현대제철 통합보고서

In 2020, Hyundai Steel conducted training on ethical management and fair trade for new employees at manager-level and above. The introductory course covers the concept and importance of ethical management, best practices and sanctions, and Hyundai Steel's rules and systems related to ethical management. A total of 47 employees have completed the training since January 2020. In 2021, the scope of trainees was expanded to all of our regular and contracted employees, with a training completion rate of 100%. Education on fair trade is conducted online in the second half of each year, covering topics including the Fair Trade Act, the Subcontracting Act, the Franchise Business Act, and the basic topics of other fair trade-related laws and regulations. A total of 69 employees have completed the training since October 2019. Hyundai Steel will continue striving to enhance its employees' understanding of ethical management and to promote a mindset of legal compliance.

There is growing demand worldwide for corporations to take on responsibilities and roles in society, international standards such as those on fair trade and anti-corruption are continuing to strengthen. As part of our efforts to support compliance management activities, Hyundai Steel is publishing its own 'Compliance News'. The newsletter is issued on a bimonthly basis for employees at manager-level and above. In 2020, 'Compliance News' was printed and distributed 22 times in total, sharing key legal changes along with trends at regulatory agencies and current legal issues. In order to skillfully adapt to the rapidly changing business environment, Hyundai Steel not only raises employee awareness of legal compliance by helping keep them to keep abreast on legal changes, precedents and legislative trends, but also does its best to prevent legal violations and related risks.

In October and November 2020, Hyundai Steel conducted online and offline training sessions on fair trade for a total of 352 people across 42 related departments. Our fair trade education covers four areas - internal transactions, subcontractor transactions, agent transactions and collusion - including foundational contents of the laws and regulations concerning internal transactions, subcontractor transactions and agent transactions, as well as major sanctions and precedents, and the trends and implications of the Fair Trade Commission(FTC)'s legislation and regulations.

Going forward, we will continue to provide training sessions on fair trade to relevant departments to eliminate the risks of violating fair trade laws, and to enhance employees' awareness of self-disciplined compliance.

In July and September 2020, Hyundai Steel provided training on the U.S. Foreign Corrupt Practices Act(FCPA) for a total of 12 newly appointed expat employees, covering the basic contents of the Act, a comparison with Korean laws, and cases of sanctions. In the future, Hyundai Steel will continue to boost anti-corruption training to enhance employees' understanding of ethical management and to foster a mindset of compliance.

In accordance with the Act on External Audit of Stock Companies, Hyundai Steel operates an internal accounting management system. Of the system's internal control measures, those related to ethical management include 'posting(the Ethics Charter and the Code of Conduct) on the corporate website and intranet; carrying out related training(on corporate ethics and fair trade); and expressing the CEO's commitment to fair trade'. Our internal management activities, including compliance with the law and ethical management, are verified annually by a third-party external auditor(accounting firm).

In order to spread a culture of ethical management, the Ethics Charter and the Code of Conduct, which should be observed by all members of the company, are posted on our website. In July 2020, we revised the Code of Conduct on ethical management practices to reflect the need to request documents when registering overseas client deliveries and factory audits, respond to new social issues and corporate ethics matters, and improve ethics rules in our sustainable management evaluations. In addition, we continue to provide training on fair trade to relevant departments to eliminate the risks of violating fair trade laws, and to enhance employees' awareness of self-disciplined compliance with fair trade. In the future, we plan to reinforce our framework for ethical management by adding provisions as required by international standards, and to make sustained efforts to promote employees' awareness of ethics and respect, fair competition and transactions, realization of customer value, and continuous ethical management.