Ethical Misconduct

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Reward for Reporting

With the goal to build a sound corporate culture by preventing ethical misconduct, we reward those who report unethical behaviors.

Ethical Misconduct

·Act of accepting bribes or lavish treatments offered by external stakeholders to influence business decision

·Use of one’s position of power to gain unjustified personal benefit; using unjust means and/or harboring wrongful intent to cause harm to the company

·Other ethical misconduct involving external stakeholder(s)

※ Please note that your report may be excluded from the investigation if.

·you report about an employee's personal life and/or private disputes that the company cannot get involved in;

·you request preferential treatment in connection with the report or make the report for unjustifiable purposes;

·or you slander others with unfounded, malicious reports or falsehoods or one-sided allegations.

Eligibility & Value of Reward

1. Eligibility

General public (exception: POSCO Group employees)

2. Reward

·Maximum: ₩10 million

·When liability compensation or recovered loss results in direct growth in corporate revenue and/or reduced cost, a percentage of the money recovered will be added, based on the following rules, to the total value of the reward.

①When the filed complaint results in loss ruling and when the money is recovered

Recovered Value Reward
Below ₩10 million None
In excess of ₩10 million 3% of the recovered amount (₩10 million max.)

·If the report leads to a one-off recovery of revenue or loss, reward shall be based on the total recovered amount. However, if the recovery is expected over time, the reward is to be based on the annualized recovery amount.

·Any additional recovery identified during ESG team’s investigation shall be excluded from the reward.

②When value of the recovery cannot be estimated or when no recovery of loss results from the report, no reward shall be provided.

3. Exceptions to Reward Payment

·When the report is proven to be false, or when claim cannot be substantiated due to insufficient evidence

·When the reported misconduct is unassociated with the business activities involving external stakeholder(s)

·All whistleblowers are rewarded for reporting conduct that causes direct damage, i.e., embezzlement, theft

·When the reported misconduct has been reported or is under investigation by the ESG team or other organizations and/or external agencies, and for which disciplinary action has been taken or is underway

·For misconduct already exposed in media

·When the whistleblower requests anonymity or uses a pseudonym, making it impossible to identify the complainant

·When the report simply suggests a business process improvement

·When deliberation rules ineligibility for the reward

Whistleblower Protection

1. Payment of Reward

To protect the whistleblower’s identity during the payment process, the ESG team leader shall collect the reward and deliver it to the whistleblower through means desired by the recipient and in a manner that ensures confidentiality

2. Whistleblower Identity Protection

·Should an employee become aware of the whistleblower’s identity in line of work or by chance, the identity shall be kept concealed

·Any act or attempt, such as inquiry or investigation, made to expose the whistleblower’s identity is strictly prohibited

·Any act that exposes, disclosed or implied, the identity of the whistleblower and/or those interviewed during the investigation without their consent is strictly prohibited

·An employee who has violated the duty to protect the identity can be penalized

3. Protection against Retaliation

Any adverse action taken against a whistleblower is strictly prohibited; those in violation shall be subject to punishment as provisioned in the Company bylaws.

How to File a Complaint

1. Select a Method

At Cyber Center (to report online) or by post mail, phone, fax or in person

2. Reporting Instruction

Identify self and the violator and document the event based on the 5W 1H guiding framework to report the ethical misconduct

3. Report Filing

·Online: Visit POSCO Holdings website (www.posco-inc.com) and go to Ethics & Reporting → click Report

·Tel: (External) 080-390-3366 (Internal) 02-3457-3366

·Mail: (Postal code) 06194 /440, Teheran-ro, Gangnam-gu, Seoul (892, Daechi 4-dong, Gangnam-gu, Seoul) ESG team, POSCO Holdings

We receive information about POSCO Group employees and their unfair business practice, unreasonable demands made using positions of power and other ethical misconduct. Filed reports are kept strictly confidential. Groundless slander, facts pertaining to personal life, payment delays and overdue wages unrelated to POSCO Group companies do not qualify as whistleblower reporting. For qualifying reports, cases are processed as quickly as possible; their outcome can be tracked through the channel used to file the complaint. Upon the request of the reporter, results can be provided by e-mail.


The whistleblower’s confidentiality is thoroughly protected; outcome will not be provided to anonymous reporters. For general business-related inquiries, please refer to other pages of this website and/or reach out to the relevant department.

Confidentiality of the Reporter’s Identity

A. Prohibition on Revealing or Tracking Down the Reporter’s Identity

- All employees, if having become aware of the reporter’s identity by duty or accident, shall not reveal such information.

- All actions that may expose the reporter’s identity are prohibited, such as inquiries about the identity or engaging in investigations to find out about the reporter.

- Disclosure or suggestion of the reporter’s or investigation cooperator’s identity is prohibited without their consent.

- Those violating the duty to protect the identity may be punished.

Those violating the duty to protect the identity may be punished.

- Prohibition on punishment in personnel affairs to the reporter and stipulation of the penalty clause in case of violation.

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- To view the result of the report, please make sure to keep the password and the registration number issued upon the completion of your complaint.

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Consent to Collect Personal Information

□ Personal Information Collection Purpose/Type/Use

1. The Ethical Misconduct Reporting Center collects minimum personal information necessary to confirm the wrongdoing and to provide reply of outcome. Therefore, we ask for your consent to the collection and use of personal information.

2. Type of Information Collected
- Reporter, phone number, email address and password

3. Personal information is retained for 5 years from submission of the complaint by the reporter (data subject).

4. The data subject has the right to decline to consent, in which case s/he will not be able to use the reporting system.
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- To view the result of your report, please provide one of password, registration number, phone number or email address

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Consent to Collect Personal Information

□ Personal Information Collection Purpose/Type/Use

1. The Ethical Misconduct Reporting Center collects minimum personal information necessary to confirm the wrongdoing and to provide reply of outcome. Therefore, we ask for your consent to the collection and use of personal information.

2. Type of Information Collected
- Reporter, phone number, email address and password

3. Personal information is retained for 5 years from submission of the complaint by the reporter (data subject).

4. The data subject has the right to decline to consent, in which case s/he will not be able to use the reporting system.
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