홈 지속가능경영 공정거래
Operating Report on the Fair Trade Compliance Program (CP), 2H 2025
2026년 1월 8일
| 1. Status of Fair Trade Compliance Program (CP) Operations | ||
| 1. Title | Operating Report on the Fair Trade Compliance Program (CP), 2H 2025 | |
| 2. Key Details | ||
| [CP Operational Performance, 2H 2025] | ||
| ■ Fair Trade Commission (FTC) CP Rating Evaluation | ||
| ○ Achieved 'AA' rating in the FTC Fair Trade CP Evaluation | ||
| - First company in the MRO industry to obtain an 'AA' rating for two consecutive | ||
| evaluations (2023, 2025) | ||
| ■ CP Budget Execution Rate: 98% | ||
| ■ Internal Events with CEO Participation Related to Fair Trade CP (2 events) | ||
| ○ Declaration Ceremony for Strengthening Fair Trade CP (July 24): | ||
| Attended by the CEO and members of the Compliance Council | ||
| ○ The 1st N2B “Fair Trade Day” (November 28): Open to all employees | ||
| ■ Fair Trade Education Programs | ||
| ○ Training for Internal Employees | ||
| - External expert training on fair trade (3 sessions) | ||
| * PIUM online training (July), P-Holdings Legal Department training (September), | ||
| Attorney Jang Poong training (November) | ||
| - Annual distribution-based fair trade training (62 sessions/year) | ||
| * Fair trade campaigns (54), subcontractor training (6), online training (2) | ||
| - Face-to-face fair trade training for all employees hosted by the Office of Ethical | ||
| Management(7 sessions, September 5–19) | ||
| - Compliance training on the Fair Trade Act for CP violators (through December 31) | ||
| ○ Training for CP Operating Staff | ||
| - Participation in the “Briefing Session on the Subcontract Price Linkage System” | ||
| hosted by the Subcontract Price Linkage Support Division (October 31) | ||
| - Participation in PCA (POSCO Compliance Academy) hosted by POSCO Group (September 9) | ||
| - Participation in compliance-related training conducted by the Korea Fair Trade | ||
| Compliance Association (2 sessions) | ||
| - Renewal of Certified Compliance Professional (CCP) qualifications for CP managing | ||
| department staff (2 persons) | ||
| ■ Audits and Pre-Inspections Related to Fair Trade CP in the Second Half | ||
| ○ Pre-audit of private contracts in 2H (220 cases): 40 cases rejected | ||
| ○ Business audits including joint inspections on unfair subcontracting practices (2 cases) | ||
| ○ Complaint investigations (3 cases) | ||
| ■ Compliance Council Meetings | ||
| ○ Fair Trade Compliance Council meetings held (July and December, 2 meetings) | ||
| ○ Meetings with Fair Trade Practice Leaders (September and December, 2 meetings) | ||
| ■ Effectiveness Evaluation and Improvement Measures | ||
| ○ Conducted effectiveness evaluations to assess employees' CP awareness and understanding | ||
| ○ CP satisfaction score based on employee surveys(1H 2025: 89.3 → 2H 2025: 91.4) | ||
| - With the improvement in CP satisfaction scores, CP-related internal events and training | ||
| programs will be maintained and further enhanced | ||
| ■ Establishment of a Proactive Response System through Internal Monitoring | ||
| ○ Department-level risk assessments conducted in the second half | ||
| (5 departments rated “High” risk in Q4) | ||
| ○ 2025 regular fair trade audits and complaint investigations (10 cases) | ||
| - Personnel actions: 2 employees | ||
| - Administrative actions: 18 cases | ||
| ○ 2025 pre-audit of private contracts(415 cases) | ||
| ○ Participation in group-wide joint inspections to strengthen compliance with the Fair | ||
| Trade Act | ||
| - First half: Review of unfair special clauses and improper requests or misuse of | ||
| technical data | ||
| - Second half: Review of compliance with five major prohibited unfair subcontracting | ||
| practices | ||
| ■ Revision and Implementation of the Fair Trade Compliance Manual (December 31) | ||
| ○ Addition of six pages reflecting amendments to the Subcontract Act | ||
| - Explicit inclusion of “Invalidation of Unfair Special Clauses under Civil Law” | ||
| pand “Retention Money Agreements in the Construction Industry” | ||
| - Description of relevant cases, practical response measures for principals and | ||
| subcontractors, and contract managers’ checkpoints | ||
| ■ Incentives for Employees with Outstanding CP Participation (e-coupon awards) | ||
| ○ Awards for outstanding CP participants and departments in the first and second halves | ||
| (9 employees, 2 departments) | ||
| - [July 24] Outstanding CP Participants (4 employees) and Outstanding Department (1) | ||
| for 1H | ||
| - [November 28] Fair Trade Champion (1), Outstanding CP Participants (4 employees), | ||
| and Outstanding Department (1) for 2H | ||
| ○ Outstanding participants in the second half: | ||
| - Fair trade blog contributors (18) | ||
| - Fair trade self-diagnosis checklist participants (10) | ||
| - High performers in understanding assessment (29) | ||
| - Event participants for face-to-face fair trade training (21) | ||
| - Quiz event winners for the 1st Fair Trade Day (10) | ||
| ■ Participation in the 2025 Group CP Activation Support TFT Hosted by P-Holdings | ||
| ○ Coaching support provided to two companies to promote CP activation: | ||
| POSCO Group affiliate Busan E&E Co., Ltd. and partner company A-Tech | ||
| - Coaching activities (Busan E&E) on August 22 and on-site training support | ||
| on September 25 | ||
| - Coaching activities for mid-sized partner A-Tech (July 15 and September 22) | ||
| ■ Revision and Implementation of Regulations Related to Fair Trade CP | ||
| (25 revisions in 2H 2025; total of 36 revisions in 2025) | ||
| ○ Grade A regulations (including Fair Trade CP Operation Guidelines, 3 regulations): | ||
| revised 3 times | ||
| ○ Grade B regulations (including General Terms and Conditions for Goods Purchasing, | ||
| 5 regulations): revised 5 times | ||
| ○ Grade C regulations (including Ethical Code Practice Guidelines, 12 regulations): | ||
| revised 3 times | ||
| 3. Decision Date | 2026-01-08 | |
| 4. Other Important Matters Related to Investment Decisions |
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| ※ Related Disclosure | - | |