Training & Education
Poongsan Corporation establishes and implements the guidelines and procedures that their employees and directors must observe in order to abide by statues and make their management appropriate when the employees and directors perform their duties
※ The board of directors of the Poongsan Corporation appointed the Compliance Officer according to the Article 542-13 of Korean Commercial Act.
※ Audit Committee: Examining corporate financial records and accounting to ensure compliance with the accounting laws and transparency
※ Audit Department: Investigation of any violation of the relevant laws and unethical behaviors
※ Compliance Department : To assist the compliance officer and conduct planning/management of compliance activities and compliance trainings.
※ Legal Department : To conduct day-to-day compliance activities
※ Voluntary Compliance Director: The officer who is in charge of a division of the Company
Poongsan Corporation shall enact and implement these compliance guideline (this “Guideline”) in order to achieve fairness and transparency in its business transactions through compliance and to strive for development of the Company and gain the trust of customers.
- Chapter 1. General
- Chapter 2. Compliance Structure
- Chapter 3. Compliance Activites
- Chapter 4. Efficacy Testing
- Chapter 5. Miscellaneous
Compliance Guideline Operating Manual
Chapter 1 General
Article 1. Purpose
- Poongsan Corporation (the "Company") shall enact and implement these compliance guideline (this "Guideline") in order to achieve fairness and transparency in its business transactions through compliance and to strive for development of the Company and gain the trust of customers.
Article 2. Definitions
- The following terms used herein shall have the meanings prescribed to them in paragraphs below:
- 1. "Compliance" shall mean any and all policy establishments and controlling activities conducted by the Company through the review of the relevant laws and regulation, compliance of which are required for the businesses of the company (the "Law") and internal review of officers' and employees' compliance of the Law, in order to prevent violations and systematically prepare for the Legal Risk.
- 2. "Legal Risk" shall mean the risk of civil, criminal, administrative liabilities or damages due to invalidation of contracts, caused by non-compliance of the Laws by the officers and employees of the Company (the "Employees").
- 3. "Compliance Officer" shall mean the person who is appointed pursuant to Article 542-13 of the Korean Commercial Code (the "KCC"), and who (i) implements compliance training and education programs, (ii) monitors the Compliance hereunder, and (iii) reports the Compliance related matters to the board of directors.
Article 3. Applicability
- 1. This Guideline shall apply to all of the business activities of the Company and all activities of the Employees related thereto.
- 2. Other regulations of the Company related to this Guideline shall comply with this Guideline and unless provided otherwise in the laws or in the articles of incorporation of the Company, this Guideline shall prevail.
Article 4. Establishment and Amendment
- The Representative Director shall enact and amend this Guideline through resolution of the Board of Directors.
Legal Risk shall mean the risk of civil, criminal, administrative liabilities or damages due to invalidation of contracts, caused by non-compliance of the Laws by the officers and employees of the Company.
The Company shall categorize the legal risks on the basis of the relevant laws and regulations applicable for each department of the Company, prepare the voluntary compliance check list, and provide such check list to the each department of the Company.
- Provision of Bribery
- Facilitation Payment
- Conflict of Interest
- Political Contribution / Contribution to non-profit organizations
- Third Party / Agent
- Compliance Issues(For all officers and employees)
- Voluntary Compliance Monitoring Table I
(For all officers and employees)
- Compliance Issues(For each department)
- Voluntary Compliance Monitoring Table II
(For each department)
Provision of Bribery
- All officers and employees shall not, directly or indirectly, provide, propose or promise the Valuables as briery for the purpose of exercising influence over the Interested Party or obtaining and maintaining improper business benefits.
- Providing the Valuable as bribery to the Interested Party in exchange for favorable treatment is not allowed.
- Nevertheless, providing certain Convenience during the course of business is allowed; provided that the following rules and procedures shall be followed for providing the Convenience:
- - Convenience shall be provided in compliance with the upper limit and standards as set forth in each relevant country’s laws, regulations, or the code of ethics for public officials;
- - Convenience shall comply with local cultures and practices;
- - Convenience shall be provided at reasonable and appropriate level;
- - Convenience shall not be provided to particular Interested Party too frequently or repeatedly; and
- - the expenses for Convenience shall be supported by receipts, invoices, specifications, or other means and shall be accurately recorded in the books of the Company.
Poongsan Corporation shall enact and implement these compliance guideline in order to achieve fairness and transparency in its business transactions through compliance and to strive for development of the Company and gain the trust of customers.
- Compliance with Anti-Bribery Laws / Zero-tolerance policy
- Integrity Pledge
- Board of Directors / Representative Director
- Compliance Officer
- Voluntary Compliance Director
- Compliance / Legal / Audit Department
- Report of Voluntary Compliance Monitoring
- Report of the Receipt of Valuables, Entertainment or Convenience
Compliance with Anti-Bribery Laws
- All officers and employees shall comply with all anti-bribery laws of Korea, including the Criminal Act, Illegal Request and Bribery Prohibition Act, Act on Combating Bribery of Foreign Public Officials in International Business Transactions.
- Zero tolerance policy shall apply to any Employee in violation of the Anti-Bribery Laws.
- Criminal Act
- Act on the Prevention of Corruption
- Act on Prohibition of Unlawful Solicitation and Bribery
- Act on Combating Bribery of Foreign Public Officials in International Business Transactions
- Act on Contracts to which the state is a party
- Act on the Aggravated Punishment on Specific Economic Crimes
- USA Foreign Corrupt Practices Act
- UK Bribery Act 2010
- OECD Anti-Bribery Convention
Training & Education
In order to enable the officers and employees to understand and be prepared in advance of the Legal Risk associated with their works, the Company shall design and implement detailed and systematic compliance education and training programs.
- For all officers and employees
- For freshmen
- For officers
- For managers
- For the employees of sales and purchases
- Other Training & Education