1. Compliance with business regulations

All corporate and business affairs shall be carried out based on relevant regulations and procedures, and the full period of preservation of decision-related materials shall be observed. Such materials shall not be lost, damaged, or hidden. Also, regulations on decisions made under the direction of the executive and senior management and other document management regulations shall be observed.

2. Conclusion of contracts

Business negotiations and contract signing shall be conducted within the authorized rights, and all contracts (including electronic contracts) shall be drawn up in accordance with the Company’s in-house regulations and procedures and relevant laws. Furthermore, all contracts shall include all the content agreed to by the parties thereto, and each contract shall be recorded and stored according to the prescribed method.

3. Ethical management/Anti-corruption

When engaging in a transaction with a subcontractor, SKC shall carry it out in good faith, both legally and ethically; shall thoroughly observe relevant laws and corporate regulations; and shall conduct itself ethically and with integrity. SKC’s employees shall not offer or receive any bribes or kickbacks in relation to SKC’s corporate and business affairs and shall observe the UN Convention against Corruption and anti-corruption laws of each country. The usual level of gifts and entertainment may be accepted in maintaining business relationships with SKC partners, but SKC employees shall comply with generally accepted business customs and practices. Gifts or entertainment that go beyond the usual level, and which may have an influence on business decisions, shall be considered a bribe and thus shall neither be offered nor accepted. The term “gifts and entertainment” provided in the foregoing paragraph covers valuable or pecuniary interests and non-pecuniary interests.

4. Fair trade

Employees shall observe sound principles of fair market competition and shall not engage in any unfair joint collusion in bidding in an attempt to readjust price or production quantity. Prices shall be fixed independently based on a rigorous cost analysis and overall market conditions. Prices shall be derived from documents based on openly disclosed materials, and the validity of the sources shall be verifiable.

5. Subcontractors

SKC’s subcontractors shall have the right to make independent decisions on the purchase or sale of goods, prices, and counterparties to transactions. Any attempt to block such an independent decision may constitute a violation of the Monopoly Regulation and Fair Trade Act. Employees shall refrain from using anti-competitive practices or committing deceptive or fraudulent acts; shall never fail to engage in transactions aimed at the mutual benefit of the Company and its subcontractors; and shall ensure transparency in the conduct of all transactions. Opportunities to enter into transactions shall be equitably provided to all relevant parties; and all transactions shall be handled fairly and equally according to the principle of mutual respect.

6. Win-win cooperation

SKC employees shall respect the personnel of SKC’s subcontractors and work with them based on the principle of win-win cooperation and shall strive to jointly strengthen the competitiveness of the Company and its partners through the provision of technological and management support. Employees shall provide subcontractors with fair opportunities to enter into transactions and shall not engage in any unfair acts, such as using the Company’s advantageous/bargaining power over them, and shall strive to secure mutual benefits and joint development. Employees shall strive to minimize risks to the Company and its partners by conducting risk evaluations based on ESG management indicators according to international guidelines.

7. Environment

Employees shall strive to meet the requirements of environmental regulations and take positive steps for environmental conservation by carrying out purchasing activities in accordance with relevant laws and government policies.

8. Procurement of eco-friendly products and services

Employees shall strive to minimize environmental impacts throughout the entire process of design, manufacture, distribution, use and disposal of products and the development and supply of eco-friendly products, materials and services. They shall also aim to expand eco-friendly technologies including reuse and recycling, promote the development and use of goods conducive to the reduction of GHG emissions, and minimize the use of toxic materials.

9. Prohibition of the use of conflict minerals

We at SKC shall not purchase any conflict minerals (produced in the Democratic Republic of the Congo and neighboring countries) unless the RBA’s* requirements regarding information on the country of origin and certification of the legal right to mining work are fully satisfied.

We at SKC view our subcontractors as partners in pursuing ESG management and have accordingly established a code of conduct to help them establish a shared growth ecosystem.
This code of conduct sets forth the conditions that our subcontractors are required to observe as partners in the practice of ESG management.
SKC’s subcontractors shall observe the code of conduct and all applicable laws and regulations and shall conduct their business in an ethical fashion.
SKC, or external organizations designated by SKC, may visit the subcontractors to check whether they are observing the code of conduct, and request them to make improvements or take remedial steps in the event that they are found to have violated the code of conduct.
In addition, SKC may halt all transactions or terminate a contract with a subcontractor in the event that the latter fails to take the required steps to remedy a serious violation within the deadline set by SKC.
Where the code of conduct is in conflict with the local laws and regulations of a country, the stricter of the two shall prevail and the code of conduct may be readjusted reasonably as required. This code of conduct may be verified at the official SKC website. Subcontractors are to be notified of any changes to the code of conduct in advance via the official SKC website and the integrated purchase website.

1. Human rights/labor

Subcontractors shall not discriminate against any employee based on gender, age, sex, nationality, region, race or ethnicity, religion or the like, and shall respect their civil liberties and treat them with dignity.
All employees including temporary, contractual, dispatched, migrant, and regular employees shall be guaranteed their basic rights and civil liberties, including the right to work under local laws and regulations. All work shall be voluntary. However, even in the cases of voluntary work, employment of minors aged 15 or younger shall be strictly prohibited.
Work hours shall not exceed the number of hours and number of days per week stipulated in the laws and regulations, except in the event of an internal emergency or special circumstances. Subcontractors shall ensure that their employees’ work hours do not exceed 52 hours per week, and employees shall be entitled to at least one day off per week.
In addition, workers’ right to freedom of association with other workers shall be respected, and their rights not to engage in such activities shall be respected as well.

2. Prohibition of conflict minerals

In cooperation with SKC, subcontractors shall not use any conflict minerals (produced in the Democratic Republic of the Congo and neighboring countries), and shall comply with the RBA’s* requirement to disclose information on the relevant country of origin and guarantee that the minerals used by them have been legally mined.
* The RBA (Responsible Business Alliance) is a non-profit organization composed of enterprises that strive to fulfill their social responsibilities to create sustainable value.

3. Environmental protection

Subcontractors shall obtain and maintain all environmental approvals and authorizations legally required to operate their business, observe all the relevant laws and regulations, and strive to minimize their environmental impact.
Subcontractors shall fully recognize their environmental responsibilities, systematically be aware of the status of all toxic substances and waste/waste water used by them, and strive to identify, manage, reduce, scrap, and/or recycle them.
Subcontractors shall reduce or minimize their air pollutant emissions, energy consumption, and GHG emissions, and observe the regulations prohibiting the incorporation of toxic substances into their products based on the establishment of an environmental management system.
Subcontractors shall manage such matters as identification marking and information labeling concerning all the substances they use in order to ensure the safe handling, transportation, storage and use of their products.

4. Ethical management/Anti-corruption

Subcontractors shall observe relevant laws and regulations and corporate regulations by recognizing the importance of ethical management for the sustainable conduct of their business and by engaging in fair transactions.
Subcontractors shall legally and ethically carry out all their transactions in such a way that their ethicality and trustworthiness remain uncompromised.
Subcontractors shall maintain the highest level of integrity and fairness in all their transactions and shall not engage in any acts of corruption, bribery, misappropriation or extortion.
And, whistleblowers who report such unethical practices shall be kept anonymous and not subject to retaliatory actions such as discrimination or harassment.
Subcontractors shall thoroughly protect all intellectual property rights, customer-related information, and personal information.

5. Health and safety

Subcontractors shall obtain all health and safety-related approvals and authorizations needed to operate their business and observe all relevant laws and regulations.
Subcontractors shall ensure their employees’ health and safety and strive to make their workplaces safe and healthy by eliminating all risk factors.
Subcontractors shall strive to minimize losses and/or damages caused by accidents by establishing procedures and measures designed to cope with each type of accident.
Subcontractors shall provide adequate personal protective equipment to all employees who are exposed to danger in their work duties and periodically check and assess the status of any risk factors.
Subcontractors shall conduct assessments of safety risk on a regular basis, hold training sessions on health and safety, and inform employees of the danger of accidents and risk factors.

6. Management system

Subcontractors shall operate a system of management related to human rights, labor and environmental protection, ethical management, and health & safety, and shall ensure that the following pledges are faithfully observed:
1) To observe relevant laws and corporate regulations voluntarily and willingly.
2) To fulfill the obligations and responsibilities of senior and executive management.
3) To deal with and monitor relevant laws and regulations and customer demands.
4) To conduct risk management (related to environment, safety/health, labor, and ethics)
5) To carry out objective management and assessments.
6) To implement procedures for remedial actions.
7) To encourage feedback from, and the participation of, employees.
8) To operate educational and training programs.