Action Guidelines - SPC


We contribute to the national interest and people’s welfare through happy sharing.

We create new customer value, faithfully fulfill fair trade with business partners, the development of national and local communities, and our responsibilities and obligations for shareholders and employees, and achieve fairness in work and transparency in the management according to our values to improve international competitiveness and become a top-notch company. Accordingly, we have enacted the Code of Ethics as below and imprint it as a standard for all executives and employees’ actions and value judgments.

The Purpose of the Action Guidelines

The purpose of this ‘Ethical Management Action Guidelines’ is to provide the appropriate behavioral guidelines for each situation in relation to the application of the Code of Ethics and present the standards for specific action plans according to the Code of Ethics.


1. ‘Money’ refers to cash, securities and other economic benefits.
2. ‘Entertainment’ or ‘hospitality’ refers to benefits such as meals, drinking, sports, and entertainment.
3. “Convenience” means provided transportation, accommodation, tour information and events, excluding money or entertainment and entertainment.
4. ‘Stakeholders’ refers to all internal and external natural persons, corporations, and organizations that are affected by their tangible and intangible profit or loss due to the actions or decision-making of executives and employees related to company work.

Accepting Money or Valuables (as Gifts) from Stakeholders

A. Giving or accepting money
1. When a stakeholder gives money, it must not be accepted. It must not be requested or promised. And if it is unavoidably received, it must be returned in polite declination.
2. In case money has been received inevitably, submit a ‘Report of Money Received for Convenience’s Sake’ through the groupware.
– Send or return money to the stakeholder or affiliated company that provided the money through an instrument that can prove its return to the recipient.
– A letter that cites the reason why money is being returned and expresses thanks for the good intention and urges that the same thing do not repeat in the future has to be sent to the representative of the stakeholder with a copy of the deposit slip under the name of an executive.
– When receiving the ‘Report of Money Received for Convenience’s Sake’, the result of processing such as a letter or a copy of the deposit slip without a bankbook must be attached as evidence.

B. gift giving
1. In the case of a gift from a stakeholder, the employee must politely decline and return it (in the case of promotional items or discounts, the employee can accept them as long as they are acceptable to anyone, but intentional benefits are considered gifts) .
2. If the employee is unaware that a gift has been given from a stakeholder, or if it is rude to refuse or return it immediately, the employee must handle it as follows.
– The gift recipient files the ‘Gift and Benefit Reception Report’ through the groupware.
– If it is difficult to return the gift received, the employee must provide it to a nearby social welfare facility in the name of the gift provider or the company representative and receive proof of donation.
3. Receiving gifts from overseas customers is handled in the same way as in domestic cases.
– Gifts exchanged with overseas business operators when contracting or partnering with foreign companies are handled in the same way as in the general stakeholders’ gift acceptance procedures by setting the market price of 100,000 won as the limit.
– If it is difficult to convert the exact market price of a modest gift, it is up to the judgment of the Ethics Management Secretariat.
4. If it is difficult to judge because it is not specified in other guidelines, it is decided and handled in consultation with the Ethics Management Secretariat.”

C. Giving and receiving gifts
1. When a stakeholder gives a gift, it must be returned in polite declination (promotional goods or discounts may be received, but an intentional benefit shall be considered a gift).
2. If you are unaware that a gift has been given by a stakeholder, or if it is rude to refuse or return it immediately, you must handle it as follows.
– The gift recipient files the ‘Report of Money Received for Convenience’s Sake’ through the groupware.
– If it is difficult to return the gift received, it must be donated to a nearby social welfare facility in the name of the gift provider or the company CEO in exchange for proof of donation.
3. In the case of gifts received from overseas customers, they shall be treated in the same manner as in Korea.
– Gifts exchanged with overseas business partners when contracting or partnering with foreign companies shall be handled in the same way as for ordinary stakeholders, by taking the market price of 100,000 won as the reference line.
– If it is difficult to calculate the exact market price of a gift, it is subject to the judgment of the Ethics Management Secretariat.
4. If it is difficult to judge because it is not specified in other guidelines, a decision shall be made and the matter shall be handled in consultation with the Ethics Management Secretariat.

D. Prohibition of cost shifting (act of shifting cost burden as for a dinner party)
1. An employee shall not treat a customer or call a stakeholder out to a corporate dinner to let the person cover the cost or let him or her pay the price by showing the person a receipt.
2. If you meet a stakeholder by chance at a corporate dinner, etc. and the stakeholder goes ahead and picks up the tab, cancel the payment to make it null and void. If it is impossible, report it to a higher-level manager and, depending on the case, handle it as a personal expense or get it recognized as a corporate expense, and then return the money to the stakeholder.

E. Entertainment and treatment
1. With the approval of a senior manager, customary entertainment such as meals and wholesome entertainment for business cooperation is acceptable, but the amount must be less than 30,000 won per person. It should not exceed 200,000 won per case (for multiple people and the total amount for 24 hours).
Acceptable only if not prohibited by law or industry practice.
2. Even meals for business cooperation should be avoided or sanctioned if the price exceeds the prescribed limit or if it is feared to transform into prohibited types of entertainment (meals or dinners that exceed the limit, use of luxury entertainment establishments, gambling, etc.).
3. In case of an official meeting or an event with prior approval of the company, an employee shall not be treated to sporting events such as golf or skiing at a stakeholder’s expense.
4. If you have received entertainment and/or treatment provided by a stakeholder, you must report it according to the ‘Entertainment and Treatment Report’ (Attached Form 1), regardless of whether the limit is exceeded (however, food and beverages under KRW 5,000 are an exception).

F. Conveniences Provided
1. An employee must not request or accept conveniences from a stakeholder.
2. It is permitted only so long as the content of the provided convenience is not prohibited by law or custom, when it is provided to a large number of people, or when it overlaps with the use of a stakeholder (shared ride).

G. supplies provided
1. In the case of relocation, a transfer at work, etc., support (cash or goods) from a stakeholder must not be received.
2. When notifying stakeholders of relocation or a transfer at work as needed by company operations, care must be taken lest stakeholders feel burdened by including manifest declination of money or valuables through the notice.
3. If a stakeholder has provided money without recognizing the above, only items for common use (wall clock, flowerpot, mirror, etc.) under 50,000 won are allowed, and in other cases, it must be returned politely.

H. Sponsorship/support provided
1. During in-house events such as picnics, sports competitions, and workshops, sponsorships in the form of cash, goods, and transportation must not be received from stakeholders.
2. Notifying stakeholders in advance by notifying or publicly mentioning the implementation of an event is also considered an intentional act to receive sponsorships.
3. In case it is necessary to invite or accompany stakeholders due to the nature of an event, prior approval of the company must be obtained to notify them, but the notification must declare that no support or money will be accepted.
4. If a stakeholder brings money or valuables in excess of 50,000 won, it must be returned. For small items (drinks, etc.) worth less than 50,000 won, the company policy must be sufficiently communicated and thanks should be expressed to the stakeholder by the event manager, lest such offers reoccur. At the same time, details must be shared with the Ethics Management Secretariat.
5. In the case of an event hosted by a stakeholder, it must be for business purposes and employees must obtain prior approval from the company before participating in it. If the event is feared to deviate from the purpose of the business or transform into entertainment and benefits, participants must avoid or sanction it.

I. Borrowing, buying at a low price, selling at a high price
1. No assets may be leased or provided as collateral from stakeholders for the convenience or profit of the employees themselves and/or their immediate family.
2. Obtaining real profits by receiving movable or real estate free of charge, purchasing it at a price lower than the standard price, or selling it at a higher price is prohibited, and such an act is regarded as money or valuables.

I. Debt Repayment and Loan Guarantee
1. You must not ask for payment or repayment of debts (credit card debt, price of goods sold on credit, loan, etc.) or accept an offer to such an effect.
2. When taking out a loan (regardless of the type of loan), you must not ask for the guarantee or collateral from a stakeholder or accept an offer, and when you do it, it shall be considered an act of giving or accepting money or valuables.

J. Lending or borrowing money
1. Employees and their immediate family cannot borrow money from or lend money to stakeholders.
2. Any acts in lending or borrowing money and paying or receiving interests accordingly shall be deemed to be the giving and accepting of money or valuables regardless of the reason.

K. Guaranteed action
1. An employee shall not demand or accept offers from stakeholders for any kind of promise, such as employment after retirement or job placement.
2. An employee shall not demand or accept a promise or offer from stakeholders to guarantee benefits, such as planning a business deal after his or her retirement.
3. When receiving the above offer from a stakeholder, report it to the executive immediately and report it to the Ethics Management Secretariat.

Employees’ Unfair Equity Participation in Companies That Do Business with the Company

A. Stock Transfer and Investment
1. An employee’s holding of stocks in the companies owned by stakeholders related to his or her job (including if there is no current transaction), except for affiliates, is prohibited.
2. In case you inevitably become a holder of stocks, immediately sell them. You shall not engage in buying or selling such stocks in the future.
3. If the holding of undisposed stocks is detected, it will be judged as a violation of the Code of Ethics (Including borrowed-name management stocks)

I. common investment and acquisition of common property
1. When an executive or employee and their immediate family jointly acquire movable or real estate by jointly investing funds with a stakeholder, it shall be deemed that an amount equivalent to the stake has been received from the stakeholder.
2. If a joint investment was made due to personal acquaintance before the establishment of a business relationship with the company, the fact shall be reported to the department and the Ethics Management Secretariat, and the employee’s stake should be disposed of.
3. In any case, it is strictly prohibited to register as an executive in a stakeholder’s company, or to act concurrently or to perform actual work for it.

Misconduct in Selecting Suppliers

A. Fair opportunity
1. Restriction of participation: To select specific suppliers or exclude companies to be avoided
– In case of exclusive selection of transaction conditions such as price and quality
– In case the transaction area is circumscribed without any compelling reason
– In case business partners are limited for inappropriate reasons
2. Discrimination: to give preferential treatment to preferred companies or to disadvantage companies to be avoided
– Applying different delivery prices or applying different quality conditions
– In case the transaction volume is adjusted or transactions are prioritized through collusion
– In case a specific company is advocated in order to protect an employee’s previous employer and maintain his or her relationship with retirees, school alumni, hometown acquaintances, etc.

B. Unfair trading practices
1. Unfair transaction: When a reason for changing the contract conditions occurs within the contract period, unilaterally adjusting the transaction conditions without prior consultation or deliberately delaying payment etc.
2. Unfair support: unfairly providing support for the purpose of securing the superiority of a specific supplier
– Providing funds or manpower to a specific company without justifiable reasons
– Transferring company equipment or leasing them at a low cost or free of charge
3. Business interference: intentionally obstructing the business activities of a supplier
– Unfair use of suppliers’ technology, manpower, and facilities
– Maliciously obstructing transactions with competitors
– Leaking information of suppliers without permission
– Other acts in interfering with the company business to cause disadvantages to it

Misuse of Company Assets

1. No assets of the company may be used for personal purposes, and if unavoidable, report this to the manager and reimburse the company for the expenses incurred due to the use of the assets in accordance with the accounting regulations (samples provided for business purposes are also included in the company’s assets).
2. An employee shall not conduct business for the purpose of personal profits or assist in the work of other companies by using information or knowledge acquired through position or duties.
3. Incurring financial loss by borrowing public funds, or diverting public funds for personal use, regardless of whether they are returned or not, is not permitted.
4. Falsely claiming expenses that have not actually been incurred is a violation of the Code of Ethics.

Guidelines for Using Corporate Credit Cards

1. Corporate credit card users must comply with the company’s “Corporate Credit Card Management Regulations” to settle expenses.
2. Use of a corporate card is limited to expenses incurred during company work.
3. Restricted items
a. Use of corporate credit cards is prohibited for decadent pleasures and entertainment, amusement with elements of gambling, or private purposes
– ‘Room salons’, karaoke pubs, hairdressers, massage parlors, gambling halls, game halls, golf driving ranges
b. Lending a corporate credit card to other people such as family and friends is prohibited.
c. Late night, Sunday, holiday use near an employee’s private residence (for transactions for private use suspected).
4. When an item for which the use of a corporate credit card is restricted is detected, the credit card shall be cancelled, reissuance shall be restricted, and the person involved shall provide clarification to the Ethics Management Secretariat (taken to the Personnel Affairs Committee if necessary).

Manipulation of Documents and False Reporting

1. Counts and details must be accurately and honestly written for all documents that record information or are reported or received by the company.
2. It is equally regarded as an offense for a senior employee to instruct the manipulation of documents or counts and for a subordinate or instructed person to connive at it, knowing that it is an illegal manipulation.
3. False or distorted information shall not be reported to the top management or management diagnosis organization (Integrity Management , etc.).
4. Inaccurate information shall not be delivered to outside corporations or staff whose involvement is authorized.
5. Selling products or providing services to customers or making false or misleading statements to them is also considered as an offense.
6. Deliberately manipulating information for the purpose of misleading its recipient is also considered as an offense.


1. An employee must not cause any loss to the company by not performing the duties assigned the person by your position/rank (or the duties assigned through instructions).
2. An employee must take responsibility for the results of his or her work given by his or her position/rank.
3. An employee shall fulfill the duties of management and supervision of subordinates.
4. Subordinates should not be given unreasonable instructions that have nothing to do with the company’s work.
5. An employee shall not make arbitrary decisions or make official promises to external parties that go out of the scope of his or her work.
6. An employee must not influence the performance of his or her duties or damage the reputation of the company through sexual promiscuity in private life or generally unacceptable behavior.
7. When talking with stakeholders outside the company, the counterparty, location, and purpose of the meeting must be reported to the senior manager in advance, and in the case of an accidental meeting, the same report must be made immediately upon return to work.
8. When attending an official event outside the company, or attending a forum or training as a panelist or lecturer, an employee must obtain prior approval from the company.
9. An employee must not violate Improper Solicitation and Solicitation Act or related laws, or make improper solicitations that deviate from normal trading practices.
10. An employee must not provide any form of tangible or intangible money or valuables to stakeholders.