Policy & Strategy

Implementation of Ethical Management LS MnM has implemented ethical management practices by establishing a code of ethics that encompasses ethical management regulations and guidelines for reporting bribery, as well as introducing compliance systems like the Legal Risk Map and WeLS Legal Advisory System. Moreover, we have made our ethical management and basic ethical guidelines available to our employees, promoting participation from all stakeholders in ethical management practices. We are committed to creating a fair work culture by making ethical responsibilities a fundamental duty of our employees through the establishment of ethical management and practice guidelines.

Ethical · Compliance Management Chart

Ethical Management Philosophy • LS MnM Inc. shares the vision of ‘Valuable Partner in Metals & Materials’ and promotes autonomous management based on autonomy and responsibility.
• We strongly support free and fair competition and prioritize mutual benefit, fostering a relationship with stakeholders built on mutual trust and cooperation. Through these efforts, we aspire to become a world-class superior company.
• Thus, we establish a code of ethics as a benchmark for ethical conduct for all employees to adhere to, and pledge to practice in our work environment.

Ethical Management Practice Guidelines

Basic Ethical Guidelines for Employees

Internalization of Compliance Management Our company avoids potential violations of laws by utilizing Robotic Process Automation(RPA) and legal risk maps to thoroughly examine work-related laws and regulations. Furthermore, our employees seek law-related advice from the legal team with the legal advice system when necessary. To comply with disclosure obligations stipulated in the Commercial Act and the Fair Trade Act, we have established the Regulations of Board of Directors and disclosure information guidelines. The Business Management Team and Finance Team then prepare for board meetings in accordance with the management guidelines. In the event of significant internal transactions occurring between affiliate companies, we request the board to review and approve the transaction in advance. Our board members strive to protect the interests of the company and uphold a fair market economy.

Organization

Our Legal Affairs Team is an independent management organization dedicated to ethical & compliance management. Comprised of lawyers and legal experts, they specialize not only in ethical management and compliance, but also oversee training related to the interpretation of ethical management guidelines and practices, including anti-corruption measures. Our employees work according to ethical management guidelines and receive feedback from the legal team to ensure compliance. Moreover, employees have the option to report any unethical behavior, both inside and outside of the company, through an online reporting system. Acts of bribery are handled in accordance with the procedures outlined in the bribery system guidelines. If an employee violates ethical management regulations, HR Development Committee will investigate and review the matter according to company policy. If the employee wishes to file an appeal, the disciplinary action will be reconsidered. The Legal Affairs Team is responsible for drafting legal practice regulations, scrutinizing contracts, and serving as the company's legal counsel.

Performance

Efficient Reporting System All stakeholders of LS MnM can easily report illegal and unethical management activities via our online reporting system. Anyone can also report directly to the Legal Affairs Team via phone, email, or fax, and the report can be made anonymously. We not only carefully examine and investigate each case, but also proactively seek out improvement measures based on our findings. If a partner company engages in an act of bribery, our employees take appropriate action in accordance with our bribery reporting guidelines. We also require our employees to report any bribery attempts, regardless of whether they were accepted or not.

Spreading Ethical Management LS MnM engages in various activities to encourage external stakeholders to partake in ethical management practices. We mandate that all domestic partners entering into new contracts with LS MnM sign an ethical management agreement. In 2022, we established the Business Partner's Code of Conduct to extend ethical management practices to our raw material suppliers and customers. The Code consists of 21 codes across seven key areas: human rights, environment, supply chain management, ethical management, safety, labor rights, and society. We include the Code in the contracts with our new business partners and encourage them to practice ethical management together.

Fair Trade Compliance LS MnM adopted the Fair Trade Compliance Program through a board meeting in March 2023 and established necessary guidelines, including a compliance manual. Moreover, we are dedicated to promoting fair trade compliance by implementing measures in which all members can participate. These measures include the CEO's expression of strong commitment to fair trade compliance and requiring all employees to sign the compliance agreement.

Ethical and Compliance Training LS MnM conducts annual training sessions on ethical and compliance management for our employees to prevent instances of unethical behavior or misconduct while performing their job duties. In accordance with Article 13 of the Act on Gender Equality in Employment and Support for Work-Family Harmony and Article 3 of the Enforcement Decree of the Act, we conduct sexual harassment prevention education in the workplace once a year. Furthermore, to protect the personal information of customers and employees, we conduct training once a year under Article 28(2) of the Personal Information Protection Act. We have established online training courses to implement fair trade practices. Professionals are required to participate in the training courses every year, and the first training was conducted in June of this year. In addition, we provide win-win cooperation education for the procurement team, relevant departments, and affiliates. The education covers legal training on the subcontracting law, which mandates non-disclosure agreements in the process of acquiring skills, as well as promoting win-win cooperation among stakeholders.

Ethical Management Assessment LS MnM regularly administers an organizational culture survey to all employees to assess their ethics and compliance practices. In addition, we add ethical management section to the annual employee leadership evaluation to evaluate the degree of individual compliance with ethical management. We use the assessment results to review and enhance the ethical management awareness of our employees.

Third-party Compliance Assessment In September 2022, LS MnM conducted a survey for suppliers and customers to assess the company's fair trade compliance status. To ensure fair trade practices with our suppliers and customers, we have developed survey questions based on the Code of Ethics Practice Guidelines established in 2010. The survey was designed using multiple-choice questions, assigning a score of 100 points for a positive response(Yes) and 0 points for a negative response(No). It was conducted online through an independent third-party organization to ensure anonymity and objectivity. The survey results indicated a fair trade satisfaction score of over 93 points, suggesting that the majority of our suppliers and customers are confident fair trade practices are being ensured. In addition, it was revealed that the suppliers and customers put great importance to complaint handling when it comes to creating a fairer trade environment. Based on the assessment results, LS MnM will continue to prioritize creating mutual benefits with stakeholders by improving accessibility to our online reporting system.