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Governance

Ethical Management

Ethical Management Framework

Ethical Management Implementation System

SK D&D has established a Code of Ethics to fulfill our corporate social responsibility with a strong sense of ethical and philanthropic duty, in addition to our economic and legal obligations. This code serves as a standard for decision-making and behavior in all management activities. Our Code of Ethics undergoes regular reviews by the Internal Control Part and is revised following discussions with relevant management support departments, ultimately receiving approval from the CEO. All employees at the domestic headquarters and subsidiaries participate in the 'Ethical Management Practice Pledge,' as outlined in Chapter 4, Article 22 of the Code of Ethics, conducting business honestly, fairly and transparently with key stakeholders such as customers, employees, and suppliers. SK D&D manages all ethical management risks through a 'Prevent-Detect-Respond' process, aiming to proactively prevent ethical risks, continuously monitor them, and promptly respond as necessary.

Key Concepts of Code of Ethics

Ethical Management Process

Ethical Management Organization

SK D&D endeavors to cultivate ethical awareness of our employees through the Internal Control Part, which annually conducts ethical practice training, workshops, and solicits pledges for ethical management practices. Additionally, as the lead department under the Audit Committee, the Internal Control Part oversees external audits, internal accounting management systems, internal audits, and related risk assessments. It formulates an annual plan for internal audits and ethics/anti-corruption audits, and reports these to the Board of Directors' Audit Committee. The Audit Committee reviews these plans and outcomes related to ethical management, ensuring the implementation of improvement measures, thereby contributing to establishing and advancing a transparent and responsible culture of ethical management.

Ethical Management Organization

Internalization of Ethical Management

Ethical Management Training

SK D&D is dedicated to promoting a robust ethical culture across all employees, including contract workers, through our ethics and anti-corruption training programs. These initiatives cover mandatory annual training on disability awareness, sexual harassment prevention, and workplace bullying prevention. Additionally, SK D&D offers various other training modules, including guidance on using the SK Ethical Management Reporting System and case studies on workplace bullying incidents. Achieving a 100% participation rate annually, executives and employees alike internalize ethical management practices through these sessions.

Furthermore, SK D&D hosts an annual Ethical Management Practice Workshop to reinforce ethical awareness among employees of all levels. This workshop encourages cross-hierarchical and cross-organizational discussions on effective decision-making in ethical dilemmas. In 2023, workshops tailored by position and department were held for a total of 265 employees and executives, representing approximately 91% of eligible attendees. Moreover, SK D&D actively promotes awareness through its quarterly distribution of ethical management letter via email, and prohibits holiday gift exchanges with business partners, promoting ethical practices and fostering a consensus on their importance.

2023 Ethical Management Trainings Performance

CategoryFrequencyDetailsParticipation
Ethical management letterQuarterlyDeliver updates on ethical management activities plan and performance on a quarterly basis via email100%
Ethical management practice pledgeAnnuallyPledge to abide by the Code of Ethics and Ethical Conduct Guidelines100%
Online trainingAnnuallyProvide workplace bullying cases and guidance of using reporting channel ('Sotong Hotline')100%
Legally mandatory trainingMore than once a yearConduct trainings on improving disability awareness, workplace sexual harassment and bullying prevention, and personal data protection, etc.100%
Ethical management practice workshopAnnuallyEmpower employees at all levels to make ethical decisions and voice their opinions on internal policies and issues91%*
Ethical compliance guide for holidaysBiannuallyEncourage employees and partners to adhere to ethical management practices during holidays and report gift acceptance (including training on the revised Improper Solicitation and Graft Act)100%
  • *The participation rate in 2023 includes employees from 'SK eternix Co., Ltd.' which was spun off in March 2024

Ethical Risk Monitoring and Audit

Ethical Risk Monitoring

Ethical Risk Detection System

SK D&D operates a self-regulation system at its headquarters and subsidiaries to prevent corruption and unethical behaviors in its business activities. Workinig-level departments in key business areas voluntarily monitor and detect ethical risk levels annually. In 2023, we conducted 76 detailed checks across six areas (HR, Cost, Procurement/BP, Sales/Bond, Investment, and Extraordinary risk management) to prevent and eliminate potential ethical and corruption risks, restructuring our ethical risk management system.

Ethical/Anti-Corruption Audit

SK D&D conducts annual regular audits on ethics and anti-corruption risks across all operational sites, including headquarters and subsidiaries. In 2024, we performed audits aimed at enhancing ethical and corruption risks prevention and management system within our subsidiaries, including reviews of regulations, roles and responsibilities (R&R), and processes. Audit plans and execution details were reported to the Audit Committee, and corrective actions were implemented. Upon identifying ethical and anti-corruption risks through internal audits, the Internal Control Part implements corrective actions or collaborates with relevant departments to mitigate risks.

Ethical Management Practice Survey

To diagnose and improve the ethical management practices of its employees, SK D&D conducts an 'Ethical Management Practice Survey' annually among all employees and business partners since its introduction in 2015. The survey evaluates practices, culture, systems, and types of unethical behavior. Based on survey results, priority improvement areas* are identified to strengthen and enhance the group-wide ethical management system. In addition, we carry out a regular 'Supplier Ethical Management Survey' for our suppliers. In 2023, we assessed 49 key suppliers for ethical management violations related to purchase contracts, with no reported unethical behavior issues.

*Priority improvement areas for 2023: Transparent disclosure of corrective actions, including investigations and disciplinary actions, and strengthening the reliability of reporting channels.

Ehical Management Whistleblowing Channel

SK D&D operates 'SK Ethical Management,' the SK Group-wide ethical management reporting channel for all stakeholders and its ‘Sotong Hotline' to investigate unethical behavior, such as disrespect toward internal employees. Through these channels, we receive anonymous reports on unethical behavior and unfair transaction practices by employees. We strictly protect the identity and confidentiality of whistleblowers to prevent any disadvantages to them and operate a whistleblower protection system to ensure whistleblowers do not suffer any disadvantages or discrimination for making legitimate reports. The Sotong Hotline is operated by an independent third-party organization to minimize contact among employee, ensuring objective and transparent investigations.

SK D&D Whistleblowing Channel

  • *SK Ethical Management: SK D&D Internal Control Part / skdnd.ethics@sk.com
  • **Sotong Hotline: SK D&D People & Culture Part

Types of Whistleblowing

Whistleblower Protection Program

Whistleblowing Procedure

Reports and Actions Taken

In 2023, a total of 9 ethical management reports were received through SK Ethical Management, involving one case of misconduct and bullying of business partners, four cases of improper business conduct, and four other non-administrative complaints. These reports underwent internal investigation and were successfully closed with implementation of corrective actions.

Whistleblowing Reported and Resolved Status
CategoryReporting TypeUnit202120222023
ReportingMisconduct and bullying of business partnersCases011
Lack of respect for colleaguesCases000
Conflicts of interests in business relationshipsCases000
Improper business conductCases004
Damage to social valuesCases000
Violation of company ethics rules*Cases100
Other (non-administrative reports, such as complaints)Cases674
Actions takenSuspensionCases000
Reprimand & WarningCases115
OtherCases674
Resolution rate%100100100
  • *In cases of workplace bullying in 2021, disciplinary resolutions were taken by the HR committee