A global logistics company that provides bulk ship-oriented maritime transportation and trade services.

ESG
Management

Ethics Standard

A Code of Ethics

This is to inform you about the ethics of Korean merchant ships.

I. Preamble

  • 1. Purpose
    • A) The purpose of this Code of Ethics is to provide standards for correct behavior and value judgment that all employees of SM Group must observe in the business field.
    • B) By enacting the Code of Ethics and inducing its practice, the Company establishes a clean and sound corporate culture and grows and develops with clients, employees, business partners, shareholders, and competitors, as well as local companies, to become a trusted and respected global company.
  • 2. Scope of Application
    • These standards shall be applied to all employees of the SM Group and must be observed regardless of position.

II. Scale of Action

  • Chapter 1 Client-Oriented Management
    • Recognize that the basis for business existence is the client, always respect the client's opinion, and earn the clients' trust by constantly providing the value the client needs.
      • 1. Respect for Clients
        • A) Always listen to the client's opinion, consider the client's true needs right, and reflect them as the top priority in all decisions and actions.
        • B) Conduct all transactions fairly in a mutually equal relationship, promote clients' interests by continuously creating true value that can practically satisfy clients, and provide that value on time.
      • 2. Client Protection
        • A) Protect client interests and safety by preventing client information from being leaked.
      • 3. Client Satisfaction
        • A) Put top priority on client satisfaction by providing clients with the highest quality products and services at reasonable prices.
        • B) Earn the client's trust by telling only the truth and fulfilling the promise to the client.
  • Chapter 2 Management for Shareholder Satisfaction
    • 1. Efficient Management
      • A) Maximize shareholders' sound interests by securing management's soundness through efficient and rational management.
      • B) Strive for management innovation to enhance corporate value and maintain a sound financial structure.
    • 2. Transparent Management
      • A) Establish a relationship of mutual trust with shareholders and investors by respecting the legitimate demands of shareholders and investors by securing a transparent management system.
      • B) Accurately record accounting information in accordance with legal accounting standards (K-IFRS) and provide it in a timely manner in accordance with relevant laws to help shareholders and investors make rational investment decisions.
    • 3. Shareholder Rights Protection
      • A) Ensure shareholders' legitimate exercise of rights whenever possible.
      • B) Respect the legitimate demands and suggestions of shareholders and actively reflect them in management.
  • Chapter 3 Co-Prosperity with Partners
    • 1. Equal Opportunity
      • A) Allow fair trade opportunities to all eligible companies based on the principle of free competition.
      • B) Select business partners legally based on objective and fair evaluation criteria.
    • 2. Fair Trade
      • A) Do not force or exert influence on unfair acts by using the company's superior position.
      • B) If business partners hamper the practice of Ethical Management by providing unfair benefits to employees, they may face disadvantages in transactions.
    • 3. Pursuit of Mutual Development
      • A) Make mutual efforts to create a fair and transparent trading climate with business partners based on trust and cooperation.
      • B) Support business partners' promotion of Ethical Management and pursue common development.
    • 4. Relations with Competitors
      • A) Respect the market competition order at home and abroad based on the principle of free competition.
      • B) Respect competitors and compete freely and fairly with legitimate methods and skills.
  • Chapter 4 Social Responsibility Management
    • Contribute to national economic and social development as a social enterprise that respects social and market order and complies with all laws and regulations related to business activities.
      • 1. Compliance with Laws and Regulations
        • A) As a member of the country and local community, observe social values, domestic and international laws, and internationally accepted trading customs for fair business conduct at home and abroad.
        • B) Maintain sound market order through good faith competition based on technology and quality.
      • 2. Contribution to Social Development
        • A) As a member of society, faithfully fulfill the corporate social role and responsibility through job creation, faithful tax payment, and welfare projects, and contribute to the development of society and the national economy.
      • 3. Environmental Protection
        • A) Protect nature, strive to preserve a clean environment, and comply with all laws and regulations related to environmental protection.
        • B) Prioritize preserving a clean ecological environment, minimize environmental pollutant emissions, and efficiently use resources and energy.
        • C) Systematically promote environmental protection through eco-friendly management and strive to develop eco-friendly products and services.
  • Chapter 5 Management with Respect for Employees
    • Create a foundation for all employees to be respected as independent individuals and grow into corporate citizens with creative and upright ethics.
      • 1. Respect for Employees
        • A) The Company shall recognize and respect the dignity and value of its employees.
        • B) The Company shall strive to create a workplace atmosphere where employees can take pride in their work performance based on a sense of ownership.
        • C) The Company shall establish a system so employees can legitimately perform their duties and take necessary measures to adjust the environment so that individual capabilities can be maximized.
      • 2. Fair Treatment
        • A) The Company shall provide employees with fair opportunities to improve their abilities and ensure job opportunities based on their qualifications and abilities.
        • B) The Company shall apply fair standards and fairly compensates employees based on their abilities and achievements.
        • C) The Company shall not unfairly discriminate against its employees on the grounds of gender, education, region of origin, age, and other reasons.
      • 3. Talent Development
        • A) The Company shall respect each employee's creativity and autonomy and support talent development and self-realization.
        • B) The Company shall prepare the necessary systems for employee performance and competency development and create an environment where they can practice.
        • C) Seniors shall give all necessary advice and guidance in consideration of the aptitude and talent of juniors from the perspective of talent development.
      • 4. Safe Work Environment
        • A) The Company shall provide its best to work in a clean and safe working environment in consideration of the health and safety of its employees.
        • B) The Company shall regularly conduct safety training for employees and perform safety inspections of facilities to ensure the safety of employees.
  • Chapter 6 Basic Ethics for Employees
    • Employees shall establish the right values as a member of the SM Group with the conviction of honesty and sincerity and fulfill the given mission through ongoing self-development and job performance.
      • 1. Basic Ethics
        • A) Employees shall maintain honor and dignity with pride and integrity and maintain an honest work attitude.
        • B) Employees shall be committed to self-development through constant effort and innovation.
        • C) Employees shall establish a relationship of mutual trust through smooth communication among superiors, juniors, and colleagues and take the lead in adjusting cooperative labor-management culture.
      • 2. Fulfillment of Missions
        • A) Employees shall share the SM Group spirit and management philosophy and faithfully carry out their duties in accordance with social laws and the Company's policies.
        • B) Employees shall clearly recognize the authority and responsibility given to them, make decisions and act in line with the Company's goals within the scope of authority.
        • C) Employees shall maximize work effectiveness through active cooperation and smooth communication between colleagues and related departments.
      • 3. Fair Performance of Duties
        • A) Employees shall perform all duties fairly, transparently, and rationally when handling unspecified or unclear tasks and avoid committing immoral or unethical acts that damage the honor and dignity of the company and individuals.
        • B) Seniors shall not give junior employees work instructions that do not conform to the laws and company regulations. Employees who receive such work orders from seniors may refuse to perform. They shall not be penalized even if they inform the company of such work.
        • C) Employees shall not take any financial gains (including borrowing and guarantees) that may undermine job fairness from business partners and stakeholders.
        • D) Employees shall not provide or receive gifts, entertainment, and recreation that exceed normal business levels.
      • 4. Gifts and Monetary Transactions between Employees
        • Giving gifts and financial transactions between employees are prohibited as they may cause a sense of incongruity, unfair treatment of personnel, and financial accidents.
        • A) Gifts between employees, as exemplified in the following subparagraphs, are prohibited except within the scope recognized by social norms.
          • (1) Giving holiday gifts
          • (2) Providing gifts and entertainment between departments
          • (3) Promoting and displaying ceremonies among employees related to promotion and transfer (wreaths, congratulations, etc.)
        • B) Celebrations, condolences, gifts, etc., between employees, should be made within the normal level.
        • C) Monetary transactions such as loans and guarantees between employees are prohibited.
      • 5. Prevention of Sexual Harassment in the Workplace
        • Recognize that sexual harassment in the workplace is an illegal act that hinders the victim's work motivation and productivity loss. Do not engage in the following A) and other acts judged as sexual harassment.
        • A) Prohibition of all acts related to sexual harassment, such as obscenity, access to pornographic sites, unnecessary physical access, and serving alcohol
        • B) The Company shall conduct sexual harassment prevention training in the workplace at least once a year and guide its employees in practice.
      • 6. Protection of Company Assets
        • Be responsible for protecting company assets.
        • A) Employees shall use the tangible and intangible assets of the company only for purposes approved by the company and shall not use company assets for personal gain.
        • B) The Company's assets comprehensively include the intellectual property rights developed by employees while working, the business performance process, and the field of the results thereof.
        • C) Employees shall provide the required degree of security, such as company secrets, only to authorized and legitimate authorized persons and never leak it to the outside.
      • 7. Prohibition of use of illegal software
        • Do not steal or abuse others' intellectual property rights, etc., to perform company business to have a legal and moral influence on the company.
        • A) All in-house software must be purchased and used only genuinely, and software in use illegally must be deleted.
        • B) The Company shall regularly check whether illegal software is used.
      • 8. Information Utilization and Security Maintenance
        • All in-house information obtained by investing company resources must be used only for legitimate business purposes.
        • A) Employees shall not leak information obtained in connection with the performance of their duties without permission or use it to seek economic benefits for themselves, their families, or third parties.
        • B) Employees shall not disclose or use confidential information obtained during work, even after leaving the company.
      • 9. Avoidance of Conflicts between Company and Individuals
        • All employees of SM Group shall avoid all conflicting transactions between the company and individuals in performing their duties. In the event of a conflict of interest, they must prioritize the company's interests and protect their reputation.
        • A) Prohibition of Use of Non-public Information
          Employees shall not receive any interest or profit through any securities or other transactions, including stock transactions, using non-public information of the company, clients, or business partners obtained during the company's service period.
        • B) Prohibition of Concurrent Office and Investment
          Employees may not maintain personal business relationships (appointment, consulting, investment, etc.) with business partners and competitors that may interfere with independent judgment and smooth performance of duties concerning their duties.
        • C) Prohibition of Transactions with Interested Parties
          In performing the company's duties, employees may not enter into contracts with interested parties, including themselves, for delivery or service provision without prior approval from the company.
      • 10. Other Matters
        • A) Employees shall not form a private group composed of academic, regional, or blood ties.
        • B) Employees shall protect the company's honor with neat attire, polite behavior, and dignified language as they represent the company.
        • C) Employees shall not smoke outside of designated smoking areas in the workplace.
  • Chapter 7 Compliance with Code of Ethics
    • All employees of the SM Group shall comply with the Code of Ethics, and executives and managers are responsible for managing their employees to abide by the Code of Ethics.
      • 1. All employees shall faithfully abide by the Code of Ethics, and in case of violation, they are liable for disciplinary action, including dismissal.
      • 2. When Code of Ethics violations occur, recurrence must be prevented through thorough cause investigation.
      • 3. If an employee is coerced into or aware of an act that violates the Code of Ethics, the employee should report it to the Code of Ethics manager or the Group Audit Office and take action after consulting with seniors or executives in advance on suspicious acts.
      • 4. Types of Reports
        • A) Embezzlement of public funds and acceptance of bribery by employees
        • B) Unfair business handling by employees
        • C) Demands for money and entertainment
        • D) Unfair equity participation in unlisted trading companies
        • E) Dual employment of employees
        • F) Other ethical violations
  • Chapter 8 Additional Provisions
    • 1. Enforcement Date
      • A) This Code of Ethics is effective as of January 1, 2017.