Purpose

The purpose of this Policy is for Sungwoo Electronics Co., Ltd. to comply with domestic and international laws, regulations, and standards related to occupational safety and health, and to continuously improve its occupational safety and health management system, thereby creating a safe working environment optimized for the physical and mental comfort and stability of employees.

Scope of Application

This Policy applies to Sungwoo Electronics Co., Ltd. and its employees. Sungwoo Electronics Co., Ltd. encourages its affiliated companies and their employees, as well as cooperating partners that conduct business with the Company and their employees, to comply with this Policy or policies at a level equivalent to this Policy.

Basic Principles

1. Workplace

• Identify hazardous risk factors related to all facilities and operations at business sites, establish priorities for corrective actions and improvement plans for identified risks, implement improvements, and set quantitative targets for performance assessment so that hazardous risk factors can be continuously managed.
• Establish workplace safety rules and strictly comply with them to ensure that employees can work in a safe and pleasant working environment.

2. Products and Services

• Give priority to safety throughout the process of producing products and services and delivering them to customers.
• Regularly identify issues that may pose risks to product and service safety, establish improvement measures for identified issues, and set relevant targets.

3. Employee Health Promotion

• Promote employee health by implementing activities that improve lifestyle habits, and operate mental health promotion and psychological counseling programs to prevent and manage job-related stress.
• Provide support for treatment and counseling when necessary.

Implementation Measures

1. 1. Assess occupational safety and health-related hazardous risk factors, establish a safety and health management system capable of responding to such risks, set specific performance targets, and strive to continuously improve them.
2. 2. The Board of Directors and management shall actively participate in key decision-making, management, and supervision related to the establishment and implementation of the safety and health management system, and consult with employees or employee representatives when necessary.
3. 3. Executives and department heads shall provide appropriate training to ensure that employees recognize the importance of maintaining and promoting safety and health, and understand the safety and health management system.
4. 4. Establish plans to prepare for and respond to emergency situations.

Purpose

The purpose of this Policy is to ensure that Sungwoo Electronics Co., Ltd. implements human rights management based on respect for labor principles recommended by the International Labour Organization (ILO) and ratified by individual countries, while complying with international human rights standards such as the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.

Scope of Application

This Policy applies to Sungwoo Electronics Co., Ltd. and its employees. Sungwoo Electronics Co., Ltd. encourages its affiliated companies and their employees, as well as cooperating partners that conduct business with the Company and their employees, to comply with this Policy or policies at a level equivalent to this Policy.

Basic Principles

1. General Policy

• In accordance with the UN Guiding Principles on Business and Human Rights, the Company recognizes that all human beings have the right to be treated with dignity. Such rights include, but are not limited to, the right to life and physical safety; freedom of thought, expression, and religion; freedom of association; freedom of family life and privacy; access to food and water; freedom from torture, slavery, or forced labor; the right to fair and decent working conditions; and freedom from discrimination.
• Accordingly, the Company takes appropriate measures to prevent violations of the human rights of others and to prevent and address negative human rights impacts arising from its business activities.
• To fulfill its responsibility to respect human rights and meet stakeholder expectations, employees shall comply with the following recommended principles related to human rights management:
① Comply with all applicable laws and internationally recognized global human rights standards in all areas where business activities are conducted.
② In cases where conflicting local regulations are encountered, seek ways to uphold global human rights standards.
③ Treat risks that may cause serious human rights violations as significant management issues.

2. Key Human Rights Issues

• The Company manages human rights risks arising in the following areas at an enterprise-wide level and fulfills its responsibility to respect human rights.

• ① Non-Discrimination

  The Company shall not discriminate or harass on the basis of race, nationality, gender, age, educational background, religion, region, disability, marital status, gender identity, or any other status. Where job qualifications and capabilities are met, equal employment opportunities shall be provided, and diverse cultural differences shall be respected.
  Employees performing work of equal value shall be paid equal wages regardless of gender or employment type, and unjustified disparities in wages and working conditions shall be prevented. Fair evaluations based on individual capabilities and performance shall be conducted and systematically reflected to ensure appropriate compensation.

• ② Prohibition of Forced Labor and Child Labor

  The Company shall not force labor against a worker’s free will through violence, intimidation, confinement, or any other means that unjustly restrict mental or physical freedom, including human trafficking. It shall prohibit advance agreements on damages for breach of employment contracts, shall not restrict a worker’s personal freedom due to monetary loans, and shall prohibit additional forced agreements ancillary to employment contracts.
  Child labor is, in principle, prohibited, and the labor conditions and minimum working age for minors shall comply with national labor laws and international standards.

• ③ Freedom of Association and Collective Bargaining

  In accordance with domestic laws and the core labor standards of the International Labour Organization, the Company recognizes employees’ freedom of association and the right to join labor unions or other worker organizations, and shall not disadvantage employees for union membership or activities. The Company shall not refuse collective bargaining without justifiable reasons and shall respect and faithfully implement the results of collective bargaining.

• ④ Occupational Safety Assurance

  Based on the principle that all types of industrial accidents and work-related illnesses must be prevented, the Company establishes enterprise-wide health and safety policies, strictly complies with international-level safety standards, and takes appropriate measures for identified risk factors.

• ⑤ Prevention of Workplace Harassment

  The Company thoroughly prevents acts in which employees use their position or relationships at work to inflict physical or mental suffering on others beyond the appropriate scope of 업무 or to deteriorate the working environment.
  By preventing verbal, physical, and visual behaviors that cause discomfort to others, including sexual harassment that violates individual human rights, the Company fosters a workplace culture that respects human dignity.

• ⑥ Responsible Supply Chain Management

  To assess and manage issues of forced labor and child rights violations within the supply chain, the Company manages human rights risks of suppliers, subcontractors, subsidiaries, and other major partners within its sphere of influence.
  The Company ensures that transactions with partners are conducted fairly based on mutual respect and equal relationships, and supports partners in complying with laws and regulations related to fair trade.

• ⑦ Anti-Corruption and Anti-Bribery

  To maintain fair trade practices in all transactions, the Company complies with all domestic and international anti-bribery and anti-corruption laws and regulations, including laws prohibiting improper solicitation and receipt of money or valuables, and the Anti-Bribery Act concerning Foreign Public Officials.

• ⑧ Right to a Healthy Environment

  The Company endeavors to reduce greenhouse gas emissions by decreasing the use of fossil-based raw materials and improving energy efficiency, and to restore natural ecosystems and conserve biodiversity through the efficient use of natural resources and by-products.
  The Company also establishes an environmental management system, strengthens its capabilities to respond to environmental risks, and conducts environmentally friendly management through open communication.

• ⑨ Protection of the Human Rights of Local Communities

  In cases where human rights violations occur in local communities due to the Company’s business activities, the Company listens to opinions and endeavors to resolve such human rights issues.
  As business activities may have social and environmental impacts on local residents and communities, the Company minimizes and prevents related human rights risks, and considers impacts on local environments, residents’ safety, health, food security, economic activities, cultural preservation, and biodiversity.

• ⑩ Protection of Consumer Human Rights

  The Company listens to and respects customer feedback, operates with a customer-centered approach, and actively accepts customers’ legitimate demands and reasonable suggestions.
  The Company fully considers customer safety and health in its business activities, does not provide products or services that threaten customer safety or health, and protects customer-related information.

3. Policy and Procedure Establishment

• To fulfill its responsibility to respect human rights, the Company establishes the following policies and procedures:
① A statement of policy intent, including the enactment of codes embodying the Company’s responsibility to respect human rights
② Human rights due diligence procedures to identify, prevent, and mitigate negative human rights impacts, and to review and investigate activities that may affect human rights
③ Procedures to remedy negative human rights impacts caused by the Company

Implementation Measures

1. Human Rights Management Governance

• The Board of Directors is responsible for setting overall policies and directions related to human rights management and for monitoring the implementation of human rights management.
• Responsible departments support the Board in the effective performance of its duties and carry out human rights education, information disclosure, human rights due diligence, and victim remediation.

2. Human Rights Due Diligence

• a) Key Considerations

  • Employees conduct human rights due diligence, as deemed necessary, to identify and prevent adverse human rights impacts and to take responsibility for their actions. This process includes identifying and assessing actual and potential human rights impacts, responding to identified issues, documenting response activities, and communicating with stakeholders. Human rights due diligence considers the following:
  ① Actual and potential negative human rights impacts that may arise directly or indirectly from the Company’s business activities
  ② Various factors such as the location and size of business sites, human rights risks, business characteristics and content, and the political and economic conditions of host countries
  ③ The recognition that human rights risks change over time as the Company’s activities and operating environments evolve, and therefore require continuous implementation

• b) Implementation Methods

  • Efforts to identify and review actual and potential negative human rights impacts arising from domestic and overseas business activities are conducted in accordance with the following process:
  ① When human rights-related risks are detected at major domestic or overseas business sites, conduct human rights due diligence to analyze the situation and derive improvement measures
  ② In principle, due diligence is conducted by internal experts, and external experts may be engaged when necessary
  ③ Where appropriate, conduct substantive interviews with potentially affected groups and relevant stakeholders
  ④ Identify actual and potential impacts during due diligence, share evaluation results at the enterprise-wide level, implement relevant procedures and mitigation measures, and address actual impacts that have already occurred
  ⑤ Conduct due diligence using checklists that diagnose key elements of human rights management

• c) Response and Follow-up Actions

  • Establish response systems and take follow-up actions based on findings identified through human rights due diligence to prevent and mitigate negative human rights impacts.

  • ① Establishment of Internal Response Systems

    ㈀ Clearly define roles and responsibilities with relevant departments to address identified issues
    ㈁ Apply internal decision-making, budget allocation, and monitoring procedures to effectively respond to such impacts
    ㈂ Ensure that issues identified through human rights due diligence are clearly understood by relevant departments and managed as key issues

    ② Follow-up Measures and Remedies

    ㈀ Take necessary measures to prevent or mitigate negative human rights impacts where they have occurred or may occur
    ㈁ Even where best policies and procedures are in place, make efforts independently or in cooperation with other entities to address unforeseen negative impacts
    ㈂ Where the Company has not directly contributed to negative human rights impacts but such impacts are linked to business operations, production, or services through relationships with other entities, the Company does not bear direct responsibility for systemic remediation but assumes an appropriate role
    ㈃ Where the Company has leverage to prevent or mitigate negative human rights impacts, it shall exercise such leverage; where it does not, it shall seek to enhance leverage through cooperation with relevant parties
    ㈄ Operate grievance mechanisms as effective remedies for potentially affected stakeholders

• d) Stakeholder Communication

  • Communicate responsibly with stakeholders when they raise concerns regarding human rights impacts.
  ① Communicate with affected groups, individuals, investors, and other stakeholders based on accountability and transparency, and consider various communication channels such as face-to-face meetings, issuance of official reports, and use of online platforms to ensure accessibility of information
  ② When issuing official reports, include actual and potential negative impacts, and consider independent verification procedures to enhance credibility
  ③ Provide information that helps stakeholders assess whether the Company’s responses to specific human rights impacts are appropriate

• e) Internalization and System Improvement

  • Promote substantive improvement in human rights management by internalizing the results of human rights due diligence into organizational culture and pursuing system improvements.
  ① Conduct activities to internalize human rights management into organizational culture, including consensus-building education for all employees, training on human rights management standards, and sharing of success and failure cases
  ② Continuously improve human rights management systems through expert consultation, stakeholder communication, and identification of improvement areas through policy implementation

3. Grievance Handling Mechanism

• a. Key Considerations

  • Operate grievance mechanisms for individuals and communities affected by negative impacts to ensure timely discussion and remediation.
  • Strive for prompt and reasonable resolution through the use of various channels, and do not take any adverse employment actions against whistleblowers, victims, or cooperating persons for reporting, requesting consultation or investigation, or cooperating with such processes.
  • The grievance mechanism performs the following key functions related to the Company’s responsibility to respect human rights:
  ① Facilitate the identification of negative human rights impacts and provide channels through which stakeholders who have been or may be directly affected can raise issues. Reports and requests for grievance handling may be submitted to the responsible department through in-person visits, mail, telephone, or email.
  ② Address grievances and victim remedies at an early stage to prevent the spread of human rights harm.
  ③ Identify and improve deficiencies in human rights policies and procedures through analysis of operational status.

Purpose

The purpose of this Policy is to improve diversity, equity, and inclusion for all employees of Sungwoo Electronics Co., Ltd., and to prevent discrimination, harassment, and sexual harassment in the workplace, thereby creating a sound working environment in which employees can fully demonstrate their capabilities.

Scope of Application

This Policy applies to Sungwoo Electronics Co., Ltd. and its employees.Sungwoo Electronics Co., Ltd. encourages its affiliated companies and their employees, as well as cooperating partners that conduct business with the Company and their employees, to comply with this Policy or policies at a level equivalent to this Policy.

Basic Principles

1. Diversity and Inclusion

Diversity means respecting employee characteristics such as culture, gender, nationality, race, religion or belief, socio-economic status, and ability, and inclusion means enabling all employees to feel a sense of belonging to the organization, participate in work, and fully realize their potential. Diversity and inclusion mean creating a working environment in which members of the organization are not unreasonably discriminated against and mutually respect one another, and specifically, the purpose can be achieved by complying with the following:
• Maintain an inclusive working environment by respecting diverse cultural differences.
• Create an environment in which all employees can contribute by utilizing their abilities, experience, and knowledge in the course of company 업무.
• Support employees in achieving their personal visions and enable them to perform their work flexibly in terms of time, place, and method.
• Eliminate barriers between organizations and pursue an open corporate culture of mutual cooperation through open communication.
• Establish various communication channels through which employees can interact with one another.
• Recognize that certain employees may experience difficulties at work due to physical or mental disabilities, and do not alienate or exclude them from the Company on the basis of disability.
• Recognize that the Company is a place where different generations coexist by offering different capabilities, and where employees of diverse backgrounds, nationalities, and races gather and work together.
• Create an environment in which all employees with differing family relationships, such as marital status, divorce status, and whether they have children, can coexist.
• Introduce a promotion system based on capability.
• Where artificial intelligence (AI) is used in employee recruitment, management, or training processes, do not use algorithms that promote bias against specific groups, and exercise caution to ensure that discriminatory outcomes do not occur.

2. Equity

Equity means providing equal opportunities in promotions, recruitment, training, etc. so that employees can fully demonstrate their individual capabilities, and specifically, the following shall be observed:
• Do not treat employees in a discriminatory manner on the basis of factors unrelated to capability, such as race, nationality, gender, age, educational background, religion, region, disability, marital status, and gender identity.

3. Prohibition of Workplace Harassment

• The following acts (including similar acts), in which an employee uses superiority of position or relationship at work to cause physical or mental pain to another employee or worsen the working environment beyond the appropriate scope of 업무, are prohibited:
Physical harassment
Mental harassment
 - Work-related harassment
 - Personal harassment

4. Prohibition of Sexual Harassment

• Acts in which an employee uses position or, in relation to work, engages in sexual remarks or conduct or sexual demands that cause sexual humiliation or disgust to another person; acts that impose employment-related disadvantages due to refusal to comply with sexual remarks or demands; or acts that express an intention to provide benefits on the condition of compliance are prohibited.

Implementation Measures

• Regularly conduct training to improve diversity, equity, and inclusion and to prevent discrimination, harassment, and sexual harassment in the workplace, and take necessary preventive measures.

• Management or the Board of Directors shall monitor the implementation of this Policy, and must establish a dedicated organization for receiving reports of violations, counseling, investigation, and handling. In particular, for sexual harassment, a separate counseling and reporting center shall be operated as a dedicated organization.

• Establish a reporting system (including in-person visits, mail, telephone, and email) so that anyone who becomes aware of a violation of this Policy may report such fact to the dedicated organization.

• Where the dedicated organization becomes aware of violations of this Policy, it shall conduct an investigation to verify the facts, and take necessary measures based on the investigation results, such as disciplinary action against the offender, department transfer, or training to prevent recurrence.

• Take measures to ensure that there is no employment disadvantage or other unfavorable treatment toward victims and cooperating persons, and, except where necessary for investigation and handling of the case, do not disclose any and all contents related to the case.

Purpose

The purpose of this Policy is for Sungwoo Electronics Co., Ltd. to establish a fair trade order based on mutual trust with its supply chain and partner companies, build a sustainable supply chain, and build a robust corporate ecosystem in which the Company can coexist and grow together with stakeholders through mutual growth and partnership.

Scope of Application

This Policy applies to Sungwoo Electronics Co., Ltd.
Sungwoo Electronics Co., Ltd. encourages its affiliated companies and suppliers and partner companies (collectively, “Partners”) that conduct business with the Company to comply with this Policy or policies at a level equivalent to this Policy. Furthermore, Sungwoo Electronics Co., Ltd. expects its Partners to recommend that their own partners also comply with this Policy or policies at a similar level.

Partner Code of Conduct

1. Human Rights

Partners shall not tolerate illegal minor labor, human trafficking, forced labor, etc. in accordance with the UN Guiding Principles on Business and Human Rights and the International Labour Standards of the International Labour Organization (ILO), and shall do their best to respect and protect the human rights of all workers, working hours, and freedom of association and collective bargaining. Partners shall also not discriminate against workers on the basis of race, nationality, gender, age, educational background, religion, region, disability, marital status, or gender identity, etc.

2. Environment

Partners shall comply with environmental regulations and laws, and shall establish an environmental management system to evaluate the impacts and risks of corporate activities on the environment and to systematically manage and analyze environmental management performance, and strive to improve environmental impacts throughout the entire lifecycle of products, including development, production, and use. Partners shall reduce the use of fossil fuels and fossil-based raw materials and improve energy efficiency to reduce greenhouse gas emissions, and strive to restore natural ecosystems and conserve biodiversity by efficiently utilizing natural resources and by-products.

3. Health and Safety

Partners shall establish an enterprise-wide health and safety policy, strictly comply with international-level safety rules, and take appropriate measures to prevent fatalities, injuries, and illnesses in the workplace, thereby establishing an environment in which all employees are protected from accidents and work-related illnesses and can work safely and healthily. Partners shall give priority to consumer safety in product production.

4. Anti-Corruption

Partners shall not engage in, nor tolerate, any type of corrupt practices, demands for money or valuables, or improper solicitation. Partners shall comply with domestic and international anti-bribery and anti-corruption laws and regulations, and strive to establish an ethical corporate culture through management activities that are thorough in fundamentals and adhere to principles.

5. Fair Trade

By complying with international standards and country-specific fair trade laws and regulations, Partners shall not engage in unfair collaborative acts such as collusion regarding production, pricing, bidding, market allocation, etc., or unfair trade practices that may undermine fair trade. Partners shall respect the rights and property of others, including intellectual property rights, and shall not trade or gain benefits in a manner that infringes such rights. Corporate information, including competitor information, shall be acquired and used only through legitimate means.

6. Prevention of Conflict of Interest

Partners shall avoid situations that conflict or may conflict with the Company’s interests, and shall not disclose or improperly use any confidential information or non-public information obtained through transactions with the Company.

7. Internal Reporting System

Partners shall establish and operate an internal reporting system through which workers can anonymously report unethical conduct or acts that may violate laws, and shall investigate such reports and 마련 appropriate improvement measures.

8. Wages

Partners shall comply with all wage-related laws, including minimum wage, salary, overtime pay, and wage deductions.

Implementation Measures

1. Supply Chain Risk Management and Due Diligence

• Establish a supply chain risk management and monitoring system to identify risks that may undermine sustainability in the supply chain due to Partners’ failure to comply with the basic principles of this Policy, and to minimize negative impacts.
• When selecting Partners, 확인 whether the Partner complies with the Partner Code of Conduct of this Policy.
• When contracting with Partners in the supply chain, include provisions requiring Partners to comply with this Policy, and enable Partners to include similar contractual clauses with their own partners.
• Identify negative impacts on human rights, environment, product safety, etc. in the supply chain risk management process, and where it is deemed necessary to prevent or mitigate such impacts, supply chain due diligence may be conducted within the scope permitted by law.
• Supply chain due diligence shall include identification and assessment of actual or potential negative impacts in the supply chain, establishment and implementation of action plans to prevent, mitigate, and improve negative impacts, communication with stakeholders regarding the due diligence process and results, and procedures through which stakeholders can convey grievances.
• The scope of the supply chain subject to due diligence may be determined independently in consideration of impacts on Sungwoo Electronics Co., Ltd., and may include first-tier Partners or Partners of second-tier or lower.
• Evaluate Partners’ level of implementation of this Policy through supply chain risk management and due diligence, and based on the results, may require Partners to establish and implement plans to improve and mitigate negative impacts arising from their corporate activities. If, despite such 요구, efforts to improve supply chain risks are insufficient and it is judged that the negative impact risks cannot be mitigated, the Company may suspend transactions with the Partner.

2. Establishment of Mutual Growth and Win-Win Relationships with Partners

• To establish a fair trade order based on mutual trust and build a corporate ecosystem in which the Company and Partners coexist through mutual growth, the Company shall strive as follows:
• Respect Partners’ rights (including intellectual property rights and property rights), and strive to ensure that transactions with Partners are conducted fairly within a relationship of mutual respect and equality.
• Pursue mutual benefits by sharing performance with Partners, and enable Partners to provide high-quality products and high-level services through smooth communication and mutual cooperation.
• Strive to build a stable supply chain through improvement of payment conditions for Partners and through technical and financial support, and support Partners in complying with laws and regulations related to fair trade.
• Continuously expand the scope of Partners for mutual growth cooperation in order to promote overall mutual growth of the corporate ecosystem.

Purpose

Sungwoo Electronics Co., Ltd. declares that, under its management philosophy of pursuing sustainable growth and fulfilling social responsibility, communicating and empathizing with all stakeholders, including customers, employees, and shareholders, and changing and innovating together ultimately leads to the realization of greater corporate value.
The purpose of this Policy is to define principles and implementation measures for actively collecting and communicating stakeholders’ requirements and opinions in order to realize the values of coexistence and mutual prosperity.

Scope of Application

This Policy applies to Sungwoo Electronics Co., Ltd. and its employees. Sungwoo Electronics Co., Ltd. encourages its affiliated companies and their employees, as well as cooperating partners that conduct business with the Company and their employees, to comply with this Policy or policies at a level equivalent to this Policy.

Basic Principles

1. Definition of Stakeholders

Stakeholders refer to individuals or organizations that may affect, or be affected by, the Company’s management activities, products, services, and decision-making. Stakeholders may include various groups such as customers, employees, shareholders, partner companies, local communities, governments and civil organizations, and domestic and international investors.

2. Stakeholder Participation and Communication

• Recognize truth, fairness, and integrity as the highest core values and as immutable values for building a corporate image trusted by all stakeholders, and encourage stakeholder participation and actively communicate with them.
• Through stakeholder participation and regular communication with stakeholders, objectively assess the positive and negative impacts of corporate activities on society and the environment from an external perspective, and strive to reflect stakeholders’ demands and expectations regarding issues of corporate social responsibility identified in the process into management activities.

3. Respect for and Engagement with Local Communities

• Respect and protect the culture and traditions of local communities, and support efforts to minimize negative impacts and maximize positive impacts on local communities and the environment resulting from corporate activities.

4. Local Community Development

• Contribute to the development of local communities to establish a foundation for sustainable growth, and strive to ensure that active engagement with local communities leads to the creation of social and economic value.

Implementation Measures

1. Establishment of Procedures for Stakeholder Identification, Participation, and Communication

• Establish procedures to identify individuals or groups that may be affected by, or may affect, corporate activities, and to determine the level of such impacts.
• Establish procedures and methods to efficiently collect stakeholders’ opinions in order to encourage active participation, including the operation主体, frequency, and methods of communication channels.

2. Establishment of Procedures for Protection of and Engagement with Local Communities

• Where corporate activities may affect the rights of local residents, establish procedures to identify and protect such rights, and provide sufficient information to local residents regarding whether and how business activities will be conducted, so that residents may freely present their opinions in advance based on such information.
• Actively identify the impacts of corporate activities on issues related to the resettlement and compensation of local residents, and strive to systematically improve such issues.
• Establish consultation frameworks with local communities from the initial stages of corporate activities, and endeavor to ensure that corporate activities are carried out under continuous consultation with local communities.

3. Local Community Development Programs

• In consultation with stakeholders in local communities, establish programs for local community development, monitor the progress of such programs, and periodically share the results of community development achieved through program implementation with stakeholders.

4. Grievance Handling Mechanism

• Operate grievance handling mechanisms for individuals and local communities adversely affected by corporate activities. Utilize various existing channels to strive for prompt and reasonable resolution, and endeavor to ensure that reporters, victims, and cooperating persons do not suffer disadvantages due to reporting, requesting consultation or investigation, or cooperating in such processes.