BEST CORPORATION provides total services from product planning, design development, production,
and shipment with its R&D technology from product development to finished products according to the customer’s requirements.
Anti-Corruption Ethics Action Guidelines
2022.04.18. enactmentPreamble
In order to strengthen the practice of 'ethical norms', we enact 'ethical behavior guidelines' and use them as principles of ethical decision-making and behavior for all executives and employees. All executives and employees shall thoroughly comply with this "Ethical Action Guidelines" in performing the company's business.
The purpose of this ethical behavior guideline is to prescribe matters necessary for the procedure for reporting money and valuables, entertainment, and hospitality in relation to the enforcement of ethical norms.
1. Money : It refers to cash, securities and other economic benefits.
2. Treat : It refers to entertainment such as meals, drinking, sports (golf, etc.), and entertainment.
3. Convenience : It means money and valuables, such as transportation, accommodation, tourist information, and event support, or support other than entertainment and hospitality.
4. a reporter : This refers to all executives and employees who are obligated to report in connection with the receipt of money, etc. and the recognition of such facts
5. Stakeholders : It refers to all natural persons, corporations, and other organizations inside and outside the company that are affected by the rights and interests of executives and employees related to their duties or decisions.
Criteria for performing tasks
①. Executives and employees shall not directly or indirectly offer or offer bribes or various improper contributions to all stakeholders to help maintain and develop the company's business, nor shall they ask, encourage, acquiesce or allow third parties to be involved.
1. Providing or receiving money or valuables directly or indirectly to a specific external person who may directly affect the business promoted by the company.
2. The act of purchasing goods or services of a specific person at a fairly overvalued price and receiving money and valuables
3. The act of providing or receiving money or entertainment to a specific interested party
②. If they are not sure whether they comply with these guidelines, executives and related persons must seek advice and consent from the relevant departments in accordance with the contents of Chapter 3 prior to the act.
①. Money and futures
(1) general principles
a. Money or gifts provided by subcontractors and stakeholders in relation to business shall not be received under any circumstances.
b. Receipt of money or gifts between executives and employees in a vertical or equal relationship is prohibited.
c. The act of receiving money through family relatives, acquaintances, etc. shall be regarded as the act of the reporter himself/herself.
(2) Reporting subject
Where securities and gifts, such as cash, boarding passes, gift certificates, admission tickets, etc. are inevitably received from partners and interested parties in connection with their duties, they must be reported and returned.
(3) Reporting procedure
Where money or gifts received from suppliers or stakeholders are inevitably required to be reported in writing to the superior or next superior within three working days from the date of receipt in the "Report on Receipt of Money and Gift" form, regardless of whether they are returned or not.
(4) Cash handling procedures
Where money is inevitably received from a partner company or an interested party in connection with business, it shall be reported in accordance with the "Report on Receipt of Money and Futures."
(5) Gift handling procedures
Gifts provided by subcontractors and interested parties shall not be received under any circumstances and must be politely refused. However, in unavoidable situations where the receipt of money and gifts from suppliers and stakeholders was not recognized or it is deemed impolite to refuse, it must be reported to a superior or subordinate in accordance with the prescribed procedure, and the gift must be submitted to the Compliance Management Team within 7 days for processing in accordance with regulations.
②. Related to hospitality and entertainment
(1) General principles
a. All entertainment and hospitality provided by subcontractors and interested parties shall not be received, and shall be politely refused.
b. In exceptional cases other than those subject to reporting, if it is deemed that the nature may deteriorate into entertainment or hospitality exceeding the prescribed limit, it shall be immediately prevented or avoided.
c. Acts of receiving through family, relatives, or acquaintances are considered as one's own actions
d. Inevitably, when receiving entertainment and hospitality provided by suppliers and interested parties, a report shall be made in accordance with the "report of receipt of money and gifts."
(2) Reporting subject
a. Where benefits such as meals, drinking, sports, entertainment, etc. are inevitably received from partners and stakeholders in connection with their duties, they must be reported. Provided, That this shall not apply to the following cases.
- Where an external restaurant, etc. is inevitably used for smooth business cooperation or in connection with business handling, the relevant department head shall be reported to the relevant department head in advance or afterwards.
b. Entertainment and hospitality receipts at luxury establishments such as room salons, bars, golf courses, casinos, massage parlors, etc. are prohibited.
③. Misconduct using one's duties
(1) Acceptance of convenience
a. In any case, convenience shall not be received from interested parties in connection with their duties, and shall be politely refused. Provided, That this shall not apply where facilities, meals, and transportation convenience provided to all trainees are received in connection with the participation of official educational programs.
b. If convenience is inevitably received in the performance of duties, the reporter shall immediately pay a reasonable price and report it.
c. he act of receiving money through family members, relatives, or acquaintances shall be regarded as the act of the principal.
(2) Repayment of liabilities and receipt of guarantees
a. The payment or repayment of card payments, credit payments, or loans made by interested parties in connection with their work shall be deemed to be monetary receipt.
b. These include the receipt of shares or loan guarantees in property provided by stakeholders in relation to business, movable property with stakeholders, real estate, securities, goodwill, and membership.
c. The act of receiving money through family members, relatives, or acquaintances shall be regarded as the act of the principal.
(3) a loan on property and real estate
a. Money borrowing from stakeholders related to work is regarded as money receiving. Provided, That this shall not apply to cases where money is borrowed from financial institutions recognized by the State in accordance with legitimate methods and procedures.
b. In relation to work, it is prohibited to rent assets or receive collateral from interested parties for personal convenience or profit. One line here is untranslated.
c. In connection with business, you shall not lease assets or receive collateral from stakeholders for the purpose of personal convenience or.
d. Borrowing through family members, relatives, acquaintances, etc. shall also be regarded as one's own act
④. Prohibition of Unfair Practices
(1) Prohibition of offences
a. Do not violate fair trade, such as unfair returns, reductions, delays in payment of payments, forced events, transfer of promotional costs, refusal to receive them, forced sales of promoters, or forced delivery of contracts.
b. Never register any purchases/sales that do not involve the real thing.
⑤. Prohibition of unfair business practices
a. We do not engage in false returns or arbitrary adjustments of sale prices, among other things
b. Inventory must be accurately computerized and adjusted by real inspection, and purchase processing without real inspection or inspection shall not be carried out.
⑥. Prohibition of factional formation
Employees must not form factions based on blood relations, acquaintanceship, or school ties within the workplace
Measures in case of violation and designation of responsible person
①. Where it is unclear whether an employee violates this Code in performing his/her duties, he/she shall handle it after consulting with the person in charge of ethical management.
②. The person in charge of ethical management shall take necessary measures on/offline the dedicated window so that counseling can be carried out smoothly
①. When an employee or other interested parties, such as an employee or a subcontractor, become aware of the violation of this norm, the employee shall report it to the head of the department under his/her jurisdiction or to the person in charge of ethical management. The head of the affiliated department may transfer the reported matters to the person in charge of ethical management for processing.
②. The head of the department or the person in charge of ethical management shall ensure confidentiality of the reporter and the details of the report, and ensure that the reporter is not disadvantaged by the report.
③. Notwithstanding the provisions of the preceding paragraph, a reporter who has been discriminated against or disadvantaged may request the head of the department or the ethical management manager to take protective measures and remedy disadvantages, and in such cases, the head of the department or the ethical management manager shall take appropriate measures therefor.
④. Where one's own misconduct is found by reporting by ethical management, disciplinary measures, etc. against the (voluntary) reporter may be reduced or exempted.
Penalty
①. All executives and managers are responsible for managing their employees to comply with the guidelines, and executives and employees who violate the guidelines shall be punished in accordance with the disciplinary regulations.
1. These guidelines will be enacted and implemented from April 18, 2022.