posco HOLDINGS

This Code of Ethics establishes the ethical values and behavioral standards that must be respected and cultivated by all employees. At POSCO Group, we practice the Code by embracing modern principles as well as by inheriting the foundational spirit of steelmaking patriotism founded on self-sacrifice and service to the country.

It is our enduring goal to establish a corporation that holds the values of integrity, fairness and honesty in the highest esteem and that is trusted by all stakeholders. Hence, in 2003, POSCO Holdings wrote the Code of Ethics to be observed by all employees. In 2014, the values that proclaim support and respect for human life and dignity, as defined in the UN Guide, was explicitly added to the principles. Most recently, the Code was amended to include stricter ethical standards in its management practices.

This Code of Ethics consists of the Preamble, followed by the Principles of Ethical Management that define compliance and responsibilities of employees and practice guidelines that set the standards for ethical decision-making.
All members of POSCO Group must strictly abide by the principles and practices defined by the standards in all aspects of business and conduct.

Observance of the Code offers a means to pay tribute to the exceptional commitment of our founding members in their effort to preserve the history and to continue the spirit of POSCO Holdings.

POSCO LithiumSolution has established and is operating a variety of ethics-related policies to help employees be accustomed to ethical practices.

POSCO LithiumSolution is contributing greatly to the establishment of an ethical corporate culture through various channels of ethics education.

The purpose of the Clean POSCO System is to create a zero-tolerance culture against improper solicitation. To do so, we keep records of all referrals, recommendations and special requests with the goal to manage them.

• An employee who receives solicitation has grounds to refuse on account of system registry
• The solicitor is discouraged by the record of solicitation being kept on file, thereby foregoing future requests

• Create a culture of integrity and transparency; once an improper solicitation is made, do the right thing and enter the case in the whistleblow registry
• Any entry made in the registry is considered voluntary reporting; the good faith employee shall be protected and exempted from all subsequent consequence and/or responsibility

Register all employees involved in the process of making the improper solicitation; that includes the final recipient and anyone involved in the delivery of the request, including working-level staff

The final recipient of the improper solicitation shall use the 5W 1H question as the guiding framework to document the event

Registry must be made within 24 hours after a solicitation is made
Extension can be granted for special circumstances (e.g. meetings, travel)

Any act of a person with expression of intent, i.e., special request, made with the goal to accrue benefit to oneself or other with knowledge that the act can impact the performance and decision-making of the employee, to whom the intent is expressed.

• Act that has personal consequence on the employee when the request is either accepted or denied
• Act that imposes undue mental burden on the employee while performing a just duty due to the improper request

The Clean POSCO system was designed with the goal to prevent misconduct before they happen. Therefore, the qualifying definition of solicitation is broader than how it is defined in the statutes. Solicitation refers to any expression of intent that could undermine fairness. When in doubt as to what is and what is not improper solicitation, the guiding principle is to err on the side of 100% registry of all events in the system.
An employee who becomes aware of improper solicitation but fails to report the event may be subject to severe disciplinary action.

The outcome of processed registries are managed separately by relevant organization, i.e., HR, Sales; based on the findings, disadvantage may accrue to the involved employee and/or the solicitor.