• 1. All employees of the Company (the “Employees”) shall conduct their duties based on the principle of integrity, while clearly recognizing the scope of their authority and responsibility. Employees shall not hold outside jobs, nor engage in any part-time job or any extra job which may affect their duties with the Company.
• 2. Being aware of that each Employee’s words and deeds may directly affect the Company’s integrity and reputation, Employees shall endeavor to fulfill their responsibilities and obligations as a member of the community.
• 3. Employees shall not engage in any action that undermines the establishment and development of sound interpersonal relationships in the workplace between superiors and inferiors, or among colleagues, including sexual harassment and coercion of personally burdensome wrongdoings. Further, Employees shall promote sound corporate culture by respecting each other in a spirit of mutual trust.
• 4. Employees shall distinguish between Company business and personal affairs when performing work, and perform their assigned tasks fairly and transparently. Employees shall not receive from, nor offer to, the Company’s stakeholders, money and other valuables, treats or favors.
• 5. Relevant Employee shall promptly report it to the Help Line in the event of any business deals between the Company or BPs and a family member or a relative of the Employee, to prevent any possible conflict of interest.
• 6. Employees shall not engage in any activity directly or through a third party where there is a conflict of interest between themselves and the Company.
• 7. Employees shall protect the Company’s tangible and intangible assets, and use them in a fair manner. Employees shall proactively protect the Company’s intellectual property rights, including trademark rights, patent rights and copyrights. In the event of the occurrence of actual loss to the Company or a possibility thereof, Employees shall immediately report such occurrence or possibility to the Company and take measures to prevent or minimize any loss to the Company.
• 8. Employees shall make appropriate use of the Company budget, in accordance with the intended purpose of the budget and relevant rules and shall not divert the budget for personal gain.
• 9. Employees shall protect and properly manage the Company’s information and trade secrets. Employees shall maintain the security of important confidential information, except as permitted by law or company internal regulations. Confidential information includes all non-public information that could be harmful to the company or its clients if disclosed to third parties, encompassing both confidential information provided by BP to the company and information provided by customers to the company. The obligation to preserve confidential information remains in effect even after termination, as reaffirmed by signing a confidentiality agreement upon departure. Employees shall not use any confidential information of the Company obtained during his/her performance of duties for any personal purpose, or make any attempt to gain personal benefit by disclosing such information to a third party. Employees shall not disclose, internally or externally, the Company’s information and trade secrets without prior approval, and shall fully cooperate in the safekeeping and reviewing of electronic documents transmitted outside the Company in accordance with the Company’s information security policy.

This Code of Ethics is applicable to the Company (including its domestic and foreign subsidiaries controlled by the Company) and all Employees of the Company. The Company shall encourage its stakeholders to understand and practice this Code of Ethics. Employees have the obligation to comply with this Code of Ethics and to pledge their compliance to this Code of Ethics. If there are any questions related to interpreting or implementing this Code of Ethics, Employees should contact the Head of the Ethics Management Office to seek advice using the Help Line, etc. Employees shall report any violation of this Code of Ethics to the Help Line. Department Leaders shall be responsible for managing and supporting their Employees and stakeholders to correctly understand and comply with the company’s Code of Ethics.

The Company’s Ethics Management Office shall establish and operate the online Help Line on the Company’s Internet homepage (http://www.skplanet.com). The head of the Ethics Management Office shall further investigate inquiries and reports related to ethics management and take the following measures where it is deemed necessary. The head of the Ethics Management Office may transfer the matters to the Audit Team of affiliates or other relevant teams. Where it is deemed necessary that the inquiries and reports should be reviewed in detail, the Director in charge of Ethics Management shall handle the matters following the consultations with related teams. The Company may make favorable arrangements in handling the cases related to BPs after considering the importance and seriousness of the violation and receiving from the BPs a written pledge not to repeat the violations in ethics management. The Company may take necessary measures including the restriction on transaction volume, or the cancellation of contracts with the BPs, in consideration of the seriousness of the violation and the effects of the violation on the Company and the community at large. The Company shall strive to protect the status of the inquirer or whistleblower and encourage reports and inquiries related to the ethics management. The Company shall protect the status of the inquirer or whistleblower related to the ethics management (the “Whistleblower”), including the contents of any inquiries or reports, and shall strive to protect them from any disadvantageous treatment. Upon the disclosure of the identities of the Whistleblower, such Whistleblower may notify such disclosure to the head of the Ethics Management Office and ask for the protection of his/her status. In this case, the head of the Ethics Management Office shall take necessary measures including the transfer of the Whistleblower to another Team, in consultation with the head of the Human Resource Management Office. The Company’s employees shall not take any action that may cause the identities of Whistleblowers to be disclosed, including an inquiry or investigation into the identities of the Whistleblowers. When a Whistleblower, who is involved in any acts of business ethics violation, makes an inquiry about or reports such acts, his/her efforts to tell the truth shall be taken into account in punishing or taking a disciplinary action against him/her. The Company may reward parties that make reports and inquiries regarding the Company’s ethics management, in cases where such reports have benefited the Company.

SK Planet promotes the happiness and value of its stakeholders and grows together with them through communicating through various channels.

• Stakeholder identification

• Materiality assessment and implementation of core needs

• Stakeholder Engagement

• Comm. channel operation

• Mornitoring

• Review