1. Purpose

HYUNDAI STEELPIPE aims to be a global company that contributes to humanity’s dreams with creative thinking and a relentless dive to overcome challenges. As the practice of ethical management is the keystone of such a goal, HYUNDAI STEELPIPE has amended its Ethics Charter and Code of Conduct to become a reliable partner for diverse stakeholders and increase value for our customers. All members of HYUNDAI STEELPIPE should comply with this Ethics Charter and Code of Conduct.

2. Coverage

This Ethics Charter and Code of Conduct applies to HYUNDAI STEELPIPE, including production and sales corporate bodies at home and abroad, subsidiaries, second-tier subsidiaries, and joint ventures, and the executives and employees of HYUNDAI STEELPIPE should act in accordance with this Ethics Charter and Code of Conduct when dealing with suppliers and sales/service organizations. Executives and employees who work for organizations covered under the scope of this Ethics Charter and Code of Conduct should comply with local laws and perform their duties in accordance with the Ethics Charter and Code of Conduct. Moreover, all stakeholders holding contractual relationships with HYUNDAI STEELPIPE, hereinafter referred to as the “Company”, should respect the content and spirit of this Ethics Charter and Code of Conduct.

All persons and organizations who fall under the scope of this document shall perform their duties in accordance with the regulations, policies and rules that guide this Ethics Charter and Code of Conduct. Where this Ethics Charter and Code of Conduct, and related regulations, policies and rules contradict local laws, the local laws shall prevail. In such cases, the Company may amend this document to reflect local legal and industrial obligations, and if necessary, may specifically establish detailed policies in response.

Five Guiding Principles at HYUNDAI STEELPIPE

1. We shall perform our duties based on clear and transparent standards and do our utmost to fulfill our responsibilities with integrity.
2. We shall compete fairly in the market and conduct business ethically with parties that engage in contractual relationships with us.
3. We shall provide safe products, exceptional services and accurate information, and we rigorously protect personal information to increase customer value.
4. We shall respect our members as independent individuals, and to this end, we provide fair working conditions and safe working environments.
5. We shall contribute to sustainable development by fulfilling our social & environmental responsibilities as a member of society, so that diverse stakeholders may prosper together in harmony.

1. Ethics for Executives and Employees

We shall perform our duties based on clear and transparent standards, and do our utmost to fulfill our responsibilities with integrity.

2. Fair Competition and Trade

We shall compete in the market fairly and conduct business ethically with parties that engage in contractual relationships with us.

3. Realization of Customer Value

We shall provide safe products, exceptional services and accurate information, and we rigorously protect personal information to increase customer value.

4. Respect for Executives and Employees

We shall respect our members as independent individuals, and to this end, we provide fair working conditions and safe working environments.

5. Commitment to Sustainability

We shall contribute to sustainable development by fulfilling our social & environmental responsibilities as a member of society, so that diverse stakeholders may prosper together in harmony.

A. Contact Information for Whistle Blowing / Grievance

     Internet : Cyuber Audit https://www.hyundai-steelpipe.com/en/sustainability/ombudsman
     TEL: +82-2-460-3724
     Mail (Address): Ethics Management Officer 14F, 534, Teheran-ro, Gangnam-gu, Seoul, 06181, Republic of Korea

B. Reference

① Universal Declaration of Human Rights, UN General Assembly, 1948.
② The Ten Principles of the UN Global Compact, UN Global Compact
③ International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, ILO (1998).
④ Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, OECD (2019).
⑤ United Nations Convention Against Corruption, UN General Assembly (2013).
⑥ Paris Agreement, UNFCCC (2015).
⑦ The OECD Guidelines for Multinational Enterprises, OECD (2011).
⑧ Global Automotive Sustainability Practical Guidance, Drive Sustainability (2017).
⑨ Guiding Principles on Business and Human Rights, UNGC (2011).
⑩ Guidance on social responsibility, ISO(2010).
⑪ UN SDGs (https://sustainabledevelopment.un.org)
⑫ CDP (https://www.cdp.net/en)

A. Purpose

In order to have Hyundai Steelpipe proactively support human rights, prevent human rights violations following the operation of the business simultaneously and moderate pertinent risk, Hyundai Steelpipe hereby proclaims the Charter for Human Rights. For human rights management, Hyundai Steelpipe is committed to complying with a wide range of recognized human rights/labor-related international standards and guidelines, such as the Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights and International Labor Organization and OECD Due Diligence Guidance for responsible Business Conduct, among others.

B. Scope of Application of the Charter for Human Rights

This Human Rights Charter applies to all Hyundai Steelpipe employees, including all domestic and overseas corporate sales entities, and partner companies. Further, Hyundai Steelpipe employees shall abide by this Charter when dealing with suppliers and sales/services entities, as well as encouraging all stakeholders – across the entire spectrum of business activities and trading relationships, including partner companies and mergers and acquisitions - to respect the Charter and the principles contained herein.
In the event that the matters handled under this Charter for Human Rights contradict the laws and regulations of the local state, the local laws and regulations are complied with first, except for cases of having special provisions in the laws of local states, articles of incorporation or company regulations of the organization, and so forth the works are carried out in accordance with this Charter for Human Rights of Hyundai Steelpipe.

C. Human Rights Risk Management System

Hyundai Steelpipe should establish an internal system required for implementing the human rights management in accordance with this Charter for Human Rights for respecting the human rights of all officers and employees and relieves the ensuing risk, and the human rights risk is regularly evaluated and improved, sufficiently sharing the result with stakeholders. The organization in charge of human rights management for Hyundai Steelpipe carries out the management system of human rights risk following the principle of good faith and due diligence, and reviews the human rights management procedure on a regular basis, actively reflecting social change to revise the management system.

Article 1. Prohibition of Discrimination and Harassment

Hyundai Steelpipe does not discriminate against anyone in the aspect of employment, promotion, education, wage, welfare, etc. on the ground of gender, race, ethnicity, nationality, religion, disability, age, family status, social status, and political opinion for all officers and employees and it structures the organizational culture to respect the diversity of officers and employees.
Hyundai Steelpipe also prohibits sexual harassment, making other employees feel sexually humiliated or disgusted with sexual comments or actions, and non-sexual harassment inflicting physical and/or mental pain on other employees beyond an acceptable level. To prevent the occurrence of discrimination and harassment, we conduct discrimination and harassment prevention training in the workplace for all executives and employees and apply a zero-tolerance policy when related behaviors occur.

Article 2. Compliance with Working Conditions

Hyundai Steelpipe complies with the legal work hours for each country where it engages in business and it pays all officers and employees reasonable wages for the work together with the wage statement. In addition, it provides a work environment appropriate for the performance of duties and sufficient opportunity of education for developing the competency of and improving the quality of life for all officers and employees.

Article 3. Humane Treatment

Hyundai Steelpipe respects the privacy of officers and employees and fully protects personal information and it does not abuse, mentally or physically, or adversely treat any officer or employee.

Article 4. Guarantee of the Freedom of Association and Collective Bargaining

Hyundai Steelpipe respects the labor relations laws of the country where this Charter for Human Rights is applied to provide sufficient opportunity for communication with all officers and employees.

Article 5. Prohibition of Forced Labor and Child Labor

HYUNDAI STEELPIPE does not engage in any act of violence, threat, false imprisonment or the like against any officer or employee and it does not coerce any work against the free will by the method of demanding a personal ID or company ID. HYUNDAI STEELPIPE also does not permit illegal activities such as human trafficking. Moreover, child labor is prohibited in principle, and measures are taken to ensure that educational opportunities for minors are not limited due to work.

Article 6. Guarantee of Industrial Safety

Hyundai Steelpipe regularly inspects the facilities, equipment, tools and others of the business premises for all officers and employees to work in a safe work environment and prepares the support plan for post management and appropriate measures for the purpose of preventing physical and mental hazards.

Article 7. Protection of the Human Rights of Local Residents

All officers and employees of Hyundai Steelpipe are cautioned not to interfere with the human rights of the local residents when carrying out their work. Moreover, the rights to safety and health for local residents, and freedom of residence are protected.

Article 8. Protection of the Human Rights for Customers

All officers and employees of Hyundai Steelpipe must make it their highest priority to protect the life, health and property of customers when providing products and services, and must make their best endeavors to protect the personal information collected from management activities.

A. Establishment of Governance

Responsibility of Human Rights Management

HHyundai Steelpipe should manage and supervise the status of promoting the human rights management through the meetings of committees or management conferences participated in by the highest decision makers or decision makers of major departments or working conferences participated in by decision makers of key departments. The role of committees, management conferences, or working meetings and the scope of responsibility could be classified for the 1) review of the establishment or revision of the Charter for Human Rights, 2) presenting opinions on revising pertinent internal regulations, such as the personnel system, employment regulations, audit standards and others, 3) recommendation for actions on implementation and result of evaluating human rights risks, 4) instruction for investigation on cases of human rights violations and deliberation for relief plans, and 5) other matters deemed to be required for the protection of human rights.

Performance of Human Rights Management

Hyundai Steelpipe should have the point person to be in charge of human rights management to carry out the relevant affairs. The works to be carried out by the organization in charge of human rights management may be classified for the 1) establishment and revision of the Charter for Human Rights, 2) establishment of the human rights management execution plan, 3) evaluation of the human rights risk, 4) operation of the grievance channel, and, 5) in-house education and report as well as external communication.

B. Operation of the Grievance Procedure

① Report and Reception of Violations of Human Rights

Hyundai Steelpipe should operate a channel to receive the report from officers and employees or other persons or organizations (reporters) that suffer a human rights violation or perceived human rights risk. Upon receiving a report of a human rights violation, the characteristics of the individual report case are considered in discussion for a detailed relief plan regarding the case of human rights violence by the pertinent department.

② Processing of Reports on Violations of Human Rights

Hyundai Steelpipe shall, with reference to court precedents, regulations of relevant government agencies, past internal practices and other industrial practices, strive to identify the best course of remedial action with support from the legal department. In the event that the cases of human rights violence exercise significant influence on freedom and the rights of victims or it is highly likely to create risks to the corporate reputation, the relief plan may be discussed by a committee, management conference, practical meeting and gatherings in which the highest decision makers participate.

③ Guarantee of Status for Reporters

Executives and employees of all Hyundai Steelpipe must not disclose, reveal or otherwise report any personally identifiable information that may be used to identify a reporter. All information relating to victims, incidents, remedial procedures and outcomes, as transmitted during the reporting and notification process, must be kept strictly confidential. In addition, measures must be implemented to protect employees from adverse consequences arising from the reporting of human rights violations and risks.

C. Education and Efforts to Raise Awareness

① Human Rights Management Education

Hyundai Steelpipe should encourage the promotion of the understanding of human rights of officers and employees and improvement of perception, and process the human rights management education with the purpose of the internal promotion scheme for human rights management and delivery of the enforcement plan. Through the human rights management education, discriminatory acts by officers and employees are prohibited and should also encourage aggressive reporting of detected cases and risks of human rights violation.

② Enhancing Human Rights Management

Hyundai Steelpipe is encouraged to share information pertaining to the Charter for Human Rights, its implementation plan, and the human rights risk assessment process and associated outcomes, not only within Hyundai Steelpipe, but also with suppliers, sales/service organizations and other organizations with which Hyundai Steelpipe has trading relationships. Such content is shared via the optimal channels (voice, video and written media) and methods (Korean, English, etc.) for all organizational members to conveniently access information relating to human rights management.

A. Evaluation of Risk

① Development of the Evaluation Index

Hyundai Steelpipe should reflect the UN Guiding Principles on Business and Human Rights, OECD Due Diligence Guidance for Responsible Business Conduct, human rights management guidelines from the Ministry of Justice (currently in development), and others based on the basic principle of this Charter for Human Rights to develop and operate the assessment and due diligence index to evaluate the work environment, work conditions, human resource operation, industrial safety, and human rights risks to local residents and customers.

② Operation of the Evaluation Process

Hyundai Steelpipe should operate the evaluation process to confirm the possibility of having potential human rights risks and status of actual cases of human rights violence with the subject of the organization included within the scope of this Charter for Human Rights. The self assessment should be made by providing the evaluation index and guidelines to the subject of evaluation, and with respect to the insufficient matters shown in the result of self assessment by the subject of evaluation, the establishment of a self improvement plan is recommended. On the basis of the written assessment result, the on-site due diligence that confirms the risk in detail may be processed through the internal regulations, system confirmation interview, on-site assessment process related to human rights with the subject of the organization. Hyundai Steelpipe should regularly review and revise the evaluation index and process for human rights risks in order to accurately find cases of human rights violations and efficiently operate the evaluation process.

B. Performance of Risk Improvement

① Formulation and Stipulation for Improvement

Hyundai Steelpipe should establish plans for improvement and performance regarding the human rights risk formulated as a result of evaluating the human rights risk. The head office that received the evaluation of human rights risk, production and sales corporate bodies at home and abroad, suppliers, sales/service organization, and other organizations in transactions should formulate the detailed enforcement tasks to carry out the improvement plan for the risks.

② Monitoring of the Performance Status

Hyundai Steelpipe should continuously monitor whether the person in charge of the organization that received the evaluation of human rights risks is diligently and effectively performing the mutually stipulated improvement plans. Mutual communication should be made regularly in order to process for the detailed task execution to meet the schedule and the expected outcome is secured in time, and if it is expected not to carry out the improvement plan, required measures can be undertaken.

C. Disclosure of Status and Outcome

① Report to the Key Decision Makers

Hyundai Steelpipe should report meaningful indications, important risks and improvement plans confirmed through the evaluation of human rights risk to the major decision makers, including the committees and working conference of management meetings. The report data obtained with the approval of the committees, management meetings, major decision makers, etc. may be shared with the applicable departments and others through enhancing the effectiveness in promoting the human rights management.

A. Contact Information of the Person in Charge

B. Reference

This Charter for Human Rights has been established on the basis of human rights-related provisions, standards and initiatives specified under domestic and overseas human rights standards and pertinent laws and regulations.

① UN, Universal Declaration of Human Rights (1948)
② UNGC, A human Rights Management Framework (2010)
③ UN, The UN Guiding Principles on Business and Human Rights (2011)
④ OECD, The OECD Guidelines for Multinational Enterprise (2011)
⑤ OECD, Due Diligence Guidance for Responsible Business Conduct (2018)
⑥ National Human Rights Commission of Korea, Manual of Human Rights Management for Public Institutions (2018)
⑦ National Human Rights Commission of Korea, Checklist for Human Rights Impact Assessment Operated by Institutions (Corporate enterprises) (2018)
⑧ Ministry of Justice, Guideline for Human Rights Management Standards for Corporate Enterprises (Tentative) (2019)

A. Purpose

HYUNDAI STEELPIPE has developed this environmental policy to continually improve environmental performance through eco-friendly business management and minimize negative environmental impacts across its business activities along with employees & executives, suppliers, customers and the local community as well as an entire value chain.

B. Scope

This environmental management policy applies to HYUNDAI STEELPIPE, its affiliates and their worldwide business units. HYUNDAI STEELPIPE recommends that its supply chain, including all suppliers and contract partners, adhere to this environmental management policy and provides the necessary support.
HYUNDAI STEELPIPE complies with each country’s relevant environmental laws and regulations before this policy. It references this policy when local authorities’ environmental laws and regulations do not cover or do not have special provisions regarding environmental management.

C. Implementation plan

HYUNDAI STEELPIPE’s environmental management shall do the followings: comply with environment-related laws and regulations; declare policies to implement ecological management; establish an Environmental Management System and introduce management guidelines; monitor the environmental performance; discover risks and execute measures to address them; engage in continuous improvement for better environmental performance.
The organization in charge of environment management shall capture new or revised regulations and changes in the social and corporate environment to refine corresponding implementation measures.

HYUNDAI STEELPIPE shall think about the natural environment first and work towards a paradigm shift for future energy, developing eco-friendly products and services, activating cycle economy, and creating eco-friendly business sites. HYUNDAI STEELPIPE defines the following basic principles for each environmental element to facilitate environmental management.

A. Raw and subsidiary materials

HYUNDAI STEELPIPE shall develop a policy to minimize unnecessary waste of natural resources by efficiently using raw and subsidiary materials used to produce products and services. In addition, it shall monitor whether raw and subsidiary materials are produced by illegally damaging natural resources or causing environmental pollution.

B. Energy

HYUNDAI STEELPIPE shall lead energy transition across an entire value chain, including establishing a production system based on eco-friendly energy, investing in new renewable energy (including Carbon Free Electricity) generation facilities, expanding eco-friendly products, utilizing hydrogen and CCUS. Furthermore, it will deploy energy-saving activities daily, such as identifying areas to enhance the energy efficiency, implementing measures, and staging energy-saving campaigns. Each affiliate of HYUNDAI STEELPIPE shall develop and enforce energy management policies to save energy and use renewable energy more.

C. Water

HYUNDAI STEELPIPE shall recognize the need for sustainable conservation of water resources and seek ways to reduce water consumption and recycle water. It shall actively consider water storage facilities to expand the capacity to contain water, centering on water-scarce areas.

D. GHG

HYUNDAI STEELPIPE shall devise proactive measures to respond to climate change and cut GHG substantially to achieve the Net Zero target. It shall gradually transition to a renewable energy system and develop and implement policies to manage GHG and meet carbon neutrality, including carbon sequestration/offset activities to achieve the carbon neutrality target.

E. Waste

HYUNDAI STEELPIPE shall develop and implement policies for waste management and recycling to reduce waste generated out of business operations and efficiently dispose of waste.

F. Pollutants

HYUNDAI STEELPIPE shall reduce emissions of air pollutants and water pollutants, minimize negative impacts on the natural environment, and do its best to protect the health and safety of customers and employees. HYUNDAI STEELPIPE shall establish and apply criteria to manage the generation and emission of pollutants based on the respective nation’s environmental laws and regulations.

G. Chemicals

HYUNDAI STEELPIPE shall identify the status of (harmful) chemicals used during the business process or contained in the product and provide the necessary information to stakeholders. Also, it shall establish and implement policies for hazardous materials management, including reducing the use of hazardous materials, managing the risk, and preventing the diffusion of leakage.

H. The local community

HYUNDAI STEELPIPE shall recognize that the company and its employees are local community members and develop measures to manage the environmental issues reasonably considering their impacts on the local community. HYUNDAI STEELPIPE shall prepare procedures necessary to disclose its environmental information to the local community, reflect opinions from the local community, and continuously engage in communication with the stakeholders.

A. Governance

B. Training and dissemination

C. Communication

D. Performance management

A. Purpose of enactment

HYUNDAI STEELPIPE shall monitor and evaluate risks of biodiversity degradation and loss throughout business operations such as parts procurement, business site operation, and product distribution/sale. At the same time, HYUNDAI STEELPIPE declares this biodiversity protection policy to conserve, restore, and expand the biodiversity of local communities. This biodiversity protection policy has been established regarding Convention on Biological Diversity, Convention on International Trade in Endangered Species of Wild Fauna and Flora, IUCN Guidelines for Applying Protected Area Management Categories.

B. Coverage

HYUNDAI STEELPIPE's domestic headquarters and business sites, overseas subsidiaries, subsidiaries, etc. shall be subject to this biodiversity protection policy. In addition, HYUNDAI STEELPIPE shall recommend this biodiversity protection policy to stakeholders such as suppliers and business partners. The company shall spread and disseminate the need to prevent biodiversity damage and loss and protect biodiversity in local communities. HYUNDAI STEELPIPE shall promote biodiversity assessment and conservation-restoration-expansion activities throughout the business operation based on this biodiversity protection policy. When there are local laws and regulations on biodiversity promotion, wildlife management, natural habitat conservation, and other use of forest, soil, and water resources, HYUNDAI STEELPIPE shall follow them first.

C. Implementation system

HYUNDAI STEELPIPE shall operate a system to protect the biodiversity of the workplace and its surrounding areas or natural ecosystems nearby under this Biodiversity Protection Policy. HYUNDAI STEELPIPE's business sites, etc., shall conduct biodiversity assessment in consideration of the natural environment characteristics of each country/region where business sites are located, when required by laws and regulations, or when a stakeholder such as a local community raises a reasonable concern about biodiversity degradation or loss. HYUNDAI STEELPIPE shall identify the species and numbers of organisms (plants, animals, and microorganisms) affected by the business operation as a result of the biodiversity assessment. The company shall also establish and implement a plan to conserve, restore, and expand the species and numbers of those species in a 3 state of considerable risk or vulnerability. In addition to the initial biodiversity assessment, HYUNDAI STEELPIPE shall build and operate a system that can monitor the increase or decrease of biodiversity according to biodiversity conservation-restoration-expansion activities.

A. Goal

HYUNDAI STEELPIPE shall do its best to protect biodiversity throughout its business operations, such as the purchase/procurement of raw materials, the operation of business sites, the distribution/sale of products, and the collection/recycling of waste products, etc. To this end, HYUNDAI STEELPIPE declares the following goals regarding the prevention of biodiversity damage and loss due to business operation, the prohibition of business operation in biodiversity protected areas, and the expansion of investment and activities for biodiversity protection.

B. Biodiversity Assessment and Protected Areas

HYUNDAI STEELPIPE shall define biodiversity assessment and protected areas by comprehensively considering domestic and foreign biodiversity or wildlife protection laws and regulations, or IUCN Category I ~ IV Protected Areas. HYUNDAI STEELPIPE shall promote conservation-restoration-expansion activities by taking into account the composition/role/ potential of biodiversity in the region and the historical/cultural/scientific/educational significance of biodiversity when its business site is located in or near the relevant region or when the supply chain including suppliers and origins is located or when the negative impact on the region is clearly identified as a result of business operation.

C. Biodiversity Assessment and Protection Procedures

HYUNDAI STEELPIPE intends to establish a procedure to monitor 1) biodiversity species and 5 numbers status, 2) potential biodiversity risks to achieve the ‘goal’ of this biodiversity protection policy, focusing on areas near business sites and ‘protected areas’. HYUNDAI STEELPIPE shall prepare appropriate measures and response systems to protect biodiversity when biodiversity degradation or loss is confirmed, or biodiversity-related risks are recognized. In addition, HYUNDAI STEELPIPE shall monitor whether biodiversity protection measures and response systems are being implemented as planned.

① HYUNDAI STEELPIPE shall monitor the current status of biodiversity in or near the business site, considering the natural environment characteristics of each country/region where business sites are located when required by laws and regulations or when a stakeholder such as a local community raises a reasonable concern about biodiversity degradation or loss. Hyundai Motor shall implement natural habitat protection activities to maintain/expand biodiversity within its business sites and check the progress of its implementation.

② HYUNDAI STEELPIPE shall recommend that suppliers monitor and mitigate biodiversity risks in business operations as part of the ‘Supplier Code of Conduct.’

③ HYUNDAI STEELPIPE shall check whether there is any act of biodiversity degradation or loss at the sourcing process of raw materials in the mid-to-long-term for sustainable raw material procurement and recommend improvement measures to protect endangered species.

④ HYUNDAI STEELPIPE shall collect opinions from local communities and stakeholders on biodiversity damage/loss and natural habitat destruction due to business operation and prepare improvement plans for reasonable concerns.

A. Governance

B. Grievance and Handling

① Filing a grievance
HYUNDAI STEELPIPE shall operate a channel through which employees and other organizations (individuals) can report grievances related to biodiversity that arise in the course of business operation.

② Grievance handling
HYUNDAI STEELPIPE shall prepare countermeasures for reported cases related to biodiversity degradation and loss in consideration of court precedents, regulations of the competent authority, and past internal handling practices. If the reported case is highly likely to violate laws/regulations, exert influence on local residents' property rights, etc., or spread to corporate reputation/reputation risks, the highest decision-making body, such as the Management Committee, discusses countermeasures.

C. Education and diffusion

D. Performance management

① This biodiversity protection policy shall be enacted and enforced as of 2024. 00. 00.

HYUNDAI STEELPIPE strives to establish transparent and ethical management in order to become a trusted partner of various stakeholders and enhance customer value.

This Policy aims to prevent corruption and bribery, which are economic crimes that damage the tangible and intangible assets of HYUNDAI STEELPIPE and deter fair fulfilment of duties by HYUNDAI STEELPIPE employees; and to ensure that HYUNDAI STEELPIPE employees actively put ethical and moral value standards into practice.

The entire employees and business partners of HYUNDAI STEELPIPE must perform tasks related to HYUNDAI STEELPIPE in compliance with all related laws and regulations, including Foreign Corrupt Practice Act (FCPA) of the US., UK Bribery Act, clauses related to receiving bribery by breach of trust or occupational breach of trust under the Criminal Act and Improper Solicitation and Graft Act of Korea, and all other local anti-corruption regulations of countries where HYUNDAI STEELPIPE operates.

In cases where this Policy conflicts with local regulations, such local regulations shall take precedence over this Policy. This Policy can be revised and used according to local regulations and industrial features of the country.

This Policy shall apply to all of the following entities:
(i) Production and sales corporations of HYUNDAI STEELPIPE in and outside of Korea;
(ii) Subsidiaries, sub-subsidiaries, and joint ventures of HYUNDAI STEELPIPE; and
(iii) HYUNDAI STEELPIPE’s business partners, including suppliers

3-1. Bribery

One should not receive, offer, or promise to offer any kinds of monetary, non-monetary, illegal, or unethical gains or bribery from/to stakeholders. Bribery refers to all forms of gains given or received to achieve monetary or non-monetary goals and includes money, services, entertainment, gifts, donations, support funds, preferential measures, and conveniences.

If direct payment of prices by an HYUNDAI STEELPIPE employee or business partner is inappropriate, the payment should not be made indirectly either. In particular, any signs of bribery attempts should not be overlooked, even if they serve the interests of HYUNDAI STEELPIPE.

3-2. Improper Solicitation

Improper solicitation between HYUNDAI STEELPIPE employees and stakeholders or between HYUNDAI STEELPIPE employees are prohibited. One should not make unreasonable requests to or get paid from stakeholders using his/her superior or dominant position. There should be no good offices or requests to make stakeholders have unfair transactions with HYUNDAI STEELPIPE or its partners.

In particular, one should avoid doing business under conditions that are favorable to a certain account or partner. One should clearly reject any requests to provide convenience in business. In the case of receiving improper solicitation, it should immediately be reported to his/her superior.

3-3. Gifts and Entertainment

One should not receive any souvenirs and gifts that exceed the normal range of small gifts according to social norm. In the case of inevitably receiving souvenirs or gifts, they should be handled as per HYUNDAI STEELPIPE’s gift management policy. One should not publicly tell stakeholders related to work about his/her congratulatory or condolence events. The amount of congratulatory or condolence money should not exceed a conventional range.

3-4. Payments to governments or government employees

Payments following transactions with a government or government organization should be made in the country of the government or government organization. In the case of making payments outside of the country, written consent from the local legal and compliance departments should be obtained in advance. In the case of providing civil servants with meal, accommodation, and transportation allowances concerning signing a contract for, promoting, or marketing products or services, regulations in and outside of Korea, including the Improper Solicitation and Graft Act of Korea, should be followed.

3-5. Express Charges

HYUNDAI STEELPIPE continues its efforts to eradicate the practice of giving government employees the socalled “express charges” directly or indirectly, either to speed up the normal process or to avoid administrative delays. Even in cases where government employees illegally demand express charges, HYUNDAI STEELPIPE employees should reject the request and immediately report it to his/her superior to eradicate the practice of giving such express charges.

However, if immediate discussions with one’s superior or the local compliance manager are impossible due to exceptional situations, such as when life, health, or assets come under threat, one can pay express charges and immediately share specific reasons and details with the superior.

Charity donations and sponsorships should be fairly provided in accordance with internal criteria and procedures. Donations and sponsorships for political purposes are prohibited.

5-1. Monitoring

A company that applies this Policy should establish a reporting system that can be accessed by company employees and stakeholders, as well as a system that can provide around-theclock monitoring of corruption and bribery risks and due diligence, when necessary.

5-2. Actions for Violations

An organization that adopts this Policy should immediately take necessary actions on policy violations according to its internal regulations. Related information should be disclosed using a proper method to prevent the recurrence of violations.

HYUNDAI STEELPIPE has enacted this Health & Safety Policy to ensure the sustainable value of life through the provision of a safe and healthy work environment, in conjunction with the prevention of potential accidents that may occur across our business operations – including our supply chain, business sites, distribution network, and sales channels. This policy was established based on domestic and overseas laws and regulations concerning health and safety, as well as health and safety management standards and guidelines (ISO 45001, etc.), HYUNDAI STEELPIPE’s Health & Safety Management Directives, and Health & Safety Management Strategy and Targets.

This policy applies to all of HYUNDAI STEELPIPE’s domestic and overseas business sites. Further, we encourage all stakeholders with whom we have business relations, including our suppliers, partners, and distribution network, to comply with the terms of this Health and Safety Policy. We also conduct joint activities to promote preventative health and safety inspections, internalization of a safety culture, and the introduction of new safety technologies. HYUNDAI STEELPIPE complies with all laws and regulations concerning health and safety, and we establish and implement plans for health and safety in accordance with this policy insofar as this does not violate the relevant laws and regulations.

HYUNDAI STEELPIPE establishes implementation systems in line with global health and safety guidelines, including ISO 45001, and sets health and safety objectives and specific targets accordingly. We develop action plans to help achieve defined management standards, targets, and priorities, and a dedicated health and safety department implements the following roles and responsibilities.

(1) Regular safety risk assessments with respect to the scope of this policy
(2) Implementing corrective measures for safety risks and hazard/risk factors
(3) Monitoring the enterprise-wide health and safety management system and assessing its effectiveness
(4) Continuously improving the management system in line with domestic and overseas occupational health and safety
      trends
(5) Enhancing employees’ capabilities and awareness of health and safety through relevant education and training

HYUNDAI STEELPIPE’s Health & Safety Policy is overseen and approved by the Board of Directors on an annual basis. This policy was enacted through, and is revised by, a deliberation and approval process conducted by Board directors. Further, we operate an Occupational Safety and Health Committee, whose members are composed equally of labor and management, to discuss and resolve agenda relating to health and safety on a quarterly basis.

A. Purpose of enactment

HYUNDAI STEELPIPE declares this policy to ensure that all our executives and employees receive equal treatment without discrimination while preventing issues related to discrimination and harassment that may occur while conducting business-related activities. In addition, we expect all subsidiaries, joint ventures, supply chains, and contractors to comply with this. HYUNDAI STEELPIPE shall comply with laws related to discrimination and harassment, such as the Act on Equal Employment of Men and Women, Support for Work-Family Balance, Labor Standards Act, Occupational Safety and Health Act, and Industrial Accident Compensation Insurance Act, etc.

B. Definition of Discrimination and Harassment

- “Sexual harassment” means that the employer, supervisor, or worker in the workplace makes other workers feel sexually humiliated or disgusted by sexual words or actions, or gives disadvantages in employment for non-response to other demands, using their position in the workplace or related to the work.
- “Non-sexual harassment” means that the employer, supervisor, or worker in the workplace inflicts physical or mental pain on other workers or worsens the working environment beyond the proper scope for work by taking advantage of position or relationship in the workplace.
- “Discrimination” refers to discriminatory treatment based on the gender, race, ethnicity, nationality, religion, disability, age, political opinion, and region of the executives and employees.

HYUNDAI STEELPIPE shall inform and train all employees about the contents of this policy to prevent sexual harassment, non-sexual harassment, and discrimination in the workplace and improves the awareness of the primary value of this policy, respect for diversity. To this end, HYUNDAI STEELPIPE shall conduct activities such as continuous trainings and the operation of reporting channels.

HYUNDAI STEELPIPE shall strive to prevent discrimination and harassment, and when problems arise, resolve them according to the internal procedures.

HYUNDAI STEELPIPE shall investigate the situation as confidential as possible, prepare appropriate countermeasures for complaints that may be raised and take prompt action.

HYUNDAI STEELPIPE shall create a channel for all employees to report. When a problem occurs, HYUNDAI STEELPIPE shall provide appropriate procedures to solve the problem and prevent recurrence and guide the use of these procedures.

HYUNDAI STEELPIPE shall not divulge secrets learned during the investigation to others against the victim's will. However, HYUNDAI STEELPIPE makes it exceptions to report cases related to investigations to the superior or provide necessary information at the request of the relevant agency. In addition, HYUNDAI STEELPIPE shall protect the person who reports the complaint or the person who testifies against retaliation and provide support as deemed necessary to the victim.

HYUNDAI STEELPIPE shall take a disciplinary action against those found to be the perpetrators as a result of the investigation.

A. Grievance and Handling

① Filing a grievance
Anyone who becomes aware of workplace discrimination and harassment (sexual harassment, non-sexual harassment, discrimination, etc.) shall be able to report the incident. HYUNDAI STEELPIPE shall devise appropriate measures, such as requesting an investigation upon receiving the report. HYUNDAI STEELPIPE shall not take any steps to give any personnel disadvantages to the reporters or victims of workplace discrimination and harassment and implement appropriate measures such as a change of place of work or vacation there is a request from the victim.

Reporting channels
Name of department: HR team
Online reception channel: (To be updated)

② Grievance handling procedure
HYUNDAI STEELPIPE intends to establish an escalation process of reporting incidents to eradicate acts related to discrimination and harassment. When becoming aware of a victim of discrimination and harassment or such an act, HYUNDAI STEELPIPE shall prepare a response system to protect the victim and take appropriate measures on the incident.

B. Education and diffusion

HYUNDAI STEELPIPE shall contribute to spreading an organizational culture based on mutual respect and dignity through active guidance on the prohibition of discrimination and harassment against employees. When discriminatory and harassing acts are identified, the company shall induce an active report of them through the reporting channel.

C. Zero tolerance principle

HYUNDAI STEELPIPE shall recognize the importance of a workplace culture based on mutual respect and dignity and apply the zero tolerance policy to acts that constitute discrimination and harassment.

D. Corrective action and disciplinary action

HYUNDAI STEELPIPE shall take appropriate corrective and disciplinary actions against discrimination, harassment, or other unlawful violations of any kind in the workplace, depending on the seriousness of the situation.

① This non-discrimination & anti-harassment policy shall be enacted as of 2024. 00. 00.

1. Moving forward, we will implement a ban on all forms of deforestation when developing our business sites, and restore green areas (including forests) when existing business operations are shut down. By nurturing green areas in cooperation with local communities, we strive to regenerate forests in conservation areas and regions with damaged forests, including in the vicinity of our business sites. Further, we endeavor to apply this policy to our own business operations, tier one suppliers, and tier two suppliers and above.

2. We establish internal procedures to review deforestation risks relating to our own business operations, our supply chain, and our partners. Through regular risk reviews and collaboration with a specialist partner, we plan afforestation projects to achieve Zero Net Deforestation and secure the funds required for afforestation projects if necessary. Additionally, we continuously promote information dissemination activities to raise awareness of deforestation among employees and other stakeholders.

3. In collaboration with a specialist partner and local community stakeholders, we strive to realize our commitment to Zero Net Deforestation through reforestation by 2050. We also continue to research and collaborate externally on recycling waste and expanding green spaces within our company. Further, we endeavor to unceasingly implement afforestation projects that contribute to strengthening ecological functions, reducing greenhouse gas emissions, and improving the landscape.

Deforestation Prohibition Policy Enacted in ___, 2024

1. Definition of Local Community Engagement

The objective of local community engagement is for the company to understand and resolve, in cooperation with local communities, the diverse issues that may arise in such communities. In particular, this involves the inclusion of local community stakeholders in a variety of decision-making processes, enabling decisions based on better information through the consideration of local community opinions. Local community engagement includes the following activities.

- Provision and sharing of information relating to key issues with the local community.
- Action plans to respond to issues arising within the local community.
- Diverse communication channels.

Local community engagement is used as a decision-making guideline that facilitates sustainable management through decisions based on a diverse collection of opinions and information.

2. Objective of Local Community Engagement and Framework Development

The main objectives of local community engagement are as follows.

- Enhancing decision-making through engagement with stakeholders.
- Supporting local community councils to promote communication with local communities.
- Improving relationships between local communities and a broad range of stakeholders.
- Mutual cooperation within local communities to facilitate resolution of key project-related issues.

To achieve the above objectives, a Local Community Engagement Framework was developed to cover the following.

- A process to listen to, and acknowledge, local community opinions, and to reflect these opinions in the decision-making process.
- Operations with a consistent approach to local community engagement.
- Employees’ understanding of corporate decisions that impact local communities.
- Communication between decisions-makers (senior management) and local community stakeholders.

Definition of the Principles of Local Community Engagement

The Principles of Local Community Engagement consist of a total of six principles (preliminary engagement, transparent disclosure, inclusive engagement, selection and implementation of appropriate engagement methods, information inclusivity, local community engagement period), which are described as follows.

1) Preliminary Engagement

A commitment to provide local communities or key stakeholders with actual opportunities to influence decision-making and strategy through the provision of information in the early stages of project development.

2) Transparent Information Disclosure

Ensuring transparency and effective cooperation by communicating with local communities through the provision of relevant information and materials.

3) Inclusive Engagement

Providing all individuals – outside of local communities or key stakeholders – impacted by relevant issues with the opportunity for negotiation.

4) Selection and Implementation of Appropriate Engagement Methods

Prior to making any final decisions, we shall provide local communities with the appropriate information, tools, engagement methods, and other such relevant details.

5) Information Inclusivity

Prior to making any decisions that may impact the local community, we shall consider all available information and strive to provide honest feedback.

6) Local Community Engagement Period

Whenever an issue arises which impacts, or may potentially impact, local communities, local residents, or their lifestyles.

Article 1. No Discrimination or Harassment

The Local Community Engagement Framework is comprised of the following items, and is managed in accordance with the relevant processes.

A. Purpose of enactment

HYUNDAI STEELPIPE has established a D&I policy to create an organizational culture that helps diverse talents develop both creative and challenging thinking to contribute to the transition to an inclusive society. We also promise not to discriminate against employees for such reasons as gender, race, ethnicity, nationality, cultural background, disability, age, individual gender identity, political/religious beliefs, or social status without any reasonable reasons. We further vow to create working environments where employees with diverse backgrounds can realize the values of diversity and inclusion. We will also work hard to become a company that respects the diversity and inclusion of customers, partners, local communities, and various stakeholders.

B. Scope of application

This policy applies to all members of HYUNDAI STEELPIPE’s headquarters, domestic/overseas production and sales corporations, subsidiaries and sub-subsidiaries, and executives and employees of joint ventures. Furthermore, this policy shall apply to various stakeholders within our business influence, such as the products and services we provide, customers, business partners, and local communities with whom we do business. In case the matters covered by this policy conflict with the local country's laws, the local laws shall be followed first. However, this policy must be complied with unless there are special provisions in the local country's laws, the articles of organizations, or the company rules.

C. Management system

HYUNDAI STEELPIPE will build an internal system necessary to implement the basic principles of this policy, regularly inspect and improve the status of diversity and inclusion, and fully share the results with stakeholders. Furthermore, the dedicated diversity organizations of HYUNDAI STEELPIPE will implement a diversity and inclusion management system by the principle of good faith by actively reflecting social change. We will also continue to improve the management system to establish a culture of diversity and inclusion throughout business operations.

HYUNDAI STEELPIPE shall prohibit discrimination against employee’s gender, race, ethnicity, nationality, cultural background, age, individual gender identity, differences in political and religious beliefs, weakness in social status, etc., without due reasons, and provide equal opportunities in employment, promotion, education, wages, and welfare.

Article 1. Gender

HYUNDAI STEELPIPE shall treat all employees and stakeholders equally, regardless of gender, gender identity, sexual orientation, etc., and apply the zero-tolerance principle to perpetrators of sexual harassment and sexual assault. Also, the group shall operate a system that allows both men and women to pursue work-family balance while preventing unfair treatment and disadvantages due to pregnancy, childbirth, childcare, etc.

1. We do not discriminate based on gender, etc., in employment, promotion, education, wages, welfare, etc.
2. We guarantee leave due to pregnancy, childbirth, childcare, etc., and do not discriminate on leave based on gender.
3. We regularly provide education on sexual harassment and sexual assault prevention and gender equality and protect victims' rights.

Article 2. Race, nationality, and cultural background

HYUNDAI STEELPIPE shall not discriminate based on its employees' ethnicity, race, nationality, cultural background, religion, etc., without due reasons. We encourage the expression of opinions and active communication of minority groups such as foreigners, immigrants, overseas Koreans, multicultural families, and North Korean defectors, as long as the same does not infringe upon the rights of others. In addition, we support language education, etc., to help minority groups improve their job performance and develop themselves.

1. We respect our employees' diverse cultures, values, and religions and do not allow discrimination based on the same.
2. We pursue harmony of diverse cultures among employees by providing language and cultural education and opportunities for mutual communication.
3. We encourage exchange activities between employees and stakeholders from various 4 backgrounds (Employee Resource Group).

Article 3. Age

The employees of HYUNDAI STEELPIPE shall respect and communicate with each other in an open manner, regardless of age, and strive to create an organizational culture that can resolve conflicts from generational differences. In addition, everyone shall be free to express their opinions, and we shall improve organizational productivity and creativity through a work culture that listens to others' views. In particular, we shall not impose unnecessary hierarchies based on age or interfere with others' work unnecessarily.
1. We work with mutual respect and encourage a horizontal atmosphere among our employees.
2. We create an organizational culture where active communication can take place, not restricted by age.
3. We do not impose unnecessary hierarchies or personal needs or infringe on privacy based on age.

Article 4. Disability

HYUNDAI STEELPIPE shall not discriminate against employees based on disability or disease without reasonable grounds. We shall create an environment where employees with disabilities or illnesses can work without discomfort. We encourage educational activities and awareness-raising campaigns to eliminate invisible barriers and discrimination as well as physical conditions.

1. We prohibit all acts such as discrimination and harassment in the workplace based on disability or disease.
2. We provide equipment and materials necessary for executives and employees with disabilities to perform their duties without restrictions.
3. We strive to implement a work environment that considers the accessibility of employees with disabilities.

Article 5. Veterans

HYUNDAI STEELPIPE honors veterans and their families, such as those of national merit and independence, during the recruitment process. We promote community contribution activities such as education and employment programs, life stability support, and welfare promotion to support the honorable life of veterans who have contributed to national development and security.

1. When hiring, we encourage an employment policy that gives preference to veterans and their families, such as those of national merit and independence.
2. We strive to support economic activities such as education and employment support for veterans.
3. We strive to contribute to the local community by promoting stability in life and the improvement of the welfare of veterans.

HYUNDAI STEELPIPE believes that diverse talents and an inclusive organizational culture are the basis for its sustainable growth. HYUNDAI STEELPIPE respects and encourages its employees' creativity and potential regardless of gender, race, nationality, cultural background, or age. HYUNDAI STEELPIPE will enhance its global business competitiveness based on the creativity and potential of its diverse employees.

A. Human Resource Planning

HYUNDAI STEELPIPE affiliates are establishing a mid-to-long-term human resource operation plan, taking internal and external environmental changes, business strategies, and the knowledge and skills of employees into account. We will review a workforce plan in the future, considering diversity such as gender, race, ethnicity, nationality, cultural background, and age.

-HYUNDAI STEELPIPE affiliates will work hard to provide sufficient opportunities to minority groups in the recruitment and transition placement process, recognizing that embracing diverse talents increases corporate value.
- We will check whether minority groups are being discriminated against in the hiring process through demographic analysis and whether existing employees are being excluded due to their diversities in the transitional placement process.
- We will analyze the influence of diversity in the composition of employees on corporate value and establish a human resource management plan to put necessary talents in business activities that realize the value of diversity.

B. Education and Mentoring

HYUNDAI STEELPIPE affiliates support individual employees in improving their knowledge and skills through education and competency development activities. We will provide all our employees with equal opportunities to participate in education while developing educational programs that consider diversity and inclusion in the future.

- We will ensure no restrictions on opportunities to participate in education by identifying the needs of various employees' training programs and developing training programs where employees can participate.
- We will check educational satisfaction and achievement by diversity group to learn whether the education programs provided by HYUNDAI STEELPIPE affiliates effectively enhance corporate value.
- We will also promote activities to improve organizational culture and campaigns to spread a culture of diversity and implement the 'Diversity Mentoring Program' to build rapport among the same groups.

C. Performance evaluation

HYUNDAI STEELPIPE affiliates have set organizational and individual goals for employee performance evaluation and have been working hard to achieve them. In the future, we will build a comprehensive performance evaluation system to prevent bias and disadvantages due to diversity in the employee performance evaluation process.

- In the future, we will review and manage performance evaluation to set fair and objective individual performance goals without discrimination against diversity in the future employee performance evaluation process.
- Through fair performance evaluation standards, we will prevent bias and disadvantages in performance evaluation results due to gender, race, ethnicity, nationality, cultural background, age, etc.
- We will respect the diversity in the employee performance management process and manage the performance evaluation results to ensure no discrimination in expressing opinions on the grounds of diversity.
- We will also designate a department dedicated to promoting organizational diversity and inclusion and operate KPIs to manage diversity and inclusion performance.

D. Compensation

HYUNDAI STEELPIPE affiliates ensure no discrimination or disadvantage in compensation due to gender, race, ethnicity, nationality, cultural background, age, etc. We will build a reasonable and transparent compensation system in the future.

- We will operate a compensation policy, compensation payment standards and procedures, etc., to stop discrimination in compensation due to differences in gender, etc., for work of equal value.
- We will operate a compensation policy, compensation payment standards and procedures, etc., to prevent discrimination in compensation due to differences such as gender, etc.
- In the event of a discriminatory factor against the value of diversity in employee compensation, we will operate a channel to mediate, resolve, and communicate the same.

E. Employee Resource Group

HYUNDAI STEELPIPE affiliates encourage ERG activities where employees with a common interest in diversity and inclusion and a common diversity background can communicate and share culture. We recognize that ERG's active opinions are the foundation for diverse and inclusive corporate growth and support the spread of ERG activities.

- We recognize that it is an opportunity to form better teamwork when executives and employees with a common diversity background share interests and exchange cultures.
- We encourage the formation of various types of ERGs such as women, MZ generation, those ready to retire, the disabled, veterans, black/African, Hispanic/Latin, etc.
- We encourage all our employees to participate in at least one ERG to create a culture of diversity and inclusion within the organization and to spread positive influence among employees.
- We will support external link activities such as mentoring, cultural exchange, job/leadership education, and community participation to promote and spread a culture of diversity while activating the ERG.

A. References

This D&I Policy has been established with reference to domestic/international standards and initiatives.

① ILO, Promoting Diversity and Inclusion through Workplace Adjustment – Practical Guide (2016)
② ISO, ISO30415:2021 Human Resource Management – Diversity and Inclusion (2021)
③ S&P Global, CSA Companion – Workforce Breakdown (2021)
④ The Centre for Global Inclusion, Global Diversity, Equity & Inclusion Benchmarks (2021)
⑤ UNDP, Gender Diversity and Inclusion for a Fair Business Environment (2021)
⑥ UNHCR, Policy on Age, Gender and Diversity (2018)
⑦ UNSDG Goal 8 – Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all (2016)
⑧ WEF, Measuring Stakeholder Capitalism – Diversity & Inclusion (2020)
⑨ GRI, Standards 405 – Diversity and Equal Opportunity (2016)

B. Additional clause

① This D&I Policy is to be enacted as of 2024. 00. 00.