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Code of Conduct

All the executives and employees of Koscom shall commit to comply to the ethical regulations as our core value.

  1. Article 01 Objectives
    • This code of ethics aims at providing behavior standards by which all the executives and employees of Koscom Corporation (hereinafter referred to as “Koscom”) shall comply.
  2. Article 02 Basic attitude of executives and employees
    • Koscom shall pursue the goal of a customer-trusted global financial IT company and exert its ethical obligations as a member through the fair execution duty while undertaking the responsibilities and obligations for customers with such purpose.
  3. Article 03 Definition
    • Definitions applied to this code of conduct are as follows.
      • “Job Related Company” refers to any person or organization related to carrying out any job in accordance with all the regulations for Koscom.
      • “Job Related Employee” refers to other employees who might have any advantage or disadvantage either directly or indirectly in relation with their job performance.
    • Manual View

      A job related company in the scope of being applied to the code of ethics refers to a company or a person directly or indirectly related to the job of employees. Any company having no relation with the job of employees shall be excluded from the application even if it is one of our cooperative companies, provided that such circumstances shall be decided not on discretion, but by the decision of an official in charge of ethics.

      • Any company related to the job of an employee shall naturally become a job related company to any superior of the employee as well.
      • * Example: A company supplying Item A to an employee in charge of purchasing Item A shall become a job related company to the employee, but not one to an employee in charge of purchasing Item B, provided the company might become a job related company if the employ in charge of purchasing Item B can affect the employee in charge of purchasing Item A.

      A job related employee refers to any employee or executive having primary relationships or influences.

      • * Example: Any employee carrying out a job including the personnel, budget, audit, reward or discipline, appraisal, etc. for the employees and executives would fall into a job related employee in general. The simple relation of office work, including the salesperson for Commodity A and employees related to operations, will not be considered a job related employee.
  4. Article 04 Applicability
    • This code shall apply to all the employees and executives employed by Koscom.
  5. Article 05 Compliance obligations
    • All executives and employees shall be familiar with these codes and observe them.
    • The president may ask any executive or employee to submit a letter of commitment to comply with the code of conduct to guarantee the compliance of codes while arranging the prevention of corruption and the creation of a conducive work environment for job performance.
  6. Article 06 Our own questions and answers to ethical practices
    • All executives and employees shall make efforts to eradicate any unethical behavior by asking themselves the questions and answers as follows until we have ethical discretion and confidence when we have any ethical conflict in all our behaviors including any presence of violations against laws in carrying out our jobs.

      • Do I feel nervous while carrying out this job?
      • Can I comfortably talk to my family about what I have done?
      • What would I say if others exhibited this behavior?
      • What would others think of me if this behavior carried out by me is made public?
    • Manual View

      The official in charge of ethical management takes charge of any inquiry and demand in relation to any ethical behavior.

  7. Article 07 Respects toward customers
    • All executives and employees shall make efforts to provide optimal services and show respect toward customers.
    • Manual View

      Decisions shall be made in reference to the following examples.

      • We shall make efforts to make prompt arrangements for any complaint and demand from customers while listening to their opinions.
      • We shall make efforts to keep our promises with customers.
      • We shall keep strict management concerning customer information in accordance with the related laws to prevent any infringement to the privacy of customers or any damage to their credence that may occur due to information leakage.
      • We shall initiate continuous activities on quality improvements to provide products and services satisfactory to the needs of customers.
      • We shall carry out research on market circumstances with customers at any possible time and reflect those results in our management policies.
  8. Article 08 Work standards of executives and employees
    • No employee shall undertake any fraudulent behavior on one’s job or excessive destructive action to business efficiency.
    • All employees shall fulfill their obligations in preventing sexual harassment in order to create a healthy work environment.
    • All employees shall fulfill their obligations to have mutual respect between superiors and sub-ordinates and make efforts to embody an organizational culture based on mutual trust and understanding while keeping one’s own work environment creative and autonomous.
    • Manual View

      Decisions shall be made in reference to the following examples.

      • Any excessive Internet surfing, chatting, entertainment, gossip, etc. with no direct relation to job performance.
      • Staying in the office or requesting overtime wages and/or meal expenses for the night shift for personal affairs after working hours.
      • Smoking in places other than the designated smoking sites in the company.
      • Any obscene conversation and/or behavior forcing others to participate in drinking or dancing in the case of official meal occasions.
      • Any behavior involving connection to obscene Internet sites, or to view or listen to or distribute such obscene -contents in one’s workplace.
      • Any unnecessary physical contact or sexual jokes that might incur any sexual humiliation.
      • Any behavior to arrange partisanship or discriminating treatment with no relation with personal abilities, including school relationships, regional relationships, blood relationships, gender, etc.
      • Any behavior to provide objective and severe suffering to others, including inappropriate naming, swearwords, slander, negative prejudices, threatening words or actions, etc. using any superior condition such as one’s own job grade, physical condition, etc.

      Any matters on compliance upon carrying out the job of employees shall be made in reference to the following examples.

      • Any sub-ordinate shall obey any fair order and instruction in carrying out one’s job while respecting opinions of any superior.
      • No superior shall make any unfair business or private instruction without legal foundation to their sub-ordinate, and any sub-ordinate might refuse such instruction if made.
      • No superior shall undertake actions that might make others misunderstand opinions or business records of one’s sub- ordinate as their own opinion or record.
      • No employee will make word or action to incur slander against another employee.
  9. Article 09 Avoiding jobs of conflict of interest
    • Employees shall in principle avoid undertaking a job if that job is related to their own interests or the interest of their relatives within a range of cousins (relatives provided in Article 767 of Civil Codes, hereinafter referred to the same).
    • Any need for avoidance in the job provided in Clause 1 shall be resolved after consultation with the employee’s direct superior regarding the necessity of such avoidance in their job.
    • Manual View

      Examples

      • An examination for promotion which includes the person in charge, where the employee’s elder brother is an employee of the supplier, etc.
        * Relatives within a range of cousins.
      • Blood relationship: lineal ascendant (parents, grandparents, great-grandparents, grandfather of mother’s parents, great-grandfather of mother), lineal descendent (offspring, grandchildren, great grandchildren), lateral blood relationship (brothers and sisters, uncles and aunts, nephews and nieces, cousins), adopted children and their blood relationship with their adopted children.
      • Relatives by marriage: spouse of blood relationship, blood relationship of spouse, spouse of blood relationship of spouse.
        Spouse: wife or husband
  10. Article 10 Exclusion of privilege
    • Employees shall not provide any privilege for any specific person for reasons of regional, blood or school relationships in carrying out their job.
    • Manual View

      This article refers to the giving or promotion of any superior position with no clear foundation in law or regulation, or to deteriorate fair trade or competition.

      • Regional, blood or school relationships do not specify any specific range, but decisions shall be based on the presence of impact on the job performance from the presence of relationship to the extent of friendly relationships that might have possibilities of tacit pressure or involvement.

      Examples : Illustrated relationships above cannot be considered as a justifiable cause of providing privileges.Therefore such degradation to fair competition or provision of economic or social interests shall be considered as a violation the codes of conduct.

  11. Article 11 Prohibiting any private use of budget
    • Employees shall not incur any damage to Koscom by using any budget for their job for private reasons.
    • Manual View

      It applies to the circumstance that both the use of budget in private and damage to Koscom is sufficed
      at the same time.

      • This applies to the circumstance that both the use of budget in private and damage to Koscom are interrelated. Use in private refers to use for personal interests with no relation to the company’s businesses.

      Example : using any expense account for business trips in any personal expense for celebration or condolence, partly appropriating expenses of overseas training expenses for the accompanying family, using expenses for product promotion in meal expenses with family, etc.

  12. Article 12 Prohibiting any personnel favor requests, etc.
    • Employees shall not ask others to make any favor requests to persons in charge of personnel management which would have an unfair impact on personnel affairs, including their promotion, upgrade, transfer, etc.
    • Employees shall not have any unfair involvement in personnel affairs such as the promotion, upgrade, transfer, etc. of other employees using their position.
    • Manual View

      As it refers to asking outsiders to make favor requests, any consultation or request for personnel matters to their superiors or persons in charge of personnel affairs can be allowed.

      As it refers to unfair involvement, opinions upon the request of persons in charge of personnel affairs by team managers and head office directors are allowed.

      Awards and discipline are also included.

  13. Article 13 Handling any instruction to deteriorate fair job performance
    • Employees might not follow any instruction of super-ordinates to significantly deteriorate the fair job performance for their or others’ unfair interest and explain reasons to the super-ordinate.
    • They can report to the next level superior of the superior in question or the President if the same instruction continues regardless of such non-execution in accordance with provisions in Clause 1.
    • Regardless of provisions in Clause 1 or 2, the employee can have consultations with the person in charge of ethical management, and the person in charge of ethical management should carry out the follow-ups upon his or her discretion in this case.
    • Manual View

      In the case that decisions on instructions to deteriorate the fair job performance shall not be made by the person making the instruction or the person in charge of the job, any doubt on such matters shall be referred to the person in charge of ethical management.

  14. Article 14 Prohibiting any involvement into interests
    • Employees shall not try to have their own unfair interest or make others have any unfair interest by using their position.
    • Employees shall not use the name of the company or their position or make others use those circumstances in order to enhance their own or others’ interests.
    • Manual View

      Decisions shall be made in reference to the following examples.

      • Employees are prohibited from supporting any friendly events for their friends by any cooperative companies related to their job.
      • A Personnel Team Manager is prohibited from distributing and collecting applications for credit card membership as it is possibly considered using his/her position when the authority of Personnel Team Manager is taken into consideration.
      • Any personal request for application for such membership is allowed between team members where no influence of position is involved.
  15. Article 15 Prohibiting favor arrangements/requests, etc.
    • Employees shall not make any favor arrangements/requests to deteriorate the fair job performance of other employees in order to enhance their own or others’ unfair interests.
    • Employees shall not introduce job related companies to other employees or other job related companies in order to enhance their own or others’ unfair interests in carrying out their job.
    • Manual View

      Violations are deemed being made although no bribery undertaken, such as assets or entertainments in exchange for payments of such arrangements and/or requests.

      • Arrangements refer to the introducing of acts to deteriorate fair job performance, and favor requests refer to asking for something, but both are used together in reality.
  16. Article 16 Restricting any trade using job related information, etc.
    • Employees shall not commit any property trade or investment related to securities or real estate, or provide information for others to help their property trade or investment while using information known to them in relation with their job performance.
    • Manual View

      • This article refers to circumstances where an employee acquires information on any specific company in advance while carrying out their job.
  17. Article 17 Prohibiting any private use/profit of company assets
    • Employees shall not use and/or exploit Koscom’s properties in private for no reasonable explanation.
    • Manual View

      Decisions shall be made in reference to the following examples.

      • Private use of vehicles for business by the family of employees.
        * Use with the acceptable range of reasons under approval of the company is allowed with fair reason such as activating employee activity clubs, etc.
      • Use of office supplies in private including PR gifts, copy papers, etc.
        * Excluding the use of trial products and the temporary personal use of office supplies for business purposes.
  18. Article 18 Restrictions on giving and taking money, etc.
    • Employees shall not take any money, real estate or entertainment (hereinafter referred to as “money and others”) from their job related companies, except for the taking of the following items.
      • Money and others provided by reasonable sources including the repayment of debts, etc.
      • Meals and convenience normally provided within a normal range (limited to 50,000 won) in the case of unavoidable circumstances in carrying out their job.Money and others commonly provided to participants by sponsors in official events related to their job.Souvenirs or promotional items distributed to many and unspecified persons Money and others openly provided to help employees who have difficulties due to disease, disaster, etc.Money and others otherwise provided within a
        range permitted by the President for the purpose of smooth job performance, etc.
    • Employees shall not take any money or others from their job related employees, except for the following circumstances.
      • In the case of one of the following items in Clause 1:
      • Gifts in a small amount (limited to 50,000 won) provided within a range of normal custom
      • Money and others openly provided by the employees’ mutual help union, etc.
      • Money and others provided to enhance morale including condolence, encouragement, rewards, etc. to sub-ordinates by superiors
    • Regardless of provisions in Clause 2, any behavior that sub-ordinates provide gifts to superiors or any behavior to deliver gift such as flowers between employees shall not be done according to their promotion or transfer of positions, etc.
    • Employees shall not take any money or others in relation with their position from job related companies or job related employees, except for the items described in Clause 1 or 2.
    • Manual View

      Examples of money and others

      • Drafts, checks, stocks, bonds, boarding pass, commodity coupons, public phone cards, ski lift boarding pass, etc.
      • Anything with economic value including goodwill, rights of allotment for apartments, etc.
      • Meals, drinking (room salons, taverns, night clubs), golf, skiing, casino, horse racing, steam bath, massage parlor,
      • high-quality barbershop, train ticket, flight ticket, travel coupons, tickets for sports such as soccer, condo.
        * Condo reservations under difficult circumstances in seasons for such reservations fall into entertainment although the actual expenses are paid.

      As any money or others exceeding 50,000 won are prohibited, any orchid pot exceeding 50,000 won is
      prohibited in the case of floral arrangements for promotion or upgrades.

      • If the excessive amount (difference) is paid immediately, it might be allowed. (For example, making payment of 50,000 won in the case of an orchid pot worth 100,000 won, provided that compensating with meals shall not be deemed as making payment.

      Allowable circumstances

      • Food and convenience provided in a range of normal customs (limited to 50,000 won): Food refers to beverages and meals provided in business discussions and convenience to the use of communication facilities and vehicle support.
      • Money, transportation, accommodation or food commonly provided in any official event: any provision from unofficial events or to specific employees shall be prohibited.
      • Souvenirs or promotional items distributed to many and unspecified persons, such as souvenirs for customers and promotional items for events including seminars, are allowed; but souvenirs given to specified persons are prohibited.
      • Money or others to help employees having difficulties from disasters, etc.: any unofficially collected money or items are prohibited.
      • Money or items otherwise provided within a range allowed by the President for smooth job performance: the official in charge of ethical management shall prepare criteria defined by the President and decisions can be made upon request in advance (for example, participation in an unofficial golf event to share industry information or identify market trends).

      Prohibited examples

      • Any act to provide a member of a department with a massive amount of cooperative items.
      • In the case of overseas trips sponsored by credit card companies by selecting 2~3 employees in charge of accounting by institution that has higher records of credit cards.
      • Any behavior to provide a newly positioned superior with gifts from expenses collected by a number of sub-ordinates.
      • Any treating of meals or drinking at a meeting with job related companies in the past during celebration or condolence of colleagues.
      • In the case of cooperative money from cooperative companies because of a shortage in budget for the event.

      As any gift to superiors by sub-ordinates is prohibited, gifts or compensating items provided for participants in such events as celebration or condolence are allowed if they are given under no conflicting relationship.

  19. Article 19 Restrictions on giving and taking money and items by spouse
    • Employees shall prohibit their spouse or linear ascendant or descendant from receiving any money or items prohibited in accordance with Article 15 or from providing money or others prohibited in accordance with Article 16.
    • Manual View

      Examples: In the case of free items provided by job related companies for the Women Association of an apartment to which a spouse of an employee belongs.

      • Lineal ascendants: parents, grandparents, great-grandparents, etc.
      • Lineal descendants: offspring, grandchildren, great-grandchildren, etc.
  20. Article 20 Prohibiting borrowing of money, etc.
    • Employees shall not borrow money and others from their job related companies (excluding relatives within cousins), or borrow real estate with no interest (including a significantly lower price compared to the market price or customary trading price), except for the borrowing from financial institutions under normal conditions.
    • Regardless of Clause 1, any employee who unavoidably wants to borrow money or real estate with no interest from their job related companies should report to the official in charge of ethical management.
    • Manual View

      A significantly lower price refers to a level of price deemed as inappropriate benefit to the extent that it might affect fair job performance, which the official in charge of ethical management should decide case by case.

      If such borrowing had been made before the execution of these codes of ethics, the extension of such borrowings is not allowed, provided that the extension can be made in accordance with Clause 2 if there exists any unavoidable circumstance.

      • Any case where the company became their job related company after such borrowing should also be reported by applying Clause 2.
  21. Article 21 Entering into and executing clean and honest contracts
    • Employees shall prohibit their spouse or linear ascendant or descendant from receiving any money or items prohibited in accordance with Article 15 or from providing money or others prohibited inaccordance with Article 16.
    • Manual View

      Employees shall not demand any money or unfair trade either by violating regulations or procedures or by using a superior position in trading.

  22. Article 22 Creating a sound celebration and condolence culture with prohibition on any private use of budget.
    • Employees shall take initiative in cultivating reasonable and sound culture of celebration and condolence.
    • Employees shall not notify their job related companies of their celebration and condolence events, except for the following cases.
      • Notification to relatives
      • Notification to unspecified persons through newspapers or broadcasting
    • Employees shall not give or take any money for celebration or condolence to or from their job related companies or other employees exceeding 100,000 won.
    • Manual View

      There is no problem if their job related companies come to know the contents of notification through newspaper or broadcasting.

      The Internet homepage should not show any related posting as their job related companies can frequently visit.

      • Posting on the in-house bulletin including Nanumi can be allowed.

      Any notification done by persons, other than the person directly concerned with the celebration
      or condolence, is also deemed as a violation.

      • Any notification to job related companies by sub-ordinates, regardless of clear instruction by the superior, is deemed as a violation, even with reasonable instructions by the superior.

      If any money or others exceeding 100,000 won are given by other employees or their job related companies, the difference should be returned, except for the cases where the payment is made by an employee as a relative or by a friendly organization that allows the payment by its articles of association or organizational rules.

  23. Article 23 Consultations for any possible violation
    • Any possible violation of these codes shall be consulted with the official in charge of the ethical management if the feasibility of the violation is not clear.
    • Manual View

      All the provisions of these codes shall be interpreted by the official in charge of ethical management, and any discretionary decisions by employees cannot be justified for such possible violations.

  24. Article 24 Reporting violations
    • Anyone who is aware of violations against these codes by employees shall report to the reporting center for unethical behavior.
    • Anyone making such a report in accordance with Clause 1 should point out the nature of the violation along with personal information including the reporter and the violator.
    • Koscom should guarantee the confidentiality and identification of the reporter and should not give any discrimination or disadvantage to the reporter for reporting.
    • Manual View

      All the provisions in these codes shall be interpreted by the official in charge of ethical management and any discretionary decisions by employees shall be prohibited.

      • Considerations should be applied until employees have confidence through the company’s questions and answers for ethical practices defined in Article 6, and the confirmation should be done through consultations in any case of doubt.

      All executives and employees have obligations in ethical management and thus they should make reports to the report center for unethical behavior if they are aware of any unethical behavior

      • Especially, any employee related to ethical management, including the official in charge of ethical management, should report any unethical behavior or violations against these codes in the process of their job performance, and any failure of such reporting is subject to discipline in accordance with guidelines for ethical management, provided that the report should be given under the employee’s real name and any anonymous reporting might not be accepted as damage to employees from a report with false charges.
  25. Article 25 Rewards and disciplines
    • The President shall take necessary actions, including rewards and disciplines, in accordance with Koscom’s regulations to a reporter of unethical behavior or to anyone who committed unethical behavior in relation with the codes.
    • Manual View

      Any unclear case of prohibited money or items and any amount to be returned shall be consulted with the person in charge of the ethical management in any case.

  26. Article 26 Handling prohibited money and items, etc.
    • Employees who received any money and others in violation to these codes shall immediately return the excessive amount or the prohibited items to the provider. The employee might request the person in charge of ethical management to pay the returning expenses under the attachment of evidence details in this case.
    • If there is any concern about the loss, decomposition or deterioration of items to be returned in accordance with provisions in Clause 1, or any difficulties in returning them to the provider including inability to identify the address of the provider, the employee shall immediately report to the official in charge of ethical management.
    • The official in charge of ethical management who received the report in accordance with provisions in Clause 1 shall arrange donation to social welfare facilities or public organization or other appropriate methods in handling the money or items.
    • The official in charge of ethical management shall notify the reporter of the fact while recording and managing the provider and receiver, the provided money or items and handling contents, etc. for the money or items processed in accordance with provisions in Clause 3, except for the case the identification of the address of the provider cannot be traced.
    • Manual View

      Any unclear case of prohibited money or items or the amount to be returned shall be consulted with the official in charge of ethical management.

    • These codes shall be enacted from 1 January 2009.
    • Manual View

      Any violation committed before the date of enactment shall not be raised as any special problem, but any case of continuous effect even after the date of enactment shall be reported or dissolved voluntarily as soon as possible.