Ethics / Compliance Management

Ethics Management

Ethics Management Pledge

Ethics Management Pledge

  • In executing operations, I will not engage in any unfair transactions or corrupt practices by complying with the LS ELECTRIC Code of Ethics.
  • I will execute operations according to the principle of good faith and will make all-out efforts not to impede the operations or cause damage to the company by deliberately or due to negligence.
  • In executing operations, I will dedicate utmost effort to protecting the company's funds, assets, and information.
  • In the event of a violation of the Code of Ethics, such as when I become aware of an employee's unfair or corruptive practice or got propositioned to engage in such practice, I will report it immediately to the Business Audit Team.
  • In the event of an investigation on any unfair or corruptive practice in violation of the LS ELECTRIC Code of Ethics, I will fully cooperate with the investigation, such as submitting the data requested by the company (documents necessary in the unfair or corruptive practice investigation).
  • I will execute operations fairly by following the LS ELECTRIC Code of Ethics and Practical Guidelines.
  • Should I violate this pledge, I will assume all associated responsibilities.

LS ELECTRIC Code of Ethics

LS ELECTRIC pursues autonomous management based on the principles of autonomy and responsibility pursuant to the LS ELECTRIC Partnership management philosophy and Charter in all its business fields.
LS ELECTRIC intends to constantly develop as a world-best company by pursuing the common interests of all its stakeholders based on mutual trust and cooperation, while respecting the order of the free market economy and its dominant principle of free and fair competition. Therefore, we hereby adopt and pledge to practice this code of ethics as the criteria for determining the right actions and judgment values to which all LS ELECTRIC officers and employees should adhere.

  • Targets of Application

    • This Code shall apply to LS ELECTRIC and all the affiliated or subsidiary companies over which LS ELECTRIC exercises management rights among those invested by LS ELECTRIC.
    • This Code shall apply to overseas corporations over which LS ELECTRIC exercises management rights in consideration of the local statutes at the same time.
    • LS ELECTRIC shall induce its third-party partners (invested companies, partner companies, distributors, consultants, agents, intermediaries, etc.) to actively comply with this Code by fully understanding those of its provisions which are applicable to them.
  • Organization and Operation of Ethics Committee and Secretariat

    • The “Ethics Committee” shall be composed of members of the HR Committee as the supreme decision-making body concerning matters related to the practice of this Code.
    • The “Ethics Committee Secretariat” shall be formed to conduct administrative matters related to compliance with the Code.
    • The Ethics Committee Secretariat shall provide the necessary education and information to ensure that all departments systematically comply with the Code while streamlining the overall systems required for autonomous compliance with the Code.
    • The Ethics Committee Secretariat shall adopt and operate various rules and procedures to enable all LS ELECTRIC’s officers, employees, partner companies or customers to report any violation or potential violation of the Code or the related regulations.
    • The Ethics Committee Secretariat shall make an authoritative interpretation, complete with a review by the Ethics Committee, as required whenever any question or ambiguity arises with regard to the officers’ or employees’ application or interpretation of the Code or matters related to business operations and other important issues.
  • Duties of Officers and Employees

    • All the officers and employees of the Company shall comply with and practice the Code, the related regulations and guidelines.
    • All the officers and employees of the Company shall promptly report to their superiors or the Ethics Committee Secretariat pursuant to the given procedures in the event that either they or a third party violate or are forced to violate the Code.
    • All the officers and employees of the Company shall address to their leader or the Ethics Committee Secretariat any questions pertaining to violation or fear of violation on the understanding that they cannot in any way be exempted from the Code of ethics or the related regulations on the grounds that they are unaware of them.
    • The Company’s leader shall take in or support the necessary actions so that the Company’s officers or employees are not influenced by any illegal pressure or requests in making decisions on business issues.
    • Responsibilities and Duties toward Customers

      LS ELECTRIC shall secure the unconditional trust of its customers by incessantly creating and providing values that are helpful to them, while always respecting their opinion in the belief that they are the true basis of our business.

    • Provision of faithful information

      • LS ELECTRIC shall provide only truthful information to its customers. It shall not circulate or provide any false information.
      • LS ELECTRIC shall faithfully provide its customers with information concerning matters for which care should be exercised when responding to the customers, and shall provide clear and precise information on the use of its products to ensure they are fully intelligible to the customers.
    • Responding to customers

      • All promises made to customers shall be kept without fail.
      • LS ELECTRIC shall provide only products and services of the highest quality to our customers, and shall ensure we do not incur the customers’ dissatisfaction by the sale or provision of defective products or poor services.
      • Prompt and accurate responsive actions shall be taken to resolve customers’ legitimate return of a defective product or request for services.
    • Protection of customers’ interests

      • The customers’ assets shall be protected in a manner identical to that established and implemented for the company’s own assets, and they shall not be used without obtaining their approval in advance.
      • The customers’ confidential information shall be protected and shall not be disclosed or used for unauthorized purposes without obtaining their approval in advance.
      • No unethical acts that may cause harm to the customers’ interests shall be committed.
    • Fair Competition

      LS ELECTRIC shall comply with the pertinent local statutes in all of its business operations around the world.

    • Provision of faithful information

      • Legitimate collection and utilization of information
        • Information related to competition shall be collected via legitimate methods free from social denunciation.
        • Information collected concerning competition shall be utilized for legitimate purposes.
      • Legitimate securing of competitive advantages
        • Stealing or infringing tangible or intangible assets belonging to the competition shall be prohibited.
        • No organization shall be organized with vendors belonging to the same industries or business lines for the purposes of forging an illegitimate alliance or engaging in collusion.
          LS ELECTRIC shall not participate in any such organization.
      • Prohibition of illegitimate collusion
        • No damages shall be inflicted on the customers through illegitimate collusion with competitors over selling prices, conditions and market allocation.
        • No organization shall be organized with vendors belonging to the same industries or business lines for the purposes of forging an illegitimate alliance or engaging in collusion.
          LS ELECTRIC shall not participate in ant such organization.
    • Responding to customers

      • LS ELECTRIC shall compete using legitimate methods while respecting the pertinent statutes and business practices in the relevant territories.
      • Compliance with the law regarding the prevention of bribing overseas (Foreign Corrupt Practice Act)

        Public Officials in International Business Transactions; the Act on the Prevention of Bribery of Foreign Government Officers in Connection with International Business Transactions; and the Act on the Prevention of Bribery of Foreign Government Officers in Connection with International Business Transactions, each of which prohibits promising or providing or expressing the intention to bribe foreign government officials directly or indirectly in order to obtain illegitimate gains in connection with international business transactions.

    • Fair Transactions

      All transactions shall be conducted based on the principle of free competition in an environment where equal opportunities are ensured for participation. Win-win development shall be pursued on a long-term basis by promoting mutual trust and cooperative relations through transparent and fair trading.

    • Selection of business partners through a fair procedure

      • Regulations and systems concerning the “procedure for selecting business partners” shall be established and implemented so that our business partners may be selected and registered according to fair assessment criteria.
      • The “procedure for selecting business partners” shall include specific items and methods of assessment that are set up in consideration of the characteristics of business transactions.
      • Pressure or illegitimate requests shall be entirely excluded from the procedure for selecting business partners.
    • Fair transactions and assessment

      • The fairly assessed results of transactions shall be notified to the customer and shall be reflected in all subsequent transactions.
      • Sound opinions presented with the aim of improving transactions shall be duly reflected in business processes.
      • The approval of vendors shall always be obtained before using technologies or other assets belonging to an account.
      • Fair compensation shall be awarded for damages inflicted on an account as a result of a mistake made by the company.
      • The company shall not commit any of the following unfair acts as prohibited under the statutes related to fair trade.
        • Acts of forcing an account that is unwilling to buy a product.
        • Acts of unfairly prohibiting an account from conducting a transaction with a competitor or limiting the range or targets of its transactions.
        • Acts of rejecting a legitimate return or unfairly rejecting or delaying the acceptance of goods that have been ordered.
        • Acts of neglecting legal obligations concerning payment terms.
        • Acts of discontinuing business relations or remarkably reducing the volume of business with an account without legitimate reasons.
        • Acts of determining unfair business terms by discriminating against a specific account.
        • Other unfair acts that are prohibited under other pertinent statutes.
    • Maintenance of clean trading order

      • LS ELECTRIC shall not accept or request unfair financial gains, including articles of monetary value, entertainment or other conveniences from its accounts.
      • LS ELECTRIC shall not make any illegitimate request based on such special relations as those of blood and/or school ties, and shall not exercise external pressure by abusing a business-related position in connection with business deals.
      • Information or technologies belonging to a business partner that have been acquired in the course of transactions shall not be used to obstruct that partner’s business operations.
    • Support for partners

      • Standards for supporting or fostering business partners shall be established and implemented.
      • The standards for fostering business partners shall specify the qualifications required of business partners who are eligible for support by the company, and shall include specific operational criteria for technical support or managerial guidance.
      • Earnings generated through technical support or managerial guidance shall be shared in a fair manner.
    • Basic Ethics of Officers and Employees

      LS ELECTRIC’s officers and employees shall establish a right sense of value with a fair creed and shall perform their given mission on the basis of continued self-development and the fair performance of their duties.

    • Maintenance of dignity as LS ELECTRIC officers and employees

      • LS ELECTRIC officers and employees shall not commit any immoral or unethical acts that may damage their honor or integrity.
      • LS ELECTRIC officers and employees shall not commit any acts that may generate distrust or damage the sound organizational atmosphere, including the fabrication or dissemination of rumors
    • Honest and fair reporting

      • LS ELECTRIC officers and employees shall not mislead or frustrate their superiors’ or the relevant departments’ decision-making by manipulating documents or figures or by making false reports.
      • LS ELECTRIC officers and employees shall make reports such as are necessary for performing company business fairly and honestly.
    • Protection of company assets

      • LS ELECTRIC officers and employees shall immediately report and take appropriate actions regarding a serious event that they fear might, or are certain will, cause losses to the company’s assets.
      • LS ELECTRIC officers and employees shall not use the company’s assets for illegal or illegitimate purposes.
      • The company’s confidential information shall be kept secure pursuant to the pertinent regulations. The external disclosure of any company information shall be approved in advance.
      • The company’s confidential information shall be disclosed only to duly authorized persons.
    • Evasion of conflicts of interest with the company

      • LS ELECTRIC officers and employees shall not commit acts that may interfere with the fair performance of their duties, including the acceptance of gratuities.
      • LS ELECTRIC officers and employees shall not directly operate or invest in an outside business whose interests may conflict with those of the company.
      • LS ELECTRIC officers and employees shall not be employed concurrently by a business that has competing relations with the company, and shall not provide consulting or advice that may conflict with or affect the company’s profit.
      • LS ELECTRIC officers and employees shall report to and obtain advance approval from the company when they are offered employment by another company or when they intend to practically perform duties similar to those they perform for LS ELECTRIC.
      • LS ELECTRIC officers and employees shall not trade in or induce others to trade in the company’s stock using internal information.
      • LS ELECTRIC officers and employees shall not select, or exercise influence on behalf of, businesses that are run by members of their immediate family or other relatives as the company’s vendor or (that) deal with the company.
    • Prevention of sexual harassment in the workplace

      • LS ELECTRIC officers and employees shall always be prudent in their speech or actions, remembering that they may cause mental or physical harm or discomfort to others.
      • LS ELECTRIC officers and employees shall abstain from causing any impediments to company life or personal integrity through acts of sexual harassment, regardless of their rank or position.
    • Responsibility toward Officers and Employees

      LS ELECTRIC shall respect all of its officers and employees as human beings, treat them fairly based on their ability and performance, and endeavor to enable them to fully demonstrate their creativity

    • Development of human resources

      • LS ELECTRIC shall establish a desirable image regarding its employees and implement policies aimed at developing their capabilities.
      • LS ELECTRIC shall establish and actively support the institutions or systems needed to enable its officers and employees to develop into autonomous and creative human beings.
      • LS ELECTRIC shall assign duties to its officers and employees in consideration of their desires, aptitudes and capacities and shall help them to develop their abilities throughout the performance of their duties.
    • Fair treatment

      • LS ELECTRIC shall grant fair opportunities to all its officers and employees to advance their competences without discrimination based on their schooling, gender, age or place of origin.
      • LS ELECTRIC shall ensure fair remuneration is awarded to its officers and employees by fairly evaluating their aptitudes, capacities and performance.
    • Health and safety

      • LS ELECTRIC shall take all appropriate actions to ensure the health and safety of its officers and employees in performing their duties.
      • In particular, LS ELECTRIC shall implement the necessary safety measures at workplaces that are exposed to specific hazards.
    • Respect of individuals’ opinions

      • LS ELECTRIC shall protect the privacy of all individuals unless their behavior or acts otherwise impede the work atmosphere or public morals.
      • LS ELECTRIC shall develop the systems and atmosphere required to enable its officers or employees to make constructive suggestions or recommendations or to freely express their distress.
      • LS ELECTRIC shall not compel or oblige its officers or employees to participate in specific religious or political party activities and shall respect each individual’s religious or political opinions.
    • Responsibility toward Nation and Society

      LS ELECTRIC shall protect its shareholders’ interests and contribute to public affluence and social development by growing into a sound business based on the pursuit of rational business operations.

    • Rational business stages

      LS ELECTRIC shall respect society’s sense of ethical value, shall not commit any acts that may harm the national economy or provoke a sense of alienation, and shall undertake business activities that match the people’s sentiment

    • Protection of shareholders’ rights and interests

      • LS ELECTRIC shall grant fair opportunities to all its officers and employees to advance their competences without discrimination based on their schooling, gender, age or place of origin.
      • LS ELECTRIC shall ensure that fair remuneration is awarded to its officers and employees by fairly evaluating their aptitudes, capacities and performance.
    • Contribution to national and social development

      • LS ELECTRIC shall fairly grant opportunities for employment to anyone without discrimination based on their schooling, gender or place of origin.
      • LS ELECTRIC shall faithfully file its tax returns and pay all due taxes.
      • LS ELECTRIC shall endeavor to accommodate and resolve legitimate demands made by the various tiers of society and local residents.
    • Protection of the environment

      • LS ELECTRIC shall comply with all the statutes related to environmental protection, and shall endeavor to undertake environmentally-friendly business activities.
      • LS ELECTRIC shall secure and operate pollution-prevention facilities and deploy the designated personnel to prevent environmental contamination.

Overview of CP

What is a Compliance Program?

  • An independently operated internal compliance management system to ensure autonomous adherence to fair trade regulations
  • A program that provides employees of the company with explicit behavioral standards to adhere to fair trade-related regulations
  • Activities (internal control systems) that suppress and prevent legal risk factors in business operations

The Need to Adopt CP

Strengthening regulations by the Fair Trade Commission
  • Strengthening investigations and sanctions for businesses engaging in unfair trade practices
    (e.g., abuse of position in transactions, collusion, rebates)
  • A focus on protecting the interests and rights of consumers
  • Imposing severe fines and criminal and civil punishment for breaking the law
Internal corporate environment
  • Unfair trade practices have become a significant risk to business management
  • Increased need for an autonomous compliance system that ensures fair competition
  • Significant monetary damage and deteriorated social standing for a breaching company
Evaluation of corporate governance
  • CP operation matters are reflected in social evaluation items when evaluating the corporate governance structure of a listed company (ESG).

8 Components of CP

  1. 1
    Preparation and implementation of CP standards and procedures
  2. 2
    The CEO’s commitment to autonomous compliance and support
  3. 3
    Appointment of an autonomous compliance manager in charge of CP operation
  4. 4
    Production and circulation of autonomous compliance guidebook
  5. 5
    Ongoing and systematic autonomous compliance training
  6. 6
    Internal monitoring system
  7. 7
    Sanctions on employees who violate fair trade-related regulations
  8. 8
    Effectiveness evaluation and improvement measures

Clarification of Will for Compliance of CEO

CEO
CEO
Dear members of LS ELECTRIC
LS ELECTRIC is opening the future of smart energy as a leader in the industrial electrical and automation sector through LS's management philosophy of 'LSpartnership,' which aims to create greater value together.

As you are aware, violating fair trade regulations poses a major risk to a company’s existence in this era of intense global competition. Consequently, in line with the fair trade environment that surrounds our company, we are pursuing compliance management.

We declared a code of ethics in 1994 and have been working to adhere to the Fair Trade Act and carry out ethical business practices within the bounds of the law since 2002, when we enacted the Fair Trade Autonomous Compliance Guidebook.

Moreover, we have established and are operating the “Compliance Program (CP)” as the industry-leader in the heavy electrical equipment sector in an effort to take the initiative and lead the way in creating a culture of fairness.

The Compliance Program comprises standards and internal control systems that are enacted and operated autonomously by each company in order to ensure compliance with fair trade regulations. We want to improve the ethical and law-abiding consciousness among our employees, prevent violation of laws, and disperse and internalize a culture of fairness by implementing our compliance program.

Therefore, we kindly request that all employees actively engage in autonomous compliance program-related activities and advance LS ElECTRIC’s culture of fairness. Furthermore, please bear in mind that various obligations such as following the law, consulting beforehand when legal violations are suspected, reporting violations found in the company, and participating in CP trainings, among other obligations, are outlined in the company’s CP standards for all employees to follow.

The company will provide unwavering support for the autonomous compliance program’s operation, and any legal violations that undermine the culture of fairness or failure to fulfill obligations will face severe sanctions under a “zero tolerance” policy.

With these efforts, our company will uphold the market economic order and continuously grow into a top-tier global corporation based on business ethics.

We kindly request your support and participation.

Thank you.

April 19, 2023


CEO
sign

CP Operation

Fair Trade Consultation and Reporting

Acts Subject to Reporting

  • Unfair collective actions by interested parties, such as bid-rigging with the intention of trading with our company
  • Acts that go against our fair trade code of conduct (see the rules in the fair trade autonomous compliance guidebook)
  • Unfair treatment and exposure of identity of legitimate reporters
  • Violation of other laws, such as the Fair Trade Act (collusion, internal transactions), Subcontracting Act, and Display and Advertising Act
  • Reporting corruption of business partners and engaging in unfair trade practices
  • Accepting illegitimate money, entertainment, or favors from interested parties
  • Involvement in cases of embezzlement or bribery
  • Abusing one’s position or authority to gain unjust profit or cause damage to the company
  • Interrupting fair business practices of other employees in order to gain unjust profit for oneself or others
  • Disclosing business secrets and customer information without consent

How to Report

Online Reporting Channel

This reporting channel, accessible from all websites operated by LS ElECTRIC, provides a prescribed reporting format.

Report

Reporter Protection

  • Complete anonymity of the reporter’s identity and reported content
  • Revealing or identifying the reporter’s identity is strictly forbidden
  • Discriminating against or unfairly treating the reporter is strictly forbidden

Report Handling Process

  • STEP.1

    Report submitted

  • STEP.2

    Content reviewed

  • STEP.3

    Investigation begins

  • STEP.4

    Investigation completed

  • STEP.5

    Processing result