Fair Trade Compliance Organization Structure
We will pursue fair management by presenting clear action standards for fair trade.
SK AX has established its own Compliance Program (CP) for adhering to fair trade practices, which includes self-regulation, operation, education, and supervision. This serves as a clear action standard for fair trade, preventing unconscious violations of regulations by employees and fostering transparent management.
Fair Trade Compliance Implementation Organization
At SK AX, a Compliance Officer appointed through a board of directors' resolution oversees CP operations. The Compliance Officer regularly reports risk assessments, CP performance, and future plans to the CEO, and reports CP performance and plans to the board of directors semi-annually, continually incorporating feedback to improve CP operations. At SK AX, the Legal Department serves as the Compliance Secretariat, carrying out CP operations in cooperation with relevant departments. In addition, departments involved in risk management, centered around the CEO, have established a Compliance Committee, which also serves as a pre-operation consultative body, regularly discussing and determining matters necessary for CP operations. SK AX appoints a Compliance Agent for each division to monitor risks specific to that division, and selects instructors composed of experts from each compliance department as CP Experts to provide employees with tailored compliance education.
Roles and Authority of the Compliance Officer
| Compliance Officer’s Roles | Compliance Officer’s Authority and Duties |
|---|---|
1. Oversee and plan the overall operation of the Compliance Program, including setting strategies and goals. 2. Conducting risk assessments to identify and manage risks of violations of fair trade-related laws and the company's essential regulations. 3. Report on activities and issues related to the Compliance Program to the Board of Directors and the CEO. 4. Analyzing violations of fair trade-related laws and the company's essential regulations, and devising improvement, corrective, and preventive measures. 5. Determining the level of sanctions for violators of fair trade-related laws and the company's essential regulations, and requesting deliberation by the Personnel Committee. 6. Provide regular compliance training for employees and manage training records. 7. Monitor compliance status, address shortcomings, and implement improvements. 8. Conducting prior consultations to ensure compliance with fair trade-related laws and the company's essential regulations. 9. Develop detailed action plans to encourage employees' adherence to compliance standards. 10. Evaluate the effectiveness of the Compliance Program and reflect this in the following year's operational plan. 11. Provide support and advice to the Board of Directors, management, and operational teams. 12. Maintaining records of CP-related activities and results 13. Carry out any additional tasks deemed necessary by the Board of Directors or the CEO. (As per Article 4.2.3 of the CP Operating Guidelines) | < Compliance Officer's Authority > 1. The right to inspect and investigate compliance status. 2. The authority to request the submission of necessary data and information for the performance of duties. 3. The authority to investigate and report on violators and violations of fair trade-related laws and the company's essential regulations. 4. The authority to correct and improve matters that violate fair trade-related laws and the company's essential regulations. 5. Any other authority deemed necessary by the Board of Directors. < Compliance Officer's Duties > 1. The duty to exercise care as a responsible manager. 2. The duty to operate the Compliance Program efficiently. (As per Article 4.2.2 of the CP Operating Guidelines) |
Performance by Compliance Program (CP) Implementation Requirement
Since implementing the Compliance Program (CP) in 2009, SK AX has actively worked to internalize relevant laws and procedures and to foster a culture of voluntary compliance. To this end, we have undertaken various initiatives, including sending CEO/Compliance Officer letters, providing compliance training, and conducting compliance activity audits.
| Implementation Requirements | Performance |
|---|---|
Establishment and Implementation of CP Standards and Procedures Establish and implement the necessary standards and procedures within the company, ensuring that they are communicated to all employees through documentation. |
|
Commitment and Support from Top Management Top management publicly expresses a commitment to compliance and actively supports the operation of the Compliance Program (CP). |
|
Appointment of Compliance Officers Responsible for CP Operation The Board of Directors appoints Compliance Officers, and this appointment is communicated to all employees. |
|
Creation and Distribution of Compliance Manuals Compliance manuals are provided to employees and made accessible to all staff. |
|
Continuous and Systematic Compliance Training Regular training is conducted for all employees, including top management. |
|
Establishment of an Internal Monitoring System Monitoring and audit results are periodically reported to the Board of Directors. |
|
Sanctions for Employees Who Violate Fair Trade Laws The company operates internal regulations that impose sanctions proportional to the severity of violations, and also implements measures to prevent recurrence. |
|
Compliance Reporting/Consultation Channel Information
SK AX operates a Compliance reporting/consultation channel for stakeholders, which can be used not only by employees but also by anyone who becomes aware of illegal activities, including business partners and customers.
Subjects of Reporting/Consultation
- You may report or consult on matters under the jurisdiction of the Fair Trade Commission, such as fair trade and subcontracting laws, as well as Compliance-related issues in general.
Online Reporting Method
- Email: skax.compliance@sk.com (Contact: Compliance Officer)
Reports and consultations may be submitted anonymously, and the principle of conducting a 100% investigation is upheld for all reports received.
Whistleblower Protection
SK AX has formally established the following provisions through its Code of Ethics, CP Operating Regulations, and the whistleblower protection clauses on its online reporting site:
- Protection of the whistleblower's identity
- Prohibition of any disadvantageous treatment or retaliation resulting from a report
- Guarantee of confidentiality regarding the content of the report and the whistleblower's anonymity
Notes
Providing specific details such as the date, time, location, related parties, and supporting evidence is of great help to the investigation in verifying the facts accurately. However, individuals who intentionally report false information or use the channel for improper purposes may be excluded from protection.
Request for voluntary compliance with fair trade
Dear members of SK AX!
I would like to express my deepest gratitude to all of you who are doing your best in your respective positions for the development of the company in the midst of a rapidly changing domestic and international environments.
Compliance' is a principle that we must follow as naturally as we breathe while conducting our business. This means more than simply pursuing profit; it reflects the values that SK AX pursues and our responsibility for the future. Compliance with processes and laws plays an important role in helping us grow into a trusted company and achieve sustainable development together.
First, 'Compliance' is a basic value that we should all uphold
together. This goes beyond complying with our legal obligations and is the basis for trust in our customers and partners.
Second, 'Compliance' strengthens SK AX's competitiveness in the
long run. We can earn the trust of more customers and partners by maintaining transparent and fair trading practices.
Third, 'Compliance' is the way to fulfill our social
responsibilities. We must become a company that grows together with society, not a company that simply pursues profit.
Dear Members!
'Compliance' is not a grandiose slogan. 'Compliance' begins with
respecting each other, working honestly, and maintaining
transparency in our dealings.
It cannot be overemphasized that fair and transparent corporate
management is essential to becoming the best IT service company in
Korea, so I would like to ask once again for your greater interest
in and active practice of compliance.
Thank you.
Pledge of Commitment to Fair Trade Compliance
I solemnly pledge that, in performing my duties, I will thoroughly comply with all applicable laws and company regulations, and, deeply recognizing that the management of legal risk is central to the company's sustainable growth and survival, I will practice the following principles.
1. Thorough Compliance with All Applicable Laws and Internal Regulations
- I will thoroughly comply with all domestic and international laws and guidelines related to IT business, including not only the Fair Trade Act but also information security, personal data protection, and intellectual property rights.
- I will keep in mind that no illegal or improper act can ever be justified for the sake of achieving business objectives, and I will exercise the utmost care in complying with regulations.
2. Establishing Fair Competition and Fostering a Culture of Win-Win Subcontracting
- I will not participate in any unfair collusive practices that undermine fair market competition, such as bid rigging, price fixing, or volume adjustment, and I will exercise particular caution when in contact with competitors.
- In transactions with business partners, I will reject unfair trade practices such as delayed payment of subcontracting fees, unjust order cancellations, and misappropriation of technology, and I will strive to achieve mutual growth under transparent conditions.
3. Making Proactive Legal Risk Management a Habit
- I will recognize that identifying, in advance, the legal risks that may arise in the course of daily work and the pursuit of new businesses (services) is one of my core responsibilities.
- When major decisions or legal judgments are required, I will not make arbitrary determinations, but will always consult with the department in charge of Compliance in advance to fundamentally block risk at its source.
4. Participating in the Compliance Program and Immediately Reporting Non-Compliance
- I will actively participate in the company's Compliance Program (CP), faithfully completing related training and compliance activities.
- If I become aware of a fact (or suspected case) of non-compliance with laws and regulations, whether by myself or others, I will not turn a blind eye to it, but will take the lead in reporting it immediately through the company's designated channel so that the issue can be resolved early.
I hereby pledge to faithfully abide by the above commitments and to do my utmost to realize the company's Compliance management policy through the fair and transparent performance of my duties.