Chapter 2 Fair Competition

The Company shall comply with relative regional laws and regulations in all business activities worldwide and secure competitive advantages by fair means.

1. Compliance with laws and regulations

①The Company shall comply with the laws and regulations of the country in all business activities at home and abroad and respect commercial convention.

②The Company shall help its executives and staff members to understand laws and regulations to be complied with in their daily lives and in the discharge of their duties, and support them to solve legal issues facing them.

2. Pursue of free competition

①We shall respect the order of the market economy anywhere in the world according to the principles of free competition, and recover clients’ trust through quality products and services.

②We shall compete in good faith with true competence and shall not violate interests of competitors or exploit their weaknesses.

3. Acquisition and utilization of legitimate information

①We shall legitimately acquire and utilize information in accordance with laws and regulations as well as commercial convention, and shall not unfairly disclose information of competitors even if it was legitimately acquired.

②We shall not give criticism of competitors or groundless comparison through advertisement.

Chapter 3 Fair Transactions

All transactions shall be made in accordance with the principles of free competition with guaranteed equal participating opportunities, and we shall pursue common growth from a long-term perspective by building mutual trust and partnership through transparent and fair transactions.

1. Fair transaction procedures

①All transactions shall be made fairly in a mutually equal position and fully consulted on transaction terms and procedures, and any form of unfair action with abuse of power shall not take place.

②All information necessary for transactions shall be mutually provided in a timely manner through appropriate procedures and the transaction results shall be periodically evaluated and complemented in accordance with fair standards.

2. Pursuit of mutual growth

The Company shall actively support its partners to improve competitiveness and grow, and shall mutually share the profits generated thereby.

Chapter 4 Basic Ethics of Executives and Staff Members

All executives and staff members of the Company shall establish upright values based on honesty and faithfulness and accomplish given missions through constant self-development and fair discharge of duties.

1. Basic ethics

①Executives and staff members shall have pride and self-esteem as Heesung PMTech personnel and stick to an honest and earnest attitude at all times.

②Executives and staff members shall have high ethical values and try to maintain individual dignity as well as Heesung Pmtech’s honor at all times.

2. Accomplishment of missions

①Executives and staff members shall accomplish their individual missions faithfully according to the Company’s vision and policy.

②Executives and staff members shall do their utmost to discharge their duties by fair means and comply with all relevant laws and regulations.

③Executives and staff members shall improve work efficiency through positive cooperation among colleagues and departments.

3. Fair discharge of duties

①Executives and staff members shall discharge their duties honestly and fairly, and try to foster a sound corporate culture at all times.

②Executives and staff members shall not take any pecuniary interests from interested parties that could hinder the fairness of judgment with regard to duties, and shall not take immoral and unethical actions that could be criticized by society.

③Senior employees shall not order duties to junior employees which do not accord with laws and regulations or the Company’s rules. Employees who received orders that do not accord with laws and regulations or the Company’s rules can refuse to conduct such duties and shall not have a disadvantage even if such event is notified to the Company.

4. Prohibition of sexual harassment

①Executives and staff members shall be restricted from having obscene conversations and forcing others to serve drinks or dance at dinner.

②Executives and staff members shall not see pornographic sites on the internet at work.

③Executives and staff members shall not make sexual comments about coworkers’ bodies and be restricted from unnecessary physical contact and comments that emphasize fixed gender roles.

5. Mutual respect of executives and staff members

①Executives and staff members shall keep basic manners necessary for work life and shall not do irreverent behaviors or say critical words towards other employees.

②Executives and staff members shall not discriminate each other or create factions based on educational background, sex, religion, blood, place of origin, age, disability, marital status, nationality, or race, and shall not make wrongful requests to each other.

③Executives and staff members shall not act in any way that could distress senior employees, coworkers, or junior employees such as cursing, slander, or personal attack.

6. Prohibition of customer and company information disclosure

①Information about customers shall never be disclosed to a third party without prior consent of the customer.

②Information belonging to the confidentiality of partners shall not be disclosed to unauthorized persons inside and outside the company.

③The Company’s internal information such as confidential information and new legal information shall not be leaked to a third party without prior approval from the supervisor, and executives and staff members shall not disclose such information even after resignation.

7. Use of Company Assets

①Company assets shall not be used for personal purpose or lost, misused or stolen.

②It is prohibited to copy, install, use, transmit or save illegal software.

Chapter 5 Responsibilities with regard to Executive and Staff Members

The Company shall respect all executives and staff members of Heesung PMTech Ltd. as human beings and treat them fairly based on their capabilities and achievements, and make efforts to use their creativity to the fullest extent.

1. Respect for humans

①The Company shall treat each employee as an independent personality with faith and true affection for humans, and do its utmost so that its employees can have pride and feel rewarded through work based on work based on the sense of ownership.

②The company shall do its utmost so that its employees can have pride and feel rewarded through work based on work based on the sense of ownership.

③The Company shall take necessary measures such as establishment of the system, education and guidance so that its employees can carry out missions by fair means.

2. Fair Treatment

①The Company shall give equal opportunities to executives and staff members according to their abilities and qualities, and shall evaluate their abilities and achievements according to fair criteria and fairly compensate.

②The Company shall provide fair opportunities to improve the abilities of its employees and does not discriminate according to academic background, gender, religion, place of origin, age, disability, marital status, or nationality.

3. Promotion of creativity

①The Company shall maximize conditions under which employees' creative thinking and autonomous action can be promoted.

②The Company shall actively support employees' capacity building and foster talents from a long-term perspective.

③The Company shall respect individuals’ privacy and build a mature organizational culture based on mutual trust and understanding.

Chapter 6 Responsibility with regard to the State and Society

The Company shall grow as a sound company through rational business development, protect interests of stockholders, and contribute to affluent lives of citizens and the development of society.

1. Rational business development

The Company shall conduct business respecting the social values of the region regardless of home and abroad, and promote expansion business on the basis of stable growth of the Company.

2. Protection of interests of stockholders

The Company shall protect stockholders' investment returns by realizing sound profit through effective management.

3. Contribution to social development

①The Company shall contribute to national development by creating jobs and reporting taxes in earnest, and to social development by ensuring and encouraging the participation of employees in social activities.

②The Company shall contribute to social development by correcting and encouraging the participation of employees in social activities.

③The Company shall provide equal employment opportunities to everyone without discrimination against race, sex, religion, place of origin, age, disability, marital status, nationality, or race.

4. Conservation of the environment and complying with safety regulations

①In order to conserve the clean environment, the Company shall make every effort to prevent environmental pollution and to protect nature and comply with all laws and regulations related to environmental protection.

②The Company shall make every effort to eliminate wasteful consumption of resources and shall not carry out any business activities that are contrary to environmental protection.

③The Company shall comply with laws and regulations related to safety.

Chapter 7 Obligation to Comply with Code of Ethics

All executives and staff members are required to comply with the Code of ethics, and executives and managers are responsible for ensuring that their employees comply with the Code of Ethics.

①In case of violation of the Code of Ethics, the Company shall prevent recurrence through thorough investigation of the cause and training.

②All employees shall faithfully comply with the Code of Ethics. In case of violation of the Code, they shall be responsible for such violation including disciplinary punishment according to the disciplinary regulations.

③If employees were forced to violate the Code of Ethics or recognized any violation, they shall notify the team leader or personnel department, and any doubt shall be consulted with the team leader in advance.