"SAC is managing the company
and legally to grow together
with our customers and joint
ventures and create profit"

We try to be the company that are trusted not only by our customers but also by various interested parties such as joint ventures / internal customers / local community for our executives and employees by establishing and executing Ethics Regulations and Code for Ethics as follows.

Ethics Regulation
Chapter 1 General Rules
Article 1 ( Purpose )
The purpose of this regulation is to define the right behavior and standard with which management and employees (Hereinafter referred to as "personnel") of SAC Co., Ltd. (hereinafter referred to as "company") comply in the pursuit of their duties.

Article 2 ( Definition )
The definition of the terms that are used in this regulation is as follows.
1. "Personnel" shall be management and employees of company, and employees include workers who don't determine employment period.
2. "Interested Party" shall be every natural person, legal person, and other organizations who are affected by the behavior or decisions made by personnel in connection with business.
3. "Gift" shall be goods, securities, hotel vouchers, membership, tickets, or equivalent items provided for nothing.
4. "Treat" shall be entertaining with food, golf, etc. or providing convenience including transportation, accommodation, etc.
5. "Regulation Director" shall be the person who generalizes Ethics Regulation of company who appointed by auditor or CED of company.
6. "Personnel Committee" shall be the legislative organ which is composed by rules of employment and personnel policy, and its members are appointed by CEO the company.

Article 3 ( Subject of Application )
This regulation shall be applied to all executives and employees.

Article 4 ( Obligation and Responsibility )
Every personnel shall be fully aware of and abide by the regulation and have accompanying responsibilities for any offenses.

Chapter 2 Fair Performance of Duty
Article 5 ( Treatment of Instructions Hindering Fair Performance)
1. Personnel, when supervisors give instructions hindering fair performance to pursue their or others' unfair profits, shall declare the reasons to the supervisors and reject the instruction.
2. In case the same instructions keep being given despite the nonperformance of the instruction under Section 1, it shall be reported to Regulation Director or CED under the Ethics Regulation Article 29.

Article 6 ( Avoiding Tasks with Interested Parties )
1. Personnel, when they judge it is impossible to execute fair performances because the tasks that they perform are related to their interests or their relatives are interested parties, shall consult their manager or regulation director about avoiding the tasks and take actions.
2. The manager or regulation director who is asked to counsel under Section 1 shall decide whether it is proper for the personnel to keep performing the tasks or not and make report to CED. Only, the manager shall not make report to CEO if he/she can reassign the tasks temporarily within the scope of his/her authority.
3. CEO who is reported under Section 2 shall take necessary actions such as reassigning employees so that the task can be performed fairly.

Article 7 ( Excluding Favors )
Personnel shall not give any favors to specific person for any reasons including regionalism, school relations, or kinship when they perform their tasks.

Article 8 ( Prohibition of Use of Budget for Other Purpose )
Personnel shall not make a loss to company property by using budgets for other purpose other than job performance including travel expenses and business operating expenses.

Article 9 ( Prohibition of Requesting Job Position )
1. Personnel shall not make other person to request special consideration of human resources manager to have an unfair influence on their promotion or transference.
2. Personnel shall not make unfair intervention in personnel matters such as promotion or transference of other personnel by abusing their position.

Chapter 3 Prohibition of Accepting Unfair Profits
Article 10 ( Prohibition of Exercising the Right to Privileges )
1. Personnel shall not derive any unfair profits for himself/herself or assist other people to make unfair profits by using his/her authority or position.
2. Personnel shall not take advantage of the name of company or his/her position or let others to use it to derive any unfair profits for him/herself or others.

Article 11 ( Prohibition of Arrangement and Request )
1. Personnel shall not make arrangement or request that hinder fair performance of other personnel for their or other person's unfair profits.
2. Personnel shall not introduce an interested party to another interested party in connection with their performances for their or other person's unfair profits.

Article 12 ( Restriction on Dealings with Job-Related Information )
Personnel shall not make property transactions including securities and real estate or make investment by using the information concerning their tasks or help other person to make deals or investment by providing the information.

Article 13 ( Prohibition of Receiving Money and Valuables )
1. Personnel shall not receive money, valuables, real estate, gift, or treat (Hereinafter referred to as "Money and Valuables, etc.") from interested party. Only, it shall make an exception in any of the following subparagraph.
① Money and Valuables, etc. provided by fair title including fulfillment of obligation
② Plain meal or convenience including transportation or communication that is usually provided within 50,000 won per person.
③ Transportation, accommodation, or meal provided uniformly to the participants by host in an official event related to the duties
④ Souvenirs or promotional goods for handing out to many and unspecified persons.
⑤ Money and Valuables, etc. provided officially to assist personnel who are in difficult conditions due to illness, disaster, etc.
⑥ Simple gift usually provided within 50,000 won per person.
⑦ Money and Valuables, etc. provided by superiors to their subordinate for the purpose of boosting to their morale including comfort, encouragement, reward, etc.
⑧ Simple gift to show good faith of members for celebrating personnel's birthday, transference, etc.
⑨ Money and Valuables, etc. provided within budget permitted by CEO for effective performance of duties.
2. Personnel shall not receive Money and Valuables, etc. from interested party concerning duties of the day.
3. It shall not be permitted to receive sponsorship or gift from interested party for a get-together or event for division other than official events.
4. Personnel shall not let their spouse or family members receive any Money and Valuables, etc. prohibited under Section 1 from interested party.

Article 14 ( Prohibition of Personal Use•Profit from Company Property )
Personnel shall not use or make profit from company property including office cars, business or office materials, chattel, realty, etc. for personal use without reasonable cause.

Article 15 ( Prohibition of Providing Money and Valuables )
1. Personnel shall not provide Money and Valuables, etc. to government officials or politicians who are concerned to the duties for pursuing the benefit of company. Only, it shall make an exception of small amount of political fund with tax credits under the "Political Fund Act" Article 27.
2. Personnel shall not let their spouse or family members provide Money and Valuables, etc. prohibited under Section 1 to government officials or politicians who are concerned to the duties for pursuing the benefit of company.

Article 16 ( Incorrupt Conclusion and Fulfillment of Contract )
1. Personnel shall perform their duties fairly and transparently according to the prescribed procedure in the related Act in bid contract and its fulfillment.
2. Personnel, in pursuance of the bid contract and its fulfillment of Section 1, shall not request prohibited Money and Valuables, etc. or make unreasonable demand such as enforcing unfair business terms by abusing its superior position.

Article 17 ( Fair and Transparent Information Acquisition and Finance Management )
1. Personnel shall record and report every information which is obtained in fair method and shall not manipulate or destroy information for the benefit of specific individual or group.
2. Personnel shall record and manage accounting records, and other finance management accurately and transparently on the basis of the fact under related Act and generally accepted accounting principles.

Chapter 4 Observance of Confidentiality
Article 18 ( Prohibition on Information Spill )
Personnel shall not reveal any job-related information to the third party without prior permission or approval from company.

Article 19 ( Prohibition on Using Illegal Software )
1. Personnel shall not make illegal copies of software or download it from the internet.
2. Personnel shall certainly delete illegal software and company shall purchase only original software.

Article 20 ( Compliance Details )
For observing and managing Confidentiality, and related matters, personnel shall abide by System Security Management Guidelines which are separately provided.

Chapter 5 Proper Conduct
Article 21 ( Restriction on Speculative Behavior )
Personnel shall not speculative behaviors such as gambling, golf for money, etc. that are considered to be illicit through generally-accepted idea in the society.

Article 22 ( Prohibition of Inappropriate Use of Information Network )
Personnel, by using in-house information network, shall not do behaviors equivalent to the following paragraphs
1. Using network to connect to harmful site or unhealthy chat site, gamble, play games, etc.
2. Purchasing or selling stocks
3. Illegal behavior including using or appropriating unauthorized IP address and transferring IP permission without notice
4. Hindering normal operation of network by spreading computer virus
5. Other behaviors using network for inappropriate purpose other than job performance

Article 23 ( Prohibition of Sexual Harassment )
Personnel shall not do any behaviors seducing others sexually or causing sexual humiliation including the following paragraphs.
1. Touching or contacting specific body parts
2. Telling filthy joke or dirty and indecent talk
3. Describing sexually or evaluating other's appearance
4. Posting or showing obscene photos or pictures
5. Forcing to serve liquor or dance at office dinners
6. Other behaviors that are considered to cause sexual humiliation through generally-accepted idea in the society

Article 24 ( Conflict of Interests )
1. Personnel shall put company profit priority than personal profit when performing duties.
2. Personnel, who are in relationship of conflict of interest with customers or company, or perform their duties under the circumstance that might have conflict of interest, shall consult with Regulation Director or CEO.

Chapter 6 Creating Sound Corporate Culture
Article 25 ( Prohibition of Borrowing Money )
1. Personnel shall not borrow money or realty for free of charge (this includes noticeably low price compared to market price or common practice ) from interested party. Only, it shall make exception in case personnel borrow money from banking facilities under "Law of Real Name Financial Transaction" Article 2 on common terms.
2. Personnel, who is willing to borrow money or realty for free or charge owing to unavailable circumstances despite the Section 1, shall report Regulation Director or CEO.
3. Personnel shall not have debt exceeding their capacity of performance or imprudent debt guarantee.

Article 26 ( Restriction on Noticing Family Event and Accepting Money and Valuables )
1. Personnel shall not notice their family event (Marriage, childbirth, first Birthday, death, 60th birthday party of themselves or their family members) to interested party. . Only, it shall be permitted in any of the following subparagraphs.
① Noticing to relatives, members of social gatherings (alumni meeting, clubs), and members of religious group
② Noticing to personnel from formal organization
③ Noticing through newspapers and broadcasts
④ Noticing through bulletin of the social gatherings or website
2. Personnel shall not provide or receive money and valuables exceeding common range any of the following subparagraphs.
① Money and valuables provided by interested party
② Money and valuables provided by mutual employees

Article 27 ( Voluntary Reporting of Charging with Criminal Case )
Personnel shall immediately report to Regulation Director or CEO if they are under indictment on criminal case or sentenced more than imprisonment. Only, it shall make exception on equivalent to the following paragraphs.
① In case of summary order
② Due to traffic accident

Article 28 ( Recommendation for management improvement )
1. Personnel shall suggest freely when they have recommendation for management improvement.
2. CEO shall consider its urgency and importance and introduce it to Personnel Committee as an agenda or a matter of decision.

Chapter 7 Measures for Violation
Article 29 ( Counsel for Violations )
1. Personnel, who are unsure of violation of the duty, shall consult with Regulation Director before handle the duty.
2. Regulation Director shall record and store its contents and corrective measures in written form.

Article 30 ( Report and Treatment of Violations )
1. Anyone who is aware of violation of other personnel shall report to Regulation Director or CEO.
2. Informant who report under Section 1 shall specify personal information of oneself and the violator, and content of violation.
3. Regulation Director shall confirm the reported violation under Section 1 and report it to CEO with the material for explanation from the relevant personnel.

Article 31 ( Identity Security of Informant )
1. CEO and Regulation Director shall ensure security on informant and its contents and make sure that informant would not be treated discriminatingly or disadvantaged in any way.
2. Informant who has received any discrimination or disadvantage despite the above regulation shall request CEO or Regulation Director to take protective and relief actions. On this occassion, CEO and Regulation Director shall take proper measures.
3. In case of the violation is revealed by voluntary report under the regulation, the disciplinary action or punishment on the reporter shall be deducted or remitted.

Article 32 ( Reward and Disciplinary Actions)
1. CEO shall offer rewards such as reflecting in performance review which are equivalent to the personnel's behaviors including abiding by the regulation and contributing to reinforce ethical management.
2. CEO shall take necessary measures such as disciplinary action to the personnel who behave against the regulation.
3. Personnel Committee shall be established to evaluate and try reward and disciplinary action. Operation and composition of Personnel Committee shall follow the rules of employment and other regulations.

Article 33 ( Handling Prohibited Money and Valuables )
1. Money and valuables that are against Article 13 or Article 25 Section 2 shall immediately be returned.
2. If Money and valuables which have to be returned under Section 1 may be apprehended to be destroyed, corrupt, or deteriorated, or may not know its provider or the address of the provider, or it is difficult to return it to the provider, it shall immediately be delivered to Regulation Director.
3. Delivered money or valuables, etc. under Section 2 shall be handled as the following paragraphs.
① Money or valuables, etc. do not have financial value owing to destruction, corruption, or deterioration shall be disposed.
② Money or valuables, etc. that may be apprehended to be destroyed, corrupt, or deteriorated shall be donated to social welfare foundations.
③ Other money and valuables that have financial value shall be donated to social welfare foundations through procedures such as noticing on website.
④ Regarding money and valuables, etc. handled under Section 3, its information including provider, Receiver, Provided money and valuables, etc., date of providing, and details of measures shall be recorded in annexed form and it shall be informed to the provider. It shall not be informed only provider's address is not available.

Article 34 ( Regulation Director )
1. Regulation Director shall generalize ethics regulations and the tasks are as follows..
a. Education and counsel of regulation
b. Report, accept, and treatment of violation and protection of the informant
c. Executive office of personnel committee concerning ethical management
d. Other regulations related to ethical management and necessary matters to operate the regulations
2. Regulation Director shall not divulge any secret information obtained by performing Section 1 tasks.

Chapter 8 Others
Article 35 ( Education )
Personnel shall have education of this regulation in case of the new employment and can execute this education frequently if necessary.

Article 36 ( Inspection of Compliance )
① Regulation Director shall regularly inspect personnel to ensure their full compliance with the regulations.
② Regulation Director, who detects any violation by personnel as a result of inspection under Section 1, shall immediately report it to CED and take necessary measures.

Article 37 ( Detailed Rules for Operation )
The CEO shall establish detailed rules for operation on matters concerning operation of the regulation.

Additional Clause
Article 1【Enforcement Date】
1. This regulation shall enter into force on September 01, 2013.

Code for Ethics
Chapter 1 Management
We, the members of SAC Co, Ltd., exist together with our customers, and the customers are the foundation of our growth and existence. Therefore, we provide goods and service with the best quality by putting priority on customer satisfaction in all management activities.

Article 1 (Providing Goods and Service with the Best Quality)
We shall pursue the customer-first principle with best quality, best service, and reasonable price to realize customer satisfaction.

Article 2 (Good Communication with Customers)
1. We shall positively and actively accept suggestion and request form customers and make a rapid settlement for any complaints and disputes fairly and reasonably.
2. We shall keep every promise that we have made to our customers and do our best to communicate well with our customers.

Article 3 (Protection of Customers' Rights)
1. We actively make public any contents of which customers should be aware for customers' rights.
2. We shall protect all assets of our customers on equal terms with our assets. We also shall avoid external leakage of customer-related information or using it for another use that are different from its original purpose without prior consent of the customers.
3. We shall not cause damage to customers' rights and interests due to our immoral acts.
4. We shall mark faithfully and properly on our products and shall not release false or exaggerated advertisements.

Chapter 2 Abiding by laws and Social Responsibility
We abide by all the laws with which companies must comply and contribute to the affluent lives of citizens and the social growth by developing the company with healthy business through a fair competition.
Article 1 (Abiding by laws)
We shall abide by all the international and national laws, rules, standards that companies have to comply with in regard to social activities and commercial transaction and shall not make profits by dishonest means that are against business ethics and trade ethics.

Article 2 (Healthy Business)
1. We shall recognize that competition is the driving force of mutual development, respect market-economy system, and avoid any actions that may hinder it.
2. We shall obtain every information fairly and shall not use or leak out by dishonest means.
3. We shall compare ourselves with our competitors based on clear and objective data.
4. We shall not use our competitors' weakness which is not officially confirmed and release abusive advertisements.

Article 3 (Social Responsibility)
1. We shall recognize the fact that social responsibility of companies set out from voluntary service to the society and actively participate in various community service and cultural development projects.
2. We shall contribute to establish a welfare society by sincerely conducting obligation to pay taxes and creating jobs.
3. We shall perform the business reasonably and avoid all actions that may harm to the national economy.
4. We shall heighten the sense of unity between the company and local community where each business site is located by opening welfare facilities to the local residents, supporting disadvantaged and encouraging employees to participate in community activities.

Article 4 (Protection of Environment and Resources)
We shall conduct our business in environment-friendly way, actively participate in protection of environment, abide by all the regulations related to this, and take the lead in protection of environment and resources through saving resources and continuous technical development.

Article 5 (Safety Management and Accident Prevention)
1. We shall make every effort to manage safety and prevent accidents, and in the event of accident, shall take rapid measures by considering the safety of customers and local residents as top priority.
2. We shall implement education and training to prevent negligent accident and take a rapid measurement when the accident occurs and shall inspect facilities regularly.

Chapter 3 Co-Prosperity with Joint Ventures
We recognize the fact that we are required to strengthen relationship with our joint ventures and form a mutual partnership to prosper together. We coexist on the base of trust and cooperation.

Article 1 (Equal and Fair Trade)
1. Every joint venture shall have equal opportunity to be selected as contractor on the basis of qualification.
2. Joint ventures shall be selected objectively and reasonably on the basis of fair standards.
3. Every transaction shall be performed fairly in such positions of equality with prior consultation, and any sorts of actions of abusing superior positions shall not be allowed.

Article 2 (Co-Prosperity)
1. We shall make an effort toward co-prosperity with our joint ventures through various support and cooperation to their business operation.
2. We shall make an effort not to go against the aim of Code for Ethics by creating equal, fair, and transparent business environment.

Article 3 (Prohibition of Receiving Money, Valuables, Treats, Etc.)
1. We shall not receive any kinds of gifts, money, valuables, or treats including cash, vouchers, etc.
2. We shall not be provided any expenses including transportation or accommodation incurred on business trip and any convenience for personal purpose.

Article 4 (Prohibition of Other Unfair Practices)
1. We shall prohibit any gambling acts with employees from joint ventures.
2. We shall prohibit double employment as executives or employees of our joint ventures.
3. We shall not conduct any acts including cash loan, a joint surety, etc.

Chapter 4 Basic Ethics of Management and Employees
Our executives and employees are bases of SAC. Therefore, we recognize that upright ethics of each employee are the foundation of business ethics and make our best to be ethical citizens through fair performance of duties.

Article 1 (Maintenance of Honor and Dignity)
1. The executives and employees shall dress neatly and behave in a good manner with pride that their behaviors represent the company.
2. The executives and employees shall respect each other as independent human beings and shall not behave irreverently to and slander others.

Article 2 (Fair and Autonomous Work Performance)
1. The executives and employees shall recognize that we are an organic community working towards a common goal and pursue the company's growth and development by excluding egoism and supremacy between divisions and cooperating reasonably.
2. The company shall not give too much discretionary power to the executives and employees who have less credibility, and the executives and employees shall recognize the aim of the company and have responsibility for their decision and behaviors.
3. The company may take necessary personnel measures if the executives and employees are considered to be insolvency due to cash loan, joint surety, etc. and be mentally and physically unable to perform a fair and effective job.
4. The executives and employees shall keep their private and public lives separate and perform their tasks neutrally.
5. The executives and employees shall make their best efforts under authority and responsibility that have given to them, abide by all the regulations and rules, and not take actions including misfeasance, mendacity, exaggeration, concealment, divulgement, etc. for personal profit.

Article 3 (Fair and Harmonious Organizational Culture)
1. The executives and employees shall make more harmonious organizational culture by respecting privacy for each other and creating an atmosphere to express their suggestions, proposals and difficulties freely.
2. Seniors shall actively develop their subordinates' talents and support them for developing human resources.
3. The executives and employees shall not discriminate or form cliques for any no job-related reasons including regionalism, school relations, kinship, gender, or physical disabilities.

Article 4 (Pleasant and Safe Working Environment)
1. We shall practice arrangement and cleaning for clean and pleasant working environment.
2. We shall prevent all sorts of accidents beforehand by complying with safety-related rules.

Article 5 (Prohibition of Sexual Harassment in Job)
1. Thorough management for preventing sexual harassment including regular education shall be conducted since sexual harassment in job may damage not only individuals but also the company's brand and even cause financial loss.
2. All sorts of words and behaviors that are relevant to sexual harassment such as causing sexual humiliation or hindering good customs shall not be allowed.

Article 6 (Responsibility)
1. The executives and employees shall not use company's property for personal use and divulge information that has been obtained while working.
2. All the executives and employees shall not spread any groundless rumors that may affect the company.
3. The executives and employees shall not use any illegal software besides software provided by the company and connect to any websites that might disrupt the performance during work hours.
4. The executives and employees shall not be involved in any improper behaviors and gambling at work site.
5. The company shall have necessary systems and actively support to cultivate creative personnel. And the executives and employees shall try to develop their abilities through autonomous self-improvement.
6. Any executives and employees who commit a violation of this code of ethics or additional ethics or find out others' violation shall report immediately to the Regulation Director

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