Chapter 1 General Provisions

Article 1 (Purpose)

The purpose of this Code of Ethics (hereinafter referred to as the “Code”) is to provide employees with standards for correct decision-making and ethical judgment.

Article 2 (Applicable subject)

The Code applies to all executives and employees belonging to Seowon Co., Ltd. (hereinafter referred to as “Seowon Co., Ltd.”).

Chapter 2 Basic Ethics of Employees

Article 3 (Basic Ethics of Employees)

① Executives and employees have pride and pride as a member of Seowon Co., Ltd. and always maintain an honest and sincere attitude.

② Executives and employees shall strive to maintain and develop individual dignity and the honor of Seowon Co., Ltd. with high ethical values.

③ In performing their duties, executives and employees shall comply with all laws and regulations and act not to violate their conscience.

Article 4 (Fulfillment of Mission)

Executives and employees share the management philosophy and vision of Seowon, and sympathize with the goals and values pursued by Seowon, and fulfill their responsibilities with creativity and sincerity.

Article 5 (Fair Performance of Duties)

① Executives and employees shall perform their duties in a fair manner by complying with all relevant laws and regulations.

② Executives and/or employees shall not engage in unethical or illegal acts that may undermine the fair performance of their duties or others, such as unreasonable instructions, mediation, solicitation, and granting of preferential treatment, etc.

Article 6 (Avoidance of Conflicts of Interest)

① Executives and employees shall endeavor to avoid acts or interests that conflict with Seowon's interests in performing their duties.

② In the event of a conflict of interest between Seowon Co., Ltd. and an individual or department, executives and employees shall consider the interests of Seowon Co., Ltd. first.

Article 7 (Prohibition of Receiving Unfair Profits)

Executives and employees shall not provide or receive money, valuables, entertainment, etc., to or from job-related persons that may impair fairness beyond the scope permitted by social norms in relation to their duties.

Article 8 (Relationship between executives and employees)

① Executives and employees shall observe the basic manners necessary for working life with each other, and shall not engage in disrespectful speech or conduct or conduct that causes suffering such as slandering other executives and employees.

② Executives and employees shall not form factions or discriminate against them based on academic background, gender, religion, blood ties, or region of origin.

③ Executives and employees shall not engage in unreasonable solicitation or excessive gift giving or monetary transactions between employees according to social norms.

④ A superior shall not give an unreasonable instruction to a subordinate, and a subordinate shall comply with the legitimate instruction of the superior, but reject any unfair instruction.

⑤ Executives and employees shall not engage in acts that induce sexual temptation or sexual shame among each other.

Article 9 (Transparent Information and Accounting Management)

① Executives and employees shall acquire and manage all information in a fair and transparent manner, and information such as accounting records shall be recorded and managed accurately and honestly.

② Executives and employees shall not disclose or unfairly use job-related acquired information without prior permission or approval.

③ Executives and employees do not report false or exaggerated reports for the benefit of specific individuals or departments, and do not conceal or monopolize important information.

④ Seowon Co., Ltd. enhances transparency and reliability of management by disclosing management information in accordance with relevant laws and regulations.

Chapter 3 Ethics for Customers

Article 10 (Customer Respect)

Recognizing that customers are the reason and goal of our existence, our executives and employees always respect customers, think from the customer's point of view, and put customers as the top priority in all actions.

Article 11 (Protection of Customer's Interest)

① Executives and employees shall protect customer assets, intellectual property rights, trade secrets, customer information, etc. more preciously than Seowon's property and do not infringe on customer interests due to immoral conduct.

② Executives and employees shall provide the facts that customers need to know or should inform customers accurately and promptly.

Chapter 4 Ethics for Employees

Article 12 (Fair Treatment)

Seowon Co., Ltd. grants equal opportunities to employees according to their individual abilities and qualities in education and promotion, and provides fair evaluation and compensation for performance and achievements, and not discriminates for compensation for gender, academic background, age, religion, region of origin, physical disability, etc.

Article 13 (Fostering Talent and Promotion of Creativity)

Seowon Co., Ltd. actively supports the development of abilities of its employees to foster professional and creative talents, and to promote creative and autonomous thinking and actions of employees, creating conditions where all employees can freely propose and express their opinions.

Chapter 5 Ethics for the State and Society

Article 14 (Prohibition of Unjust Political Activities)

① Seowon Co., Ltd. does not unduly engage in politics and does not provide illegal donations or expenses to political parties, politicians, election candidates, etc.

② Seowon Co., Ltd. respects the individual political views of its executives and employees. However, executives and employees must be careful not to be misunderstood personal political views as the political positions of Seowon Co., Ltd.

Article 15 (Safety and Risk Prevention)

Employees must do their best to prevent and manage accidents and risks by complying with all safety-related laws and standards.

Chapter 6 Supplement

Article 16 (Obligation for Compliance and Responsibilities)

① All executives and employees must be fully aware of and comply with the Code, and take responsibility for violations.

② The CEO is responsible for managing and supervising whether his/her employees comply with the Code.

Article 17 (Reward and Discipline)

① The CEO may give corresponding rewards, such as reflecting in personnel evaluation to executives and employees who have complied with the Code and contributed to the establishment of ethical management.

② The CEO may take necessary measures such as disciplinary action against executives and employees who violate the Code.

③ The type, procedure, effect, etc. of disciplinary action pursuant to Paragraph ② shall be governed by the disciplinary regulations of Seowon Co., Ltd.

Article 18 (Operation of the Code)

① The CEO shall continuously supplement, develop and operate the contents of the Code in accordance with the development of the organization and changes in the environment.