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Ethics

Code of Ethics

These regulations were established by Nano Solution Co., Ltd. (hereinafter referred to as the "Company") and its executives and employees to set standards of proper conduct and value judgment for executives, employees, and stakeholders in order to establish a fair and transparent corporate culture. They consist of the "Ethics Charter," which presents the standards of proper conduct and value judgment that executives and employees must follow; the "Code of Ethics," which specifies the Company's concrete ethical standards toward stakeholders; and the "Code of Conduct," which specifies the detailed matters and standards necessary for executives and employees to realize the ethics regulations.


01

Ethics Charter

The purpose of the Ethics Charter is to present the standards of proper conduct and value judgment that executives and employees must follow, so that both the Company and its executives and employees carry out their work transparently and with integrity, and to realize the exemplary ethical management demanded by society.

02

Code of Ethics

The purpose of the Code of Ethics is to present the standards of proper conduct and value judgment that the Company must follow toward key stakeholders who are affected economically, socially, and environmentally by the Company's management activities.

Attitude Toward Shareholders and Investors

Protection of Shareholders' Rights and Interests
  • The Company protects the rights of shareholders and respects their legitimate demands and proposals.
  • The Company strives to build a relationship of mutual trust through continuous management innovation and growth strategies, and to maximize shareholder value.
Equal Treatment
  • The Company treats all shareholders, including minority shareholders, fairly and equally.
  • The Company always considers the interests of all shareholders as a whole to ensure that the interests or rights of minority shareholders are not unfairly infringed upon.
Proactive Disclosure of Information
  • The Company transparently discloses its financial condition and management performance.
  • The Company provides accurate management information in a timely manner in accordance with relevant laws and regulations, so that investors and other information users can make rational investment decisions.

Attitude Toward Customers

Respect for Customers
  • The Company thinks and acts from the customer's perspective, and strives to realize customer satisfaction by providing the best products and services.
Protection of Customers' Rights and Interests
  • The Company protects customers' interests, safety, and personal information, and does not engage in unfair demands or actions.
  • The Company respects and complies with consumer protection laws to protect customers' rights and interests.

Attitude Toward Competitors and Partner Companies

Fair Competition with Competitors
  • The Company respects the order of a fair and free market economy and complies with laws and regulations related to fair trade.
Fair Transactions with Partner Companies
  • The Company pursues mutual development through fair transactions with partner companies.
  • The Company does not force any form of wrongful conduct or exert influence by taking advantage of a position of superiority.

Responsibility Toward Executives and Employees

Strengthening Ethical Awareness Among Executives and Employees
  • The Company conducts systematic training so that executives and employees comply with the Code of Ethics.
Fair Treatment
  • The Company does not unfairly discriminate against executives and employees based on race, religion, regional or school ties, blood relations, gender, or disability, and grants fair opportunities according to ability and qualifications.
  • The Company establishes clear evaluation criteria for executives and employees to fairly evaluate and compensate them.
Creating a Good Working Environment
  • The Company strives to create a healthy and safe working environment for its executives and employees.
  • The Company respects the autonomy and creativity of each executive and employee, and supports talent development and individual self-realization by fairly granting opportunities.
  • The Company respects the independent dignity and basic rights of executives and employees, and creates an environment where they can freely make suggestions and proposals.

Attitude Toward the Nation and Local Community

Compliance with Domestic and International Laws
  • As a member of the nation and local community, the Company complies with domestic laws and internationally recognized laws and regulations and international conventions.
Contribution to National Economic and Social Development
  • The Company contributes to national economic and social development through productivity improvement, job creation, faithful tax payment, and social contribution.
Environmental Protection
  • The Company conducts all its businesses in an environmentally friendly manner, actively participates in environmental protection, and complies with all relevant laws and regulations.
  • The Company takes the lead in environmental protection and nature conservation through resource conservation and continuous technology development.
Safety Management and Accident Prevention
  • The Company makes its best efforts for safety management and accident prevention, and complies with regulations on safety and quality.
  • The Company conducts education and training to prevent safety accidents and respond promptly in the event of an accident, and thoroughly carries out regular inspections of various facilities.
03

Code of Conduct

The purpose of this Code of Conduct is to clarify the detailed matters and standards necessary for executives and employees to realize the ethics regulations.

Definition of Terms
Duties

"Duties" includes not only one's own assigned work but also work within the scope of another person's responsibility over which one can exert influence.

Money and Goods

"Money and goods" refers to cash, checks, cards, gift certificates, vouchers, and items, etc.

Entertainment

"Entertainment" refers to benefits such as meals, drinking, sports (golf), recreation, and performances.

Stakeholders

"Stakeholders" refers to specific natural persons, corporations, or other organizations, whether inside or outside the Company, who may be affected by the actions or decisions of executives and employees related to their duties, including executives and employees, business partners, customers, and domestic and foreign public officials.

Essential Personnel

"Essential personnel" refers to the investigation team members, investigators, and executives and employees who are reported to the relevant content when an investigation is conducted upon the raising of an issue regarding a violation of ethical management.

Protection of Company Assets and Information
  • Executives and employees shall protect the Company's tangible property, intellectual property rights, and trade secrets, and shall not use them for personal purposes.
  • Personal use or embezzlement of the Company's public funds, expenses, equipment, and facilities is prohibited regardless of the reason.
  • Executives and employees shall not pursue personal gain by taking advantage of their position, nor engage in unfair trading practices or stock trading using non-public information obtained from the Company.
  • Executives and employees may not disclose important information that may affect the Company's profits or stock price to outside parties without going through lawful procedures.
Prohibition of Monetary Transactions
  • Executives and employees are prohibited from engaging in monetary transactions such as loans or loan guarantees with stakeholders or among executives and employees, or from participating in the equity of business partners that have an interest relationship with the Company. In addition, borrowing money from subordinates is prohibited regardless of whether interest is paid.
  • All economic activities and gambling that undermine sound colleague relationships are prohibited.
Prohibition of Receiving Money, Goods, or Other Unfair Benefits
  • Executives and employees shall not receive or request money, goods, or gifts from stakeholders such as business partners.
  • Executives and employees shall not provide money, goods, or gifts beyond what is generally accepted by social norms to stakeholders such as business partners in connection with Company business, or in response to solicitation.
  • Executives and employees shall not exchange money, goods, or excessive gifts among themselves.
  • Relatives within the 4th degree of kinship, including spouses, of executives and employees shall not receive or provide money, goods, or other unfair benefits.
Prohibition of Entertainment/Hospitality
  • Private golf outings with business partners and golf among executives and employees are prohibited except for official gatherings or cases pre-approved by the Company, and even when prior approval has been obtained from the Company, the costs must not be borne by the business partner.
  • In cases where a meal with a stakeholder is unavoidable, the Company shall in principle bear the cost. However, the stakeholder may pay for a simple meal that is socially acceptable, but this should not occur frequently.
  • If a stakeholder offers additional hospitality after a simple meal, this must be politely declined.
Congratulatory and Condolence Events
  • Informing stakeholders of one's own or other executives'/employees' congratulatory or condolence events is strictly prohibited. However, notices of such events through the internal company network may be given only for the employee's own or their spouse's immediate family.
  • If congratulatory/condolence money or gifts are received that exceed what is socially acceptable, the principle is to return them immediately.
  • The person who received an excessive amount of congratulatory/condolence money must immediately report the action taken to their supervisor, and the supervisor must politely ask the relevant stakeholder to prevent recurrence.
  • Congratulatory/condolence wreaths shall not be accepted from stakeholders, and even if unavoidably received, they must not be displayed.
Prohibition of Receiving Sponsorship for Events
  • Stakeholders shall not be invited to department-level events other than official Company events.
  • If it is necessary to invite a stakeholder due to the nature of an event, prior approval must be obtained from the supervisor, and the stakeholder must be informed at the time of invitation that no sponsorship money or goods will be accepted, so that they do not feel burdened about attending the event.
  • If a stakeholder brings cash or goods, they must be returned without fail.
  • If receipt is unavoidable or the item is of small value (such as beverages), the event manager must express gratitude to the stakeholder while asking that this not happen again in the future, and must notify the supervisor and the compliance officer of this fact.
  • In cases such as an office relocation, if a small gift (wall clock, potted plant, mirror, tissue, etc.) is unavoidably received, the supervisor must ask that this not happen again in the future.
  • Events hosted by a stakeholder or for which the stakeholder bears all or part of the cost may be attended only after obtaining prior approval from the team leader. In this case, the team leader must decide whether to grant prior approval considering the nature of the work and the existence of any conflict of interest.
Prevention of Sexual Harassment
  • Executives and employees shall not engage in any language or behavior that undermines sound colleague relationships, including physical, verbal, or visual language or behavior recognized as causing sexual humiliation.
Prohibition of Conflict of Interest with the Company
  • Executives and employees shall strive to prevent any act or relationship that conflicts with the interests of the Company, and when there is a conflict of interest between the Company and an individual or department, they shall think and act with the Company's interests as the top priority.
  • The following acts by executives and employees are prohibited:
  • Cases where an executive/employee or their family or relatives are a stakeholder in a transaction related to the Company.
  • Cases where an executive/employee or their family or relatives receive separate compensation from a third party, in addition to the direct compensation received from the Company, in connection with the Company's transactions.
  • Cases where an executive/employee or their family or relatives work for another company that has an interest relationship with the Company, thereby causing a conflict of interest with the Company.
  • Cases where an executive/employee uses confidential information acquired in the course of performing their duties for personal gain.
Prohibition of Political Involvement
  • Executives and employees shall not engage in political activities within the company during working hours, and shall not use the Company's organization, personnel, or property for political purposes.
  • While the right to vote and political views of individual executives and employees are respected, care must be taken to ensure that their political views or involvement are not mistaken for the Company's position.
Raising Issues Regarding Violations of Ethical Management
  • If an executive or employee becomes aware of a violation of the Company's ethics regulations or has a related concern, they must immediately raise the issue with their department supervisor or a higher-level supervisor.
  • Not only the confidentiality related to the report or issue raised, but also the identity of the whistleblower, must be absolutely protected.
  • The identity of the executive/employee and the information provided shall be shared only with the "essential personnel" responsible for resolving the issue.
Disciplinary Action for Violations of Regulations
  • Executives and employees who violate the Company's ethics policy shall be subject to disciplinary action according to the severity of the violation.
  • The violations subject to disciplinary action are as follows:
  • Cases of violating the Company's ethics regulations.
  • Cases of requesting another person to violate the Company's ethics policy.
  • Cases of failing to immediately report a known or suspected violation of the Company's ethics policy.
  • Cases of failing to cooperate with the Company's actions regarding a matter that may involve a policy violation.
  • Cases of retaliating against or attempting to identify an employee who reported an issue related to ethical management.
  • Cases of failing to show leadership or being unfaithful in complying with the Company's ethics policy and laws and regulations.
  • Matters related to the disciplinary action of executives and employees shall be governed by the "Personnel Regulations (NSG-01-05)."