Ethical Management

Ethical Management

The SUNBO Family is always striving to
practice a fair and honest corporate culture.

Code of Ethics

SB SUNBO firmly demonstrates its commitment to practicing integrity and
ethics through the [SUNBO Code of thics].

Under no circumstances should money or gifts be given or received for profit.
Such actions can result in criminal liability for both individuals and the company.
SUNBO explicitly prohibits the giving and receiving of money and gifts in all business transactions conducted in all countries worldwide, including government and private sectors.

However, reasonable and limited payments for gifts directly related to product or service promotion, contract execution, business entertainment, or customer travel expenses should not be misconstrued as improper payments.

Internal Regulations
(Charter/Code of Conduct)

Ethical Management Practice Regulations
1. Purpose

SUNBO Industries Co., Ltd., SUNBO Unitech Co., Ltd. and SUNBO Hitech Co., Ltd. (hereafter referred to as “SUNBO family”) shall endeavor to create values and bring happiness to all concerned parties (e.g., customers, staff members, shareholders, partner companies and society) through ethical management of the company. Moreover, the SUNBO family shall bring happiness to the world by playing a key role in the development of society and economy.

· Our company shall satisfy customers to gain their trust and ultimately, contribute to society’s progress.
· Our company shall create an environment that fosters voluntary work of staff members, enabling them to contribute to the company’s progress during the conduct of their duties.
· Our company shall increase the value of the business in order to gain profit for the shareholders. To achieve this, our company shall promote transparency and implement efficient management.
· In addition to the contribution to economic development, our company shall also contribute to society through social and cultural activities. Our company shall do its best to implement management practices according to social rules and ethical standards.

In order to accomplish these, the SUNBO family established these rules on ethical management practices. These rules shall be used as ethical decision making and conduct criteria for staff members during all management activities.

2. Target of Application

These rules on ethical management practices shall apply to all constituent members who work for the SUNBO family.

3. Ethical Decision Making and Principles of Conduct

When faced with ethical conflict related to the implementation of work, a constituent member shall make decisions and conduct himself/herself based on ethical management rules and practices. However, in case that decision criteria are not clearly stipulated in ethical management rules, decision and actions shall be made in accordance with the following decision-making principles.

· Lawfulness: Can your action be interpreted to violate laws or company rules?
· Transparency: Can you disclose your decision-making processes and details?
· Rationality: Will other staff members make the same decision under the same conditions?

In case that a staff member is not sure whether or not his/her decision violates lawfulness, transparency and rationality criteria, he/she shall follow the advice of the organization leader or the ethical management division.

4. thical Management Practice Details
4.1. Responsibility of Staff Members
Our company shall strengthen the individual value of a staff member and perform efficiently the business implementation system. Our company shall enable all staff members become proud of rewarding work processes and results by fostering an environment that encourages a staff member to develop his/her abilities and improve his/her personality voluntarily and willingly.
- Our company shall respect all staff members and provide a systematic growth opportunity.
- Our company shall make reasonable assessment of and provide fair compensation for staff members.
4.1.1. Providing Growth Opportunity

Our company shall consider the staff member’s abilities and ideas regarding work-related matters in order to provide them with an opportunity to improve their leadership and work skills.

4.1.2. Fair Assessment and Compensation

1) Our company shall provide clear criteria for the achievement of goals and end-results and make fair assessment according to the staff member’s performance and ability.
2) Our company shall make fair and reasonable compensation for an individual or organization that showed good performance.
3) Our company shall provide a fair opportunity to improve the staff member’s ability. Our company shall not discriminate on the basis of academic background, gender, religion, region of origin, age, disability, marital status, nationality, race, etc.

4.2. Attitude of Staff Member
With the mindset of ‘This is my company’, a staff member shall exert full efforts to become the best professional in the field through excellent performance and self-development; the personnel shall also show professional ability for the progress of the company.
- A staff member shall observe basic manners and company rules that are the basis of ethical management.
- A staff member shall try to protect the company’s properties and information.
- Particularly, leaders shall create an environment that can bring out the staff member’s best abilities and lead in the creation of an ethical organization.
4.2.1. Observing Basic Manners
1) All personnel shall observe basic manners and there shall be mutual respect between superior and subordinate and among colleagues.
2) A staff member shall respect an individual’s private life and observe a mature organizational culture based on mutual trust and understanding.
3) A staff member shall not ask an unreasonable request or favor from other personnel.
4) 수A staff member shall live a moderate life without overspending and try not to shop in extravagant stores.
5) A staff member shall not engage in acts that can cause trouble to superiors, colleagues and subordinates. Acts that can cause trouble are:

- Verbal acts : Abusive words, defamation, negative prejudice, threatening or hostile words, etc.
- Non-verbal acts : Assault, throwing objects, staring angrily, etc.
- Visual acts : Derogatory or offensive picture, painting, gesture, etc. However, a constructive criticism, encouragement, and words of advice regarding work performance shall be excluded from this provision.

6) Smoking in a non-designated area is prohibited; entertainment activities.
(e.g., gambling, playing computer games and Paduk game, etc.) are prohibited as well.
4.2.2. Sexual Harassment Prevention

Sexual harassment acts in the workplace can reduce work motivation and affect productivity. Because it can eventually cause burden to the company resulting to legal action, damage to the company’s reputation, etc., staff members shall strictly avoid sexual harassment acts.

1) Our company shall provide clear criteria for the achievement of goals and end-results and make fair assessment according to performance and ability.
2) Our company shall provide fair and reasonable compensation for an individual or organization that showed good performance.
3) Our company shall provide a fair opportunity to improve the staff member’s abilities. Our company shall not discriminate on the basis of academic background, gender, religion, region of origin, age, disability, marital status, nationality, race, etc.

4.2.3. The Company’s Interest Shall Prevail in Case of Conflict of Interests
1) When a staff member shall decide on the following matters or is in a position that can influence outcome of the following decisions, the company’s interest shall prevail if there is conflict between the staff member’s interest and the company’s interest.

* mportant cases related to company’s interest
- Purchase: Purchase of goods or services for the company
- Sales: Decision on price, quantity, sales conditions, and quality of products or services
- Investment: Acquisition of securities or investment on other company’s real estate
- Loan: Loan from financial institution or extension of loan period
- Lease: Lease of property and facility from other company

2) A staff member cannot work for an outside company or government organization (charity, education, religious and union organization excluded) without prior approval from the company.
3) A staff member cannot directly or indirectly acquire shares and assets of clients, person who desires business, competitors, etc.
4) A staff member cannot engage in acts that can reduce the company’s present and future profits through the use/transfer of knowledge/technology developed and applied by the staff member as an employee of the company.
5) A staff member cannot engage in business activities with a company or individual related to his/her family members/relatives without prior approval.
4.2.4. Protection of Company’s Properties and Information
1) A constituent member shall not use the company’s goods or other asserts for personal purpose by strictly distinguishing between official and personal uses.
2) The company’s funds shall be used for the company’s operation. When the company’s funds are used, the laws, company rules, and staff member’s ethical conduct shall be observed.
3) The company’s inside information such as confidential information and new business information shall not be disclosed to a third party without prior approval.

*mportant cases
- Management information: The company’s important policies, decision-making information, management plan, financial earning information, etc.
- Operation information: Human resource information, media promotion related information, revenue information such as sales and profit margin, product information, partner company information, etc.

4) mportant records and documents shall be protected from disclosure to other companies or a specific person by appointing a security manager.
5) A staff member shall be responsible in providing information to himself/herself within the extent allowed by laws and company rules. The acquired information cannot be disclosed externally without approval from the said staff member except by lawful demand of the company or other organizations.
6) For other specific company information related to security activities, security management rules shall be followed.
4.2.5. Observing Company Rules

1) A staff member shall perform his/her duties properly to the best of his/her abilities. A staff member shall understand and observe the company’s rules and systems related to work performance.
2) A superior cannot give work instructions to a subordinate that are against laws and company rules and the subordinate can refuse such work instructions. Even if the subordinate notifies the company about such case, the subordinate shall not receive disadvantageous treatment

4.2.6. Prohibition of Accepting Bribe from an Interested Party
1) Under any circumstance, a staff member is prohibited to accept money, entertainment service, reception service, convenience or benefit from interested parties.
2) In case of accepting entertainment service, reception service or convenience from interested parties (overseas business travel included) due to unavoidable reasons, the said staff member shall return the corresponding amount immediately.
3) A staff member shall not inform company acquaintances about any celebratory or condolence events, and personnel shall not accept money for the said events.
4) If a staff member accepts bribe even through a third party (e.g., mediator, agent, family member or relative), the staff member himself/herself shall be considered to have accepted the bribe.
5) A staff member can introduce customers to a third party with prior approval from the company to the extent that the company’s interest shall not be affected or compromised. A staff member shall not accept improper compensation.
6) If money was given as a gift for a celebratory or condolence event and it is within the extent accepted socially and conventionally, then its acceptance shall be allowed.
7) Bribe and money transaction among staff members shall be prohibited.

① Giving or accepting money or gift among all personnel shall be prohibited.
However, these gifts shall be allowed: gift to subordinates from a superior to revitalize an organization; birthday gift purchased with the money shared equally by team members (but participation of staff members from other teams is prohibited); gift to congratulate a staff for joining the company; and gift exchanges.
② A staff member shall be prohibited to conduct financial transactions that can damage team relationships. These include loaning money, allowing loan guarantee, and accepting joint liability on guarantee with other staff members using superior position.

4.2.7. Leader’s Role

11) A leader shall create an environment that can encourage staff members to show their best abilities. Also, a leader shall continue to produce significant results by maximizing the organization’s capacity.
2) Based on ethical conduct, a leader in our company shall take the lead in terms of words and actions. In case that a sign of unethical or illegal activity is detected, a leader shall report it immediately.

4.2.8. Brand Value Management

A staff member shall try to increase the company’s brand value while performing his/her job. Moreover, a staff member shall try not to lower the brand’s value through discretionary use or brand expression.

4.3. Attitude towards Customers
Our company shall practice customer-oriented management through customer-oriented thinking and decision-making from the customer’s viewpoint. Our company shall satisfy customers and obtain their trust by identifying potential opportunities through customer-oriented management. Based on this, our company shall ultimately make progress along with customers..
4.3.1. Increasing Customer Value

1) A staff member shall impress customers by making them true partners and by optimizing products and services provided to them; employees shall also support the management system.
2) A staff member shall provide the highest-quality products and services that customers want.
3) A staff member shall establish a company image that is loved and trusted by customers by providing the world’s best products and services through continuous R&D.
4) A staff member shall gain customer’s trust and provide satisfaction by measuring and managing performance of provided services 5) A staff member shall immediately respond to customer’s reasonable demands.
6) A staff member shall treat customers fairly in all areas such as service and product sales.
7) A staff member, when responding to customers, shall act as if he/she is a representative of the company. A staff member shall implement fair sales activity according to social norms and manners.

4.3.2. Customer’s Interest Protection

1) A staff member shall prepare for anticipated accidents by efficiently managing the customers’ important data.
2) A staff member shall be prohibited to disclose customers’ information to a third party without prior approval from the customer.
3) A staff member shall immediately respond and take action in case that a customer properly demands for exchange or refund of provided products and services.
4) A staff member shall prioritize the customer’s safety during all management and sales activities.
5) A staff member shall tell the truth to customers and shall keep his/her promises to them.

4.3.3. Customer Information Protection

1) A staff member shall prepare for anticipated accidents by efficiently managing the customers’ important data.
2) A staff member shall be prohibited to disclose customer’s information to a third party without prior approval from the customer.
3) A staff member shall not disclose acquired customer information without prior approval from the customer, or shall not use it for other purposes.
4) A staff member shall understand the importance of customer information protection and observe security management rules.

4.4. Responsibilities of Shareholders
Our company shall support the management’s reasonable decisions and obtain support from society through the leadership of the board of directors. At the same time, our company shall increase the efficiency and execution of management by implementing responsible management practices based on fast and autonomous decision making.
4.4.1. Creating Shareholder Value

Our company shall maximize company value through efficient management and continuous innovation, and share the outcome with shareholders.

4.4.2.Transparent Management Led by the Board of Directors

Our company shall implement transparent management led by the board of directors, and respect proper requests and suggestions by shareholders.

4.4.3. Accounting System Transparency and Disclosure

Our company shall prepare management data in accordance with relevant laws and standards, and disclose relevant information in accordance with laws to protect the shareholders’ interests.

4.5. Relationship with Partners and Competitors
Our company shall seek mutual progress through win-win management based on fair relationship with partner companies.
- The win-win management is an essential element for the company’s competitiveness improvement and mutual progress. It should be established as part of the company culture that increases its competitiveness.
- Our company shall enhance its competitive edge against outside competition using the core ability of partner companies, and share growth opportunity by finding and implementing business opportunities.
4.5.1. Fair Trade with Partners
1) Our company shall provide an opportunity for all companies to participate in the registration and selection of partner companies. Registration and selection processes of partner companies shall be implemented in accordance with objective and fair review criteria.

① Partner companies shall be selected transparently and fairly based on quality, price and credibility of provided products and services.
② In principle, partner companies shall be selected using public tender. If there is a reasonable cause, other methods can be used.
③ Assessment of partner companies shall be implemented in accordance with clear and fair criteria.

2) All trades shall be made fairly and equally by both parties. Full prior discussion on conditions and procedures shall be held.
3) Our company shall support partner companies to become competitive in the long-term and share the profits created in this way.
4) A staff member shall not engage in any type of improper activities using a superior position

① A staff member shall observe fairness to prevent business dealings using improper method.
② A staff member shall observe fairness to prevent any improper conduct such as abusing superior position or forcing business without prior discussion with partner companies.
③ A staff member shall secure credibility by prohibiting the passing/transferring of expenses to partner companies during the trade processes without prior discussion.
④ Our company shall not accept support for expenses during meetings except for the company’s official meeting with partner companies.
⑤ A staff member shall not make employees of partner companies wait for a long time during visits to our company. (In case of canceling appointment due to unavoidable reason, a staff member shall politely ask for understanding.)
⑥ A staff member shall not disclose public tender information provided by partner companies, such as pricing and quality, to unauthorized person in and outside of the company

5) Our company shall work with partner companies to create clear and transparent trade atmosphere and maintain fair trade order.
4.5.2. Fair Trade with Competitor

1) Our company shall respect the market order in any location around the world in accordance with the principle of free competition.
2) Our company shall not engage in collusion (e.g., price-fixing) that violates the condition of market economy.
3) Our company shall compete fairly and properly with competitors based on mutual respect. Our company shall not violate competitor’s interest or shall not use competitor’s weakness improperly.
4) Our company shall acquire and use information in accordance with laws or trade customs.
5) Our company shall not disclose competitor’s information even if information was obtained properly.
6) Our company shall not slander competitor companies or make baseless comparisons through advertisement.
7) Our company shall honor competitor company’s tangible and intangible property rights.

4.6. Role In the Society
We shall take responsibility as a member of society and community. We shall implement social activities based on the company’s capability and staff members’ voluntary participation. We shall become a company respected by society by observing laws and practicing ethical management.
4.6.1. Observing Law

1) A staff member needs to understand laws and regulations that shall be applied to his/her work when working in Korea or overseas. A staff member shall observe relevant laws and regulations and observe work ethics while respecting local culture and trade customs as a corporate citizen.
2) A staff member shall observe the ‘Convention on Combating Bribery of Foreign Public Officials in International Business Transactions’ of OECD and the ‘Fair Trade Act’ of Korea. A staff member shall not engage in illegal activities for business benefit or interest and shall not offer bribe or entertainment service.
3) A staff member shall use only licensed software, and shall not use unlicensed software obtained through the Internet or other methods.
4) A staff member shall not be involved in politics, and shall not offer illegal funds directly or indirectly to selected/appointed officials.
5) A staff member shall protect nature and preserve a clean environment. A staff member shall observe regulations related to environment protection
6) A staff member shall implement constructive business activities, and shall not engage in activities that can cause harm to the nation’s economy or stir public sentiment such as real estate speculation.

4.6.2. Social Contribution

1) A staff member shall participate in social activities to make everyone in society feel happy.
2) A staff member shall help the neglected group of people (e.g., handicapped people) become independent through various professional support activities.
3) To spread social contribution activities, the opportunity to participate in these activities shall be extended to the staff member’s family.

4.6.3. Observing Law

Our company shall seek continuous growth in order to share prosperity with people in the community and contribute to society. Our company shall increase its value through continuous growth and eventually, contribute to national development.

5. Supplementary Provisions
5.1 Time of Enforcement

These rules on ethical management practices shall be enforced starting October 1, 2013

5.2 Rewards and Disciplinary Actions

The company shall observe the rules on ethical management practices and shall try to spread ethical management in society by rewarding an individual/organization that contributed to the company’s ethical management activities. On the other hand, our company shall discipline an individual/organization that violated rules on ethical management practices.

5.3 Counseling and Consultation

A staff member may get counseling or consultation services from the ethics office if doubts arose during the interpretation or implementation of rules on ethics management practices.

5.4 Interpretation Criteria

If our company’s ethics management activity is not stipulated in the rules regarding ethics management practices or causes dispute during interpretation, interpretation and decision-making by the ethics committee shall be carried out.

5.5 Other Company Rules

The rules on ethics management practices, which are the basis of ethical behavior, shall precede other in-house or company rules. The company’s internal rules that shall be established or amended shall observe the rules on ethics management practices.

Clean Reporting Center

Reports are made under real names in principle. For anonymous reports,
investigations are conducted only when they are clear and verifiable.
* Defamation, false reports, and malicious reports about individuals are not investigated.

Online Reporting Clean Reporting Center Director (Management Support Executive)
TEL : +82 51-260-5531