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Ethical Management

The Preamble to the Code of Ethics

This code of ethics fundamentally seeks to uphold and evolve the legacy of our founding spirit - a dedication to the nation through steel production, a profession rooted in sacrifice and service. Moreover, it embodies the contemporary ethos. It signifies the ethical values and standards of conduct that every member of the POSCO Group is expected to maintain and cultivate.

Our paramount values, the goals we all ought to strive for, are Integrity, Fairness, and Honesty to craft a corporate persona that elicits Trust from all stakeholders. In line with this, eNtoB has formulated a code of ethics that all employees are obligated to adhere to, expressly integrating the United Nations human rights management, a staunch advocate of human dignity, into our code of ethics. We have revised our code of ethics to elevate our ethical standards in sync with the objectives of management innovation that prioritizes ethics.

The code of ethics comprises the ethical management principles reflecting the employees' compliance and accountability towards the code of ethics and the pragmatic guidelines that establish the foundation for ethical decision-making.
All eNtoB employees are required to strictly observe the ethical principles and guidelines detailed in this code of ethics throughout their professional responsibilities.

Ethical Principles

Obligation to Comply with the Code of Ethics

eNtoB must comply with all relevant laws and regulations anywhere in the world where it operates businesses.

Roles and Responsibilities of Employees

Employees must fully comprehend and adhere to thical standards.
As members of a global enterprise, they are required to abide by international and domestic anti-corruption legislation.

Roles and Responsibilities of Leaders

As a leader, play a pivotal role in enhancing the company's core competitiveness by preventing and eradicating unethical behavior through compliance with ethics.

Sanctions for Ethical Breaches

Employees who breach our code of ethics may be penalized in line with relevant regulations, including termination.

Implementation Guidelines

Ethical Practice and Compliance

As a global corporation, we are committed to solidifying an ethical business culture, engaging in principled operations that strictly adhere to legal and ethical guidelines.

Fostering Harmony Between Work and Personal Life

We champion the harmonious growth of our team and company by fostering an optimal work-life balance, creating a gratifying and balanced work environment underpinned by a culture of mutual respect and understanding.

Generating Customer Value and Securing Trust

We understand that our future prosperity hinges on earning our customers' trust and facilitating their success. Therefore, we make it a point to respect customer feedback, understand their needs, and contribute to their growth by creating valuable solutions.

Fulfilling Our Duty to Investors with Good Faith

We aim to maximize investor value by generating fair and justifiable profits through transparent decision-making processes and practical management activities.

Fostering a Synergistic Relationship with Trade Partners

At eNtoB, we establish a business ecosystem rooted in mutual trust and fair trading, enabling us to thrive in unison with our stakeholders.

Committing to National and Societal Progress

As global corporate citizens, we shoulder our responsibilities and duties to contribute to national and societal advancement.

Preserving the Environment and Ecosystem

We commit to eco-friendly management by building robust environmental management systems, strengthening our capabilities to respond to environmental risks, and maintaining open communication.

Protection and Respect for Human Rights

At eNtoB, we uphold human rights, endorse applicable international guidelines, and champion the inherent dignity of every stakeholder through fostering freedom, ensuring safety, and advancing the quality of life.

CEO Message


eNtoB, a supply-chain specialist within the POSCO Group, is actively pursuing the goal of being a reliable, respected, and sustainable corporation founded on our unwavering commitment to 'corporate citizenship' and strong ethical values.

eNtoB, an innovative partner rooted in e-commerce platforms, is committed to ethical management, promising fair and transparent dealings, and timely and precise task execution, with the overarching goal of becoming a company cherished by all stakeholders.

In this vein, all eNtoB employees are dedicated to fully comprehending ethical guidelines, exerting utmost effort in their respective roles and responsibilities, and enthusiastically advancing ethical conduct. We will strictly enforce a zero-tolerance policy for the four significant unethical actions: bribe acceptance, embezzlement, violation of sexual ethics, and data manipulation. We also classify unintentional yet abrasive, unkind, or insincere behaviors as breaches of our ethical guidelines, warranting necessary follow-up actions.

We encourage our valued shareholders, customers, suppliers, local community opinion leaders, and other key stakeholders to provide candid feedback on areas where our commitment to ethical adherence may falter or require improvement.
I assure you that all eNtoB employees are committed to attentively listening, engaging, and responding to even the subtlest concerns and feedback from our stakeholders.

We kindly request your continued observance and support as eNtoB faithfully abides by the principles and standards of ethical governance, actualizing the values of empathy, coexistence, and mutual growth, all while evolving into a superior company. We look forward to your ongoing support and interest.

Thank you.

System Management

eNtoB has established and operates various ethical systems to foster a culture of ethical practice among employees.

Ethical Practice Pledge

Each January, we conduct a pledge to adhere to ethical guidelines involving all employees before work commencement.

Special Provision of Ethical Practice

During contract signing with trading partners, we include special clauses emphasizing the obligation to adhere to ethical guidelines.

Ethics Session

We conduct an ethics session, which assesses the ethical standards of executives, group heads, and leaders through subordinate employee surveys.

Donation of External Lecture Fees

Proceeds generated from external lectures employees give are generously donated to the company.

Gift Return Center Operation

Upon receipt of gifts from stakeholders, these are registered at our 'Gift Return Center,' affixed with a 'polite refusal' sticker, and subsequently returned.

Ethical Dilemma Counseling

We offer a dedicated counseling service for situations presenting ethical dilemmas to help employees navigate and resolve such difficulties.

Educational Initiatives

eNtoB conducts ethical education through various channels to instill a strong sense of moral values among our employees.

Compliment Corner

Accepting examples of courteous and efficient employees who exemplify best practices in their duties.

This space is dedicated to acknowledging the efforts of courteous and efficient employees who exemplify best practices in their duties.

Reporting Unethical Behaviors

Accepting inquiries and submissions regarding unjust business conduct, improper demands, and instances of corruption or fraud by eNtoB staff members.

We welcome reports about unjust business practices, improper demands, and instances of corruption or fraud perpetrated by eNtoB staff members.

Please note that unfounded defamatory claims and matters about personal life will not be processed as formal complaints.

Rest assured that all submitted report details will be kept strictly confidential. For reporters disclosing their identities, we pledge comprehensive protection.
Anonymous reports, however, will not receive notification of outcomes.

Reporting Abuse of Authority

Complaints about instances of rudeness, verbal assault, or other forms of abuse of authority experienced by eNtoB employees.

We invite you to report experiences of rudeness, verbal assault, or other forms of abuse of authority by eNtoB employees.

Reportable actions include: - eNtoB employees engaging in verbal or physical abuse by exploiting a superior position within the organization. - eNtoB employees using derogatory language that infringes upon an individual's dignity. - eNtoB employees instructing others to work under unsafe conditions.
The confidentiality of the reporter will be safeguarded. After conducting the necessary proceedings, we respond as swiftly as possible.

Reporting Workplace Harassment and Sexual Harassment

Submitting complaints about workplace harassment and sexual harassment perpetrated by eNtoB employees.

We are open to receiving complaints about workplace harassment and sexual harassment by eNtoB employees.

Acts that are subject to reporting of workplace harassment include:
- Any behavior within the workplace that infringes upon the dignity and personality of employees, causing physical or psychological distress or creating a hostile work environment.
Acts that are subject to reporting of sexual harassment include: - Actions that, within the workplace, leverage one's position or work-related circumstances to cause another person to experience feelings of sexual humiliation or repulsion. - Actions that result in professional disadvantages due to non-compliance with sexual demands or comments.
The confidentiality of the reporter is ensured. After following due process, we commit to responding as expediently as possible.

Consultation and Reporting of Fair Trade Practices and Collusion

Consultation and whistleblowing in the event of violations of fair trade and subcontracting laws, engagement in collusion among suppliers, or when awareness of collusion among other suppliers is acknowledged.

Reportable actions include: 1. Violations of fair trade regulations by eNtoB or its employees. 2. Violations of subcontracting laws by eNtoB or its employees. 3. Non-payment of subcontracted fees by eNtoB or its partners. 4. Your company's involvement in collusion with other suppliers or awareness of collusion among other suppliers.
- Please note that unfounded defamatory claims will not be processed as formal complaints. - Reporter's information will be held in the strictest confidence. However, limited disclosure may occur in certain circumstances, such as non-payment of subcontracting fees by partners, which necessitate revealing the reporter's identity.


Reporting Reward System

Reportable Misconduct

  • - Receipt of gifts or favors from external stakeholders in relation to professional duties.
  • - Abuse of position to secure unfair gains or cause losses.
  • -Other unethical actions connected to external stakeholders.

Primary Categories of Unethical Actions

  • - Receiving cash or presents, aside from customary commemorative items and gifts.
  • - Accepting hospitality, such as meals, alcoholic drinks, or entertainment exceeding conventional limits.
  • - Accepting conveniences, such as transportation, lodging, sightseeing, event support, and so forth, surpassing regular standards.
  • - Engaging in financial or real estate transactions, such as money lending/borrowing, loan guarantees, property buying/selling, or leasing, may hinder impartial job execution. Per reasonable social norms, the term "conventional limits" implies a universally acceptable level enabling beneficiaries to perform their duties objectively without feeling indebted.

Reward Policy for Whistleblowers

Reward Eligibility

- Non-company individuals

Reward Criteria

- Employees who are on the receiving end of recommendations/requests should record the content without alteration or omission, following the 6H principle.

Reward Amount

- If a direct increase in eNtoB's revenue or a cost reduction is achieved, this value becomes the eligible reward amount. It is compensated following the reward payment standards, with a maximum of 10 million KRW.

Reward-eligible Amount Reward Payment Criteria
Below 10 million KRW Not eligible for a reward
10 million KRW or more 3% of the eligible reward amount (maximum 10 million KRW)

· If profit enhancement or loss reduction effects manifest immediately, the total amount is recognized as the reward-eligible sum. The anticipated annual value is considered if the effects occur over an extended period.

· Any amounts disclosed during an internal audit are excluded from the reward-eligible total.

- If it is not feasible to calculate the eligible reward amount, or if there is no recouped amount due to the report (or cannot occur), no reward is issued.

Guaranteeing Whistleblower Anonymity

Reward Payment to Whistleblowers

- Confidentiality is ensured to prevent identity exposure during the reward payment process, and the reward is delivered in the method preferred by the recipient.

Prohibition on Whistleblower Identity Disclosure

- Ban on whistleblower identity disclosure · Any employee who discovers the whistleblower's identity through their job or accidentally is prohibited from revealing it.

- Ban on whistleblower identity investigations · All actions that might disclose the whistleblower's identity, including queries about the whistleblower's identity from the reported individual, their department, or other related departments, are prohibited.

Prevention of Detriment to Whistleblowers and Position Management for Identity Disclosers

- Investigation of exposure route when identity is exposed · Notify the audit department if the whistleblower's identity is exposed. · The audit department investigates the exposure route and enacts punitive measures against the accountable parties.

- Prevention of personnel-related detriment and position management · Detriment to the whistleblower in personnel matters is prohibited, with punitive measures for violations. · Personnel action such as a position change is enacted when detriment is expected.

Reporting Procedure

Reporting Destination

- Jeongdo Management Group

Reporting Method

- Cyber report, mail, phone, fax, visit, etc. The whistleblower can select the most convenient method.

Reporting Guidelines

- The whistleblower should note their personal information, the violator's details, and the specifics of the violation as per the 6H principle.
(However, only factual reporting is permissible for ongoing unethical actions at the time of reporting or in urgent situations.)

Report Submission Point

- Cyber Reporting
Access our website ( and submit a report to the "Hotline."

- Telephone/Fax Reporting
TEL. 02-2007-0839, FAX. 02-2007-0710

- E-Mail Reporting

- Postal Reporting
Jeongdo Management Group, eNtoB Co., Ltd., 11 FL, Posco Tower-Samsung, 514 Bongeunsa-ro, Gangnam-gu, Seoul (06163).

The Clean eNtoB System


Our objective is to cultivate a corporate environment untouched by improper solicitations, achieved through meticulous documentation and management of all solicitation activities.

Proactive Approach to Deter Unethical Actions

- By requiring solicitations to be recorded, we provide employees an official rationale to decline them. This also deters potential solicitors, as the psychological burden of a permanent solicitation record can discourage future improper behavior.

Promoting a Whistleblowing Culture

- Employees encouraged to conscientiously register any solicitation they encounter contribute to an environment of integrity and transparency.

- Voluntary registration of solicitation is seen as an act of self-reporting, offering protection to the reporting employees from potential future liabilities or issues.

Operational Protocol

Registrant Criteria

- All employees who have interacted with a solicitation, including recipients, intermediaries, and those handling the solicitation or recommendation.

Registration Methodology

- Employees subject to a solicitation should faithfully document the entire incident, without any alteration or omission, adhering to the 5W1H principles.

Timing of Registration

- The registration process should commence within 24 hours post the solicitation event, with flexibility for an extension in special circumstances like meetings, business trips, and more.

Processing Procedure for Recommendation/Solicitation Registration

  • Employees must voluntarily register the solicitor and the solicitation details in the company's system after receiving a recommendation or solicitation.

  • The Jeongdo Management Group is responsible for receiving and validating the registration.

  • Upon validation, the relevant department is notified of the findings.

  • If needed, the Ethical Management Group will initiate an in-depth investigation and take appropriate action should an issue arises.

Understanding Solicitation

- Solicitation encompasses all expressions intended to manipulate an employee’s professional judgment or decision-making to serve the personal or secondary interests of the solicitor.

Criteria for Evaluating Fairness in Job Execution or Decision Making

- A conflict of interest arising when an employee either accepts or rejects a solicitation.

- The undue psychological stress an employee experiences in maintaining impartiality in their work due to a solicitation.

Scope of Solicitation Registration

- The Clean eNtoB system is designed to pre-emptively thwart any unethical behavior stemming from solicitations. Therefore, the scope of what constitutes a solicitation is broader than the legal definition, encompassing all acts that could compromise fairness.

- In cases where it's unclear whether an action is a solicitation or a regular task, employees should refrain from making a judgment and register all details in the system as a matter of principle.

- Employees who knowingly avoid registering any act of solicitation could face severe disciplinary consequences.

Actions Requiring Registration
as a Solicitation

1. Special favor requests concerning equipment/material procurement and contractual matters.

2. Appeals for preferential treatment in personnel-related activities, including recruitment, promotion, rewards, punishments, or position relocations.

3. Requests for extraordinary privileges or benefits that deviate from standard procedures.

4. Requests leading to a neglect of managerial or supervisory duties such as inspections and audits.

Actions Exempted from Solicitation Registration

1. Immediate withdrawal of a solicitation upon expression of rejection.

2. Official requests for cooperation.

3. Routine directives from an organizational superior.
* If the directive is deemed to violate regulations, it should be registered.

4. Straightforward confirmations, queries, or complaints regarding factual matters.

5. Requests for assistance from related organizations or departments for task execution.

Handling of Registered Solicitations

- The outcomes of registered solicitations are managed independently by respective departments, such as HR and Procurement. Based on these outcomes, disciplinary measures may be implemented against relevant employees or firms.