Article 1 (Purpose)

This Code of Ethics (“Code”) aims to instill the understanding that ethics is the foundation of corporate competitiveness, providing ethical decision-making and behavioral standards for Sewon Group employees.

Article 2 (Scope of Application)

• The Code applies to all employees of Sewon Group and its subsidiaries, and encourages adherence by third parties such as investors, suppliers, agents, and consultants.

Article 3 (Basic Ethics of Employees)

• ① Employees shall take pride in the company and maintain an attitude of honesty and sincerity at all times.
• ② Employees shall uphold high ethical values and strive to maintain and enhance their personal dignity and the company’s reputation.
• ③ Employees shall uphold high ethical values and strive to maintain and enhance their personal dignity and the company’s reputation.
• ④ Employees shall perform their duties with a sense of ownership and do their utmost to find pride and fulfillment in their work.
• ⑤ Employees must promptly report any violations of this Code, or any instructions to commit violations, through established procedures to their supervisor or the Ethics Committee.
• ⑥ Employees recognize that ignorance of this Code and related policies does not excuse misconduct, and they must consult their supervisor or the Ethics Committee if they have any questions or concerns about potential violations.

Article 4 (Fulfillment of Mission)

Employees shall share the company’s management philosophy and vision, embrace its goals and values, and diligently fulfill their assigned responsibilities with sincerity, harmony, and creativity.

Article 5 (Self-Development)

Employees shall establish for themselves the ideal qualities of talent required in this era of globalization and openness, and strive to achieve them through continuous self-development.

Article 6 (Fair Performance of Duties)

• ① Employees shall perform their duties fairly and in strict compliance with all relevant regulations.
• ② Employees shall not engage in any unethical or illegal behavior, including improper instructions, solicitations, requests, or preferential treatment, that may undermine their own or others’ fair performance of duties or that would be subject to public criticism.

Article 7 (Avoidance of Conflicts of Interest)

• ① Employees shall exercise due care in performing their duties to ensure that no conflicts of interest arise between the company and themselves.
• ② Employees shall respect the privacy of colleagues as long as it does not disrupt the work environment or public morals, and shall promote a mature organizational culture based on mutual trust and understanding.
• ③ When conflicts of interest arise between the company and individuals or departments, employees shall prioritize the interests of the company.

Article 8 (Prohibition of Improper Benefits)

Employees shall not offer or accept money, entertainment, conveniences, or other benefits from stakeholders that exceed socially acceptable norms and could undermine fairness in the performance of their duties.

Article 9 (Separation of Public and Private Affairs)

• ① Employees shall clearly distinguish between public and private matters in the performance of their duties.
• ② Employees shall not use company property for personal purposes or misappropriate company budgets for unintended uses, thereby causing financial loss to the company.
• ③ Employees shall not use company property for personal purposes or misappropriate company budgets for unintended uses, thereby causing financial loss to the company.

Article 10 (Mutual Relationships Among Employees)

• ① Employees shall observe basic workplace etiquette and shall not engage in disrespectful language, defamatory remarks, or any behavior that causes distress to colleagues.
• ② Employees shall not form factions or engage in discriminatory treatment based on educational background, gender, religion, blood ties, or place of origin.
• ③ Employees shall not engage in improper solicitations, exchange of gifts, or financial transactions that exceed socially acceptable norms.
• ④ Supervisors shall not give unjust instructions to subordinates, and subordinates shall follow legitimate instructions while rejecting improper ones.
• ⑤ Employees shall not engage in sexual advances or behavior that could cause sexual humiliation among colleagues.

Article 11 (Wholesome Lifestyle)

• Employees shall reject extravagance and maintain a frugal lifestyle, practicing modest consumption and engaging in wholesome leisure activities.

Article 12 (Transparent Information and Accounting Management)

• ① Employees shall acquire and manage all information accurately, and record and manage accounting information with integrity and honesty.
• ② Employees shall not disclose or misuse information acquired in the course of their duties without prior authorization or approval from their department head or executive.
• ③ Employees shall not submit false or exaggerated reports for the benefit of any individual or department, nor conceal or monopolize important information.
• ④ The company shall disclose management information in accordance with relevant regulations to enhance transparency and trust.

Article 13 (Protection and Proper Use of Company Assets)

• ① Employees have a duty to protect and use company assets efficiently.
• ② Employees shall protect company assets from loss, damage, misuse, theft, or embezzlement.
• ③ Employees must immediately report any situations or incidents that may cause such outcomes to their supervisors.

Article 14 (Confidentiality and Information Protection)

• ① As most company business information is confidential or proprietary, confidentiality must be strictly maintained unless disclosure is approved by the company or required by law.
• ② Employees shall not use information acquired in the course of work for personal gain.

Article 15 (Code of Ethics Pledge)

• Employees, recognizing that ethics is the foundation of corporate competitiveness, shall submit a pledge to practice this Code so that the company may earn and maintain the trust of its customers.

Article 16 (Respect for Customers)

Employees shall always respect customers, recognizing them as the reason for the company’s existence and its ultimate goal, and shall make customers the top priority in all actions by thinking from the customer’s perspective.

Article 17 (Customer Satisfaction)

• ① Employees shall accurately understand customer needs and expectations and strive to provide the best quality products, unique technology development, and superior service in response.
• ② Employees shall always listen humbly to customer opinions and suggestions and promptly and accurately address customer complaints.
• ③ Employees shall recognize that the growth of customers is their own growth and shall continuously create genuine value that benefits and satisfies customers.

Article 18 (Protection of Customer Interests)

• ① Employees shall protect customers’ assets, intellectual property rights, trade secrets, and information even more carefully than company property and shall not infringe customer interests through unethical conduct.
• ② Employees shall promptly and accurately provide customers with information they need or are entitled to know.
• ③ Employees shall always speak the truth to customers, keep promises, offer products and services of the highest quality at reasonable prices, and respond promptly and accurately to legitimate customer requests.

Article 19 (Compliance with Relevant Laws and Regulations)

• ① Employees shall obtain information on competitors and business partners through legitimate means that do not invite social criticism.
• ② Employees shall not infringe or misappropriate competitors’ tangible or intangible assets without authorization.
• ③ Employees shall not engage in unfair collusion with competitors regarding prices, sales terms, or market allocation that may harm customers.

Article 20 (Pursuit of Free Competition)

Employees shall respect the principles of a market economy and pursue fair and sound competition with competitors based on mutual respect.

Article 21 (Fair Transactions)

• ① Employees shall provide equal opportunities to all qualified individuals and organizations in bidding and contract processes for construction, services, and procurement conducted by the company.
• ② Employees shall conduct all transactions fairly and transparently on an equal footing, ensuring that they take place openly and in ordinary business locations.
• ③ Employees shall not exploit a superior position in transactions to demand money or impose unfair terms and conditions.
• ④ Employees shall enter into integrity agreements for all transactions and comply with them.
• ⑤ Employees shall not be subject to any internal or external pressure or solicitations in conducting transactions.

Article 22 (Respect for Employees)

Employees shall respect one another with trust and affection under the belief that they are one family, and respect individual religions, political opinions, and privacy.

Article 23 (Fair Treatment)

The company shall provide equal opportunities for education, promotion, and other matters based on individual abilities and qualifications, and shall fairly evaluate and reward performance and achievements.

Article 24 (Talent Development and Promotion of Creativity)

• ① The company shall actively support employees’ capacity building, foster them as professional and creative talents, and create an environment where all employees can freely make suggestions and express opinions to encourage independent and creative thinking and behavior.
• ② The company shall assign duties comprehensively considering employees’ aspirations, aptitudes, and abilities so that they can grow into talents through job performance.

Article 25 (Improvement of Quality of Life)

• ① The company shall establish systems that enable employees to perform their duties properly and strive to ensure they achieve pride and fulfillment through their work.
• ② The company shall create a pleasant and safe working environment and actively develop and implement programs to improve the quality of life for employees and their families, including health, education, and welfare.

Article 26 (Contribution to National and Community Development)

• ① Employees shall endeavor to grow the company into a world-class manufacturing company through rational and responsible management and improve employee wages and welfare through efficient business operations.
• ② Employees shall promote industrial accident prevention activities to enhance individual happiness, research and develop new industrial technologies, and actively contribute to the development of individuals, local communities, and the nation by creating social wealth.

Article 27 (Prohibition of Improper Political Involvement)

• ① Employees shall not engage in improper political activities in violation of relevant regulations.
• ② Even when engaging in lawful political activities, employees must ensure that such activities are not misunderstood as the company’s political involvement.

Article 28 (Safety and Risk Prevention)

Employees shall maintain cleanliness in the workplace and comply with all relevant safety regulations to prevent accidents and manage risks.

Article 29 (Environmental Protection)

Employees shall recognize the importance of environmental issues, fully understand and comply with domestic and international environmental laws and regulations, and continuously strive to protect the environment and prevent pollution.

Article 30 (Labor-Management Harmony)

Employees shall recognize that both labor and management are stakeholders in the company and shall strive for coexistence and prosperity based on trust and harmony.

Article 31 (Compliance with International Business Norms)

Employees shall respect the order of international trade, comply with the laws and cultures of the countries where they operate, and contribute to the economic development of the host countries.

Article 32 (Duty of Compliance and Responsibility)

• ① Employees must understand and comply with this Code and bear responsibility for any violations.
• ② Executives and department heads are responsible for supervising and ensuring their staff’s compliance with this Code.

Article 33 (Duty to Report and Confidentiality)

• ① Employees who become aware of or commit any violations of this Code must report it to their department head or the Ethics Management Committee.
• ② Department heads and the Ethics Management Committee must not disadvantage or disclose the identity of whistleblowers.
• ③ Employees who learn about reports during their work or incidentally must maintain confidentiality.
• ④ Self-reported violations may result in mitigated disciplinary action.

Article 34 (Inspection of Compliance)

• ① The General Affairs Team shall regularly inspect employee compliance with this Code at least once per year and may conduct additional inspections during periods when violations are more likely (e.g., holidays, vacation seasons).
• ② The General Affairs Team shall report inspection results to the Ethics Management Committee.

Article 35 (Sanctions for Violations)

• ① If an employee obtains property or financial benefits valued at 100,000 KRW or more through non-employees and fails to report it in accordance with regulations, the individual shall be referred to the Ethics Management Committee; if the counterparty is a business partner, a warning shall be issued.
• ② The company may suspend all transactions with any partner that has received three or more warnings.

Article 36 (Training)

• ① he General Affairs Team shall establish and implement an annual training plan to promote ethical awareness and compliance with this Code among employees.
• ② Training shall be conducted at least once annually and also provided to new employees upon hiring.

Article 37 (Disciplinary Action and Awards)

• ① The company’s CEO may take disciplinary action or other necessary measures against employees who violate this Code.
• ② The types, procedures, and effects of disciplinary actions shall follow the company’s disciplinary regulations.
• ③ The CEO may grant appropriate rewards or personnel benefits to employees who comply with this Code and contribute to establishing ethical management.

Article 38 (Establishment of the Ethics Management Committee)/p>

• ① The company’s CEO shall establish and operate an Ethics Management Committee to promote and implement ethical management and ensure the execution of this Code.
• ② The Ethics Management Committee shall perform the following duties:
  • · Decide major policies related to promoting ethical management
  • · Establish and amend ethics-related regulations
  • · Interpret important ethics-related regulations
  • · Review employee practices related to this Code
• ③ The Committee shall be composed of three or more executives, and details regarding its establishment and operation may be specified separately.
• ④ The Committee shall continuously improve and develop the contents of this Code to reflect organizational and environmental changes, and may separately define and operate detailed matters related to the operation and procedures of this Code as needed.