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Ethical Management

Ethical Management System

Underpinned by SKMS as its foundation, SK Materials Co., Ltd. delivers values to a variety of stakeholders including members, customers, and society to play an essential role in fostering social and economic development and contribute to the happiness of mankind. The code of ethics, which is the standard for right behavior and value judgement that members must observe, is taken as the basic rule of ethical management. Ethical risks are determined and improved according to the ethical management process that consists of Prevention, Detection, and Response.

Ethical Management Framework

윤리경영 Framework에 관한 이미지 입니다. 자세한 설명은 하단 내용을 참고하세요.
  • 예방

    진단서베이 (개인, 조직) → FeedBack → 교육

  • 식별

    제보채널 → 감사 ← 상시모니터링

  • 대응

    감사 → 징계 → 후속 조치 (내용전파 / 후속교육, 시스템 개선) → 예방에 반영 → 교육


SK Materials Co., Ltd., with a zero-corruption goal, is taking the lead in ethical management with a zero-tolerance principle for unethical and corruptive activities. From 2022, we plan to expand the application of the self-cleaning system to subsidiaries, and afterward, we will establish a systematic anti-corruption operation process combined with the self-cleaning system through the anti-corruption management system certification (ISO 37001).

Zero-corruption goal
  • Expanded application of the self-cleaning system to subsidiaries
  • Certification of anti-corruption management system
    (ISO 37001)
  • Establishing a systematic anti-corruption operation process

Ethical Management Structure

SK Materials Co., Ltd. operates the Ethical Management Department, which is organized under the direct control of the CEO, to implement and monitor the ethical management process. By operating the Ethical Management Team, an organization dedicated to establishing an ethical management organizational culture, we are striving to create an environment where members can actively practice ethical management. The audit committee, under the board of directors, is responsible for and supervises the overall management activities of SK Materials Co., Ltd. through periodic reviews. The main issues and activities of ethical management are reported to the BOD at least once a month at CEO meetings.

윤리경영 실천조직

Implementation Elements Of Ethical Management

Materials Co., Ltd. recognizes ethical management as a critical prerequisite for corporate sustainable management. We are striving to create a fair and transparent corporate culture and practice ethical management by establishing the following ethical management 3C (Code, Compliance, and Consensus) system.

Ethical Management System’s 3 Elements (3C)
  • 윤리규범 Code
    • Practice Rules of Ethics Code
    • Violations cases by main themes (Don’ts)
    • Ethical management practice FAQ for SK leaders
    • Ethical management practice pledge
    • Prohibition of holiday gift acceptance
  • 제도 compliance
    • Operation of an organization / system dedicated to ethical management
    • Operation of the Integrated Group Reporting Site and information protection
    • Operation of the Ethics Complaints Counselling Center (Happiness Empathy)
    • Operation of the self-cleaning system
  • 공감대 형성 Consensus
    • Development and implementation of ethical management education program
    • Ethical management practice letter
    • Operation of communication and participation program for members
    • Conduct a survey for diagnosis of ethical management level
    • Ethical management practice workshop

Code of Ethics

SK Materials Co., Ltd. focuses on establishing ethical management as a corporate culture by having all members (including contract workers and dispatched workers), who work at the headquarters, overseas subsidiaries, and affiliated companies, equipped with ethical thinking and practice it. To this end, we have established practice rules of ethics code by each company and taken them as a criterion for decision-making and right behavior in all management activities.


Principles of Ethical Decision-Making and Conduct

Legitimacy / Transparency / Rationality


Attitude of Members

Performing Duties with Integrity / Prohibition of Conflicts of Interest / Protection of Company’s Assets / Prohibition of Offer or Receipt of Gifts and Hospitality / Mutual Respect among members


Compliance with Laws, Regulations, and Business Policies

Quality / Management Information / Fair Trade and Competition / Safety, Health, Environment


Execution of Guidelines

Department in Charge / Informant Protection

  • Code of Ethics
    • Download(ENG) Download(KOR)

      Chapter 1 General Provisions

      Article 1 (Purpose)

      Underpinned by SKMS (SK Management System) as corporate management foundation, SK Materials Co., Ltd. (hereinafter referred to as the “Company”), values to a variety of stakeholders, including customers, members, shareholders, business partners and the community, to play an essential role in fostering social and economic development and implementing corporate management that can contribute to the happiness of mankind.

      Article 2 (Application)

      ① This code of ethics is applicable to the Company (including subsidiaries) and the members (including part time and contractual employees), and the Company and the members inform and recommend practicing this code of ethics to the Company’s stakeholders.

      ② Measures will be taken pursuant to the company rules in case of violating this code of ethics.

      ③ “Action plans for the code of ethics” will be established and managed in order to properly interpret and implement this code of ethics.

      Chapter 2 Attitude Towards Customers

      Article 3 (Respecting Customers)

      ① Diverse opinions of customers will be respected in good faith, and legitimate demands and rational proposals of customers will be reflected in the Company’s management activities.

      ② Truthful and accurate information will be provided to the customers, information related to the customers will not be disclosed to others or used for other purposes, and the customers’ property and honor will be protected.

      Article 4 (Improving Customer Value)

      ① Efforts will be exerted continuously to identify the values needed by the customers through customer-centered mind.

      ② All stages of product development, manufacturing, shipment, usage, and disposal will be explored to secure global quality competitiveness, and will obtain customer trust through timely provision of products and services.

      Chapter 3 Responsibilities for the Members

      Article 5 (Respecting Members)

      ① Member will be respected, and the best working environment will be established to improve the members’ quality of life.

      ② Safe culture, participated by all employees, will be created for the health of all members and safe working conditions, serious accidents will be prevented through continuous health improvement activities and safety improvement activities, and accident-free workplace will be established.

      Article 6 (Fair Treatment)

      ① Opportunities for employment, promotion, job transfer, training and remuneration, etc. will be provided fairly pursuant to principle and standards, without regards to race, nationality, age, gender, education, place of origin, disabilities and marriage status, etc.

      ② Clear standards for the members’ goal and performance will be provided, and individuals and groups contributing to the performance will be provided with fair and rational rewards.

      Article 7 (Talent Cultivation)

      ① Tasks will be given to the members to development the members’ abilities by considering the members’ talent and ability, and growth opportunities will be provided through continuous education.

      ② Individual abilities and job performance will be improved through educational, technology development and training opportunities, and efforts will be exerted for health and high quality life

      Chapter 4 Responsibilities for the Shareholders

      Article 8 (Protecting Shareholder Interests)

      ① The Company will protect the interest of the shareholders and investors by continuous growth and development through transparent and efficient management.

      ② The members will not interfere with the interest of the shareholders through acts of obtaining profits from improper stock transactions using inside information or disclosing inside information to the outside, etc.

      Article 9 (Guaranteeing Shareholder Rights)

      ① The shareholders’ right to know and to make proper demands and proposals will be respected, and they will be reflected in the Company’s management activities.

      ② Materials on overall management will be prepared according to relevant laws and standards, and the related information will be provided according to the relevant laws.

      Chapter 5 Relationship with Business Partners

      Article 10 (Equal Opportunities)

      ① All qualified businesses will be provided with equal opportunities to participate in registration and selection of business partners (hereinafter referred to as the “BP”).

      ② The BP registration and selection will be implemented in rational methods according to objective and fair criteria.

      Article 11 (Fair Transaction Procedure)

      ① All transactions with the BP will be implemented fairly in a mutually equal position, all agreed transaction terms will be complied with, and proper opinions to improve and innovate the transactions will be properly reflected in the work.

      ② All fair trade related laws will be complied with during transactions with the BP, and no improper actions will be taken by using the superior position.

      ③ When using the technologies or properties of BP, the approval of the other party will be obtained, and no information will be disclosed to the outside without a written consent.

      Article 12 (Seeking Mutual Development)

      ① Technology support and management guidance will be provided actively in order for the BPs to grow and to become competitive in the long-term, and will seek mutual interest and joint development.

      ② Mutual efforts will be exerted with the BPs to establish customs of clean transactions and maintain fair transactions.

      Chapter 6 Roles for the Society

      Article 13 (Contributing to Social Development)

      ① Members’ participation in healthy social activities will be guaranteed, and contribution to society will be made through social and cultural activities.

      ② Company recognizes that the Company’s social responsibilities begin with social volunteering, and the Company will participate actively in various social volunteer activities and cultural development projects, as long as the activities do not interfere with the budget and management activities.

      Article 14 (Eco-Friendly Management)

      ① Domestic and international laws and treaties related to environment, safety, health and energy will be observed, and strict international management standards will be applied and implemented in all business activities to prevent environment safety accidents. Education will be conducted to understand and practice environment safety management system, and the environmental safety policy and management performance will be announced to all internal and external stakeholders.

      ② Efficient use of energy and water resources, and strict management of chemical substances will be implemented by introducing eco-friendly design to prevent pollution, and continuous efforts will be exerted to encourage re-use of waste water, waste and recycling and to reduce pollutants.

      ③ The Company recognizes the climate change crisis as problems of everyone in order to preserve the environment, and continuous efforts will be exerted to increase the use of renewable energy, reduction of greenhouse gas emission and establish low-carbon ecosystem to overcome the climate change crisis.

      ④ Efforts will be exerted to protect the community’s environment and safety, and strictly implement prevention measures to avoid loss due to accidents or disasters, etc.

      Addendum (July 1, 2023)

      Article 1 (Effective Date) This code of ethics will be effective from July 1, 2023.
  • Code of Ethics Practice Guide
    • Download(ENG) Download(KOR)


      Article 1 (Purpose)

      The purpose of this “Code of Ethics Practice Guide” (hereinafter the “Practice Guide”) is to provide the standards for decision-making and determining how to behave in an ethical conflict that may arise during the course of business so as to ensure that the members of SK Materials Co., Ltd. affiliates fully understand and practice the Code of Conduct.

      Article 2 (Ethical Decision-Making and Behavioral Principles)

      When a member is faced with an ethical conflict in relation to his/her duties, he/she must judge and behave according to the Code of Ethics and the Practice Guide However, if the standards for determining are not clearly defined in the Practice Guide, he/she must judge and behave according to the following decision-making principles, and if he/she is not confident in his/her judgment, he/she must act according to the advice of the organization’s leader or the department in charge of ethical management.

      Article 3 (Applicability)

      This Practice Guide applies to the Company (including subsidiaries) and all members (including part time and contractual employees). However, as to the affiliates for which the Company holds a minority stake and business partners that deal with or have a contract relationship with the company, their members are recommended to comply with this Practice Guide.


      Article 4 (Loyal and Conscientious Performance of Duties)

      Members must be clearly aware of their rights and responsibilities and perform their duties under the principle of good faith.

      Article 5 (Prevention of Conflicts of Interest)

      ① Members must make every effort to avoid any situation where a conflict of interest renders them to breach their duty of good faith owed to the Company in relation to performing their duties.

      ② Conflicts of interest to be aware of are as follows. However, since the following does not list all incidents of conflict of interest, members are required to exercise strict judgment and application in real circumstances:

      • 1. Where the conduct is prohibited;
        • a. Using the Company's assets or management information for personal purposes to obtain personal gain;
        • b. Abusing one’s business position to exert undue influence on business partners, etc. to ask for an HR-related favor, various entertainment, and more;
        • c. Engaging in a sideline that requires enough effort to the extent that it impedes one's conscientious performance of his/her duties;
      • 2. Where it is necessary to disclose the details of the conflict of interest to the organization’s leader and obtain approval from the Company in line with associated procedures such as the rules on the approval by delegated authority;
        • a. Signing a contract or dealing with the Company directly or through a third party;
        • b. Possessing stocks of partner companies that may directly or indirectly exercise influence through business or performing management duties, etc.
      Article 6 (Protection and Appropriate Use of Company Assets and Information)

      Members must protect Company's tangible and intangible assets and use them in a reasonable manner.

      ① Members must not use Company's assets for personal gain without approval, transfer, or lend them to a third party.

      ② Members must not use Company's budget for personal reasons but spend it for the purpose set by the Company, and accurately record it in the ledger.

      ③ Members must not excessively use the computer, Internet, e-mail, telephone/fax, etc. for personal reasons.

      ④ Members must actively protect intellectual property rights such as patent rights, goodwill, trademark rights, copyrights, and other information with the asset value of the company. In addition, members must equally protect the intellectual property rights of others or other companies, and, in particular, must not use illegal software.

      ⑤ Members must strictly manage Company's information assets, including business information and technical information, by the security management regulations. Whether to disclose information assets and the scope of the disclosure are determined by applicable laws, company regulations, and company policies, and the same applies to interviews with the media.

      Article 7 (Prohibition of Financial Benefits, Gifts, Entertainment, Etc.)

      ① Members must engage in all business activities in a fair and transparent manner. Therefore, members must not provide any money and valuables, entertainment, etc. to stakeholders for the enjoyment of improper and unfair benefits.

      ② Members must not accept money and valuables, entertainment, or other personal conveniences from stakeholders such as business partners; provided, however, that to maintain a wholesome relationship with stakeholders, members may provide stakeholders with foods and conveniences within the scope accepted under social norms or in an official event related to business, members may exchange transportation, accommodation, or foods that a host uniformly provides to attendants. Each organization may formulate and enforce its own regulatory details on this matter.

      ③ Forgiving debt or paying off debt on behalf of the debtor, renting a property at a price lower than its normal price, and accepting guarantees are deemed as financial benefits.

      ④ Employees must not accept or provide financial benefits from and to each other, and the financial benefits accepted by the employee's family members may be deemed to have been accepted by the employee.

      Article 8 (Creating a Wholesome Corporate Culture)

      ① Members must respect each other regardless of their position, practice good manners and maintain their dignity as members of SK Group.

      ② Members must not discriminate based on gender, school affiliation, region of origin, marriage, race, nationality, religion, and so on.

      ③ Members must not engage in any acts of sexual harassment, workplace harassment, bribery, neglect of duties, and false reporting that may infringe upon individuals’ human rights and undermine the working atmosphere.


      Members must be well-versed with domestic and foreign laws, Company policies, and Company rules associated with the Company’s management activities and perform their duties in line with them.

      Article 9 (Creation of Management Information and Faithful Reporting)

      ① Accounting information must be accurately recorded and maintained according to generally accepted accounting principles, associated laws, and company rules, and no accounting information must be manipulated or hidden.

      ② All management information of the Company, including financial information, must accurately reflect the relevant facts or transaction details to back up the decisions made by the management, and must not enable the management to make wrong decisions by reporting intentionally concealed, understated, or exaggerated facts.

      ③ The management information must be disclosed to external stakeholders in a transparent and fair manner by applicable laws and company rules.

      Article 10 (Fair Trade and Competition)

      ① Members must clearly understand and comply with fair trade-related laws and the Company's management regulations on voluntary compliance with fair trade requirements.

      ② Issues that may be interpreted as violations of fair trade-related laws must be dealt with after sufficient consultation with the compliance officer in advance, and decisions must not be based on discretionary interpretation.

      Article 11 (Compliance with Quality Policy)

      All requirements must be observed to supply products that meet customer expectations and requirements for quality, reliability, and safety.

      Article 12 (Policy on Safety, Health, and Environment)

      Members must comply with domestic and foreign laws and international conventions associated with safety, health, and environment, and seek to make continuous improvements in safety, health, and environment outcomes.


      Article 13 (Responsibilities and Duties of Members)

      ① All members are responsible for complying with the Code of Ethics and Practice Guide, and for any questionable issues, they must inquire and consult with the leader of the organization or the ethical management department, and act according to the interpretation given.

      ② Members who have violated this guide are obliged to report the violation to the leader of the organization or the ethical management department, and members who become aware of another member’s violation are also obligated to report the fact to the ethical management department of the Company.

      ③ If an investigation is launched into a transaction or act that has violated or may violate the Code of Ethics, members must submit the data requested by the Company before the deadline and provide full cooperation. Members who do not provide full cooperation may be deemed to have admitted their violation of the Code of Ethics.

      ④ Organization leaders are responsible for active support and management for their members and business-related stakeholders to properly understand and comply with the Company's Code of Ethics and Practice Guide. In addition, Members must serve as a model for others by complying with the Code of Ethics and Practice Guide through conscientious and responsible decisions and behaviors.

      Article 14 (Protection of Whistleblowers)

      To create a wholesome organization, all members must report or consult with the ethics management department immediately if they become aware of any unfair trade or unethical behavior or receive a proposal to engage in unethical behavior from a stakeholder. The Company must run an internal reporting scheme to prevent risks through early detection of unfair and unethical behaviors and unreasonable business processes of the organization or its members, protect the identity of whistleblowers and prohibit penalization or retaliation against whistleblowers for their reports.

      ① No penalization in the status or discrimination in terms of working conditions is allowed due to the whistleblowers’ legitimate reports, related statements, and submission of data.

      ② Those who helped with the investigation by making statements and providing data during the process of verifying the facts about the report must be equally protected as the whistleblowers.

      ③ If a whistleblower is penalized for his/her report, he/she may request the ethics management department to take protective measures such as a remedy and transfer to another department. In this case, the ethics management department must inquire whether it is true and address the issue and develop and enforce measures designed to prevent recurrence that include sanctions against involved personnel.

      ④ The person who investigated the report and the person who learns the report must keep the identity of the whistleblower confidential to ensure that it is not disclosed against his/her will.

      ⑤ The following conducts in violation of the duty to protect whistleblowers will be subject to disciplinary action under relevant regulations:

      Article 15 (Duties of Auditors)

      When investigating a report, the auditor must, as a matter of principle, protect the whistleblower, and must comply with the following.

      ① The auditor must not disclose or suggest the identity of the whistleblower without the whistleblower's consent.

      ② All aspects of data related to the report must be accessible by authorized personnel only and security must be maintained strictly.

      ③ If the auditor discloses the identity of the whistleblower known during the investigation at will, he/she will be subject to disciplinary action by relevant regulations; provided, however, that an exemption may be granted under the following circumstances:

      ④ The head of the ethical management department is responsible for educating and managing auditors for issues associated with the investigations on reports.

      Addendum (July 1, 2023)

      Article 1 (Enforcement Date) This Practice Guide shall enter into force on July 1, 2023.
      Article 2 (Measures against Violations) Any violation of this Practice Guide shall be dealt with by the Company rules.

Anti-corruption Regulation

SK Materials Co., Ltd. has established the "compliance regulations of Anti-Corruption Act" and taken them as a criterion for decision-making and behavior, to pursue the continuous happiness of all of its members (including contract workers and dispatch workers) working in the headquarters, overseas branch, and affiliated subsidiaries and all stakeholders, and to realize social values through ESG management.

  • Detailed information on compliance regulations of Anti-Corruption Act
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      Article 1 (Purpose)

      SK Materials Co., Ltd. (hereinafter referred to as the “Company”) hereby establishes these regulations to conduct businesses in an ethical and legitimate manner in compliance with domestic and foreign anti-corruption laws and to promote the wholesome and sustainable development of the Company

      Article 2 (Fundamental Principles)

      ① Members of the Company must comply with all Korean anti-corruption laws, including the Criminal Act, the Act on the Aggravated Punishment of Specific Crimes, the Act on Combating Bribery of Foreign Public Officials in International Business Transactions, and the Improper Solicitation and Graft Act, and all overseas anti-corruption law, including the Foreign Corrupt Practices Act (hereinafter referred to as the “FCPA”), the UK Bribery Act 2010, the OECD Anti-Bribery Convention, and anti-corruption-related laws of countries where the Company conducts businesses (hereinafter referred to as the “Anti-Corruption Laws and Regulations”).

      ② The Company may set guidelines to ensure compliance with these regulations (hereinafter referred to as the “Detailed Guidelines”), and members must comply with the Detailed Guidelines.

      ③ Members must ensure that all individuals and organizations doing business with the Company understand and comply with these regulations in relation to the business with the Company.

      Article 3 (Applicability)

      ① These regulations apply to all members of the Company and its subsidiaries regardless of their place of work.

      ② Notwithstanding the prohibition herein, exceptions may be applied if permitted by the laws of the applicable country, and where it is necessary to determine whether such exceptions indeed apply, members must consult with the Ethical Management Division in advance.

      ③ Each country may set its own detailed guideline for compliance with these regulations in line with local laws and circumstances.

      Article 4 (Definitions)

      ① The terms used in these regulations are defined as follows:

      ② Terms not defined herein will be subject to the definitions contained in the anti-corruption laws of each country, and, if necessary, they may be defined by the Ethical Management Division.


      Article 5 (General)

      ① Prohibition in principle

      ① Prohibition of improper solicitation

      Article 6 (Gifts and Entertainment)

      ① General prohibition

      ② Acceptable gifts and entertainment

      ③ If a member intends to provide gifts, entertainment, or money for congratulations and condolences to public officials or public affairs workers related to their work, and it is unclear whether it falls under Paragraph (2) of this Article, he/she must consult with the Ethics Management Division in advance to determine whether such provision would constitute a violation.

      Article 7 (Travel and Business Trip)

      ① General prohibition

      ② Permitted travel (business trip)

      Article 8 (External Contribution)

      ① General prohibition

      Permitted provision

      Article 9 (Political Contribution)

      The Company must not provide any political contributions, including contributions to candidates for public office or members of the National Assembly.

      Article 10 (Facilitation Payments)

      ① (1) The term “facilitation payment” means a small amount paid to lower-level public officials to expedite or facilitate routine government procedures.

      ② Members must not pay facilitation payments for any reason.

      Article 11 (Conflict of Interest)

      ① The term “conflict of interest” means a circumstance in which the personal interest of a member conflicts with that of the Company during the course of business, including the following circumstances:

      ② Members must endeavor to avoid conflicts of interest, and if a conflict of interest is inevitable, they must, as a matter of principle, be excluded from a related business. In this case, members must report the conflict of interest to the HR department or the Ethical Management Division and then follow the Company's decision.

      ③ Even in cases where there is a risk of affecting the fair performance of business due to blood ties, academic ties, or other special relationships with public officials of government agencies that oversee the licensing, investigation, etc., or if fairness may be questioned, Paragraph 2 will dictate.


      Article 12 (Merger and Acquisition)

      ① By acquiring another company, the Company may be required to assume its past legal responsibilities, and in recognition that it may be held liable for acts continued after the acquisition in violation of the Anti-Corruption Laws and Regulations, the Company must conduct compliance due diligence to find and address legal risk factors before acquiring another company.

      ② The Company must make sure that its internal control and compliance programs such as compliance training for members, inspection and monitoring programs, and compliance due diligence of a third party take root in the acquired company in the early stage.

      ③ Company members must provide full cooperation to take necessary measures for mergers and SKMR CIC-0108-5 acquisitions.


      Article 13 (Approval and Records Management)

      All matters to which these regulations are applicable must follow the set cost execution and approval procedures in the Company, while Company members must reflect various transactions and when and where the money is spent in the ledger in a detailed and accurate manner and keep receipts and other proofs attached. In addition, Company members must draft accounting and financial reports in a fair and appropriate manner in accordance with applicable laws and regulations and must not record false or forged information for any purpose or omit information that must be recorded.

      Article 14 (Reporting, Etc.)

      ① If a Company member discovers a violation or potential violation of these regulations and anti-corruption laws, he or she must immediately notify thereof to the relevant department. In addition, a Company member who has been requested to provide money or valuables from public officials, etc. must immediately report to the Ethics Management Division.

      ② If a Company member or his/her spouse constitutes a public official or a private person performing public duties, and is related to the Company business, he/she must immediately report any change to his or her position such as acquisition or loss thereof to the Ethics Management Division.

      Addendum (Dec. 1, 2021)

      Article 1 (Enforcement Date) These Regulations shall enter into force on December 1, 2021.
      Article 2 (Application) Upon the enforcement of these regulations, the previous regulations on compliance with the Improper Solicitation and Graft Act will be abolished and replaced with these regulations.

Code of Conduct for Members

  • One,

    I keep in mind that I must stick to safety for the safety, health, and environmental protection of myself, the company, and furthermore mankind, and make every effort to prevent accidents by complying with the company's safety rules and working procedures.

  • One,

    Recognizing that the transparency of the company begins with my actions, I take the lead in ethical management through the distinction between public and private affairs.

  • One,

    In order to make stable profits and secure new growth engines for the company, I focus my best capabilities on cost reduction, quality improvement, and technological innovation.

구성원 행동강령
  • One,

    I create an organization culture of mutual respect, cooperation, and trust through better communication.

  • One,

    I provide the best value to customers and shareholders under the highest quality and service principles.

  • One,

    I cope with the changing environment through future-oriented creative thinking and continuous self-development, and strengthen the internal capabilities necessary to overcome the crisis.

  • One,

    I devote myself to working with creativity and passion to make sure to create a good company for all members to work for and want to work for.

Code of Ethics for Manufacturing

SK Materials Co., Ltd. is taking precautions for ethical risks by separately enacting the 'Code of Ethics for Manufacturing Regulations' that identifies topics related to ethical management in the production/manufacturing and research/development/investment process due to the nature of the industry.

  • Detailed guidance on the Code of Ethics for Manufacturing
    • Download(ENG) Download(KOR)

      Article 1 (Purpose)

      Members of the SK Materials Co., Ltd. affiliates must have mutual respect for customers and business partners and ensure mutual growth through fair trade. To this end, the Manufacturing Code of Ethics has been drawn up as the standard for making decisions and judging behaviors in business activities. The Code of Ethics is not simply a means to control the unethical behaviors of individual members. It measures up to SK's philosophy on ethical management which seeks to enhance its ethical standards during the course of business to gain trust of stakeholders and achieve continuous growth and development.

      Article 2 (Applicability)

      This Code applies to the members of the SK Materials Co., Ltd. affiliates, that is, all members (including irregular workers and outsourced staff) who serve at SK Materials Co., Ltd, and its subsidiaries and affiliates (including overseas affiliates), irrespective as to where their place of work is located.

      Article 3 (Fundamental Principles)

      ① Building a global competitive edge for quality

      ② Keeping records and reports accurate

      ③ Maintaining independence in the investment decision

      ④ Protecting information and maintaining trade secrets in confidence

      ⑤ Reinforcing the global environmental safety management system

      ⑥ Building an eco-friendly production process

      ⑦ Practicing the climate change policy

      ⑧ Implementing a safe workplace

      ⑨ Building a partnership of mutual growth

      Article 4 Compliance with Laws and International Conventions

      SK members must perform their duties based on the spirit of supply for mutual growth and the principle of good faith and comply with associated domestic and foreign laws and regulations, including the Monopoly Regulation and Fair Trade Act, the Act on the Promotion of Mutually Beneficial Cooperation between Large Enterprises and Small And Medium Enterprises, the Fair Transactions in Subcontracting Act, the U.S. Foreign Corrupt Practices Act of 1977, 15 U.S.C. §§ 78-1 et seq., and the UK Bribery Act, and the Canadian Corruption of Foreign Public Officials Act. SK members must endorse and faithfully implement internationally accepted laws and international conventions, such as the Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the 10 Principles of the UN Global Compact, and the UN Guiding Principles on Business and Human Rights.

      Article 5 Matters on Reporting Violations and Protection of Whistleblowers

      If a violation of the Code of Ethics occurs during the course of business, SK members must report it through the following channels to ensure that the conduct is addressed promptly, and the whistleblower will not be penalized for reasonable reports.

      Website :

      Email :

      Post: 22nd floor, Grand Seoul Tower 1, 33 Jong-ro, Jongno-gu, Seoul, Korea

Ethical Practice Terms and Conditions for Partner Companies

SK Materials Co., Ltd. delivers the ethical practice terms and conditions to all of its partner companies conducting business with SK Materials Co., Ltd. and its affiliates, and recommends them to comply with ethical management principles.

  • Ethical Practice Terms and Conditions for Partner Companies
    • Download(ENG) Download(KOR)

      [                ](hereinafter referred to as “Our Company / We / Us”) fully acknowledges and empathizes that it is of the utmost importance to secure and maintain ethics and reliability in the transactions (including transactions currently in progress and all transactions to be conducted under contracts entered into with You in the future; hereinafter referred to as “All Transactions”) and relationships with SK Materials Co., Ltd. and its subsidiaries and affiliates (hereinafter referred to as “Your Company”), and therefore, We hereby take an oath as follows in connection with the fulfillment of our duties and responsibilities to prevent unethical conduct (hereinafter referred to as the “Written Oath”).

      Article 1 (Purpose)

      Our Company/We are aware that the purpose of this Written Oath is to ensure that all transactions with Your Company comply with the ethical practices set forth in this Written Oath so as to facilitate a wholesome and fair trade order and to make sure that an ethical corporate culture takes root.

      Article 2 (Duty to Prevent Payment of Bribery to Public Officials)

      Our Company/We understand Your Company's commitment to ethical management and We will comply with all domestic and foreign anti-bribery and anti-corruption laws and regulations, including the United Nations Convention against Corruption, the Foreign Corrupt Practices Act (FCPA), the Act on Combating Bribery of Foreign Public Officials in International Business Transactions to maintain a fair trade order in all transactions.

      Article 3 (Types of Violations and Sanctions for Violations)

      ① Our Company/We declare and guarantee that Our Company/We have committed no violation of associated laws and regulations, and commercial practices or in particular the following unethical conduct (hereinafter referred to as “Unethical Conduct”) in past business relationships with Your Company (excluding cases where we have been sanctioned for unethical conduct but the sanction period has expired), and Our Company/We make an oath to prevent any violations of associated laws and regulations, and commercial practices or unethical conduct during the course of future transactions (including all transactions currently in progress with Your Company and all transactions to be conducted under contracts entered into with you in the future). In addition, Our Company/We promise not to engage in any unethical conduct that adversely affects corporate ethics and reliability even in transactions with another company or a third party.

      ② If Our Company/We are deemed to have breached Paragraph 1 of this Article, Your Company may launch an investigation into Our Company/Us, and Our Company/We agree that if any unethical conduct (including post incident discoveries of unethical conduct related to past transactions with Your Company) occurs, Your Company will notify Your Company and all subsidiaries and affiliated within the corporate group (SK) affiliated to Your Company hereinafter referred to as “subsidiaries and affiliates that share information on unethical conduct”) of the fact that the Our Company/We have committed unethical conduct and the detailed description of the applicable unethical conduct (hereinafter referred to as the “information related to unethical conduct”). Our Company/We certify that this notice and the resulting distribution of information related to unethical conduct do not constitute a breach of Your Company's duty of confidentiality, nor do they constitute an infringement upon Our Company/Our trade secrets.

      ③ Our Company/We agree that, based on the unethical conduct (including publicly known unethical conduct that occurred in connection with Our Company/Our transactions with another company or a third party), the subsidiaries and affiliates that share information on unethical conduct may impose disciplinary actions (meaning the refusal to renew a contract and the restriction on new transactions, but for Your Company as the party directly concerned in the transaction in which unethical conduct occurred, they are not necessarily limited those actions, meaning reasonable sanctions corresponding to the unethical conduct) for transactions with Our Company/Us, and certify that Our Company/We will not raise any objections, including holding Your Company and the subsidiaries and affiliates that share information on unethical conduct accountable for civil and criminal liability in this regard.

      ④ Our Company/We will reject any offer to engage in unethical conduct from the employees and stakeholders of Your Company, and immediately report the details thereof to Your Company's ethical management team ( and fully accept any request for cooperation in the investigation related to the unethical conduct.


      • SK Group runs an ethical management reporting/counseling website ( You can report or have a counseling session on the website anonymously without any need to log in or certify your identity. Also, the website is managed and investigations are conducted at the group level rather than by an individual company. In the process of verifying the facts in the report, the identity of the whistleblower is strictly protected in accordance with internal regulations to prevent its disclosure against his/her will, and members who provide cooperation for the investigation, such as making statements and providing data, are equally protected as the whistleblower. In addition, SK Materials Co. Ltd. and its subsidiaries and affiliates run a “reduction/exemption scheme for voluntary reporters.” Even if a partner company or an employee of a partner company has participated in unethical conduct, please note that, as long as the conduct is voluntarily reported, disciplinary actions for the unethical conduct may be reduced or exempted on account of the type of unethical conduct, the degree of participation, the timing of the voluntary report, and the accuracy of the report.

        Ethical Management Team of SK

      Date of consent :

      Corporation :

      Business Registration No :

      Address : :

Ethical Management Education for Members and Partner Companies



SK Materials Co., Ltd. conducts ethical management and anti-corruption training every year for all members (including contract and dispatched workers) working in the headquarters, overseas branch, and affiliated subsidiaries to raise the members’ ethical awareness while sharing enactments and revisions of laws and regulations related to major issues. In addition, specialized education on ethical management practices is provided for the CEO, management, and the board of directors. Specialized courses are also operated for specific corporations, departments, and positions. To improve the awareness level of ethical management among overseas members, the practice rules of ethics code, counseling, and reporting procedures are provided in the local language for each overseas business site, and ethics training contents specialized for foreign members are translated into the local language for each overseas business site.


Partner Companies

SK Materials Co., Ltd. provides anti-corruption education not only for its members but also for its 28 shared-growth partners every year to enhance their ESG and plans to expand ethical management and anti-corruption education to more partners of SK Materials Co., Ltd. and affiliates.

Anti-corruption Education
  • Implemented anti-corruption education for member companies of the Shared-Growth Council
    (28 companies)
  • Expanding anti-corruption education to 50 partner companies
  • Expanding anti-corruption education to 100 partner companies

Ethical Awareness Promoting Activities


SK Materials Co., Ltd. is operating communication channels such as ethics counseling and ethical management site to strengthen ethical management status monitoring and supervision. The Code of Ethics is made public and we receive counseling and reports for unethical behavior through these channels. In addition, a separate page is operated on the company intranet to facilitate communication with internal members. Ethical management issues that may arise are shared with members. Furthermore, we are carrying out a variety of activities to motivate members to practice ethical management through a campaign not to give and receive gifts on holidays, providing the letter of ethical management guide, an ethical management quiz event, and information on reporting procedures.

Ethical Management Practice Survey


Each year, SK Materials Co., Ltd. conducts an ethical management practice survey targeting all members of SK Materials Co., Ltd. and the whole subsidiaries to check the compliance with the company’s Code of Ethics and ethical culture level. The key implications derived from the ethical management surveys which include mutual ethical behaviors among members, elements of impeding SV, and continuous improvement of the ethical management practice system shall be reflected in the ethical management activities in the next year. We are supporting ethical management infrastructures such as providing customized ethical management content and material to key business sites and organizations where it is deemed that ethical management risk is growing.

Ethical Management Practice Pledge


Members and business partners promise to implement ethical management through the pledge of ethical practice. In addition, all members and business partners write a pledge of ethical practice each year through the online system, to voluntarily reflect the meaning of the Code of Ethics and review the ethical standard.

Ethical Management Practice Workshop


SK Materials Co., Ltd. holds an ethical management practice workshop for all members of the entire SK Materials Co., Ltd. affiliates every year, to support members in making the right choices in the ethical dilemma situations they may face in the organization. After watching videos related to the topics, members actively discuss ethical risk cases and major issues such as “lack of personality respect” and “false reporting”, share ideas on improving the ethical management practice, and form consensus on the direction to improve the organizational culture.

Operation of System for Reporting Bribery


Accepting bribery from stakeholders is prohibited regardless of any reason whatsoever. And in case that money, gifts, and other things have been accepted inevitably, they have to be reported to the Ethic Management Team according to the procedure, then returned to the stakeholder. In case it is disrespectful or impossible to return the items, they will be donated to a social welfare facility and it shall be notified to the stakeholder with a letter to prevent any recurrence.

Ethical Risk Assessment by Operation Field


To enhance the level of autonomous ethical management, SK Materials Co., Ltd. conducts internal inspections of ethical risks by each field through a checklist at least once a year. The checklist has been made to inspect and assess risks reflecting the characteristics of operations, including HR management, cost management, purchase/business partner management, sales/receivables management, investment management system, inventory management, and management of peculiar risks.

Ethical Management Reporting

SK Materials Co., Ltd. operates an ethical management reporting system so that not only members but also all stakeholders can report unethical behavior. Report is received and processed behind closed doors, and the identity and content of the informant are thoroughly protected in accordance with the informant protection regulations.

Report Processing Procedures

Receiving the report


Identifying the contents


Initiating the investigation


Wrapping up the investigation


Closing the case


Processing result


How to Write a Report

Please describe the case in as much detail as possible according to the principle of 5 W's and 1 H.

  • Please fill in the personal information of the subject using real name if possible.
  • Please provide detailed description of when, where, and what kind of the problem occurred.
  • Documentary evidence such as photographs, documents, etc. would be of great help in the investigation of the violation.
    (In the case where the evidence is insufficient despite the obvious violation, specify the channel of obtaining information and the details, place, and confirmation method of the violation to verify the facts)
  • Investigation will begin after receiving the report, feedback on the progress of each step will be provided to the informant until the investigation is closed, and the results of the processing can be checked on the "Report Processing Results" page or via the reply method (e-mail or phone) selected by the informant.
  • Detailed guide on reporting procedures
    • Ethics Counseling and Report Handling Procedures
      1. General Matters of Ethics Counseling & Report Handling

      1.1 Solution to inquiries regarding ethics

      • 1)If executives and staff members have any questions about the interpretation or application of the Code of Ethics, Practice Guideline or FAQ, they shall ask them to the leader of the organization or the department in charge of ethical management or have counseling and follow their interpretation.
      • 2)The leader of the organization shall resolve the matters asked by the executives and staff members under his/her control according to the standards and policies of the Company. If it is difficult to resolve the matters by himself/herself, the leader shall handle them through consultation with the department in charge of ethical management.
      • 3)The department in charge of ethical management shall conduct counseling according to the procedures of “Ethics Counseling.”

      1.2 Reporting and handling of violations

      • 1)An executive or a staff member who noticed violations of the Code of Ethics, Practice Guideline or FAQ shall report the case to the leader of the organization or the department in charge of ethical management.
      • 2)If the leader of the organization receives a report about violations, he/she shall resolve it according to the standards and policies of the Company or through consultation with the department in charge of ethical management. If the leader of the organization has solved the matter personally, it is necessary to inform the department in charge of ethical management of the result of the measures.
      • 3)The department in charge of ethical management shall handle a reported matter according to the procedures of “Report Handling.”

      1.3 Installation and operation of ethics counseling & reporting channel

      • 1)The department in charge of ethical management shall operate the counseling & reporting channel to facilitate easy counseling and reporting of ethical management for interested parties and systematic handling of the matters.
      • 2)Counseling and reporting can be done through the following channels and all channels are available 24/7.
        • Online at: Integrated online report channel of SK Group (the Group), available 24/7
        • E-mail:, available 24/7
        • Mail: Person in charge of ethical management of Audit Room, available 24/7 SK Materials Co., Ltd. 22F, Granseoul Tower 1, 33 Jong-ro, Jongno-gu, Seoul, 03159, Republic of Korea
      2. Ethics Counseling

      2.1 Processing the applications for counseling

      • 1)Ethics counseling shall be offered for the following inquiries.
        • The Company’s standards and policies for ethical management
        • Interpretation of the Code of Ethics, Practice Guideline and FAQ
        • General knowledge regarding ethical management, etc.

      2.2 Counseling

      • 1)The department in charge of ethical management shall provide appropriate and consistent interpretation and guidelines for the matters of counseling according to the Code of Ethics, Practice Guideline, FAQ and the ethical management policies of the Company.
      • 2)When consultation from relevant departments are needed or when there is no established policy of the Company on the matters of counseling, it is required to establish policies of the Company through consultation with the related departments and provide counseling accordingly.

      2.3 Notification and follow-up management

      • 1)The result of ethics counseling shall be notified to the counselee in an appropriate manner.
      • 2)The department in charge of ethical management is required to prevent disclosure of the identification of the counselee or the contents of counseling against the will of the counselee.
      • 3)The contents of counseling shall be maintained and managed using a separate form.
      3. Report Handling

      3.1 Acceptance of report

      • 1)Reporting means providing information about violations of Code of Ethics, Practice Guideline or FAQ by executive or a staff member.
        • Dereliction of duty, Conflict of interest, Inappropriate usage of the Company’s assets and information, Improper offer or receipt of gifts/hospitability/etc., Violation of mutual respect between the members of the Company (discrimination, sexual harassment, verbal abuse, etc.), Distortion of management information, Violation of Fair trade and competition, Violation of policies on safety/health/environment, Violation of anti-corruption, Violation of protecting personal information, and Violation of the Company’s other policies and working principle etc.
      • 2)For fact check, the department in charge of ethical management shall receive the report based on the principle of 5W1H and secure related evidentiary materials as many as possible.
        • Personal information of the Informant (including whistle-blower): Name, department, telephone number, etc.
        • Contents of report :
          • Identify details based on the principle of 5W1H
          • Evidentiary materials, etc. that can support the contents of the report
      • 3)In case a report is received through channel other than the integrated online report channel of the Group, such as e-mail and mail, it shall be registered in the integrated online report channel of the Group.

      3.2 Fact verification

      • 1)In principle, fact verification of a report shall be conducted only for the report submitted under the Informant (including whistle-blower)’s real name. However, fact verification of an anonymous report can also be allowed depending on circumstances in consideration of the character and materiality of the report.
      • 2)e department in charge of ethical management shall conduct fact verification of the report.

      3.3 Taking measures against violations

      • 1)If violations are confirmed to be true upon the investigation results, measures shall be taken against the violators (executives, staff members or suppliers) under relevant Company regulations.
      • 2)If it is confirmed that the report has been made for solely personal purposes including libel, slander and falsehood, appropriate measures shall be taken against the involved Informant (including whistle-blower) according to relevant Company regulations.
      • 3)If no violation is found, the case shall be concluded by the department in charge of ethical management.

      3.4 Reporting and follow-up actions

      • 1)If any disciplinary measures are needed, the case shall be reported to the person who has the right of approval for the matter.
      • 2)The result of the measure shall be notified to the Informant (including whistle-blower) in an appropriate manner.
      • 3)The result of the measure shall be concluded after registering it in the integrated online report channel of the Group.
      4. Informant (including whistle-blower) Protection Policy

      4.1 Protection policies

      • 1)An Informant (including whistle-blower) should not suffer from retaliatory action in any form by other executives or department to which he/she belongs for having reported a possible violation or submitting related statements or materials.
        • If an Informant (including whistle-blower) has received disadvantageous measures due to the report, he/she can request the department in charge of ethical management to rectify the disadvantages and take protective measures including transfer to another department.
        • If there is a request for corrective action and protection from an Informant (including whistle-blower), the department in charge of ethical management shall take measures to minimize the disadvantages of the Informant (including whistle-blower) and establish and implement measures to prevent recurrence of such an incident including sanctions against the person involved.
      • 2)It is required to keep the identity of the Informant (including whistle-blower) and the contents of the report confidential to prevent them from being revealed against the Informant (including whistle-blower)’s will.
      • 3)A person who cooperates with the investigation by submitting statements or materials during the process of fact verification of the report shall be protected in the same way as that of the Informant (including whistle-blower).
      • 4)A report made for solely personal purposes including libel, slander and falsehood shall not be protected.

      4.2 Sanctions and reduction/exemption

      • 1)If a person violates the “Informant (including whistle-blower) Protection Policy,” measures shall be taken according to the Regulation.
        • A retaliatory action giving disadvantages to the Informant (including whistle-blower) who has reported possible violation
        • Disclosure of identity of the Informant (including whistle-blower) or the contents of the report obtained officially or accidently
        • Tracking down the Informant (including whistle-blower) or instructing to track down the Informant (including whistle-blower)
      • 2)If a person who was involved in an action violating the Code of Ethics, Practice Guideline or FAQ or an illegal action reports the action voluntarily, sanctions against such an action can be reduced or exempted.

Subject to Report


Anti-corruption and exercising power trip on business partners (BP)
(Acceptance of money / hospitality, personal requests, equity investment, unfair instructions, verbal/physical abuse, etc.)


Lack of respect for colleague(s)
(Verbal / physical abuse, sexual harassment, ostracizing, unfair exclusion from business responsibilities, demand for personal errands, etc.)


Conflict of interests in business relationships
(Side job, excessive care of personal errands on the job, monetary transactions between colleagues, investment using inside information, transactions with specially related parties, etc.)


Unfair business decisions
(False reporting, performance data rigging, unlawful marketing practice, illegal use of company funds or assets, unauthorized disclosure of corporate information, etc.)


Damage to social values
(Non-compliance with environment / safety / health / quality regulations, disregard of socially disadvantaged groups, unauthorized disclosure of customer data, disclosure of false information to customers)

Cases where the investigation is difficult

  • In the case where there is no specific factual relationship or where it falls under speculation or vague suspicion
  • In the case where it is impossible to confirm the fact without the informant's additional cooperation because the contents are not clear
  • In the case of simple complaints and inconveniences, such as reporting unkind acts, expressing displeasure, and unilateral complaints filing
  • In the case of the request for a role beyond the legal authority of the company (BP's overdue wages, non-payment of payment by subcontractors, etc.)
  • In the case where what you intend to report is pending in the court

Informant Protection Regulations

We operate an informant protection program so that informants can report with reassurance that there is not any disadvantage.

  • 1. You will not be disadvantaged or discriminated against for the reason of the legitimate report.
  • 2. In case of receiving disadvantage due to reporting, you can submit a request for correction and protection to the ethics management department, and the ethics management department will take all measures to minimize the disadvantage.
  • 3. The identity and information of informants are kept strictly confidential so that they are not disclosed against their will.
  • 4. We will equally protect those who have cooperated with the investigation by making statements or providing data during the fact-checking process of the report.
  • 5. In the event of participating in an unethical or illegal act but voluntarily reporting the fact, your sanctions on the act can be reduced or exempted.

Anti-corruption Report Result

Category Unit 2019 2020 2021
Number of reports received during the reporting period case 5 6 10
Number of reports resolved during the reporting period case 5 6 10
Resolved reports rate % 100 100 100

Internal Audit

SK Materials Co., Ltd.’s Ethical Management Team aims to provide independent and objective audits that can add value to the company and improve the company’s operations. All management activities of SK Materials Co., Ltd.’s as a whole, including affiliated businesses, functions, and overseas subsidiaries which could be potentially subject to audit are managed as an audit population. The population list is annually updated with the change in the business environment. The annual audit plan is established through risk assessment in consideration of various factors such as audit resources and cycle, and then finalized through Audit Committee’s approval. The regular audits are conducted every year based on the finalized annual audit plan to evaluate the efficiency, effectiveness, and adequacy of internal control of the company's business activities, in order to derive recommendations and action plans established by organizations aiming for continuous improvement and mitigation of risks. We have a systematic audit process with guaranteed independence and effectiveness.

In addition, we are receiving reports from various stakeholders such as members and business partners via on-line, e-mail, and telephone reporting channels. Subsequently, we conduct fact verification to determine whether there is a violation of ethical standards. The planned audit and investigation results are regularly reported to the Audit Committee, and follow-up audits are conducted annually to track the implementation of audit recommendations. The company actively supports participation in various trainings and acquisition of professional certifications in order to continuously strengthen the capacity of the internal audit organization.