Article 1 (Purpose)
Wonik Materials Co., Ltd. (hereinafter referred to as the “Company”) has established this Code of Conduct to pursue ESG (Environmental, Social, and Governance) management and sustainable management.

Article 2 (Rationale)
① This code of conduct is based on global standards such as the RBA Code of Conduct, the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, the UN Convention on the Rights of the Child (UNCRC), the ILO Declaration on Fundamental Principles and Rights at Work, and the ILO Core Principles.
② If the actions recommended in this Code of Conduct conflict with the laws of the country in which we conduct business, the laws of that country will take precedence.

Article 3 (Applicability)
① This Code of Conduct applies to “Company” and all executives and staff members of “Partners” who supply goods, services, and dispatched manpower to the “Company” or enter into contracts with the “Company” for other transactions.
② “Company” and all of its “Partners” must comply with this Code of Conduct, and may recommend that its business partners(or customers) also comply with this Code of Conduct.
③ “Company” and “Partners” strive to grow into a company more respected by society and achieve mutual growth by complying with this Code of Conduct.

Article 4 (Responsibilities and Roles of Partners)
① All "Partners" of the "Company" shall consider the matters set forth in this Code of Conduct in their management decisions and business operations
② The “Company” or a third party designated by the “Company” may inspect and conduct due diligence on whether the “Partner” is complying with this Code of Conduct under Article 40 of this Code of Conduct.
③ Based on the results of the inspection and due diligence on compliance with this Code of Conduct, the “Company” may recommend improvements to the identified risks to the “Partners”, and the “Partners” will establish and implement a risk mitigation plan for the improvement recommendations.
④ This Code of Conduct does not specify all obligations of the Partners. The “Company” may supplement and revise this Code of Conduct on a regular or irregular basis for ESG management and sustainable management.

Article 5 (Integrity)
Executives and employees of the “Company” and “Partners” must maintain the highest level of integrity in all business transactions and comply with the following provisions.
① Appropriate and effective policies and procedures must be in place to maintain the highest level of integrity against bribery, corruption, extortion, and embezzlement in all areas of our business.
② There must be no identified risk, no evidence of bribery, or any unfair or improper advantage being promised, offered, approved, or accepted.
③ There must be no identified risk of conveying inaccurate information to the public, false reporting, falsification of records, misrepresentation, or evidence.

Article 6 (No Unjust Enrichment)
① “Company” and “Partners” must not promise/offer/provide, permit the provision of, or receive bribes or other compensation for the purpose of inappropriate and unfair profits. In addition, this includes any act of promising/offering/providing, authorizing the provision of, or receiving certain value, either directly or indirectly through a third party for the purpose of obtaining/maintaining business opportunities, providing business opportunities to others, or for other improper gains.
② “Company” and “Partners” must monitor and comply with related procedures to ensure compliance with anti-corruption laws and regulations.

Article 7 (Disclosure of Information)
① All transactions between the “Company” and “Partners” must be conducted transparently and be accurately reflected in the partner company’s accounting books and business records.
② “Company” and “Partners” must disclose information on the partner company’s labor/safety health/environmental management status, management activities, governance structure, financial status, and performance in accordance with applicable laws and general industry practices.
③ Falsification of records or misrepresentation of the actual status and practices of related areas within the supply chain of the “Company” and “Partners” cannot be tolerated.

Article 8 (Intellectual Property Protection)
① The intellectual property rights of the “Company” and “Partners” must be respected, and the transfer of technology and know-how must be done to protect intellectual property rights.
② “Company” and “Partners” must take appropriate measures to protect the intellectual property rights they hold, and at the same time, periodically check whether the intellectual property rights are being infringed.
③ "Company" and “Partners” must have no confirmed risk or evidence of loss or unauthorized disclosure of intellectual property or business information.

Article 9 (No Disclosure of Inaccurate Information)
"Company" and "Partner" must have no evidence or identified risk of non-compliance with fair business, advertising, and competitive standards.

Article 10 (Avoiding Conflicts of Interest)
① Executives and employees of the “Company” and “Partners” must handle their work with a sense of responsibility following established regulations and procedures.
②Executives and employees of the “Company” and “Partners” must not promise, suggest, permit, or provide various means or other methods for the purpose of obtaining unfair and inappropriate profits. This includes actions by individual executives and employees that cause damage to the company for their own benefit or receive a promise to obtain profit through a third party.

Article 11 (Preventing Unfair Trade Practices)
① "Company" and "Partner" must comply with fair trade-related laws, detailed guidelines in each country where they conduct business, and advertising and competition standards.
② "Company" and "Partner" must not engage in any actions that may undermine fair competition, such as abusing their dominant market position or trading position.
③ "Company" and "Partner" must not collude with other businesses or carry out unfair anti-competitive practices related to price, supply volume, trading area, trading conditions, etc. of products or services.
④ "Company" and "Partner" must not obtain information through illegal means from competitors, business partners, or other organizations, and must not use or disclose information obtained illegally by third parties.

Article 12 (Prevention of Counterfeit and Tampered Parts)
① "Company" and "Partner" must not produce or process unauthorized raw materials and materials, and must not use or sell forged or altered raw materials or materials.
② "Company" and "Partner" must periodically check whether forged or altered raw materials and materials used in production within the workplace and if this is confirmed, you should immediately stop use and notify the trading company (or customer) to take corrective action.
③ "Company" and "Partner" must make efforts to ensure that produced raw materials and materials are used and distributed in accordance with business purposes or contract conditions.

Article 13 (Responsible Material Management)
① The "Company" and "Partner" should not use raw materials from specific origins (tantalum, tungsten, tin, gold, etc.) and illegally harvested wood whose use is restricted due to serious concerns over human rights violations and environmental destruction in the international community within the supply chain under no circumstances.
② The "Company" and "Partner" must ensure that materials contained in Samsung Electronics products exported to countries with a high possibility of producing weapons of mass destruction, conventional weapons, and missiles, such as North Korea, Iran, Syria, Sudan, and Cuba, meet the requirements of the international community. Management standards must be complied with, and policies must be established and operated that comply with international regulations and country-specific laws.
③ The "Company" and "Partner" must implement an appropriate and effective conflict minerals policy and management program to ensure that purchases of 3TG minerals do not financially support or benefit armed groups committing serious human rights abuses in the Democratic Republic of the Congo or neighboring countries.
④ The "Company" and "Partner" must track the use of substances through the entire supply chain, including the origin and business partners of the relevant substances in Paragraph 1 of this Article, and through this, the Partner Company must strive to prove the origin of substances used in the production process.

Article 14 (Data Protection)
① "Company" and "Partner" must not disclose trade secrets or information requiring the security of business partners (or customers), and information acquired while performing work must not be stored or used without permission and approval.
② "Company" and "Partner" must collect and use personal information within the legal scope, and obtain prior consent from the subject of personal information when changing the purpose of collection and use, retention and use period, etc. of personal information.

Article 15 (Identity Protection and Non-Retaliation)
Except where prohibited by law, the "Company" and "Partner" must operate a program to protect the identity of whistle blowers (ensuring confidentiality and anonymity) and inform executives and employees of the relevant procedures so that they can raise issues without fear of retaliation.

Article 16 (Nondiscrimination)
① "Company" and "Partner" must take measures to prevent workers from being harassed or illegally discriminated against. In the hiring process and employment practices such as wages, promotions, compensation, and training opportunities, there must be no discrimination based on gender, age, race, ethnicity, nationality, religion, political orientation, sexual orientation, pregnancy, disability, union membership, marital status, etc. Additionally, employees must not be fired or treated unreasonably for the same reason.
② "Company" and "Partner" shall not require conditions that are not necessary for the performance of the job when recruiting and hiring workers.
③ "Company" and "Partner" cannot require workers or job candidates to undergo medical tests that can be used as a basis for discrimination, except in cases of exceptions required by local law or workplace safety.

Article 17 (Provision of Wages and Benefits)
① "Company" and "Partner" must pay wages in compliance with the laws and systems of the countries in which they operate. Wages must be paid on a set date, and pay stubs written in a language that employees can understand must be provided.
1. Worker’s wages are accurately calculated and paid according to regulations.
2. Salaries must not be unfairly deducted without any basis in the regulations.
3. In accordance with local law, withholding amounts such as social insurance premiums must be accurately calculated and paid to government agencies.
② "Company" and "Partner" must provide a pleasant work environment for employees and strive to operate a welfare system to improve the quality of life.
③ "Company" and "Partner" must provide mandatory training prescribed by the laws and systems of the country in which they conduct business. In addition, efforts must be made to develop the careers and strengthen the capabilities of employees.
④ "Company" and "Partner" may provide a reasonably convenient place for religious activities with the written consent of a majority of employees.

Article 18 (Working Time Management)
① "Company" and "Partner" must comply with and manage the legal working hours of each country in which they conduct business based on ILO Convention No. 1
1. Standard working hours must not exceed 48 hours per week.
2. Except for emergencies or special circumstances, weekly working hours are 60 hours, including overtimes.
② "Company" and "Partner" must guarantee statutory rest/vacation, such as required rest periods including meal breaks, sick leave, or maternity leave.
③ "Company" and "Partner" shall refrain from overtime work that employees do not want to work, and if unavoidable overtime occurs, fair compensation must be provided.
④ "Company" and "Partner" must guarantee employees an average of at least one day off per week.

Article 19 (Humane Treatment)
① "Company" and "Partner" shall respect the privacy of employees and refrain from giving unnecessary work instructions outside of working hours.
② "Company" and "Partner" shall notify employees in advance when collecting their personal information, and voluntary consent shall be obtained.
③ "Company" and "Partner" must not subject workers to any inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse, or threats.
④ "Company" and "Partner" shall prohibit workplace harassment between or among employees. Victims of workplace bullying must take appropriate measures, such as changing desired working conditions (change of work location, change of assignment, etc.), and necessary measures, such as disciplinary action, must be taken against the perpetrator.
⑤ "Company" and "Partner" must not place women who are pregnant or less than one year postpartum (hereinafter referred to as “pregnant women”) and women over the age of 18 who are not pregnant in occupations prohibited by law.
⑥ "Company" and "Partner" must guarantee workers’ freedom of movement. (Toilets, drinking water, external medical facilities, factory/dormitory access, etc.) Workers must be able to freely leave the workplace when not working.

Article 20 (Guarantees of Freedom of Association, etc.)
① The "Company" and "Partner" must guarantee workers’ freedom of peaceful assembly, association, and collective bargaining, and allow the establishment and operation of legitimate bargaining organizations. Workers may form or join a union of their own free will. You must also respect workers' rights not to participate in these activities.
② "Company" and "Partner" must faithfully discuss collective bargaining matters with workers’ representatives.
③ "Company" and "Partner" must take care to allow individual workers to freely suggest matters for collective bargaining in the absence of a worker’s representative.
④ "Company" must ensure that workers and worker representatives can freely communicate and share opinions and difficulties regarding working conditions and management policies with partner companies without worrying about discrimination, retaliation, threats, harassment, etc.

Article 21 (Protection of Minor Workers)
① "Company" and "Partner" must prohibit the labor of children (under 15 years of age, under the age of completion of compulsory education, or under the legal minimum age for employment according to local laws, whichever is higher) at any stage of manufacturing, regardless of the form.
② If a child worker is discovered, the "Company" and "Partner Company" must take immediate response measures. They must immediately stop hiring child workers and improve the age verification process for workers during the hiring process.
③ "Company" and "Partner" must verify the ages of executives, employees, and job applicants through legal documents such as IDs and birth certificates, and prohibit the hiring of apprentices, interns, and student workers of personnel suspected of being children.
④ When hiring young people, the "Company" and "Partner" must not employ young people in work that is high risk for safety and health and must take measures to ensure that young people’s educational opportunities are not limited due to their work.
⑤ "Company" and "Partner" must not supply goods and services from business partners that engage in child labor or violate relevant laws and must make appropriate measures when the above facts are confirmed.
⑥ "Company" and "Partner" must comply with local laws and regulations when operating trainee programs, etc.
⑦ "Company" and "Partner" may hire youth workers who are older than the legal minimum age for employment, but workers under the age of 18 must not perform work that is hazardous in terms of safety and health (including overtime and night work).

Article 22 (Prohibition of Forced Labor)
① "Company" and "Partners" must put their employees to work in accordance with the labor standards laws of the country in which they conduct business and must prohibit forced labor or work against the will of employees, regardless of the form.
② "Company" and "Partner" must not request the submission of ID cards, passports, work permits, etc. (hereinafter “personal documents”) that may restrict workers’ activities without special reason and must not store workers’ original personal documents without any legal basis. They must also not engage in acts of physical or mental bondage, including assault, intimidation, or confinement for the purpose of forced labor.
③ "Company" and "Partner" must not receive goods and services from business partners who engage in physical or mental bondage to workers or who engage in forced labor by taking advantage of debt relationships and must take action when the above facts are confirmed.
④ "Company" and "Partner" must not require workers to pay a deposit or recruitment fee as part of employment.
⑤ "Company" and "Partner" must document and communicate working conditions (contracts, etc.) in a language that workers can understand.

Article 23 (Fair Hiring)
① "Company" and "Partners" shall hire employees by comprehensively judging the aptitude, skills, and abilities of applicants when hiring employees and be objective and fair throughout the hiring process.
② When hiring executives and employees, the "Company" and "Partner" must bear all costs incurred during the entire hiring process and must not request a separate fee from the executives and employees being hired.
③ "Company" and "Partner" must confirm whether the recruitment agency fairly hires employees, and must not receive bribes, money, or entertainment from the recruitment agency.

Article 24 (Recording/Managing Disciplinary Actions)
① If grounds for disciplinary action arise, the "Company" and "Partner" must take disciplinary action in accordance with regulations and procedures.
② All records under Paragraph 1 must be reviewed by the administrator and managed in writing or electronic documents.

Article 25 (Establishment of Safety and Health Management System)
① "Company" and "Partner" must comply with the safety and health-related laws and regulations of the country in which they conduct business and must obtain and maintain all safety and health-related licenses and permits necessary for business operation.
② "Company" and "Partner" must operate a safety and health management system consisting of organization, plan, procedure, and result inspection to prevent safety and health accidents related to business operations.

Article 26 (Safety Management of Machinery, Equipment, and Facilities)
① "Company" and "Partner" must regularly inspect and evaluate the safety of harmful or dangerous machines, instruments, and equipment in the workplace.
② "Company" and "Partner" must install and manage safety devices, protective walls, emergency devices, etc. to prevent safety accidents resulting from the use of harmful or dangerous machines, instruments, and equipment in the workplace.
③ "Company" and "Partner" shall provide safety equipment to protect each employee. Safety protective equipment must be easy and convenient for employees to use and must be maintained and managed so that it can perform its function.

Article 27 (Emergency Preparedness)
① "Company" and "Partner" must identify and evaluate in advance emergencies and accidents that may potentially occur, such as natural disasters, group infections, fires, and safety accidents. In addition, in the event of an emergency, there must be a manual consisting of reporting, worker notification and evacuation procedures, response, and follow-up actions.
② In order to prepare for emergencies, the "Company" and "Partner" must conduct training under the country's legal regulations, internally established plans, manuals, etc.
③ "Company" and "Partner" must be equipped with escape routes that are easy to find and escape without obstruction, guidance lights, fire detectors/alarms, firefighting facilities, etc. in an emergency, and must regularly check whether they are operating normally.

Article 28 (Prevention of Occupational Accidents and Diseases)
① "Company" and "Partner" shall establish a system to measure the occurrence of industrial accidents or diseases. The system must include provisions such as encouraging workers to report freely, classifying and recording occupational accidents and disease, providing necessary medical treatment, and supporting the return of workers who have taken leave due to industrial accidents or disease by investigating each case and implementing corrective measures to eliminate the cause.
② In the event of an industrial accident or serious illness, the "Company" and "Partner" must take necessary measures, such as immediately stopping the relevant work and evacuating executives and employees.
③ In the event of an industrial accident or serious disease, the "Company" and "Partner" must endeavor to investigate the cause of the occurrence and devise improvement measures.

Article 29 (Safety Diagnostics)
① "Company" and "Partner" must provide executives and employees with information on accident risks and harmful factors in the workplace based on safety risk assessment results. The information must be written in a language that executives and employees can understand and must be placed in an easily accessible place.
② "Company" and "Partner" must not employ pregnant women, minors, etc. in high-risk work in terms of safety and health. In addition, efforts must be made to create and improve a working environment so that workers belonging to socially vulnerable groups, such as the disabled and immigrants, do not have difficulty performing their work.
③ "Company" and "Partner" must take reasonable step-by-step measures, such as excluding pregnant or lactating female workers from hazardous work eliminating or reducing work with health and safety risks, and providing appropriate facilities for lactating female workers.

Article 30 (Reducing Exposure to Hazards)
① "Company" and "Partner" must identify, evaluate and control workers’ exposure to biological factors such as chemicals, pathogens, and viruses used in workplace, and physical factors such as high temperature and radiation.
② "Company" and "Partner" must prevent problems with the safety and health of workers due to hazardous factors through technical control, such as eliminating potential risks or correcting and improving production facilities, and administrative control in accordance with legal and institutional requirements. Additionally, the protection program should also include educational materials on the list of hazards and associated hazards.

Article 31 (Physically Demanding Work)
"Company" and "Partner" must identify, assess, and control workers' exposure to physically demanding work, including work that requires workers to perform repetitive manual tasks for long periods of time, heavy lifting or standing, and strenuous assembly tasks.

Article 32 (Product Safety Management)
① "Company" and "Partner" shall design products in consideration of user safety.
② "Company" and "Partner" must supply products that have passed user safety tests.
③ "Company" and "Partner" shall submit a product safety standard approval certificate for the delivered products or attach a certification label to the exterior.

Article 33 (Health Care)
① "Company" and "Partner" may provide rest areas, restrooms, restaurants, etc. to employees, and must make efforts to maintain the cleanliness of such facilities.
② "Company" and "Partner" may provide dormitories to executives and employees, and if dormitories are provided, they must provide safety signs, lighting, heating, and cooling, etc. Additionally, residence halls should be equipped with adequate lighting, emergency escape facilities, heating and ventilation, storage for personal items, and appropriate devices to restrict access to outsiders.
③ "Company" and "Partner" must regularly conduct general health checkups or special health checkups for their executives and employees in accordance with the health checkup laws of the countries in which they conduct business. Additionally, if necessary, based on the results of the health checkup, measures such as changing employees’ workspaces, switching tasks, or reducing working hours must be taken.

Article 34 (Health and Safety Training)
① "Company" and "Partner" must provide workers with appropriate safety and health training on all identified workplace hazards (mechanical, electrical, chemical, fire, and physical hazards, etc.) in the worker’s native language or a language the worker can understand.
② "Company" and "Partner" must post safety and health-related information in the workplace in a conspicuous place.
③ "Company" and "Partner" must provide training to workers before assigning them to work and must also provide regular training thereafter. Additionally, workers should be encouraged to raise safety concerns.

Article 35 (Establishment of Environmental Management System)
① "Company" and "Partner" must comply with the environmental laws and regulations of the country in which they conduct business and must obtain, and maintain all environment-related permits and permits necessary for business operation and reflect recent revisions. Additionally, you'll need to comply with the operational and reporting requirements of the licensing process.
② "Company" and "Partner" must operate an environmental management system consisting of organization, planning, procedures, performance inspection, etc. to mitigate the environmental impact of business operations.

Article 36 (Managing Energy Use and Greenhouse Gas Emissions)
① "Company" and "Partner" must establish a system to measure energy usage and greenhouse gas emissions.
② "Company" and "Partner" must strive to reduce energy consumption and greenhouse gas emissions.

Article 37 (Pollution Prevention and Resource Use Reduction)
① "Company" and "Partner" must minimize or eliminate the emission of pollutants and the generation of waste by adding pollutant control facilities, etc.
② "Company" and "Partner" must preserve natural resources, including water, fossil fuels, minerals, and virgin forests, through methods such as improving production processes, strengthening maintenance, changing facility processes, replacing materials, reusing, preserving, and recycling materials.

Article 38 (Water Resources Management)
① "Company" and "Partner" shall establish a system to measure water usage and wastewater discharge.
② "Company" and "Partner" shall strive to reduce water usage and increase recycling. In addition, water pollutants discharged must be managed according to internal standards that meet or exceed legal standards.

Article 39 (Air Pollutant Management)
① "Company" and "Partner" shall establish a system to measure air pollutant emissions.
② "Company" and "Partner" shall minimize air pollutant emissions through appropriate methods and measures. In addition, we must establish and comply with internal standards for air pollutants emitted that are legal or higher.
③ "Company" and "Partner" must identify the characteristics of volatile organic compounds, aerosols, corrosive gases, dust, ozone-depleting substances, and combustion by-products generated in the process, monitor them at all times, and manage/treat them in accordance with local laws before discharging them.
④ "Company" and "Partner" shall monitor the treatment efficiency of air pollution prevention facilities at all times.

Article 40 (Hazardous Materials Management)
Chemicals and other materials that are hazardous to people or the environment must be managed separately, including identification and labeling, to ensure safe handling, transportation, storage, use, recycling or reuse, and disposal.

Article 41 (Waste Management)
① "Company" and "Partner" must establish a system to measure waste emissions.
② "Company" and "Partner" must minimize the discharge of waste to landfills and incineration through appropriate methods and measures. In addition, efforts must be made to increase the rate of waste reuse and recycling and to recover discarded raw materials and materials.
③ "Company" and "Partner" shall consider the entire life cycle of the materials they use, and when landfilling or incinerating waste, efforts must be made to minimize the generation of residues that are harmful to the environment.

Article 42 (Chemicals Management)
① "Company" and "Partner" must strive to ensure that chemicals handled in business are safely managed during transportation, storage, use, and disposal. Additionally, information that can identify the risks and hazards of the chemical must be labeled or disclosed.
② "Company" and "Partner" must make efforts to check whether the raw materials and parts they procure, produce, sell, and distribute contain substances harmful to the human body and the environment.

Article 43 (Green Construction, etc.)
① In order to minimize environmental impact, the "Company" and "Partner" must make efforts to select eco-friendly materials, apply eco-friendly construction methods, and reduce energy throughout the construction process.
② "Company" and "Partner" shall practice eco-friendly transportation that reduces greenhouse gas emissions.
③ "Company" and "Partner" shall systematically operate a waste disposal and recycling management system and conduct standardized eco-friendly demolition.
④ "Company" and "Partner" must conduct activities to periodically inspect and improve the environmental impact of the business and its surroundings not only during the construction process but also after completion of construction.

Article 44 (Green Purchasing)
① "Company" and "Partner" must consider energy efficiency, decomposition, and recycling when designing products, and provide environmental footprint data (raw material content, water usage, greenhouse gas emissions, energy usage, etc.) for products.
② For Electronics, must have a recognized energy label or external certification of energy efficiency.
③ For wood products, a recognized Healthy Building Material (HB) certification or Forest Stewardship Council (FSC) certification must be obtained

Article 45 (Substance in Products Compliance)
"Company" and "Partner" must follow local laws and regulations related to displaying information about substances when recycling and disposing of substances, and comply with Samsung Electronics’ product management rule for environmentally hazardous substances, 「OQA-2049」.

Article 46 (Expression of Will to Comply)
"Company" and "Partner" must post a corporate social and environmental responsibility statement approved by the business manager in the local language at all workplaces of the partner company, expressing the company’s commitment to compliance and continuous improvement.

Article 47 (Duties and Responsibilities of Management)
"Company" and "Partner" shall designate a person responsible for periodic checks on the implementation and status of the management system and Code-related programs, and the CEO shall periodically review the status of the management system.

Article 48 (Dissemination of the Code of Conduct)
① "Company" and "Partner" must disseminate this Code of Conduct or its will to fulfill social responsibility at an equivalent level internally and externally.
② "Company" and "Partner" must share this Code of Conduct or its commitment to fulfilling social responsibilities at an equivalent level within the company through management’s New Year’s address, internal guidelines, and internal bulletin boards. Additionally, it can be disclosed externally through the website, business reports, promotional materials, etc.

Article 49 (Appointment of Representative)
① "Company" and "Partner" must appoint a working person in charge of social responsibility activities.
② "Company" and "Partner" must appoint a manager to supervise the establishment of social responsibility activity plans and implementation status.

Article 50 (Responding to Legal and Customer Requirements)
"Company" and "Partner" must understand applicable laws, regulations, and customer requirements, including the requirements of this Code, and establish a process to monitor them and reflect them in management procedures.
Article 51 (Risk Management)
① "Company" and "Partner" must establish an effective risk management process to detect/evaluate and control risks in the areas of ethics, labor, and human rights, safety and health, and environment that may arise during business operations to minimize/mitigate them.
② If the "Company" and "Partner" discover a significant risk, they must prepare and implement measures to mitigate the risk.

Article 52 (Performance Management Process)
"Company" and "Partner" must have an effective performance management process, such as setting/achieving goals and establishing improvement plans, in the areas of ethics, labor and human rights, safety and health, and the environment that may arise during business operations.

Article 53 (Training and Communications)
① "Company" and "Partner" must establish an appropriate and effective training process for all executives and employees regarding the contents of this Code of Conduct and related laws, systems, regulations, government policies, etc.
② "Company" and "Partner" must share with executives and employees about implementation plans and performance results for the matters presented in this Code of Conduct.
③ "Company" and "Partner" establish appropriate and effective worker/manager, partner, and customer communication/reporting processes for implementation and performance in the areas of ethics, labor and human rights, safety and health, and environment that may arise during business operation.

Article 54 (Information Management)
① "Company" and "Partner" must accurately record and manage the current status and risk-related information in the areas of ethics, labor and human rights, safety and health, and the environment.
② When a government agency, related industrial organization, or major trading company, etc. of the country in which the business is operated officially requests disclosure of information under Paragraph 1, "Company" and "Partner" must strive to disclose information transparently, except for matters prohibited by law and trade secrets.

Article 55 (Operation of the Whistleblower System)
① "Company" and "Partner" must operate an internal reporting system that allows affiliated executives and employees, business partners (or customer companies), and third parties to report (or provide consultation) in any of the following cases.
1. When executives and employees recognize or confirm that they have violated laws and regulations in the areas of ethics, labor and human rights, safety and health, and the environment.
2. In case the individual’s rights and interests are violated in relation to item 1 above.
3. All other unethical acts, anti-corruption acts, and illegal acts
② "Company" and "Partner" must protect the reporter (or counselor) from receiving unreasonable measures, such as dismissal, threats, retaliation, ridicule, etc., for reporting (or counseling) under Paragraph 1, and must thoroughly guarantee their identity.

Article 56 (Worker Consultation/Participation Process)
"Company" and "Partner" shall have appropriate and effective processes in place to encourage worker feedback and participation.

Article 57 (Self-Audit Process)
Must have appropriate and effective self-audit processes to periodically assess compliance with the RBA Code of Conduct.

Article 58 (Corrective Action Process)
"Company" and "Partner" must establish an appropriate and effective corrective action process to correct and terminate violations in the areas of ethics, labor and human rights, safety and health, and the environment that may occur during business operations.

Article 59 (Vendor Management)
① "Company" and "Partner" must encourage business partners (or customers) with whom they have entered into a contract to plan, design, sell, and manufacture products or services to comply with the provisions of this Code of Conduct.
② If a business partner (or customer company) violates this Code of Conduct or related laws, or if such a violation is expected, the "Company" and "Partner" recommend the business partner (or customer company) to make improvements or induce compliance with the Code and laws.

Article 60 (Code of Conduct Compliance Checks)
① "Company" or a third party designated by "Company” may conduct a written inspection or on-site inspection (due diligence) on "Partner" to determine compliance with this Code of Conduct. At this time, the "Partner" must provide data that can confirm compliance with this Code of Conduct and information related to the level of implementation.
② "Partner" must prepare and manage documents that can prove compliance with this Code of Conduct, and such documents must be prepared based on reality and facts about business operations.
③ "Partner" must make efforts to improve any shortcomings or violations revealed through written inspection or on-site inspection (due diligence) regarding compliance with this Code of Conduct.

Article 61 (Supply Chain Engagement and Accountability)
If necessary to achieve the purpose of the Code of Conduct, the "Company" and "Partner" must refer to the RBA standards, etc. to conduct due diligence on major business partners and manage improvement practices to the extent that it does not violate the relevant country's laws. This even includes ceasing to do business with companies that do not uphold their performance responsibilities.