Ethical Management – 코스모신소재(주) COSMO AM&T CO., LTD.

/ Sustainability / Ethical Management

Ethical Management

Ethics & Compliance Policy

We comply with all applicable laws, international regulations, and fair trade principles in every region where we operate.

We conduct all business dealings with fairness and transparency, maintaining integrity through accurate and honest financial records.

We strictly prohibit all forms of solicitation, bribery, and provision or acceptance of improper benefits.

We promote mutual respect among all employees, eliminate workplace harassment and discrimination, and uphold human rights and diversity.

We avoid conflicts of interest and act in the company’s best interest by excluding personal gains from decision-making.

We strive to create sustainable value that meets customer expectations and enhances customer satisfaction.

We comply with environmental laws and global standards, and are committed to eco-friendly and responsible business practices.

We actively engage in community development and social contribution to fulfill our corporate social responsibility.

We protect all information acquired in the course of business and strictly prohibit its use for personal or unauthorized purposes.

We strictly prohibit forced labor, child labor under the age of 15, and any form of exploitative labor including prison or slave labor.

We do not engage in any activity related to money laundering or the financing of terrorism, and fully comply with global anti-financial crime regulations.

Code of Ethics

Preamble

COSMO Advanced Materials & Technology Co., Ltd. (hereinafter referred to as the “Company”) here by establishes and proclaims this Code of Ethics as the standard for conduct and value judgments for all executives and employees. We pledge to make every effort to uphold and implement these principles as set forth below.

Principles of Ethics

We pursue the satisfaction of our customers, shareholders, and employees, and establish fair and trustworthy business practices with partners and competitors, while fulfilling our responsibilities to the nation and society.

We always respect the opinions of all customers and strive to create value that benefits our customers by providing products and services from the customer’s perspective, thereby earning their unwavering trust.

We comply with all applicable laws and commercial practices in every region where we conduct business, and compete with fairness and transparency.

We maintain mutually trusting partnerships with our business partners through transparent and fair transactions, and pursue mutual growth.

As responsible corporate citizens with a sound ethical perspective, we contribute to the mutual development of both individuals and the company through continuous self-development and fair performance of our duties.

We respect all employees as autonomous individuals, treat them fairly based on ability and performance, and strive to foster an environment where their creativity can flourish.

By growing as a transparent and sound company, we protect the interests of our shareholders and contribute to the development of the nation and local communities.

Chapter 1: General Provisions

Article 1 (Purpose)
The purpose of these regulations is to establish the standards for value judgments and other related matters for the implementation of the Company’s Code of Ethics.

Article 2 (Scope of Application)
These regulations apply to the Company and all of its executives and employees.

Article 3 (Definitions of Terms)
① Partner Company: Refers to any individual or legal entity having business relations with the Company.
② Stakeholder: Refers to all individuals, legal entities, or other organizations, both internal and external, whose rights and interests may be affected by the actions or decisions of the Company’s executives and employees. This also includes hierarchical relationships and those with work-related connections within the Company.
③ Generally Accepted Social Norms: Refers to cases that are recognized as appropriate in amount, provided with sincerity and voluntariness by the giver, and are not given in exchange for any consideration.

Chapter 2. Responsibilities and Duties to Customers

Article 4 (Respect for Customers)
① We strive to maximize customer satisfaction and delight through a culture of respect for our customers.
② We always listen attentively to our customers and place customer satisfaction as the top priority in all decisions and actions.
③ We treat customers with courtesy and professionalism, maintaining a neat appearance and demeanor at all times.
④ We prioritize the handling of customer matters above all else.
⑤ We respond to customers over the phone in a kind and sincere manner.

Article 5 (Fulfillment of Commitments to Customers)
① We become a trusted company by upholding credibility and integrity in all customer relationships.
② We always keep our promises to customers and communicate with honesty.
③ We fulfill all commitments related to sales basics, such as telephone response, in-person consultations, delivery, and customer complaints; and in the event of any issues, we take proactive measures to minimize losses for both the customer and the Company.

Article 6 (Providing Value to Customers)
① We continually strive to create value that brings satisfaction to our customers.
② Recognizing that the growth of our customers is integral to our own success, we work to provide the value our customers need.
③ We offer the highest quality products and services at reasonable prices tailored to customer needs, and respond promptly and accurately to all legitimate customer requests.

Article 7 (Protection of Customer Interests)
① We endeavor to sustain a mutually beneficial economic relationship by protecting the interests of our customers.
② When customers make legitimate requests for exchanges or returns of products, we respond quickly and take appropriate action.
③ We refrain from any unethical behavior in dealings with customers, and do not use or disclose customer-related information for any purpose other than its intended use without the customer’s prior consent.

Chapter 3. Fundamental Ethics of Executives and Employees

Article 8 (Fundamental Ethics)
① Always maintain honesty and integrity.
② Achieve the Company’s goals and values efficiently through active cooperation and smooth communication with colleagues and relevant departments.
③ Strictly distinguish between public and private matters and do not use company assets or funds for personal purposes.
④ Do not inform partner companies or others of personal events (e.g., family occasions) in a manner that imposes a burden on them.
⑤ Strive for self-development to adapt to changing circumstances and lead the Company forward.
⑥ Make every effort to prevent accidents through thorough safety inspections and management.
⑦ Take care to prevent the leakage of customer information and internal company information.

Article 9 (Fair Performance of Duties)
① Perform all duties sincerely and to the best of one’s ability, with honesty and fairness.
② Conduct all business in a fair and legitimate manner, and do not engage in acts that violate laws, company rules, or commercial practices.
③ Do not accept any form of financial benefit from stakeholders that could compromise business fairness.
④ Refrain from unethical conduct in business or daily life that is not acceptable by social norms.
⑤ Supervisors may not instruct subordinates to perform tasks that are contrary to laws, company rules, or commercial practices. If such instructions are given, the subordinate has the right to refuse and may report the matter to the Company (to a higher-level supervisor, department head, or ethics management department) without suffering any disadvantage.
⑥ In the event of any disadvantage or discrimination in employment status or working conditions due to reporting or cooperating with investigations into violations of ethical management (including the above), the affected person may request protection from the department head or ethics management department. The relevant department shall investigate and, if deemed appropriate, take necessary measures to protect the individual.

Article 10 (Efforts to Prevent the Use of Prohibited Labor Forms in Manufacturing and Procurement)
① Do not handle products produced or distributed using forced labor, child labor (under age 15), or forms such as prison or slave labor.
② Obtain separate written pledges from executive-level personnel and above to ensure that manufactured products are not produced using prohibited forms of labor.
③ Send recommendations to suppliers to ensure that procured goods are not produced using prohibited forms of labor.

Article 11 (Efforts to Prevent Money Laundering for Terrorism Funding, etc.)
① The Company does not engage in money laundering for the purpose of funding terrorism or causing social disorder, including:

Repeated transactions using borrowed names
Transactions using checks or bearer bonds issued by unrelated third parties
Securing bank loans with false business performance or illegal funds as collateral
Structuring cash transactions to evade financial institution monitoring, etc.

② Obtain separate written pledges from executive-level personnel and above to prevent the funding of terrorism and money laundering.

Article 12 (Prohibition of Monetary Transactions, Solicitation, and Gift-Giving among Employees)
① In principle, monetary loans, joint guarantees, and mutual guarantees between employees are prohibited.
② Employees shall not solicit unfair favors from each other or accept any form of financial benefit in return for such solicitation.
③ In principle, gift-giving among employees is prohibited. However, the following cases are exceptions:

Gifts voluntarily given by a supervisor to a subordinate
Modest gifts given among team members by mutual agreement for birthdays or anniversaries

④ Condolence contributions among employees are made voluntarily and in accordance with social norms.

Article 13 (Prevention of Workplace Sexual Harassment)
① Strengthen preventive education on workplace sexual harassment, as it can cause personal harm and damage the Company’s image.
② Do not cause discomfort to others through intentional or unnecessary physical contact.
③ Do not make sexual remarks or evaluations about colleagues’ bodies.
④ Do not engage in conduct or language that causes sexual humiliation or emphasizes stereotypical gender roles.
⑤ Do not force others to drink alcohol or participate in singing or dancing at company events.

Article 14 (Mutual Respect)
① All executives and employees shall recognize human dignity and value, and do their best to create a healthy and happy workplace through mutual respect.
② Observe basic courtesy required in the workplace.
③ Do not use rude language or make derogatory remarks to others.
④ Do not engage in behavior that causes discomfort or distress to others.
⑤ Do not form factions or discriminate based on educational background, gender, religion, kinship, place of origin, disability, nationality, or race.

Chapter 4. Responsibilities to Executives and Employees

Article 15 (Respect for Employees and Talent Development)
① The Company establishes systems that enable executives and employees to take pride and find fulfillment in their work, based on a sense of ownership.
② The Company provides all executives and employees with opportunities for the education and training necessary for their duties.
③ Supervisors offer all necessary advice and guidance to their subordinates, taking into account their aptitudes and abilities, from the perspective of talent development.
④ The Company respects individual privacy and strives to build a corporate culture based on mutual trust and understanding.
⑤ The Company creates an environment in which employees can perform their work creatively, and regularly identifies and addresses any difficulties they may encounter.

Article 16 (Fair Treatment)
① The Company provides executives and employees with equal opportunities for assignments, considering their aptitudes and abilities.
② The Company evaluates and rewards executives and employees according to objective criteria based on their abilities and achievements.
③ The Company equally provides opportunities for employees to enhance their capabilities, and does not discriminate based on educational background, gender, religion, kinship, place of origin, disability, nationality, or race.

Chapter 5. Supplementary Provisions

Article 17 (Ethical Management Department)
① The Ethical Management Department is responsible for all matters related to ensuring compliance with the Code of Ethics by executives and employees and promoting ethical corporate activities within the Company.
② The composition, scope of duties, and other necessary matters regarding the Ethical Management Department shall be determined by the CEO.
③ For efficient operations, the Ethical Management Department may establish an Ethics Secretariat in each division of the Company.

Article 18 (Establishment of Guidelines for Implementation)
① The Ethical Management Department shall establish and implement detailed guidelines for ethical practices to set specific standards of ethical behavior for the Company and its executives and employees.

Article 19 (Rewards and Disciplinary Actions)
① Acts of compliance with the Code of Ethics or significant contributions to the Company’s ethical management shall be recognized and rewarded, while any acts in violation of the Code of Ethics or the detailed guidelines for implementation shall be subject to disciplinary action.
② The Company shall protect the anonymity of internal whistleblowers. Whistleblowers who help uncover misconduct will be rewarded, while violators will be subject to disciplinary action.

Supplementary Provisions

Article 1 (Effective Date)
This regulation was enacted and has been effective since December 2, 2024.
This regulation was amended and has been effective since May 1, 2025.