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The Code of Ethical Conduct is purported to set forth the guidelines for all the members of Huneed Technologies on the limit, behavioral standards and the relevant compliance matters with regard to the offer and acceptance of payment, entertainment, convenience and the like to and from customers in implementing the Code of Ethics.

1. Payment: money (cash, gift vouchers, free-use tickets, etc), gifts and other financial profits
2. Entertainment: meals, drinks, golf, public performance, tour and the like
3. Convenience: travel, lodging, event support and other benefits
4. Interested parties: officers/employees, affiliates, business partners and organizations whose rights and obligations are directly affected by the performance of the duties of the members of the Company
5. Customary level: a common sense of other officers, employees and normal people points to a level that is understandable, commonplace and reasonable, in regard of which the recipients of the offers do not feel burdensome and can carry out their jobs justly and fairly

1. Under no account shall we either demand or accept payment from interested parties, nor shall the Company promise or offer payment to the interested parties. In addition, we shall not ask any improper favors to the interested parties nor make any improper offer or acceptance of gifts or financial profits to and from the interested parties for the purpose of securing a contract or maintaining current businesses. An exception, however, applies to the case in which the interested parties give a souvenir with their company logo displayed on, or give a souvenir or gifts with value less than KRW 50,000 to all the attendees of the events hosted by them. The same exception applies to the case in which the Company does the same to the interested parties.
2. Any payment received with no clear perception should be returned to the offeror immediately. If a return of payment is not practical, then, such payment should be reported and deposited to the Ethics Management Team for an open and appropriate handling of such payment.
3. Small gifts prepared with even contribution by employees and officers for the purposes of consolation, encouragement and reward is not regarded as payment.

We shall neither offer nor receive any entertainment that is above the customary level (KRW50,000 per person). If an offer or receipt of entertainment is unavoidable, it should be communicated to and discussed with the Ethics Management Team in advance. If pre-discussion is not practical, then post-report should be made within 1 week of an offer or receipt of entertainment.

1. We shall refuse to accept any offer of convenience such as travel, lodging and the like, which is over the customary level. An exception, however, applies to the case in which an offer of convenience is given to all the attendees of the event hosted by the interested parties.
2. We shall not offer any convenience to the interested parties, which is over the customary level. If such an offer is unavoidable, it should be communicated to and discussed with the Ethics Management Team in advance. If pre-discussion is not practical, then post-report should be made within 1 week of an offer of convenience.

1. We shall not indiscreetly circulate the news of congratulations and condolences to the interested parties, nor shall we circulate such news through third parties. An exception, however, applies to the case where circulation of the news of congratulations and condolences is made to the unidentified many through newspapers or intra-net notice board.
2. The amount of money received on congratulations and condolences should not exceed KRW50,000 and any amount exceeding KRW100,000 should be returned to the offeror.
3. If it is not practical to return the money received on congratulations and condolences, which exceeds KRW100,000, such money should be reported and deposited to the Ethics Management Team. An exception, however, applies to the case where the Company or team(s) or division(s) gives the money for congratulations and condolences in accordance with its internal rules.
4. In case of making a payment for congratulations and condolences to the interested parties, it is advised that such payment should not exceed KRW50,000, and any payment over KRW100,000 should be communicated to and discussed with the Ethics Management Team prior to making such payment.
5. Any gifts such as a floral wreath for promotion and job transfer should be handled in the same manner as the money for congratulations and condolences. If the number of such gifts is over the customary level, then, it should be refused or returned.
6. Personal expenditure on congratulations and condolences within the Company should not be spent out of the Company expenses.

1. Money transaction of any kind (lending, borrowing, investment, etc), loan guarantee and real estate transaction with the interested parties are strictly prohibited.
2. If a money transaction with the interested parties is unavoidable, it should be discussed with the Ethics Management Team in advance.

1. No event support from the interested parties is allowed for an event organized by the teams or activity groups under the Company sponsorship.
2. Receipt of an offer of transportation, place, services and the like from the interested parties for the Company event shall be construed and treated as receipt of an event support.
3. If an offer or receipt of an event support is unavoidable, it should be communicated to and discussed with the Ethics Management Team in advance. If pre-discussion is not practical, then post-report should be made within 1 week of an offer or receipt of an event support.

1. The Company budget allotted for meeting expenses, work-related performance expenses and other expenses should not be used for private purposes.
2. Any transaction or payment that is either processed with the receipt other than the actual one for the relevant transaction or payment, or is reflected differently to the actual transaction or payment on the Company books and records is strictly prohibited. In case of unavoidable appropriation or no-receipt transactions, such matter should be approved by the team leader and head of a division, and should also receive consent from the Business Planning Department.
3. Spending of the Company budget should be made by corporate credit card in accordance with the criteria fit for the purpose and rules of the Company budget expenditure.

1. Irrespective of its size, neither embezzlement nor misappropriation of the Company funds is allowed.
2. Miscellaneous income generated from the sale of waste toners, waste paper or scrap iron should not be appropriated for private purposes. Even, the sale of Company items with little monetary value should be carried out in strict adherence to the criteria and procedures set forth

1. No members of the Company is allowed to use favor, order or pressure to enter into a contract with companies with which he or she has a have a personal relationship.
2. If a business dealing with companies having a personal relationship with the members of the Company is unavoidable, the person in charge of such business should discuss the matter with the Ethics Management Team in advance.

Whether inside or outside the workplace, it is strictly forbidden for any members of the Company to act in a way that causes sexual harassment on the part of the recipient of such act. The following acts are strictly prohibited:
1. Unnecessary physical contact
2. Telling jokes or posting photos of a sexual nature
3. Making comments of a sexual nature on members’ appearances
4. Any other acts that may cause sexual harassment

1. Information acquired while performing work-related duties should not be disclosed nor appropriated for personal use outside the Company.
2. Irrespective of the level of importance, no exchange of information with competitors is allowed without prior consent of the team leader or head of a division.
3. Appropriation of other’s autographs or use of illegal software other than proper one provided by the Company is strictly prohibited.

1. Reporter should report any impropriety or unethical conduct to the Ethics Management Team within three days from the time of occurrence, or acquisition of the knowledge, of such impropriety or unethical conduct using the separate Report Form. (Appendix 1)
2. The Ethics Management Team has an authority to investigate any reported impropriety or unethical conduct for fact-finding, and the members of the Company concerned should actively co-operate with the Ethics Management Team for an effective investigation

1. Team leaders should give training and consultation to the team members on the Code of Ethical Conduct for them to be equipped with a sufficient level of knowledge and awareness.
2. Team leaders should take all the necessary precautionary measures to prevent any violation of the Code of Ethical Conduct on the part of the team members.
3. Team leaders are obligated to make a prompt report to the Ethics Management Team on the issues identified in the Code of Ethical Conduct.

1. The members of the Company, when in possession of knowledge of any violations of the Code of Ethical Conduct or in violation of the Code by themselves, should report such matter to the team leader or head of a division, or report to the Ethics Management Team.
2. Reporting should be made through completion and submission of the Report Form with detailed information on the reporter and the violation itself. Principally, reporters are encouraged to supply evidential material to support their report. However, late submission of evidential material is allowed in cases where the circumstances so require or it is impractical to collect evidence at the time of reporting.
3. The members of the Company should not give any unfair treatment to the reporter or informer on HR, administration or work-related matters, nor should they disclose the identity of the reporter.
4. If the reporter is likely to be unfairly treated in regard of HR matters, his or her wishes for a job transfer should be accommodated in a careful and positive manner.
5. In case the members of the Company acquire any information through work or by accident about the report of impropriety or unethical conduct, they should keep such information strictly confidential. Any members of the Company in violation of confidentiality may be subject to disciplinary action.
6. Pending final conclusion of an investigation into the reported impropriety or unethical conduct, the identity of the person(s) alleged to have violated the Code of Ethical Conduct should be protected to the fullest extent possible with no disadvantage imposed on HR or work-related matters. Any members of the Company in violation of confidentiality may be subject to disciplinary action.

1. By way of resolutions of the Ethics Committee, the Company may give an appropriate reward or compensation to the officers and employees who have contributed to achieving the objectives of the Code of Ethical Conduct.
2. By way of resolutions of the Ethics Committee, the Company shall take strict disciplinary measures against the officers and employees who are in violation of the Code of Ethical Conduct.

1. The operation guidelines on the report of unethical conduct and reward scheme with regard to offer and receipt of payment, gifts, convenience and the like to and from the interested parties shall be set forth separately.
2. In case family members, relatives or close friends of the members of the Company improperly use the name of the members of the Company and violate the Code of Ethical Conduct, such action shall be construed as that of the members of the Company concerned and shall be treated accordingly.
3. Any enquiries or concern with regard to the Code of Ethics and Code of Ethical Conduct should be directed to the Ethics Management Team for interpretation and such interpretation should be adhered to.