1. Purpose

2. This policy is intended to help us recognise ethics and compliance issues before they arise and to deal appropriately with those issues that do occur.

3. Scope

All Departments are covered under this policy

4. Policy

4.1 Legal and Policy Controls

As a global enterprise, we conduct our business activities in compliance with this policy in addition to the laws and regulations of the countries where we do business. The policy meets and often exceeds existing legal and compliance requirements.
Everyone has a duty to be aware of and abide by the legal and policy controls that apply to our jobs. If we have any questions about our obligations under our policy or legal obligations, we should seek guidance from our local management, Human Resources or Legal Counsel.
If we become aware of any questionable activity or potential violation, we must report it to our management, Human Resources or Legal Counsel. Please be aware that any form of retaliation against any employee for reporting in good faith or participating in the investigation of a suspected violation will not be tolerated.

4.2 Compliance

Every one of us has responsibility to live up to the highest ethical standards of business conduct. This policy outlines our expectations regarding our behaviour. Failure to live up to our values and compliance standards may result in disciplinary action, which could include termination for serious offenses.

4.3 Customers

We are committed to earning and maintaining our customers’ trust through fair, honest and lawful dealings. We listen to our customers so that we can meet their requirements. We provide timely and appropriate response and resolution to customer problems.

4.4 Sales and Marketing Activities

We provide accurate and complete information to our customers so that they may make informed decisions. We do not tolerate misrepresentation, fraud or deliberate omission of information in our sales or marketing activities. We honor our commitments and follow through on our promises, agreements and obligations.

4.5 Conflicts of Interest

We carry out our duties and responsibilities in a fair manner. We make business decisions in the best interest of our Company, free from personal or external influences.

4.6 Gifts and Entertainment

The propriety of giving or receiving employment-related gifts depends on the value and intent of the gift. We define gifts broadly to include tangible items and cash or cash equivalents as well as favors, special considerations, gratuities and discounts.
The only acceptable purpose of gifts and entertainment is to create goodwill or strengthen business relationships.
We, or members of our immediate family, may only accept or receive an employment- related gift if it comfortably falls within the range of common business courtesies. Gifts that make the recipient feel obligated to repay the favor by doing business with the giver are always improper. We will not extend a gift or entertainment to customers if doing so would violate their own policies. Gifts and
entertainment may never be lavish, unusual or extravagant in the eyes of a third party. Under no circumstances do we give or accept cash or cash equivalents, such as gift certificates or gift cards, regardless of the amount, from anyone who has business dealings with SK.
You must let your manager know if you receive any gift, regardless of its value. The appropriate manager must approve the giving of a gift or payment of business expenses (provided it does not violate a customer’s/supplier’s own policy) to any person who has business dealings with us.

4.7 Safeguarding and the use of Customer Information

We respect and are committed to safeguarding the confidentiality, data privacy and security of information that our customers have entrusted to us, including confidential information, personally identifiable information, proprietary information, any intellectual property and trade secrets. We exercise appropriate care at all times to prevent unauthorised disclosure and use of customer information. We take our responsibilities for customer confidentiality, data privacy and security seriously and implement appropriate safeguards for the use and handling of this information in accordance with our information security and privacy policies, and in accordance with all applicable laws.

4.8 Purchasing Integrity

We base our vendor and supplier relationships on the fundamental principles of fairness, honesty and mutual respect. We honor our commitments and follow through on our promises and agreements with everyone. We only do business with vendors and suppliers that have high standards of conduct. We expect our suppliers to adhere to ethical and legal requirements in their business dealings with their employees, their local communities and SK.
We make all purchasing decisions in the best interests of our Company and not on personal considerations.

4.9 Safeguarding and Using SK Assets

Each of us is accountable both for safe- guarding all assets entrusted to us from loss, theft, waste, misappropriation or infringement and for using them to advance the interests
of SK. We are accountable to classify, protect and handle SK, customer and other third-party information in accordance with all applicable laws, SK policy and any applicable contractual terms. We have a duty to immediately report the theft, loss or misappropriation of any SK or customer assets, including financial assets, physical assets, information assets and electronic assets.

4.10 Business Records

Accurately and honestly preparing business records is a business and legal imperative. We take our obligation to maintain business records for operational, legal, financial, historical, quality and other purposes seriously and take appropriate steps to ensure that the content, context and structure of
our records are reliable and authentic. We manage records consistent with the retention and destruction guidelines applicable to our functions and our retention policy.

4.11 Protection of Intellectual Property

We protect our, and our Customer’s intellectual property—inventions, patents, trade secrets, trademarks, copyrights, design rights, know-how and other proprietary information. We are accountable to establish, protect, maintain and defend those rights and to use those rights in responsible ways.
We respect the valid, exclusive, intellectual property rights or copyrighted materials of third parties.

4.12 Media

We are accountable to contact the Board of Directors for approval and guidance before committing to a speech, interview, article, customer endorsement, press release or other published or broadcast statement that references SK for external audiences. We do not respond to questions from members of the investment community, but rather we refer them to the Finance Department.

4.13 Insider Trading

We handle insider information appropriately and lawfully. Insider information is defined
generally, as material, non-public information. Material information is information that is important enough to affect an investor’s decision to buy, sell or hold securities. Our employees, their immediate family and anyone living in the same home are considered insiders under SK policy. As such, you may not engage in speculative trading of SK securities, including SK common stock, debentures or notes. You should buy SK stock for investment purposes only, generally holding the stock for at least six months.

SK policy and securities laws provide for additional rules for insiders who have actual knowledge of market-sensitive information about SK that has not been disclosed to the public. Examples of market-sensitive information include financial performance, acquisitions, disposals, significant new products, changes in dividends and lawsuits. Information is considered market sensitive if it would be important to a reasonable investor in deciding whether to buy, hold or sell securities. You must not reveal market- sensitive information to other individuals, either inside or outside of SK.

4.14 Information Systems

We provide electronic information systems to employees to support their achievement of business objectives (appropriate use). Systems include e-mail, computers, personal digital assistants (PDAs), printers, facsimile machines, telephones, voice mail, wireless devices and all associated operating systems and application software. Our information systems may only be used for purposes that effectively and efficiently support SK business goals and objectives. Casual personal use is permitted but only if it has negligible or trivial impact (limited frequency, duration or volume) on computer and network resources and does not impact employee productivity.

Inappropriate use includes the transmission of SK classified, sensitive personal information to unauthorized individuals or unsecured locations, communicating in a discriminatory, defamatory, derogatory, libelous or harassing manner, infringing on intellectual property rights (including copyright, trademark and trade name), non-business related video/audio material or any information that contributes to a hostile or unproductive workplace, use for any illegal purpose, excessive personal use, or creating, storing, viewing or transmitting pornography or other graphics that are offensive or would otherwise violate SK policies or national laws.

4.15 Fair Competition and Trade Practices

Fair competition laws prohibit agreements with any competitor to raise prices or reduce output. Fair competition issues are complex and may arise in dealings with customers, suppliers or competitors. Violations of fair competition laws can result in very serious civil and criminal charges and penalties both for the Company and individuals. These penalties include exposing SK to substantial fines and exposing individuals to fines and imprisonment.

We avoid contacts with competitors that could create even the appearance of improper agreements, whether the contact is in person, in writing, by telephone or through e-mail.

We use care in our writing and speech to avoid any statement that could be misconstrued to indicate an intent to act in an anti-competitive way.

The exchange of benchmarking information with competitors can also create serious competition law issues. We do not acquire commercial information by dishonest or unethical methods. In addition, if we receive questionable information from an outside party about a competitor, we do not examine the information without first contacting Legal Counsel.

4.16 Bribery and Improper Payments

We do not condone or participate in bribery or other forms of corruption. We never offer anything of value to obtain an improper advantage in selling goods and services, conducting financial transactions or representing our Company interests to governmental authorities or international

agencies like the United Nations. All countries prohibit the bribery of their own public officials, and many also prohibit the bribery of officials of other countries.

SK policy goes beyond these laws by prohibiting improper payments in all of our activities, with governments, international agencies and in the private sector. SK policy requires proper accounting for all financial transactions, including payment of commissions, fees and gratuities, as well as proper record keeping. We maintain a system of internal controls to ensure that all such transactions are properly and fully recorded, and that our records reasonably and fairly reflect these transactions.

4.17 Money Laundering

SK only does business with legitimate customers who are involved in legitimate business activities and whose funds are derived from legitimate sources. Most countries have laws that prohibit accepting or processing the proceeds of criminal activities. SK integrity and reputation can be severely damaged if we fail to detect customer or supplier relationships and transactions that place.

us at risk. If you become suspicious or have questions about money laundering, raise your concerns and questions to your management or Legal Counsel. Resolve any concerns before transactions proceed further.

4.18 Discrimination and Bullying

Each of us plays an important role in ensuring that our fellow employees are treated with dignity and respect. As an equal opportunity employer, we do not discriminate in recruitment, selection, compensation, training, job assignment, promotion, termination or any other employment-related activity with respect to a person’s race, color, nationality, religious belief or affiliation, sex, age, ethnic or national origin, marital or family status, sexual orientation, gender identity, trade union membership or activity or current or past disability. At SK, diversity is seen as a competitive advantage that goes beyond differences of any kind and embraces other characteristics, such as divergent thinking and different work styles.

Employees are protected from harassment, coercion, intimidation, victimisation, reprisal or discrimination for filing a bona fides complaint or assisting in an investigation. We do not tolerate harassment, bullying or unlawful discrimination of any kind or in any manner.

Making unwelcome sexual advances toward or otherwise harassing or bullying any SK employee, customer or supplier are completely unacceptable. Likewise, jokes or displays that disparage specific groups (e.g., nationality or religion) are completely unacceptable

4.19 Focus on Diversity

Diversity celebrates and values differences in age, outlook, cultural background, lifestyle, physical ability, sexual orientation and gender. Our focus on diversity extends to our employees as well as our suppliers.

Each of us plays an important role in ensuring that employees, customers and suppliers are treated with dignity and respect.

4.20 Health and Safety

We provide a work environment that is safe, secure and free of danger, harassment, intimidation, threats and violence. The health and safety of our employees, customers and neighbors from unacceptable risks take precedence over economic considerations and will not be compromised.

We take appropriate precautions to prevent injuries or adverse working conditions for ourselves and other sk employees. We comply with all government regulations and SK Health and Safety (H&S) standards and are responsible for reporting injuries and unsafe work practices or conditions as soon as they become known to us.

4.21 Alcohol and Drug Misuse

We prohibit the illegal use (including possession, distribution, dispensation, manufacture or transfer) or being under the influence of controlled substances or alcohol on our property.

We will assist employees who develop problems related to alcohol or drug misuse. Employees can seek assistance voluntarily or at the suggestion of their managers or supervisors. The goal is to address the problem before it impairs performance or employability.

4.22 Privacy Rights of SK People

We collect and maintain personal information only to the extent required for business or legal reasons. We comply with all applicable laws concerning the holding and processing of employee personal information.

4.23 Human Rights

Our commitment to behaving responsibly as a good corporate citizen is accomplished by running our global business with great respect for human rights. We are guided by the United Nations Universal Declaration of Human Rights. Our support for these principles is embedded in our codes of conduct, in our position on employment relations and practices, in our relationships with suppliers and customers and in how we build our business in emerging markets.

4.24 Personal Community and Charitable Activities

SK encourages us to participate, through CSR, in community and charitable activities.

SK will not favor or discriminate against employees who either support or disagree with a position taken by SK relating to community activities or organizations

4.25 Environmental Stewardship

We are committed to protecting the environment and the health and safety of employees, customers, communities and neighbors. We are guided by a number of business practices in the design, manufacture, procurement, marketing, distribution, maintenance, reuse/recycling and disposal of products and related services.

Our protection of the environment and the health and safety of our employees, customers and neighbors from unacceptable risks take priority over economic considerations and will not be compromised. We conduct our operations in a manner that safeguards health, protects the environment and conserves valuable materials and resources. We are committed to designing, manufacturing, distributing and marketing products and processes to optimise resource utilisation and minimise environmental impact.

4.26 Lobbying and Political Contributions

As a corporate citizen, SK takes positions on matters of public policy that could have a significant impact on our Company and its global operations. Under no circumstances are we to contribute to or participate in political campaign fundraising or campaigning activities while at work.

4.27 International Trade Controls and Anti-boycott

Many countries regulate international trade transactions—imports, exports and international financial transactions—for national security and foreign policy purposes. SK follows applicable international trade control regulations regarding licensing, shipping documentation, import documentation, reporting and record-retention requirements in all countries in which it conducts business.

5. Definitions

6. References

7. Document History

8. Appendices