Ethics

Fair Trade Autonomous Compliance Program Operating Guidelines

Regulations related to fair trade

Implementation of the eight core elements

• In order for a company to be recognized as having implemented CP, the following conditions must be satisfied.
• However, according to the Framework Act on Small and Medium Enterprises, Condition 5. may be set as the recommendations for SMEs.
• The eight major elements are the most important fundaments for implementing corporate law-abiding cultures and establishing a fair trade order.

Condition 1. Standard and Procedure of CP

Standards and procedures shall be prepared and implemented so that employees can clearly recognize and comply with applicable fair transaction laws related to work.

Any change in applicable laws and industrial practices shall apply to the company’s standards without delay and be informed to employees so that they can clearly recognize such change.

Procedures which prevent any violation of applicable laws shall be prepared and distributed to employees in purchase or sales exposed to competition work in promoting products and bidding to purchase goods, and it shall be checked regularly whether procedures have been complied with. Any violation of applicable fair transaction laws or concern thereabout resulting from failing to comply with procedures shall result in disciplinary action against employees based on the principles of employee discipline.

Condition 2. CEO Message

CEO’s commitment and support for compliance with applicable fair transaction laws shall be communicated to all employees through a fair transaction declaration ceremony or document (including electronic media).

CEO shall appoint a compliance officer with a resolution by the Board of Directors, establish a compliance committee if required to prepare organizations and systems needed to implement the compliance program (CP), and provide resources required for the efficient operation thereof.

CEO shall provide training to employees about complying with applicable fair transaction laws and preventing any violation thereof in consultation with the compliance officer, and make efforts to promote a free and fair competition culture by hosting training or events for subcontractors about applicable fair transaction laws and CP, if necessary.

Condition 3. Compliance Organization

The compliance officer shall be appointed by the Board of Directors and informed to all employees. The compliance officer shall be appointed from one of the senior managers knowledgeable about applicable fair transaction laws and the company’s policies and procedures, but in principle not someone directly in charge of sales, purchase/procurement, display/advertisement, and customer support.

The compliance officer shall oversee organizations and works to comply with applicable fair transaction laws, establish and implement the CP, have the authority and responsibility to create and amend the compliance manual, and plan, establish, implement, monitor, discipline, improve and operate the CP.

Condition 4. Autonomous compliance handbook

Based on the code of ethics and compliance control to establish order in competition, the compliance manual shall be prepared under the responsibility of the compliance officer and distributed to employees in departments, such as sales or purchase where applicable fair transaction laws are likely to be violated.

Clearly presenting the code of ethics and acceptable standards will prevent potential violations and improve fair transaction competencies.

Condition 5. Education and Training

At least two hours of training (including online video training) to prevent violations of applicable fair transaction laws shall be provided every six months to employees in departments such as sales or purchase where applicable fair transaction laws are likely to be violated. The compliance officer shall retain documentation about development, implementation, and results for training programs for 5 years after the end of training.

Condition 6. Monitoring

There shall be a fact that the compliance officer reports the supervision or monitoring performance and plan to (or is approved by) the Board of Directors at least once every six months.

Condition 7. Disciplinary action

Bylaws, which define disciplinary action against employees liable for violating applicable fair transaction laws to the extent of such violations, shall be prepared and operated.

If there is a concern or suspicion that any employee violates applicable fair transaction laws, the compliance officer shall investigate it immediately. If the employee has actually or potentially violated applicable fair transaction laws, the compliance officer shall take required disciplinary action such as exclusion from work, warning, transfer, suspension, wage reduction, and dismissal depending on the violation after fully consulting with CEO and heads of other departments.

If required, the compliance officer shall record, retain, and maintain investigations about law violations and related data and documentation.

Condition 8. Evaluation and Improvement measures

To ensure Daewoong Pharmaceutical’s CP continues to be operated effectively, inspection or evaluation for standards, procedures, and operations shall be conducted at least once per year and improvement measures shall be taken accordingly.