Reward Program for Reporting Ethical Misconduct

As part of our commitment to a strong ethical culture, we offer rewards to those who report misconduct in good faith.

What You Can Report

  • Accepting money, gifts, or hospitality from a business partner or other outside party in connection with one’s work
  • Misusing one’s position for personal gain, or harming the company through dishonest conduct
  • Any other unethical conduct involving an outside party

How Rewards Are Determined

  1. Eligibility
    • To protect a reporter’s identity during the reward process, reports are received directly by a senior member of the ethics team, kept confidential, and delivered by the method the recipient chooses.
  2. Reward Amount
    • Maximum reward: KRW 10 million
    • When a report leads to a direct financial benefit for the company, such as recovering income, increasing revenue, or reducing costs through compensation for damages or the clawback of improper gains, that amount serves as the basis for calculating the reward as set out below.

① When a report reduces the company's losses and the corresponding amount is recovered:

Recovered amount
Reward
Under KRW 10 million
No reward
KRW 10 million or more
3% of the recovered amount (up to KRW 10 million)
  • For one-time gains or savings, the full amount applies; for benefits arising over an extended period, the estimated annual amount is used.
  • Any additional amounts uncovered during the ethics team's own investigation are excluded from the reward calculation.

② No reward is paid when the eligible amount cannot be determined, or when the report does not result in any actual recovery.

  1. When Rewards Are Not Paid
    • The report proves to be untrue, or cannot be substantiated due to insufficient evidence
    • The misconduct is unrelated to dealings with an outside party
    • However, conduct that directly harms the company—such as embezzlement or theft of company assets—remains eligible for a reward
    • The matter has already been reported, or is already known to the ethics team, another internal department, or an outside authority—and is under investigation, or subject to disciplinary action that is ongoing or complete
    • The matter is already public, for example through media coverage
    • The report is anonymous or filed under a pseudonym, so the reporter cannot be identified
    • The report merely suggests a business improvement
    • A reward is otherwise determined to be inappropriate after review

Confidentiality of the reporter’s identity

  1. Payment of rewards
    • To protect a reporter’s identity during the reward process, reports are received directly by a senior member of the ethics team, kept confidential, and delivered by the method the recipient chooses.
  2. No disclosure or attempts to identify the reporter
    • No employee may disclose a reporter's identity, whether learned through their work or by chance.
    • Any action that could reveal a reporter's identity—such as asking about or trying to find out who they are—is prohibited.
    • The identity of a reporter or anyone assisting an investigation must not be disclosed or implied without their consent.
    • Anyone who breaches this duty of confidentiality may be subject to disciplinary action.
  3. Protection against retalization
    • Retaliation against a reporter in any personnel matter is prohibited, and violations are subject to disciplinary action under established rules.

How to Report

  1. Ways to Report
    • You can report through the Ethics Center (online), by mail, by phone, or in person—whichever is most convenient for you.
  2. What to Include
    • Provide your own details and those of the person involved, and describe the misconduct using the 5W1H framework (who, what, when, where, why, and how).

Contact the Responsible Department

email: holdings_ethics@posco-inc.com

phone number: 080-390-3366

Address: POSCO Holdings Ethics Team, 440 Teheran-ro, Gangnam-gu, Seoul, South Korea