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We recognize ethical management as an important task for our company

SK AX has been continuously promoting various ethical management activities centered on an organization dedicated to ethical management. By acquiring ISO 37001(Anti-Corruption Management System) certification in 2021, it has been recognized as meeting global standards.
Ethical Management System (3C)
CODE
COMPLIANCE
CONSENSUS
Regulation
System
Consensus

Code of Ethics

SK AX's Code of Ethics has been established based on the SK Management System to create value for customers, employees, shareholders, business partners, and other various stakeholders, in the hopes of leading social and economic development and contributing to the happiness of the humankind.
  • SK AX manages employee behavioral standards according to ethical management, and executives and employees are responsible for adhering to the company's Code of Ethics.
  • The Codes of Ethics are managed by dividing them into ethics for employees, customers, society, company/ shareholders and informant protection.
  • If the situation in question is not specified under the Code of Ethics, executives and employees must make judgments based on the decision-making principle of "legality, transparency, and rationality." When in doubt of their decision, they must seek advice from the organization's leader or department in charge of ethical management.
Ethical Management Standards
Division
Employees
Customers
Society
Sharehold-ers
Informant protection
Ethical Regulation Practice Criteria
  • Mutual respect among employees
  • Prohibition of bribery and monetary
  • Leader's role
  • Efforts to secure customers' trust
  • Protection of customer information
  • Law observance
  • Eliminating the bribery of stakeholders
  • Fair trading with business partners
  • Fair trading with competitors
  • Prioritizing the company's interest when there is a conflict of interest
  • Protection of the company's assets and information
  • Prohibition of money laundering
  • Reporting and business management
  • Operation of the internal report
    (whistleblowing) system
  • Protection of the reporter's identity and prohibition of disadvantageous treatment
Description
  • Prohibition of human right abuse and discrimination
  • Prohibition of sexual harassment
  • Efforts for safety/health
  • Guide regarding valuables and gifts
  • Examples set by leaders, etc.
  • Efforts to build customer trust and mutual development
  • Prohibition of bribery and hospitality
  • Protection of personal information of customers, business partners, employees
  • Compliance with the Fair Trade Act, Improper Solicitation and Graft Act, Subcontract Act, etc.
  • Prohibition of provision of illegal political funds(Direct or indirect political contributions)
  • Prohibition on Receiving Money, Entertainment, Hospitality, Conveniences, or Benefits from Stakeholders
  • Efforts for environmental preservation and compliance with relevant laws
  • Prohibition of unfair acts against business partners, etc.
  • Prohibition of unapproved sideline/concurrent jobs or trading with companies run by relatives
  • Prohibition of insider trading
  • Private use of company's assets and prohibition of leakage of internal information/technologies
  • Prohibition of false/delayed reports, etc.
  • Prohibition of discrimination in response to reporting
  • Protection of testifiers
  • Protection of reporters and prevention of recurrence
  • Exemption system for voluntary reports, etc.
Major Violation Cases (DON'TS)
SK AX collects cases of ethical management violations that may occur during management activities and shares them so that employees can use them as guidelines for ethical behavior when performing their duties
Area
Unethical
Security
Subcontracting
Tax affairs, fair trade
Reporting and management
Details
4 areas : Basic courtesy, Money, Treatment and hospitality, Conflict of interest, and protection of company assets and information
3 areas : PC security, Management of information and documents, and project security
4 areas : Determination and adjustment of subcontract prices, Payment of subcontract prices, Unissued documents, Unfair trade practices(provision of bribery through charitable donations, etc)
4 areas : Issue trading, Unfair internal trading, Unfair joint action(antitrust/anti-competition), Unfair trade practices(provision of bribery through charitable donations, etc)
3 areas : Reckless business promotion, false/belated/partial reporting, negligent business management
FAQs on Ethical Management Practice for SK Leaders
A separate guide is provided in the format of FAQs about situations that may occur frequently, aiming to assist internalization and set examples for ethical management among employees.
Area
Conflicts of interest
Protection of the
company's assets
and use of budgets
Gifts, bribery
Description
  • Prohibition and approval of conflicts of interest
  • Prohibition of solicitation in purchasing and personal affairs
  • Handling of compensations in the case of a concurrent job at an investment company
  • Reporting external lectures and return of compensation
  • Criteria for determining the private use of the company's assets
  • Precautions related to the use and settlement of the company's budgets
  • Prohibition of private sponsorship, advertisement, or donation to a specific organization
  • Prohibition of handling over benefits provided by the company to others
  • Personal burden for traveling expenses
  • Simplification of formalities related to business trips
  • Prohibition and allowance of bribery
  • Handling of expensive gifts from overseas business partners
  • Standards for donating gifts among employees, etc.
Business Partner Ethical Management Practice Pledge
In line with the Business Partner Ethical Management Practice Pledge, SK Inc. requires all business partners engaged with us to adhere to the same ethical standards as our company.
Area
Safety and Health
Human Rights & Labor
Environment
Ethics
Cooperation with Investigations
Details
  • Recognition of the importance of worker safety and health
  • Provision of a safe and healthy working environment
  • Prohibition of child Labor
  • Elimination of behavior that violates workers' human rights, including verbal abuse, violence, sexual harassment, and racism
  • Development, implementation, and maintenance of environmentally responsible business practices
  • Prohibition of the provision of gifts, entertainment, hospitality, and other financial or non-financial benefits to employees of the Company and its affiliated companies
  • Prohibition of unfair behavior such as collusion with our peers and competitors
  • Prohibition of intentionally misrepresenting or omitting material information in connection with the execution of a contract
  • Prohibition of any other conduct that constitutes a criminal offence against the Company or any of its employees
  • Rejection of unethical proposals and sharing of such information
  • Response in good faith to requests for cooperation with relevant investigations

System

Exclusive Organization for Ethical Management
SK AX guarantees the authority and independence of the organization and its members through the organization in charge of ethical management. The ethical management organization operates an ethical management diagnosis, self-purification system, and reporting system to internalize ethical management. It also focuses on fostering ethical awareness of executives and employees through educational campaigns and allows subsidiaries and overseas subsidiaries to spread their own ethical management practices through management diagnosis and support systems.
In particular, since 2023, The Ethics Management Organization has been moved directly under the Board of Directors to strengthen its independence and objectivity from the business divisions.
Strengthening Ethics Expertise
SK Inc. is continuously dedicated to enhancing its ethical management standards and protecting the company and its employees from a wide range of ethical risks. As part of this commitment, we focus on strengthening the professional capabilities of all members of our dedicated ethics management organization. Each year, every member of this team is required to complete at least one training program directly related to their audit responsibilities. In 2024, these programs were tailored to audit targets and included topics such as labor management, accounting, and criminal law. In addition, we host quarterly seminars featuring both internal and external experts to ensure our team stays up to date on the latest trends, best practices, and evolving methodologies in ethical management.
Operation of the Management Self-Assessment System (Risk Assessment and Implementation Audits)
SK Inc. conducts annual audits led by its internal audit department, including regular audits, implementation audits, whistleblower investigations, and self-assessments. Regular audits are performed based on a mid-term audit plan, ensuring that all business areas and subsidiaries are audited at least once every three years. Implementation audits are conducted to verify the effectiveness of corrective actions taken. For six key functions — including HR, finance, and procurement — the company conducts annual self-assessments based on internally established standards. These are complemented by additional reviews from the Ethics Management department, in collaboration with each operational unit's own inspection activities.
Year
2024
2023
2022
Target Business
Subsidiaries 
Overseas Subsidiaries
Staff
Solution Business
Staff/Cloud Business
SI/OS Business Global and Subsidiaries
Staff
Cloud Business
Subsidiaries 
Audit Area
  • Inspection of SMC's Chungju and Jeonju plant operations
  • Review of HR, cost, and procurement at European and U.S. subsidiaries
  • Check on delegated purchasing, private contracts, and key expenses (e.g., transport, project operations)
  • Investment and performance management reviews, purchasing/cost execution reviews.
  • Project performance reviews including compliance with construction-related laws/contracts, safety management, waste management, etc.
  • Project performance and purchase history reviews for Chinese subsidiaries and SMCs.
  • Project Payment Management Status Review
  • Data center facility operation and building management inspection
  • Happiness ICT Management Team
In 2024, SK Inc. improved the supply chain and quality management capabilities of its subsidiaries through audits, and eliminated operational risks across overseas entities in areas such as HR, finance, and business management. All audit plans and results at SK Inc. are reported to the Board of Directors for review and approval. For any matters requiring improvement, implementation plans are established and follow-up reviews are conducted after a designated period to verify execution, with the results subsequently reported. In addition to audit-related reports, findings from whistleblower investigations, ethics training status, self-assessment results, and ethics survey outcomes are also reported to the Board of Directors. These reports are reviewed to ensure comprehensive monitoring of ethics management activities, primarily led by the Audit Committee.
Ethical Management Reporting/Counseling System
SK AX operates various reporting/counseling channels for stakeholders and is available not only to employees but also to partners, customers, and anyone who is aware of unethical practices. Reporting and counseling can be completed anonymously, and all reported cases are investigated. The informant protection clause within the ethical regulations stipulates the protection of the informant's identity and the prohibition of disadvantageous treatment and retaliation against reporting.
Report
Email
skax.ethics@sk.com
Online report

Consensus Formation

Culture of Ethical Management Practice
SK AX is carrying out various activities to improve the level of ethical management practice of employees.
Every year, SK provides online education to all employees(regular, contract, and part-time workers) including managements, and distributes the guides reflecting ethical management compliance and inspection results to executives.
In addition, all employees sign a pledge to practice ethical management once a year and form a consensus on the importance and practice of ethical management through periodic ethical management letters.
Ethical management surveys are conducted on employees each year to examine the level of regulatory compliance in each area of ethics, the level of operation of related systems, and the level of internalization of organizational cultures. SK also creates a culture of ethical management with activities such as ethics management surveys of partner companies.
By acquiring ISO 37001(Anti-Corruption Management System) certification in 2021, it has been recognized as meeting global standards
Implementing Ethics Training
SK Inc. provides annual online ethics training to all employees—including regular, contract, and part-time staff—based on the latest trends in ethical management. In addition, all employees are required to sign an annual ethics pledge that includes our anti-corruption policy. In 2024, the training covered key topics such as workplace harassment, poor attendance, false reporting, misuse of company funds or assets, and the offering or acceptance of money or entertainment. Irregular newsletters are also distributed to share recent real-world cases, whistleblower reporting channels, and principles for whistleblower protection.
Specialized ethics programs are also offered to newly appointed leaders, as well as separate compliance training for project managers, business managers, and sales personnel who lead operations in the field.SK Inc. is equally committed to promoting ethical practices among its business partners. All partners contracting with SK Inc. are required to submit a signed Business Partner Code of Conduct Pledge, covering areas such as safety, health, environmental responsibility, and ethical behavior, as part of every contract.
Additionally, for partners participating in our projects, we provide ethics training at the point of engagement. This training introduces SK Inc.'s ethical management system, major violation cases, and reporting channels. Business partners are also required to submit a signed pledge affirming their commitment to ethical practices.
Category
SK
Inc.*
Business Partners**
(Contractor)
Trainees (Number)
Percentage of
trainees (%)
Targeted Company (Number)
Trainees (Number)
2022
3,808
99.3%
676
7,022
2023
3,838
98.5%
653
3,145
2024
3,751
96.7%
580
5,429
*
SK Inc. Investment and Business Divisions include all full-time, contract, temporary, and part-time employees.
**
Ethical management training for suppliers has been implemented since the second half of 2021. The training cycle has been changed from semi-annual to annual since 2023.

Anti-corruption Policy

SK AX operates the "Corruption Prevention Policy" as follows to pursue the continuous happiness of its members and stakeholders and to realize social values through ESG management.
Article 1
All members of SK AX prohibit corruption-related activities.
Article 2
All members of SK AX are required to comply with corruption-related laws and our regulations/guidelines applicable to business activities.
Article 3
The company establishes an anti-corruption management system that meets global standards and continuously improves the level of anti-corruption management through its implementation and monitoring.
Article 4
The company activates the reporting system, implements protective measures for well-intentioned informants, and operates so that members can participate in anti-corruption activities without any burden.
Article 5
The company will strictly deal with members who fail to comply with anti-corruption policies in accordance with relevant regulations and disclose the results to the members.
Article 6
The company ensures the authority and independence of the organization and its members responsible for preventing corruption.
Article 7
All the management of SK AX will spare no support to ensure that the anti-corruption management system is implemented efficiently.