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Anti-Unfair Solicitation System

Objective

Operating Procedures

Individuals who have received recommendations/solicitations, those who have been informed, and the actual executors. All employees along the path of recommendation/solicitation.
Employees who have received recommendations/solicitations must register the details accurately and without omission, based on the 5W1H principle.
Recommendations/solicitations should be registered in the system within 24 hours of occurrence. (Extensions are possible in exceptional circumstances (meetings, business trips, etc.))

Processing Steps for Registration of
Recommendations/Solicitations

Detailed Standards

Definition of Solicitation
- Solicitation means any expression of intent where the solicitor aims to influence an employee's duties or decision-making for their or another's benefit.
Criteria for judgment of fairness influenced by job performance or decision-making
- An act that creates a conflict of interest for the employee upon accepting or rejecting a solicitation.
- An act where the employee feels psychological pressure to perform their duties reasonably due to the solicitor's request.
Scope of Registration for Recommendations/Solicitations
- The Clean POSCO Group system is designed to prevent misconduct due to solicitations in advance; hence, the scope of registration is expanded beyond legal boundaries to include all expressions that could impair fairness.
- In cases where it is unclear whether it is a regular business matter or a solicitation, the principle is to register 100% of the content in the system without judging the solicitation.
- Employees who fail to register despite being aware of a recommendation/solicitation may be subject to strict disciplinary action.
Handling of Registrations
- The results of recommendations/solicitations are separately managed by compliance monitoring, personnel, and other related departments, which may take adverse action against relevant employees and companies.

Ethics Reporting Center

At POSCO CAPITAL, we always stand with you, attentive even to the smallest voices.

Our company adheres to the Financial Supervisory Service's exemplary standards for protecting financial consumers.
We receive and address customer complaints, including any inconvenience or dissatisfaction with our services.
If you encounter any issues or see areas needing improvement while using our services or observe any unfair or unethical behavior by our employees, please report these matters as outlined below. Our relevant departments will promptly address them.

posco HOLDINGS

Anti-Unfair Solicitation System

Objective

Operating Procedures

Processing Steps for Registration of
Recommendations/Solicitations

Detailed Standards

Ethics Reporting Center

Submission Methods (Phone and Written)

Anti-Unfair Solicitation System

Objective

Operating Procedures

Processing Steps for Registration of Recommendations/Solicitations

Detailed Standards

Ethics Reporting Center

Submission Methods (Phone and Written)

Processing Steps for Registration of
Recommendations/Solicitations