Pulmuone Code of Conduct

 

To put its principles of ethical and compliance management into practice, Pulmuone operates the “TISO Management System” and has established the “TISO Management Policy” to provide institutional support. As the company’s highest-level ethics policy, TISO policy present the philosophy, principles, and overall direction of TISO Management. Subordinate regulations include the TISO Code of Conduct which sets behavioral standards for employees; the Code of Practice for TISO Management which provide practical guidance for applying these standards to business operations; and TISO Operational Provision which define the responsibility structure and procedures for operating the system within the organization. In addition, alongside the TISO policy, Pulmuone maintains separate ‘Respect for Human Rights Operational Provision’ which sets practical standards for realizing human-centered ethical management focused on human rights and ethics.

 

Composition of Code of Conduct

 

 

 

Details of Code of Conduct

 

Each code of conduct addresses specific details according to its role and characteristics. The following are the key topics covered by each code of conduct.

 

 

■ TISO Policy   ※ The full text can be found here.

 

Article 1 (Purpose) The purpose of the TISO Policy of Pulmuone and its affiliated companies (collectively, “Pulmuone”) (the “Policy”) is, for the prevention of corruption, the creation of a clean and sound business culture, and the protection and promotion of human rights, to set forth the standards of ethical value judgment and conduct that Pulmuone employees must observe, pursuant to Article 8 of the Act on the Prevention of Corruption and the Establishment and Management of the Anti-Corruption and Civil Rights Commission, Article 2 of the National Human Rights Commission of Korea Act, Pulmuone’s TISO Management Charter and the TISO Code of Conduct. These Regulations constitute the ethical code of conduct for Pulmuone employees.

 

Article 2 (Scope of Application) These Regulations apply to all employees and dispatched workers of Pulmuone (collectively, the “Employees”). Pulmuone shall reflect matters related to compliance with these Regulations when entering into worker-dispatch agreements with dispatching agencies.

 

Article 4 (Responsibilities of Pulmuone)

① Pulmuone shall endeavor to create working conditions that enable employees to perform their duties fairly and with integrity.

② Pulmuone shall take measures to effectively identify and manage conflicts of interest so that employees are not hindered in performing their duties fairly and with integrity due to private interests.

③ Pulmuone shall strive to protect and promote the human rights of employees and to establish working conditions under which they can perform their duties.

④ Pulmuone shall take appropriate protective measures, in accordance with internal regulations on the protection and reward of public-interest whistleblowers, to ensure that employees do not suffer any disadvantage as a result of reporting violations or taking other actions under these Regulations.

 

Article 5 (Duties of Employees)

① Employees shall perform their duties fairly and with integrity, uninfluenced by private interests.

② Employees shall act impartially in the performance of their duties and shall not give preferential treatment to or discriminate against any stakeholders.

③ If employees determine that fair and honest performance of their duties is difficult due to private interests, they shall prevent conflicts of interest by, for example, recusing themselves from performing the relevant duties.

④ Employees shall respect the human rights of all stakeholders in relations to their duties and shall not engage in any acts that infringe upon human rights.

 

Article 10 (TISO Management Education and Programs)

① The CCO (Chief Compliance Officer) shall establish and implement education, and program plans to ensure compliance with these policy for all employees and shall record and manage the results.

② All employees must complete TISO Management education at least once a year. For employees who have violated these policy, the CCO may order education through relevant professional institutions. However, those who have been subject to disciplinary action due to misconduct must complete the said education within six months.

③ All employees must complete human rights education at least once a year.

④ All employees must complete sexual harassment prevention education at least once a year.
⑤ All employees must complete workplace harassment prevention education at least once a year.

 

Article 11 (Operation of Whistleblowing System)

① The company shall operate whistleblowing system to ensure the smooth implementation of TISO Management.

② All employees must report any of the following acts they become aware of in accordance with the procedures prescribed in these policy.

 

 

③ If a false report is made with the intent to defame or harm another employee, the reporter shall be excluded from the benefits of rewards and confidentiality protections under these policy and shall be treated as a violator of TISO Management-related regulations.

④ Reports may be submitted to the CCO or the dedicated department(s) by email, postal mail, telephone, in-person visit, or use of the Cyber Audit Office—whichever method is most convenient for the reporter. 

   1. Reports of human rights violations: Respect for Human Rights Department

   2. Reports of sexual harassment or sexual violence: Gender Equality Center

   3. Reports of workplace bullying: Grievance Counseling Center

   4. Reports of other violations of TISO policy: Internal Audit Department  

⑤ Upon receipt of a report, the CCO or relevant personnel shall promptly conduct an investigation and report the results to the CEO or General Manager. However, if a report is anonymous and lacks clear evidence, an investigation may not be conducted.

 

Article 18 (Disciplinary Action)

① The CEO shall take necessary disciplinary actions against any employee who violates these policy.

② The types, procedures, and effects of disciplinary actions under paragraph ① shall follow Pulmuone’s disciplinary regulations. However, if any disadvantage or retaliation is inflicted on a reporter in violation of Article 11 or Article 19, aggravated disciplinary action may be taken.

 

Article 19 (Protection of Whistleblowers, etc.)

② Confidentially shall be guaranteed regarding whistleblowers and the content of reports under Article 15, and no retaliatory measures shall be taken against the whistleblowers or others for reporting or related actions, including but not limited to the following:

 

 

Article 22 (Prohibition of Collusion with Competitors)

① Employees shall not engage in consultations or collusion with competitors regarding business secrets such as pricing policies or sales conditions through means prohibited by the Fair Trade Act or other relevant laws.

② When obtaining information about competitors or other companies, employees must acquire such information through lawful and ethically appropriate methods and shall not use it illegally or unfairly.

 

Article 23 (Fair Contracting and Execution)

① Employees must perform bidding, contracting, and contract execution fairly and transparently in accordance with procedures prescribed by relevant laws and regulations.

② Employees must strictly comply with the Fair Trade Act in transactions with partner companies.

③ Employees shall not exploit their superior position in bidding, contracting, or contract execution to demand prohibited money or valuables, impose unfair transaction conditions, or make improper requests such as interference in management.

④ In bidding and contract awards for construction, services, or purchase of goods conducted by Pulmuone, employees must provide equal opportunities to all qualified individuals, corporations, or organizations and must not grant preferential treatment to retired employees or organizations operated by retirees of Pulmuone.

⑤ Employees must not coerce the contracting party to purchase or use goods, equipment, or services designated by the employees, except for legitimate reasons such as maintaining or improving the quality of the contracted items.

 

Article 26 (Prohibition of Inappropriate Transactions with Stakeholders)

① No employee shall request or accept any form of promise guaranteeing contract agreements or comparable benefits from stakeholders.

② Employees shall not borrow money from stakeholders (including themselves, family members, relatives, and friends) nor request payment or repayment of debts (such as credit card bills, accounts payable, loans, or interest).
③ Employees shall not request or accept guarantees for loans from stakeholders, regardless of the type of lending institution.

④ Employees, their family members, relatives, or friends shall not loan money or other assets to stakeholders and receive interest, rent, or other income therefrom.
⑤ Employees shall not invest jointly with or acquire property jointly from stakeholders. Even if the joint investment or acquisition is made under the name of the employee, their family members, relatives, or friends, it shall be deemed an act of the employee.

 

Article 27 (Declaration of Interests, etc.)
① Employees performing any of the duties listed below who become aware that an interested party (including the interested party's representative, hereinafter the same in this Article) has a private interest must report this fact to the CEO within 14 days from the date of awareness and submit a request for appropriate measures and recusal.

 

Article 32 (Prohibition of Receipt of Money or Benefits)
① Employees shall not receive, request, or promise money or any benefits related to their duties, regardless of whether compensation is involved. They shall not directly or indirectly accept or condone improper benefits such as money, entertainment, favors, or gifts from stakeholders.

 

 

Article 33 (Prohibition of Receiving Entertainment or Demand for Sponsorship from Stakeholders)
① Providing money or entertainment to customers, partners, or other stakeholders in an excessive or inappropriate manner, directing such acts, or demanding or coercing improper sponsorship shall be considered unfair practices.

 

Article 48 (Prohibition of Use of Confidential Information and Protection of Customer Information)
① Employees shall not use confidential information or unpublished information of Pulmuone (referring to information learned during the performance of duties that has not been disclosed to the public and that could significantly affect the acquisition of property or financial benefits) to obtain property or financial benefits for themselves or allow a third party to obtain such benefits.
③ Employees shall not use confidential or unpublished information of Pulmuone learned during their duties for personal gain or allow third parties to use such information.
⑤ Customer information shall not be provided or disclosed to third parties except when written consent from the customer has been obtained or in accordance with methods and procedures prescribed by law. Internally, customer information must be managed so that no one other than authorized personnel can easily access it.

 

 

■ TISO Code of Conduct  

 

Chapter 1: Pulmuone Trusted by Customers

 

1. Trust with Customers

 - Always speak truthfully to customers and keep promises made to them.

 - Actively disclose facts that customers should know or rightfully need to be informed of.

 - Do not disclose customer information without their consent, nor use it for other purposes.

 

2. Customer Satisfaction

 - Continuously create genuine value that is practically helpful and satisfying to customers.

 - Provide the highest quality products and services desired by customers at reasonable prices.

 - Always listen carefully to customers’ opinions, believe that customers’ true needs are always right, and prioritize customer satisfaction in all decisions and actions.

 - Maintain various open communication channels so customers can easily present complaints or suggestions at any time and respond promptly and accurately to legitimate customer requests.

 - When interests of customers and the company conflict, prioritize thinking and judgment from the customer’s perspective.

 

3. Confidentiality of customer information

 - Customer personal information shall be used only within the scope of the customer's consent.

 - Employees, and related personnel handling customer information must comply with personal information protection guidelines and relevant laws.

 

Chapter 2: Attractive Pulmuone to Shareholders

 

1. Information Provision

 - Provide timely and accurate information through various channels to fulfill shareholders' right to know and demands for information disclosure.

 

2. Enhancing Corporate Value

 - Develop innovative and challenging management activities to increase future corporate value.

 - Establish innovative systems and secure competitive advantage and corporate value through transparent decision-making that leads the market.

 

3. Creating Shareholder Benefits

 - Respect shareholders’ investment returns and protect their interests by sharing fair outcomes.

 

Chapter 3: Pulmuone Loved by the Local Community

 

1. Compliance with Laws and Regulations

 - The company complies with relevant laws and regulations in all countries and regions where it operates, respecting customs, culture, and social values.

 

2. Environmental and Ecosystem Protection

 - Comply with environmental laws and continuously monitor changes in environmental regulations to proactively prevent possible violations.

 - Always consider the impact of the company’s business activities on the local environment and strive to protect it continuously.

 - Work to expand the use of environmentally friendly product containers and packaging materials.

 

3. Contribution to the Local Community

 - Strive to contribute to the development of local communities by promoting sound corporate activities.

 - The company makes efforts to support disadvantaged groups and participate in volunteer activities for the residents of communities where its business sites are located.

 

Chapter 4: Pulmuone in Partnership with Suppliers

 

1. Creating an Equal and Transparent Business Environment

 - The company does not use superior authority or dominant position to unjustly coerce or influence suppliers.

 - The company does not accept money, entertainment, or favors from suppliers.

 - The company does not leak technical information or trade secrets acquired through business relationships with suppliers nor use them for illegal gain.

 

2. Fair Selection of Suppliers

 - Provide fair opportunities to all suppliers.

 - Select suppliers transparently and fairly based on objective and reasonable criteria.

 - Avoid transactions with companies involved in accounting fraud, ethical or human rights issues, environmental pollution, safety and hygiene issues, or other illegal or unethical practices.

 

Chapter 5: Pulmuone, a Company where employees are happy

 

1. Basic Ethics

 - Employees understand the company's management philosophy, vision, goals, and values, and act with pride as Pulmuone employees.

 - Employees comply with company regulations in performing their duties.

 - Employees maintain ethical values and standards and strive to uphold the company’s honor and their personal dignity.

 - Employees fulfill their duties and responsibilities to ensure company safety and do their utmost to manage any risks or emergencies that occur.

 

2. Professional Ethics

 - Employees comply with moral standards, laws, company regulations, and principles.

 - Employees do not engage in unfair solicitation among each other.

 - Employees perform their duties fairly without being influenced by personal connections such as school ties, regional ties, blood relations, or external pressures.

 - Employees neither give nor receive money, gifts, entertainment, or hospitality related to their duties.

 - Company products, equipment, goods, information, and budgets are used solely for work purposes and are not used arbitrarily or fraudulently.

 

3. Confidentiality of Information

 - Employees do not engage in insider trading using non-public information and do not leak information obtained through work either internally or externally.

 - Employees recognize that information or knowledge acquired through work is the company’s intellectual property and strive to protect it, while also respecting the intellectual property of others.

 - Employees respect the privacy of each individual and do not engage in defamation or slander of others, nor do they leak personal information.

 

4. Respect and Fair Treatment (Renamed from “Respect for Employees and Non-Discriminatory Fair Treatment”)

 - No discrimination or harassment is tolerated based on race, nationality, gender, age, academic background, religion, region, disability, gender identity, or other factors.

 - Equal employment opportunities are provided to those who meet job qualifications and capabilities.

 - The company strives to eliminate authoritarian elements in work and human relations, creating an environment where all employees can confidently and autonomously carry out their duties.

 - Employees are fairly and objectively evaluated and rewarded based on their ability and performance, regardless of academic background, gender, or age.

 - The company provides equal opportunities for education, learning, and training to improve employees’ work capabilities.

 

5. Creating a Safe Work Environment

 - The company proactively inspects and prevents hazards that could affect employees and customers throughout the production, manufacturing, sales, and distribution processes.

 - Employees must report any improper work conditions or hazards to their supervisors or safety managers and strive to improve them to maintain a safe work environment.

 

6. Creating a Healthy Organizational Culture

 - The company shall strive to foster a culture of mutual respect and create an atmosphere where employees can freely express their opinions.

 - Employees shall endeavor to communicate and cooperate smoothly with colleagues and related departments.

 - Appropriate working conditions, such as maintaining reasonable working hours, shall be guaranteed to ensure employees can lead lives that preserve human dignity.

 

7. Efforts to Prevent Disrespect and Human Rights Violations

 - The company respects and supports internationally recognized human rights standards such as the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN Global Compact, and the OECD Guidelines for Multinational Enterprises.

 - Employees shall avoid behaviors or speech that cause discomfort or disrespect to others and shall strive to uphold basic courtesy.

 - Based on gender equality, employees shall recognize and consider physical differences between men and women.

- Acts such as sexual harassment that contradict social norms and company standards shall not be committed.

 -Employees shall not engage in behaviors that cause physical or mental harm by exploiting hierarchical advantage.

 

 

■ Code of Practice for TISO Management   ※ The full text can be found here.

 

Article 5 (Prohibition of Discriminatory Treatment)  All stakeholders of the company must be treated without discrimination or unfairness, and work must be conducted ethically and transparently.

 

Article 6 (Handling of Unfair Work Instructions)  Unfair work instructions must never be followed under any circumstances, and the company must not suffer losses as a result of such instructions.

 

Article 7 (Collusion with Competitors)  Engaging in consultations or collusion with competitors regarding business secrets such as pricing policies or sales conditions constitutes a hazardous act that may pose significant risks to the company and is subject to severe disciplinary action.

 

Article 10 (Protection of Stakeholder Information)  All information provided by suppliers for business transactions must not be disclosed externally without the approval of the supplier’s representative. In particular, providing key information to competitors must be avoided as it may harm their business activities or cause issues such as employee poaching.

 

Article 13 (Receiving Entertainment from Stakeholders) Receiving meals or being entertained with drinks at pubs or similar places from stakeholders is a representative example of accepting entertainment. In particular, suggesting or requesting such entertainment from stakeholders constitutes a deliberate wrongful act subject to severe disciplinary action.

 

Article 16 (Prohibition of Unfair Practices from Stakeholders) No abnormal acts that may hinder the fair performance of duties by oneself or others are permitted. This includes receiving money or gifts, solicitation of favors, preferential treatment, and any acts imposing undue burdens on related parties.

 

Article 21 (Prohibition of Illegal or Improper Use of Company Assets) Any acts of obtaining personal gains related to work performance are prohibited. This includes all cases involving position, use of facilities, or information.

 

Article 22 (Handling of Work for Personal Gain) Acts such as improper record keeping, irregular business operations aimed at inflating performance, falsifying evidence, or arbitrary changes in account titles are unfair practices prioritizing personal gain over the company’s interests.

 

Article 32 (Confidentiality of Whistleblower Identity) The company protects the confidentiality of whistleblowers’ reports and personal information and ensures they do not face disadvantages.
1.  When whistleblowers request the change of workplace, the company strives to reflect this as much as possible to protect their identity.

2.  If a staff member cooperating with investigations suffers or is at risk of suffering disadvantages, they are protected as whistleblowers.

3.  Anyone obliged to protect the whistleblower’s identity who violates this duty will be punished.

4.  Compensation procedures for whistleblower protection are as follows:

 - To prevent identity exposure during compensation payment, the audit officer receives the payment, guaranteeing confidentiality, and delivers it according to the recipient’s preferred method. Details about the actual recipient are not recorded in company books.

5.  Prohibition on disclosure of whistleblower identity: Any employee who becomes aware of a whistleblower’s identity through work or otherwise must not disclose it.

6.  Prohibition of efforts to identify whistleblowers: Departments or personnel related to the accused and others must not inquire of the audit department or engage in any activities to identify whistleblowers that may reveal their identity.

7.  Prohibition of identity disclosure by auditors: Without the whistleblower’s consent, the identity of the whistleblower or cooperating persons must not be revealed or implied. Violation of this duty is punishable.

8.  Investigation of exposure routes: If a whistleblower’s identity is exposed, the audit officer must be notified. The audit officer will investigate the exposure route and request punishment of the responsible party.

9.  Prohibition of disadvantages and management of assignments: Disadvantageous personnel actions against whistleblowers are strictly prohibited and subject to penalties. If disadvantages are anticipated, personnel actions such as reassignment will be managed, including a period of work in audit before transfer to a different department.

 

 

■ TISO Operational Provision   ※ The full text can be found here.

 

Article 2 (TISO Management Operating System)
① The company shall appoint a CCO (Chief Compliance Officer) who oversees the TISO Management across the entire company. The CCO is appointed by the General CEO after review by the Human Resources Committee.
② To assist the CCO and perform related tasks, the TISO Management Secretariat (hereinafter referred to as the “Secretariat”) is established as an organization directly under the CCO.
③ TISO Leaders are assigned within affiliated business units to perform TISO Management-related tasks. Depending on the characteristics of each business unit, separate appointments of TISO Leaders may be made at individual sites as needed.

 

Article 3 (Duties of the CCO)
① The CCO shall perform duties with the care of a prudent manager.
② The CCO shall establish systems and frameworks for the operation of TISO Management in the company.
③ Upon discovering any violations of regulations related to TISO Management, the CCO must investigate and report the findings to the General CEO.

 

Article 4 (Authority of the CCO)

① The CCO may attend and speak at meetings such as the Board of Directors, Audit Committee, and Management Meetings, and may directly report on important matters.
② The CCO may request employees to inspect or submit materials and information deemed necessary to perform duties, and employees must comply in good faith.
③ The CCO shall inspect compliance with TISO Management-related regulations, investigate violators, and may request improvements and corrective actions regarding illegal or improper conduct.
④ The CCO may request the suspension of transactions with stakeholders who have committed illegal or improper acts from the respective business unit representatives.

 

Article 9 (TISO Management Programs) The Secretariat conducts the following programs to promote TISO Management:

1.  Preparation and distribution of the TISO Management Practice Manual

2.  Implementation of education related to TISO Management

3.  Monitoring the status of TISO Management implementation within each business unit and reporting to the CCO

4.  Operation of the TISO Management Counseling Office

5.  Operation of a Cyber Audit Office that allows employees or external parties to report violations of TISO Management regulations

 

Article 12 (Handling of TISO Management Violations)

① The CCO shall review compliance with TISO Management, and depending on the severity of the case, may refer the following individuals to the Human Resources Committee:

  1. Persons who violate regulations related to TISO Management

  2. Persons involved in instructing, condoning, or concealing violations of TISO Management regulations.

  3. Persons who intentionally fail to report violations committed by others

  4. Persons who obstruct the operation of TISO Management-related regulations

② If the CCO determines that a violation by an employee is minor, the CCO may request corrective action from the employee. If corrective action is not taken or refused, the CCO may notify the General CEO or the head of the relevant business unit to take appropriate measures.

 

Article 13 (Responsibility for Violations)

① When an employee violates TISO Management regulations, the primary responsibility lies with the violator, and the head of the affiliated business unit bears responsibility as the overall supervisor of TISO Management.

② If a TISO Leader knowingly conceals violations committed by employees, they shall be held jointly responsible with those employees.

 

Article 15 (Reward for Reporting)

① The Company may provide appropriate rewards to persons who report pursuant to Article 14, after review, as follows.

 

Article 17 (Confidentiality of Whistleblower Identity)

① The company shall protect the confidentiality of all matters regarding a whistleblower’s report and personal information and ensure they do not suffer disadvantages.

② If an internal whistleblower requests a change in workplace to protect their identity, the company shall make every effort to accommodate their request.

③ If an employee cooperating in investigations is disadvantaged or at risk of disadvantage, they shall receive the same protection as an internal whistleblower.

The company shall discipline any CCO, personnel handling report processing, HR personnel, or others responsible for whistleblower identity protection duties if they violate these obligations.