Hanwha Ocean ESG

Ethics and Compliance System

Hanwha Ocean, under our effective and transparent system and the Code of Ethics, forms organizations to implement ethical management while fulfilling our stakeholders’ reasonable expectations and demands and corresponding to shared growth and development.

Through the operation of a compliance management system and assessment programs, we strive to enhance employees’ awareness of compliance and avoid legal risks.

Ethics and compliance organizations

Hanwha Ocean’s ethics and compliance organizations comprise of the Legal Department, the Management Assessment Department, and the Compliance Team under the Compliance Office. The Legal Department reviews legal affairs and responds to domestic and international disputes, whereas the Management Assessment Department conducts management assessment and improvement activities, assessment planning, bribery and fraud diagnosis, and operates an online whistleblowing center. The Compliance Team establishes a compliance system and conducts a series of activities regarding compliance education, inspection, evaluation, improvement, and ethical management.

Code of Ethics

As part of our efforts to successfully practice ethical management, Hanwha Ocean defines and implements the Code of Ethics and its practice guidelines for all employees. Our Code of Ethics serves as an ethical standard that the company must follow and our promise to our stakeholders. The Code of Ethics consists of six parts including attitude toward shareholders and investors, customers, competitors and suppliers; responsibility to employees and society, and basic ethics of employees. Specifically, Article 6 and Article 7 of the Code of Ethics stipulate principles of fair competition with competitors and fair transactions with our suppliers, respectively. The Code of Ethics Practice Guidelines are composed of six guidelines: fair trade, receiving money, improper solicitation, use of company assets, document manipulation, and basic ethics. These guidelines also provide the basis of judgment regarding ethical decisions and behaviors to our employees and stakeholders. Both the Code of Ethics and its practice guidelines are disclosed on our website and company portal.

Code of Ethics View Code of Ethics Implementation Guidelines View

Code of Ethics Practice Guidelines

01 Supplier selection and fair trade
If restrictions or adjustments to transaction terms are necessary, such restrictions or adjustments should be made following transparent procedures with clear and valid reasons. The company should strictly comply with fair trade and subcontracting laws and regulations when engaging in transactions with its suppliers. The company should not use its superior position to prevent unequal or unfair treatment or unpleasant behavior during transactions.
02 Acceptance of gifts and entertainment
Employees should not accept any form of gratuity, entertainment, or convenience provided by stakeholders regardless of the reason, and such instances should be reported to the company when it is inevitable to receive it.
03 Prohibition of improper solicitation and graft
Employees should not engage in any behavior that tarnishes the corporate image by improperly soliciting or providing graft to public officials.
04 Use of company assets
Employees must use the company’s critical assets, including tangible and intangible assets, confidential information, and company funds, for authorized purposes contributing to sound business activities. Employees should comply with the company’s standards and are responsible for preparing for the loss, misuse, and theft of company assets.
05 Documentation-count
manipulation and false reporting
All information must be recorded and reported accurately and honestly.
06 Other basic ethics for employees
Employees should serve as an example in maintaining a sound organizational culture.

Anti-Bribery and Compliance
Management Systems (ISO 37001 & 37301)

Hanwha Ocean pursued the certification of our anti-bribery and compliance management systems to establish and manage a risk prevention system concerning anti-bribery and compliance. The progress on risk identification and improvement is reported to the BoD each year. We recognize this as an important process of contributing to creating a culture of anti-bribery and compliance within the organization and demonstrating organizational transparency and credibility to our stakeholders, going beyond simply acquiring certifications.

In an effort to receive certifications for anti-bribery and compliance management systems, we have analyzed our regulations, identified obligations, and conducted a risk assessment since the second half of 2023. Following an internal review and supplementing problems in April 2024, we acquired the relevant certifications in May 2024.

Responsibilities of officers and managers

Anti-bribery and compliance officers and compliance teams perform a critical function within organizations. They contribute to nurturing a healthy organizational culture and minimizing legal risks by operating and improving the overall anti-bribery and compliance management systems, providing advice and guidance, managing risks, and assessing performance.
Moreover, our internal auditors, monitoring managers, and risk assessors further strengthen the anti-bribery and compliance culture within the organization, and identify and manage risks in advance to minimize legal risks.

Strategy and tasks

We identified and implemented the following strategic tasks to achieve the goal of establishing a culture of anti-bribery and compliance management systems.

Strategy	Tasks
Sharing policies & goals throughout the company	Establishment and dissemination of anti-bribery and compliance policy, and improvement of employees’ awareness and understanding Employees’ pledge to practice ethics and compliance Sharing the company’s anti-bribery and compliance goals
Building a management system foundation	Establishment of relevant regulations and bylaws Composition of a relevant organization
Education and promotion to raise management awareness	Preparation of educational materials to strengthen awareness PR activities including campaigns related to anti-bribery and compliance management
Identification of obligations, and analysis and assessment of risks	Identification and management of anti-bribery and compliance obligations by person in charge Identification, analysis, and assessment of anti-bribery and compliance risks
Assessments and improvements based on management system requirements	Monitoring by person in charge Internal audits Corrective and improvement actions for violations and non-conformities Reporting the management assessment results to the CEO and BoD
Acquisition and maintenance of ISO 37001 & 37301 certifications	Planning and implementing activities to fulfill and upgrade ISO 37001 & 37301 requirements

Anti-Bribery and Compliance Policy
Hanwha Ocean co., Ltd. shall establish and enforce the Anti-Bribery and Compliance Policy to cultivate a healthy corporate culture through ethical and compliance management, fulfill its social responsibilities, and become a transparent and trustworthy global company.
1. 1
  The company, its employees and executives shall adhere to all applicable regulations, including domestic and international anti-Bribery laws, compliance requirements, and internal company policies. They shall not engage in any actions that violate or could be perceived as violating these regulations.
2. 2
  Employees and executives shall not offer or accept any money, valuables, gifts, or bribes to or from any interested parties in the course of their duties and shall not participate in any corrupt or illegal activities.
3. 3
  Employees and executives are responsible for managing compliance issues and reporting them to the compliance officer.
4. 4
  The company shall establish a system for reporting corrupt activities or violation of compliance obligations by employees and executives, ensure the confidentiality of the report details and the reporter’s identity, and provide protection against any form of retaliation for making such reports.
5. 5
  The company may impose disciplinary actions in accordance with its internal policies if an employee violates compliance obligations, including bribery-related offenses, or fails to take reasonable steps to prevent such violations even though the employee was aware of the misconduct.
6. 6
  The company shall grant the compliance officer the authority and independence to operate the anti-bribery and compliance management system, and the compliance officer is required to provide direct and regular reports to the governing body.
7. 7
  The company shall establish, operate, and continuously monitor and improve an effective anti-bribery and compliance management system to achieve the goals and objectives of anti-bribery and compliance management.

Compliance Officers

and Compliance Control Regulations

Hanwha Ocean practices compliance management so as to protect the company and our employees. We ensure that our employees comply with relevant laws and regulations required to conduct their duties, thereby preventing violations of laws in advance and minimizing the risk of violations.
We have the Compliance Control Regulations in place to promote fair and transparent execution of duties, secure the company’s sound development, and gain customer trust by complying with relevant laws and regulations. Compliance officers are appointed through board resolution in accordance with Article 542-13 (Compliance Guidelines and Compliance Officers) of the Commercial Act.
The Compliance Office carries out activities to support the compliance officers. It conducts compliance risk checks, provides education and daily compliance support (legal advice), and operates an online whistleblowing system. The main activities of compliance officers and the results are disclosed in our business reports.

Other Ethics and Compliance Systems

Hanwha Ocean operates various ethics and compliance programs to instill a corporate culture of ethics and compliance with the law in its employees. Our main ethics and compliance programs are as follows.

Program	Description
Ethics PR	Promotion of the company’s ethics policy and disciplinary actions against unethical behavior through the in-house newspaper (Ocean View)
Ethics campaigns	Campaigns against accepting holiday gifts, etc.
Voluntary registration of gifts and solicitation	Encouraging employees to voluntarily register improper gifts and solicitation provided by stakeholders The list is used to carry out preventive activities such as identifying problems and managing vulnerable areas
Ethical compliance obligations as contract terms	Requiring suppliers to implement ethical compliance practices as a condition of the agreement
Sanctions against corrupt and unethical suppliers	Imposing sanctions such as warnings and suspension of business transactions on corrupt and unethical suppliers who violate ethical management obligations

Management
Assessment

To strengthen ethical management, Hanwha Ocean conducts various management assessment activities including compliance checks on regulations and financial records, review of business fairness, and detection of misconduct. The assessment results are reported to the Audit Committee.

Classification		Description
Process and business improvement	Periodic assessment	Compliance with regulations, policies, and plans Accuracy of the company’s financial records and calculations Highlights and improvement recommendations on business regulations and systems Review of the fairness and validity of work performance Checking on the management status of company assets Detection of irregularities, errors, falsehoods, etc. * The scope of assessment includes the company and its subsidiaries
	Lifetime assessment	Management assessment directed by management
	Occasional assessment	Occasional assessment conducted based on reports on specific tasks or matters deemed necessary after the management assessment
	Implementation check	Checking the implementation status of improvement items from the previous assessment
Prevention of unethical behavior	Online whistleblowing system	Receiving and investigating reports of unethical behavior
	Prevention of gift acceptance	Distribution of guidelines and reporting channels for prohibiting gift acceptance during holidays, etc.
	Activities directed by management	Investigation of unethical behaviors and risks as directed by management, etc.

Legal Review Process

At Hanwha Ocean, we conduct activities related to legal affairs, including legal reviews and litigations, through our legal system. We prevent violations of laws in advance through legal consultations on a daily basis.

Legal review process

Litigation process

Sustainability report

Ethics and Compliance

Ethics and Compliance