Ethical Management

1.Accountability towards Customers & Shareholders

We exist to serve customers who are the basis of our corporate sustenance and growth. Therefore, we prioritize customer satisfaction in all our value judgments to provide top quality products and services.

Offering top quality products & services

To deliver customer satisfaction, we vow to serve customers with top quality, bestof-breed services, and reasonable pricing. All our products are produced and stored in a hygienic environment and distributed with speed to ensure that only the best products are delivered to consumers.

Facilitating communication with customers

We positively accept customers’ ideas and needs and bring complaints and objections to a prompt resolution in a fair and reasonable manner. We remain committed to delivering on all our promises and trying our best to facilitate communication with customers.

Safeguarding customers’ rights & interests

We value customers as our critical assets and perform fiduciary duty in managing customers’ data. We comply with applicable privacy laws and regulations and ensure that customers’ data is used only for intended purposes. We humbly acknowledge customers’ complaints and feedback and endeavor actively to remove any inconvenience for them..

Upholding shareholders’ interests

We uphold shareholders’ interests by sustaining growth and development. We respect their right to know and legitimate needs, willingly responding to their suggestions and feedback. We make sure that critical information of the Company is not disclosed arbitrarily and does not use insider information to pursue unlawful gains.

2.Compliance & social responsibility

We thoroughly comply with all laws and regulations governing corporate activities and develop the Company by engaging in wholesome business activities with commitment to fair competition in a bid to contribute to fostering rich life and social advancement of the nation

Compliance

We sincerely comply with all domestic and international laws, rules, and industry norms expected to be upheld by business organizations. We do not pursue gains by engaging in unlawful practices that run counter to corporate ethical standards.

Wholesome business activities

We are aware that competition is the driver of collective growth, respecting market discipline and refraining from practices that violate such discipline. We obtain all data lawfully and do not use or disclose it to a 3rd party unlawfully. We compare ourselves with competitors only on the basis of obvious and objective data. We neither take advantage of he weaknesses of competitors not officially established nor engage in slanderous advertising practices

Social responsibility

We recognize that social responsibilities of business organizations start from voluntary contribution to society and actively participate in various outreach activities and cultural promotion initiatives. We honor our obligations as a taxpayer and contribute to national prosperity by creating jobs. We foster cohesion with local communities by opening welfare facilities for local neighbors of our business sites, extending support for the less-privileged, and encouraging employees to engage in local outreach programs

Environmental protection & resource conservation

We engage in all businesses in an eco-friendly manner, participate actively in environmental protection and comply with all relevant laws and regulations. We take the lead in protecting environment and conserving resources by saving resources and sustaining technology development trails.

Prohibition of political activities

We do not tolerate any political activities within the Company. We allow individuals to disclose their political views but require them to make sure that their views are not confused with the position of the Company. We do not raise and/or donate illegal political fund.

Safety control & accident prevention

We exert our best to control safety and prevent accidents, ensuring prompt response to accidents as they break out. We provide training programs to prevent safety incidents and ensure prompt response, meticulously inspecting facilities as scheduled.

3.Co-prosperity with business partners

We recognize that we can thrive with business partners trading with us by enhancing partnership with them and fostering mutual goodwill with them, prospering with them on the basis of trust and collaboration.

Equal & fair transaction

All our business partners are entitled to equal opportunities for participation based on their qualifications. They are selected objectively and reasonably in accordance with fair standards. All transactions are conducted fairly on mutually equal footing as discussed in advance and we do not abuse our superior status in any way.

Co-prosperity

We endeavor to ensure co-prosperity with business partners by supporting and cooperating with their managerial activities. We try hard to foster equal, fair and transparent business practices to uphold the intent and spirit of respective ethical standards.

Prohibition of taking money, entertainment, etc

We do not require, receive or provide monetary gains (money, allowance for congratulations and condolences, gift voucher, entertainment (meal, liquor, sports (golf, etc.), tangible goods, service, etc.) from or to all stakeholders including business partners. We do not have them pay for business travel and/or lodging or any other services.

Prohibition of other unfair practices

Gambling with the employees of a business partner is prohibited. Shares or properties of a business partner shall not be acquired either directly or indirectly. Business transaction with a business partner related to one’s family member or relative or him/herself is prohibited in principle. Double employment as an executive/employee of a business partner is prohibited. Loans, joint and several guarantees, investment, etc. with the employees of a business partner are prohibited.

4.Basic ethical norm for executives/employees

Executives/employees are the foundation of LocknLock Co., Ltd. Therefore, we recognize that our ethical compliance underpins our corporate ethical performance and each one of us tries to become an ethical citizen committed to fair business practices.

Maintaining honor & dignity

Executives/employees represent LocknLock Co., Ltd. with their conduct. They have pride and self-esteem and show manners and integrity in their dress code and conduct. They respect each other as independent entities and do not disrespect or slander each other.

Fairness & autonomy in business practices

Executives/employees and each department recognize that we belong to a seamless community working for shared objectives and pursue corporate growth and development by reasonably and actively cooperating with each other without egoism and sense of superiority between departments. Executives/employees recognize the collective mission of the Company, fulfill their missions with autonomous decision and conduct, and hold themselves accountable to them. Executives/employees do their best with given authorities and responsibilities, comply with applicable laws, regulations and rules, and do not abuse power, make false statements, exaggerate, hide wrongdoings or leak trade secrets for personal gains.

Fair & harmonious corporate culture

Executives/employees respect privacy with each other and create an atmosphere in which they can freely make suggestions, recommendations or lodge complaints in a bid to foster more harmonious corporate culture. Superiors motivate juniors to develop their skillsets and actively support them to foster talents. Executives/ employees do not discriminate others or create factions on the account of nepotism, educational affiliation, family ties, gender, physical disability and any other cause not relevant to business. They shall not instruct, request other or abuse their authorities to employ, promote, transfer or grant other tangible/intangible gains to others who are acquainted with them such as family members or relatives.

Pleasant & safe working environment

Working environments are always kept orderly, organized and clean to ensure pleasant and clean environment. Safety regulations are thoroughly complied with to prevent safety accidents in advance.

Prohibition of mutual monetary transactions, etc.

Executives/employees do not exchange gifts with each other unless a superior gives a present to his/her junior or gifts are exchanged on birthdays or other celebrations to boost team morale. Loans, joint and several guarantees, transaction of goods or services, arrangement of traction between executives/employees are prohibited, irrespective of the expectation of reciprocity.

Prohibition of sexual harassment at work

As sexual harassment and molestation can disrupt the dignity of executives/ employees and compromise their motivation to work, preventative controls including regular training are put in place. Executives/employees do not engage in any linguistic or behavioral conduct that can compromise decent work practices or cause sexual shame. They do not inflict physical/mental pain on their colleagues beyond generally acceptable range or aggravate working conditions by abusing their status or relations.

Duties of executives/employees

Executives/employees do not use corporate properties for their personal gains or disclose corporate information that they get to know as a part of business process. All executives/employees do not spread unfounded rumors that can impact the Company. They do not use any illegal copy of software except for legitimate copies provided by the Company or access internet sites that can compromise business integrity. They do not engage in unhealthy activities such as gambling. The Company implements programs required for training executives/employees into autonomous and creative talents, extend active support to them who are expected to advance their quality and ability by adhering to autonomous self-development plans.

5.Management & administration of ethical

Compliance requirements & responsibilities

All executives/employees shall familiarize themselves and comply with these Regulations and be held responsible for a violation hereof. The Company may stipulate a separate guideline as needed for efficient operation of ethical standards.

Reporting obligation & secrecy guarantee

1. One who is aware of a violation of ethical standards shall promptly report to the audit department or online reporting center (website or intranet of the Company). The Company may investigate relevant facts for a report and relevant executives/employees shall actively cooperate with such investigation. The Company shall not subject an insider reporter to disadvantageous treatment or disclose his/her identity.
2. Insider reporting shall be applicable to:
   1. 0. Violation of ethical standards and a statement of compliance therewith;
   2. 1. Willful misconduct or gross negligence inflicting damage to the Company;
   3. 2. Illegal and unfair business conduct;
   4. 3. Disadvantages provided in return for refusal to follow illegal and unfair instruction of a superior or join such conduct;
   5. 4. Sexual harassment or bullying at work;
   6. 5. Disadvantages provided in return for due reporting;
   7. 6. Violation of a provision in anti-graft law, OECD’s anti-bribery law, and other international law controlling bribery in international commercial transactions;
   8. 7. Giving/receipt of money and/or entertainment, etc. or
   9. 8. Other activities likely to lead to any of the above.
3. Handling of report
   1. 0. Insider reporting system is governed by the internal audit department (Ethical Management Team) in accordance with the Audit Committee Operating Rules, Internal Accounting Control System Guideline and Internal Audit Rules, etc.
   2. 1. The internal audit department may investigate applicable facts or summon related parties to determine the truthfulness of a report.
   3. 2. As objective and correct evidence needs to be secured to determine the truthfulness of a report, a report shall be handled without delay from its receipt
   4. 3. If an insider report is found to be false, the defendant may request disciplinary action or disposition, etc. against the inside reporter, depending on the severity of resulting damage.
4. Protection of inside reporter
   1. 0. Inside reporter’s identity shall be thoroughly protected.
   2. 1. Inside reporter or collaborator providing evidence to him/her shall not be subject to any disadvantageous treatment.
   3. 2. Details of a report shall not be disclosed unless applicable charge is established and applicable defendant shall not be subject to any discrimination or disadvantage.
   4. 3. LocknLock protects internal whistleblowers by law in accordance with the ‘Public Interest Whistleblower Protection Act’ (Article 12 of the ‘Public Interest Whistleblower Protection Act’)
   Public Interest Whistleblower Protection Act (Link)
   Violations of the Public Interest Whistleblower Protection Act (PDF)

Collection of ethical compliance statement

1. Executives/employees shall sign off a statement of ethical compliance based on these ethical standards, read through and sincerely comply with terms therein
2. The statement of ethical compliance shall be collected from:
   1. 0. New employees when they are hired;
   2. 1. Incumbent employees once every year; and
   3. 2. Suppliers when they are contracted
3. The statement of ethical compliance shall be collected by:
   1. 0. The HR & General Administration Team for new employees;
   2. 1. The Ethical Management Team for incumbent employees; and
   3. 2. The Legal Affairs Team for suppliers

Reward & disciplinary action

The Company may give reward to an executive/employee for contributing to fulfilling the purpose of ethical standards or subject an executive/employee to disciplinary action for violation of ethical standards.

1. Rewards and disciplinary actions for employees shall be administered by Articles 82 (Rewards), 83 (Types of Disciplinary Action) and 84 (Reason for Disciplinary Action) in the Rules of Employment.

This Regulation shall go into force on May 1, 2021.