company.

2)Employees cannot concurrently serve duties of other companies without permission from the company.

4. Signing Contracts with Partners

1)Employees shall perform their duties fairly and transparently in accordance with the procedures prescribed by the relevant laws and regulations for bidding, contracts, and contract fulfillment conducted by the company.

2)When selecting a subcontractor, all duly qualified companies shall be given equal opportunity for transaction and free competition, and will be selected according to transparent evaluation procedures.

3)In principle, orders should be placed by competitive bidding, but private contracts may be selected through due process in accordance with the company's needs and regulations.

4)Employees shall not receive any form of economic or non-economic benefits from subcontractors using their superior status.

5)Employees shall be fully aware of the basic procedures for signing contracts and shall not conclude construction, service contracts, etc. at a higher price than the market price.

6)Employees shall endeavor not to have conflicting interests when signing contracts with subcontractors. In the event of a conflict of interest with the company, they shall immediately report it to the Ethics Management Department.

1. Prohibition of Embezzlement and Misappropriation of Public Funds

1)Employees may not use the company's public funds for personal purposes for any reason. When detected, criminal charges may be filed according to the amount and loss.

2)The company's public funds shall be managed by a corporate account, and all expenditures shall be thoroughly evidenced.

2. Prohibition of Improper Budget Execution

1)Employees shall refrain from wasting budget due to unnecessary use or excessive execution, and shall ensure that all budgets are executed reasonably and efficiently.

2)Employees shall not use the sales budget for purposes other than department dinners, congratulatory money for employees, and purchasing personal items.

3)Employees may not use corporate credit cards for any purpose that is not business related.

4)Employees may not charge the company expenses used for non-business purposes.

5)If employees use the company's budget for non-business purposes and fail to report it to the Ethics Management Department, both those involved and department employees who are aware may be subject to disciplinary action.

3. Prohibition of Private Use and Damage of Company Property

1)Company assets, such as the company's physical property, intellectual property rights, and trade secrets, may not be used for personal purposes.

2)If an employee wishes to transfer or lend the company's assets to himself or a third party, they must obtain approval from the department head and the executive in charge and follow the prescribed procedures.

3)Employees may not use the company’s computer or laptop to engage in personal stock trading, gambling, illegal videos, and other sites unrelated to business.

4)Employees may not intentionally damage the company's assets. If an employee does so, the company may hold them responsible.

4. Prohibition of Bribery Acceptance

1)Employees shall not seek any money, entertainment, or convenience from interested parties by abusing their superior positions, and shall not engage in financial transactions with colleagues.

2)Employees are prohibited from receiving various personal conveniences from interested parties on business trips, such as transportation and lodging expenses. However, if such convenience is inevitably provided, it must be reported to HR and the relevant expenses shall be calculated and returned.

3)Employees may not receive money for celebration and condolence from interested parties, and must not notify them in order to receive such money.

1. Mutual Respect for Employees

1)Employees should respect each other and have good manners for work life.

2)Employees shall not discriminate each other for reasons concerning gender, religion, age, origin, educational background, or other reasons.

3)Employees shall not engage in unofficial activities such as creating factions and promoting social disharmony.

4)Employees shall not restrict, exclude, separate, or discriminate colleagues with disabilities without justifiable reasons.

2. Responsibility of Executives and Department Heads

1)Executives and department heads shall set a good example to department members by complying with the Code of Ethics and its practices through fair decision-making and actions.

2)Executives and department heads shall provide counseling from time to time so that all department members can fully understand the Code of Ethics and its practices, and take appropriate precautions to prevent unethical behavior.

3. Responsibility of Department Members

1)When a department member is given work that is unclear under the company’s regulations, they shall ask the department head or executive before proceeding.

2)If a department member is given work that is illegal or unjust by their manager, they shall not proceed with it unconditionally.

3)A department member shall refuse unjust orders from their manager by presenting evidence. If the manager still gives unjust orders, they must be reported to the Ethics Management Department.

4. Prohibition of Bullying and Sexual Harassment in the Workplace

Strong disciplinary actions, such as suspension, demotion, being placed on the waiting list, dismissal, etc. may be imposed on employees who have caused bullying or sexual harassment in the workplace. Personnel transfers may also be conducted to prevent them from working in the same place as the victim.

1)Prohibition of Bullying
- Employees shall not engage in acts unrelated to their duties that cause physical and mental pain, or worsen the working environment by using their superior position in the company.
- No unnecessary instructions or violations shall be imposed outside of legal working hours.
- Employees shall not intentionally ostracize or spread false information of their colleagues in social media or the bulletin board.
- Managers shall not use vulgar language or insult their employees even if their performance is poor.
- Managers may not force their employees to participate in company dinners, run errands, or write reports unrelated to work.
- A single employee shall not be repeatedly assigned hard work, unless specified in their labor contract.
- An employee shall not be intentionally excluded from important information or work related decision-making without justifiable reasons.
- Employees shall not be treated unfairly by their managers, through the use of authority such as change, exclusion, and transfer of duties.

2)Prohibition of Sexual Harassment in the Workplace
- Employees shall not engage in any act that causes a colleague to feel sexual humiliation, disgust, or pressure.
- Employees are prohibited from making obscene jokes, gossip, physical contact, or forcing people to pour alcohol or dance in company dinners.
- Employees may not intentionally expose or touch sensitive parts of a colleague’s body, or force colleagues to see obscene photographs and pictures.
- Employees may not sexually evaluate each other’s bodies or figures.
- A refusal of sexual harassment shall be respected, and no disadvantage shall be given in such cases.
- Employees may not make deals concerning sexual demands, and may not force meetings, romantic relationships, or physical contact.

5. Prohibition of Gambling

1)Employees may not force colleagues to purchase guarantees, financial products (insurance, etc.) or other goods.

2)Employees shall not engage in gambling activities, and in case an employee earns money or valuables through gambling, it will be regarded as bribery.

3)Employees shall not be affected by alcohol during working hours. However, such cases are tolerated in case of prior approval for hosting and sponsoring events.

4)Employees shall not work under the influence of alcohol. Provided, that where a customer or interested party inevitably drinks at a meeting, the company may grant an alternative leave of absence the following day in accordance with the company guidelines.

5)Employees may not drive under the influence of alcohol for work, and strong disciplinary measures such as dismissal may be given if detected.

1. Information Protection

1)Employees shall protect the company's physical property, intellectual property, and business secrets. They may not divulge internal information to third parties without prior approval from the company.

2)Employees may not disclose the company's business regulations prior approval from the company.

3)The company’s information system shall be used only for business purposes and shall not be used for personal interests.

2. Security Management

1)Data of the company's information system shall not be falsified, tampered with or damaged without permission.

2)The ID and password provided by the company shall not be shared with others. However, it may be temporarily shared for inevitable work purposes.

3)Employees are prohibited from attempting to identify other people's IDs and passwords, and unauthorized information may not be accessed.

4)Data that may infringe copyright may not be distributed without permission within the company.

5)Employees must use a purchased software program, and all responsibility for the use of illegal software shall be taken by the relevant employees.

3. Privacy

1)Employees may not intentionally disclose personal information of employees and stakeholders.

2)Personal information processors must manage privacy so that it is not damaged or lost.

3)In order to ensure the safety of privacy, documents containing personal information and auxiliary storage media shall be stored in a locked place.

4)In order to prevent leakage of personal information, the company shall provide education for personal information processors.