Namkwang Engineering will lead
in creating a clean company culture.

Corruption Prevention Committee, detailed management regulations revised on July 19, 2006

Article 1(Purpose)

The purpose of this detailed management regulations is to determine the matters regarding the management of Corruption Prevention Committee, intended to create a clean company culture.

Article 2 (Composition and duties of the committee)

The committee is composed of chairman, secretary-general, compliance administrator, compliance manager for each head office, and sub-committee members for each head office.

  • ① Chairman
    • A. The chairman directs the committee; the CEO takes the position ex officio
    • B. The chairman can assemble meetings for the committee, in which he or she serves as the chair.
  • ② Secretary-genera
    • A. The secretary-general assists the chairman; the head of the planning department takes the position ex officio.
    • B. The secretary general takes responsibility for practical affairs, such as report on Code of Ethical Conduct, and Related Rules (hereinafter referred to as Ethics Management Rules).
    • C. In the event where a violation of Ethics Management Rules occurs among executives and staff members, the secretary general must request an investigation to compliance administrator.
  • ③ Compliance administrator
    • The compliance administrator supervises whether the Ethics Management Rules are in compliance; the auditor takes the position ex officio.
    • The compliance administrator takes charge of investigation and audit of the reports and violations of Ethics Management Rules in the committee.
  • ④ Compliance manager for each head office
    • A. The compliance manager takes charge of compliance of Ethics Management Rules in each head office; each director of relevant head office takes the position ex officio.
    • B. The compliance manager takes responsibility for management and regulation of compliance to the Ethics Management Rules regarding the executives and staff members in the relevant head office.
    • C. The compliance manger takes measures to matters reported by sub-committee member of relevant head office, and then informs the grounds and results to the secretary-general.
  • ⑤ Subcommittee member for each head office
    • A. The subcommittee member takes charge of compliance of Ethics Management Rules in each relevant department, team, and site; each managing executive, head of department, head of team, and site manager takes the position ex officio.
    • B. The subcommittee member takes responsibility for education and distribution of Ethics Management Rules for the employees in the relevant department, team, and site.
    • C. D. (Deleted)

Article 3 (Committee meetings)

  • The committee meetings are sorted by regular meeting and on-demand meeting.
  • The regular meeting can be replaced by monthly management meeting; if required, the chair can order a call for a separate meeting.
  • The on-demand meeting can be held whenever the chairman recognizes its necessity.

Article 4 (Committee’s discussion, resolution, etc.)

  • Matters regarding decisions on major policies of the committee
  • Matters regarding the establishment of medium and long term general plan and implementation plan for corruption prevention of the company
  • Matters regarding establishment of education, promotion, and general plan for corruption prevention
  • Matters regarding the final settlement of violations and reports of Ethics Management Rules.

Article 5 (Meeting proceeding)

  • For matters of resolution or decision, the meeting is held in the order of proposal explanation, inquiry, discussion, and voting.
  • The secretary-general must distribute the bill to the committee members at least 5 days before the meeting.
  • Only the chairman, secretary-general, compliance administrator, and compliance managers for each head offices participate in voting.
  • Voting requires an attendance of more than 2/3 of members, and passes upon 2/3 or more of placet.
  • Depending on the result of the vote, the bill is submitted for either Second Reading, dismissal, or disciplinary / vindication committee.
  • In the event where a violation of the Ethics Management Rules is expected to cause a considerable loss and damage to the company, requiring an audit for the relevant matters, the audit can be ordered directly by the chairman without voting.

Article 6 (Corruption Prevention Secretariat)

Corruption Prevention Secretariat is established to handle practical matters such as report and compensation of corrupted conducts.

Article 7 (Reported matters)

  • If the executive of the company recognizes a violation of Ethics Management Rules by an executive or the other party of transaction, he or she must report to the secretary-general.
  • The method of report and compensation follows the Criteria for Corruption Report and Compensation.
  • The committee and the secretariat must protect the informant.

Article 8 (Disciplinary / vindication committee)

  • The disciplinary / vindication committee is replaced by the personnel committee; the resolution of committee discussion decides whether it will be (Type A) or (Type B) personnel committee.
  • The procedure of the personnel committee follows the company regulation.

Article 9 (Code of conduct)

  • Ethics Management Rules is enacted and revised by the committee.
  • The executives and the staff members must comply with the Ethics Management Rules.

Article 10 (Additional clause)

  • This detailed management regulation is implemented as of November 21, 2005.
  • This detailed management regulation is revised and implemented as of July 20, 2006.