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Ethical Management

1. Definitions

A. An ethical problem between the company and employees

An ethical problem between the company and employees refers to a negative effect to company's functions caused by an employee's personal business.

B. Money

Money define cash, marketable securities, vouchers and other articles that prossess economic values.

C. Gift

Gift refers to provided without recompense the goods or accommodations, invitation ticket, ticket, promotional materials, and other items.

D. Treats or Entertain

Treats define entertainment provided by the means of incitations to meals, alcohol-consumption, sport events and other leisure activities.

E. Convenience

Convenience refers to the provision of the means of transportation, accommodation and sponsorship not included under the articles that define Gifts and Treats.

F. Reporter

A reporter is the employee with the responsibility to report when faced with situations that involve gifts, treats and convenience defined in the guidelines.

G. Interested Party

An interested Party defines to an internal/external individual or organization whose rights/profits may be affected by decisions or behaviors of employees in terms of job functions.

H. Generally Acceptable

Generally acceptanle refers to the giver's intention in gifts, treats and convenience originate from ordinary and voluntary gratitude.

I. Unavoidable circumstances

"Unavoidable circumstances" refer to being obliged to receive a gift, treat or object of convenience as rejection may be considered impolite, or to receive the article through a third party without awareness.

J. Proper price

A "proper price" is the price normally accepted in the retail market.

2. Applicability

A. The guidelines apply all full-and part-time employees, advisors and agents, etc.
B. And other guidelines defined by our company obtain priority to these guidelines.
C. These guidelines take precedence over other regulations in the company.

3. Application into Job Functions

A. Obligation to comply with laws and regulations

1) Employees must comply with domestic and overseas laws and regulations, respect commercial practices, and compete in a fair and transparent manner.

2) Employees must comply with company manual, procedures, insturction, etc. (hereinafter referred to as "company laws and regulations").

B. Practice guidelines for money, valuables and entertainment

1) The ground rule

a) Receiving money, valuables, treat, entertainment and convenience offer from interested parties will affect normal decision-making and should be refused politely
b) When employees inevitably receive money, valuables, entertainment, or economic convenience from interested parties in relation to their work and voluntarily report and post-process them in accordance with the procedures set forth in the following paragraphs, Even if it is lost, it will not be punished for the report. However, if the act is a prohibited act, reporting and post-processing alone will not prevent the punishment.
c) All employees will notify the company in accordance with this guideline if they acknowledge that their colleagues have received money, entertainment, etc. and that the receiving party has not done the reporting and post-processing according to this regulation

2) Receiving the money and gift

a) Prohibited practice

(1) Money received: cash, check, voucher, ticket, goods
(2) Movables, property transfers / joint investments: movable, real estate, goodwill, membership, property shares
(3) Debt repayment: credit card price, foreign currency loan
(4) Borrow money : borrow money
(5) Buying cheap: taking real profit by purchasing movable or real estate at a price lower than normal.
(6) Indiscriminate notice of congratulations and condolences
- If you request or commend yourself or your colleagues or your subordinates, indiscriminate notification by telephone or fax.

b) Subject to report

If you receive more than USD 100 per item (150,000 KRW), you must return it after the declaration according to the following notification procedure However, for the receipt of money of less than USD 100 (or 150,000 KRW), the notification procedure may be omitted and returned.

c) Exception article of money and valuables

The following items within the general scope accepted under social customs are not regarded as bribery.

(1) In accordance with traditional Custom such as Souvenirs, congratulatory gifts, gifts that are recognized by the purity and spontaneity of the provider
(2) Publicly provided gifts to assist employees in difficult situations such as illness or disaster
(3) Promotion, commissioning and recruiting from external interested parties

d) Reporting procedure

Money and valuables received inevitably is processed as follows.

(1) The usual procedure
(a) The reporter can report the receipt of money or gifts by telephone or e-mail to the ethics management team. In addition, the ethics management team execute processing for the notification of receipt of money by telephone or e-mail
(b) Enclosed is a copy of the deposit sheet, return of goods and a copy of the donation certificate If the notifier has returned it directly to the sender.
(c) If you can not find a suitable donor or if you are unable to make a decision, ask the ethics management team or ask for treatment.

(2) When it is possible to return
Cash, checks, vouchers, etc. must be returned to the sender.

(3) When it is impossible to return
(1) If it can not be returned due to the risk of corruption, alteration or breakage, or volume, weight, etc., it should donate to social welfare facilities / organizations in the name of the company of the sender.
(2) If corruption has already progressed and donation is not possible, immediately dispose of it and report it.
(3) If the personal information of the sender is not known, it should be donated to the social welfare facility / organization in the name of the company.
(4) High-priced products not suitable for donating to external organizations are requested to be processed by the ethics management team and processed by the CEO.

3) No treat and entertainment

a) Prohibited practice

In any case, you should not receive treat or entertainment from interested parties. In particular, it should not imply nor require interested parties to be entertained.

b) Subject to report

This is applicable to cases in which meal, alcohol, entertainment etc. are received from interested parties in relation to work.

c) Reporting procedure

If you will receive inevitable treat or entertainment, please proceed as follows.
(1) The party who received the offer of entertainment and entertainment should report it to the next higher than the team leader, and the person who has reported should judge whether it is inevitable and direct the attendance.
(2) Attendees must avoid or penalize when the level of treat and entertainment exceeds USD 100 (or $ 150) or is deemed to be altered by treat or entertainment of prohibited items.
(3) When the complaint falls under the notification, the reporter sends a letter to the sender requesting cooperating with the fair cultural organization and reports to the ethics management team after receiving the approval of the next higher level team leader.
(4) The preparation of the preliminary report and the follow-up report is based on the highest ranking of the participants.

4) Convenience offer

a) Target action

(1) Business trip support: if you visit a business company of your interested parties or accompany you to a business trip, your opponent can provide rail, air, bus or accommodation.
(2) Vacation support: rail, air, bus, passenger vehicle or accommodation for personal vacation
(3) Future guarantees: guarantees for employment, placement of employment, prohibition of contracts
(4) Guarantee : guarantee for bank loans
(5) Real estate / property borrowing: renting assets or receiving collateral

b) Subject to report

If you are provided with economic convenience and have not paid the due consideration

c) Reporting procedure

If you are unable to pay a reasonable fee even if you are provided with transportation or accommodation facilities, please remit the money to the sender and send a copy of the deposit sheet attached to the promoted fair culture letter, and report it to the ethics management team after receiving payment to the next highest ranking team leader.

C. Other Ethical Problems

1) The illegal disclosure of company’s confidential information is not permitted

a) Employees shall not disclose customers’ personal information internally/externally without prior approval.
b) Employees will not disclose confidential information about the company, they will be prosecuted to the full extent of civil or criminal law

2) Protection of company assets and prohibition of misuse

a) Employees should do their best to safely protect company assets from any possible damage.
b) Employees shall not use company assets (corporate money, knowledge, information, copyrights, office facilities and other commodities) or working hours for personal use.

3) Infringement on other person’s property rights is not permitted

a) Employees shall not use copies of illegal software for official business.
b) Employees should not infringe a third party’s intellectual property rights (i.e.copyright, information on the internet, etc.).

4) Illegal actions that take advantage of an employee’s position at the company are not permitted

a) Employees shall not be engaged in unfair trade with any interested parties(other employees, customers, partners, etc.) by taking advantage of their superior position.
b) Employees shall not abuse their authority for personal profits.
c) Employees shall not request any future employment assistance, nor receive any offer of this nature.

5) Stock acquisition or employment by the company directly related to an employee’s job functions are not permitted

a) Employees should not acquire shares of the company directly related to their job functions.
b) Employees shall not be hired as an employee, executive, advisor or consultant of the company owned by the interested party.

6) Business with a company owned by G-Marine Service employee is not permitted

a) Business with a company owned by G-Marine Service employee is not permitted.
b) However, if the employee’s products or service has a patent that must be inevitably purchased by the company, the transaction is permitted after receiving a prior approval from the internal person in charge of ethical affairs.

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