Fair Trade │ SK AX

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

SK Inc. has appointed a Compliance Officer, selected by the board of directors, to oversee the integrated CP (Compliance Program) operations of the three CICs within the company. The Compliance Officer regularly reports to the CEO on risk assessments, CP performance, and future plans, and reports to the board of directors semi-annually. Feedback is continually incorporated to improve CP operations. Each CIC's legal department acts as the Compliance Secretariat, working with relevant departments to manage CP operations. Additionally, the legal teams of the three CICs have established a Compliance Committee, which also functions as a pre-operation consultative group, regularly discussing and determining matters necessary for CP management. SK Inc. appoints Compliance agents for each division to monitor risks specific to each area. In particular, SK AX, as an operating holding company, selects CP experts from among specialists in each compliance department to provide tailored compliance education for the company.

Fair Trade Compliance Organization Structure

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. Conduct risk assessments to identify and manage risks related to violations of competition law. 3. Report on activities and issues related to the Compliance Program to the Board of Directors and the CEO. 4. Analyze violations of competition law and implement corrective and preventive measures. 5. Determine sanctions for violators of competition law and refer cases to the personnel committee for deliberation. 6. Provide regular compliance training for employees and manage training records. 7. Monitor compliance status, address shortcomings, and implement improvements. 8. Conduct pre-operational consultations to ensure adherence to competition law. 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. 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 right to investigate and report violations of competition law and related activities. 4. The authority to request corrective and preventive actions for violations of competition law. 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)

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. Conduct risk assessments to identify and manage risks related to violations of competition law.

3. Report on activities and issues related to the Compliance Program to the Board of Directors and the CEO.

4. Analyze violations of competition law and implement corrective and preventive measures.

5. Determine sanctions for violators of competition law and refer cases to the personnel committee for deliberation.

6. Provide regular compliance training for employees and manage training records.

7. Monitor compliance status, address shortcomings, and implement improvements.

8. Conduct pre-operational consultations to ensure adherence to competition law.

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. 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 right to investigate and report violations of competition law and related activities.

4. The authority to request corrective and preventive actions for violations of competition law.

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.	Initial Establishment of Fair Trade Compliance Program Operating Regulations (Mar. 2009) Initial Establishment of Fair Trade Compliance Program Operating Guidelines (Mar. 2009) Initial Establishment of Fair Trade Compliance Program Reward Guidelines (Jan. 2013)
Commitment and Support from Top Management Top management publicly expresses a commitment to compliance and actively supports the operation of the Compliance Program (CP).	Public Declaration of CEO's Commitment to Compliance (Mar. 2009) CEO's Compliance Commitment Statement on the Company Website (Ongoing) CEO Compliance Messages and Employee Pledges (Annual)
Appointment of Compliance Officers Responsible for CP Operation The Board of Directors appoints Compliance Officers, and this appointment is communicated to all employees.	Appointment of Compliance Officers through Board Resolutions
Creation and Distribution of Compliance Manuals Compliance manuals are provided to employees and made accessible to all staff.	Publication of Compliance Manuals (2009) Revisions of Compliance Manuals (2010-2023, revised biennially) Revisions of Compliance Manuals (2024 and ongoing, revised semi-annually)
Continuous and Systematic Compliance Training Regular training is conducted for all employees, including top management.	Conducting Tiered Training for Executives, Managers, and General Employees (Ongoing) Customized Training for New Hires, Lateral Entrants, PM/PL, Sales, etc. (Ongoing) Targeted Training for On-Site and High-Risk Departments (Ongoing) Operation of Various Programs, Including In-Person/Online Training, CP Letters, and Elevator Campaigns (Ongoing)
Establishment of an Internal Monitoring System Monitoring and audit results are periodically reported to the Board of Directors.	Operation of Compliance Committees Led by the Compliance Officer (Ongoing) Pre-Work Consultation Systems, Including RM Meetings, Board Meetings, and Contract Review Meetings (Ongoing) Operation of Compliance Monitoring Systems (Ongoing) Operation of Reporting/Consultation Centers for Unfair Trade Practices, Legal Violations, Ethical Misconduct, and Abuse of Power (Ongoing)
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.	Conducting Various Inspections/Audits of Sites, Systems, etc. (Ongoing) Biannual Evaluation of CP Operation Effectiveness (Semi-annually) Development and Operation of Various Systems for Legal Violation Monitoring (Ongoing)

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

In the course of performing my duties, I understand the Fair Trade Compliance Program (CP) and hereby pledge to adhere to the following fair trade practices

Compliance with Regulations

1. I will familiarize myself with laws, regulations, and internal policies related to fair trade and conduct my duties in a fair and transparent manner.

Transactions with Competitors

2. I will not engage in collusion with competitors regarding bid amounts or rankings.
3. I will not participate in meetings related to pricing or other competitive issues.

Transactions with Subcontractors

4. I will proceed with transactions in accordance with the company's standard contract procedures and the Subcontracting Act.
5. I will provide written documents prior to contract signing and ensure payment of subcontracting fees or advances within the legal deadlines.
6. I will not misuse any superior bargaining position to demand unfair compensation or requests from subcontractors.
7. I will not reduce subcontracting payments without justifiable reasons after contract terms have been finalized.
8. I will not request subcontractors to provide their technical data to myself or a third party without justifiable cause.
9. I will maintain a cooperative relationship with subcontractors and build mutually beneficial partnerships.

As an employee of SK AX, I pledge to faithfully adhere to the Fair Trade Compliance Program (CP) with pride and dedication in my daily business activities and to strive to establish a fair trade culture.