POSCO FUTURE M operates the Fair Trade Compliance Program to create a transparent and fair trade culture, using it as an internal control standard. This program provides clear guidelines and standards for employees’ actions when performing their duties. It creates an environment where employees can comply with fair trade laws and regulations and prevent financial and non-financial risks.
Message on Compliance
The Korean government has recently strengthened regulatory oversight to prevent business conglomerates from engaging in unfair trade practices and to build a fair and just system.
The Fair Trade Commission (FTC) has tightened scrutiny on the unscrupulous practices of large business groups. Therefore, the FTC is taking steps to prevent illicit demands made to subcontractors and dealerships and unlawful internal trading. Additionally, the Commission has set out to curb preferential treatment given to affiliated companies for the benefit of owner families. Through these measures, the Commission is sending a clear message to adhere to fair trade laws.
In line with these policy developments, POSCO FUTURE M is focused on a business culture that underlines fairness and transparency. Starting with the introduction of the Compliance Program (CP) in 2006, we have incorporated fair competition principles into our management system by defining conflict of interest guidelines, managing a retired staff employment registry and mandating audits of direct contracting.
Today, under Sustainable management philosophy, we intend to build a robust industrial ecosystem where we can seek shared growth with partners and suppliers. Additionally, to mitigate compliance risks and enhance compliance, we have transferred fair trade responsibilities from the Jeongdo (Compliance) Office to the Legal Office. As a result, fair trade tasks, e.g. training, consultation, grievance handling and litigation, are managed and performed by one office. This new organizational structure will help us to ensure compliance with fair trade laws and regulations.
Our commitment to compliance extends beyond management practices. We provide a compliance checklist to help staff to self-monitor their status on a regular basis. Staff are also encouraged to share updates and exchange opinions at Voluntary Compliance Council meetings.
For POSCO FUTURE M, fair competition is a core corporate principle. By upholding fair competition, POSCO FUTURE M will grow into a reputable and trustworthy business.
Yoo Byeong-og Representative director POSCO FUTURE M
Compliance Program
1. Vision and Strategy
POSCO FUTURE M has established a fair trade operation system of prevention, detection, and response by reflecting CP's eight operational elements to respond to the risk of violating laws and regulations.
2. Operating organization
이사회
대표이사
자율준수관리자[법무실장]
자율준수 프로그램 설계
임직원의 공정거래 인식 고취
운영조직 관리
자율준수 편람 작성
자율준수 감시
전담조직[법무실]
공정거래 상담 및 리스크 검토
자율점검체계 운영
교육프로그램 운영
내부감독 실시
CP운영성과 측정
부서별 자율준수 담당자[자율준수협의회]
위원장 : 자율준수 관리자
위원 : 각 그룹 부서장
실천리더 : 각 그룹 실무자
CP 중요사항 심의
자율준수관리자 자문
3. Eight key factors of Fair Trade
To ensure the successful implementation of the Fair Trade Compliance Program, it must satisfy the following 8 elements.
01
Establishing and Implementing Criteria and Procedures for compliance program
02
Management's commitment to voluntary compliance
03
Designation of the Voluntary compliance officer
04
Formulation & distribution of the volunatary compliance manual
05
Offer an education program
06
Internal supervision system
07
HR system and Incentives for voluntary compliance
08
Evalution and Feedback
4. Status of Development
Jul 2001
The Fair Trade Commission and Korea Chamber of Commerce and Industry enacts the Fair Trade Voluntary Compliance Code.
Sept 2006
The Voluntary Fair Trade Compliance Program is introduced. The CEO announces the willingness to embrace voluntary compliance.
Oct 2006
Appointment of the Voluntary Compliance Manager in the board of directors (Senior auditor Lee Sang-gu).
Nov 2006
The Voluntary Compliance Council (11 members) is established. Operation standards for Voluntary Fair Trade Compliance Program are set.
Apr 2007
Reappointment of the Voluntary Compliance Manager (Senior auditor Kim Soon-gu). The Fair Trade Compliance Manual is distributed (first edition).
Apr 2008
A voluntary compliance pledge is adopted to create a culture of voluntary compliance of fair trade rules (taken annually).
Jun 2009
A revised version of the Fair Trade Compliance Manual is distributed (second edition).
Jul 2009
The operation guidelines for Voluntary Fair Trade Compliance Program are revised.
Mar 2010
Appointment of the Voluntary Compliance Manager in the board of directors (Senior auditor Kang Dae-hee).
Oct 2010
Launching ceremony for the Shared Growth Support Group.
Mar 2011
An Ethical Process forum is newly added to the integrated mailing system of the POSCO Family (also applied on mobile pages).
Mar 2012
Reorganization of the Voluntary Compliance Council (16 members).
May 2012
Operation guidelines for Voluntary Fair Trade Compliance Program are revised. (guided inspections/consultation)
Sept 2012
The revised Voluntary Fair Trade Compliance Manual is distributed (third edition).
Dec 2012
Acquired Grade A in CP ratings.
Jan 2013
Designated by the Fair Trade Commission as a company with outstanding performance in implementing the Shared Growth Agreement.
Mar 2013
Appointment of the Voluntary Compliance Manager in the board of directors (Senior auditor Lee Jong-deok).
Jan 2014
Reported CP performance for 2013 and CP plans for 2014 to the board of directors.
Jul 2014
Distributed a revised version of the Voluntary Fair Trade Compliance Manual (fourth edition).
Jan 2015
Reported CP performance for 2014 and CP plans for 2015 to the board of directors.
Jan 2016
Reported CP performance for 2015 and CP plans for 2016 to the board of directors.
Mar 2016
Appointment of the Voluntary Compliance Manager in the board of directors (Senior auditor Kim Dong-won).
Jan 2017
Reported CP performance for 2016 and CP plans for 2017 to the board of directors.
Mar 2017
Appointment of the Voluntary Compliance Manager in the board of directors (Senior auditor Hwang Seok-yeon).
Apr 2017
Employees pledge to voluntarily comply with the fair trade laws.
Jun 2017
Earned an Excellent rating in the Fair Trade Shared Growth Index.
Jan 2018
Reported CP performance for 2017 and CP plans for 2018 to the board of directors.
Mar 2018
Employees pledge to voluntarily comply with the fair trade laws.
Jun 2018
Earned an Excellent rating in the Fair Trade Shared Growth Index.
Oct 2018
Distributed a revised version of the Voluntary Fair Trade Compliance Manual (fifth edition).
Jan 2019
Reported CP performance for 2018 and CP plans for 2019 to the board of directors.
Jun 2019
Earned an Excellent rating in the Fair Trade Shared Growth Index.
Jan 2020
Employees pledge to voluntarily comply with the fair trade laws.
Appointment of the Voluntary Compliance Manager to the board of directors (Director of the Legal Office Won Hyung-il).
Apr 2020
Reported CP performance for 2019 and CP plans for 2020 to the board of directors.
May 2020
Operation guidelines for Voluntary Fair Trade Compliance Program are revised (increased number of reports to the BOD).
Jul 2020
Renovation of the fair trade section of our website (a show of determination to promote voluntary compliance).
Sept 2020
Acquired an Excellent rating in the Fair Trade Shared Growth Index for four years in a row.
Oct 2020
Voluntary Compliance Council is held (participated by members and action leaders).
Jan 2021
Employees pledge to voluntarily comply with the fair trade laws and the FCPA.
Jan 2021
Reported CP performance for 2020 and CP plans for 2021 to the board of directors which were made public voluntarily.
Jan 2021
Appointment of new Voluntary Compliance Council members and action leaders.
Feb 2021
Held a self-compliance meeting (participated by action leaders).
Mar 2021
Operation guidelines for Voluntary Fair Trade Compliance Program are revised (penalty standards are devised).
Consult Us or Report on Compliance
Should you have any questions or concerns about fair trade, report the case to us and we will promptly reply to your email or the contact information you provide.
- You may report or consult with us in respect to our CP operation policy and the ethical policy on the condition of anonymity or by using an alias.
- Your report will only be disclosed to the person in charge and yourself. We are obliged to protect informants who have discovered acts of violations by ensuring confidentiality of the information provided and the identity of the informant, as well as liability relief.
- Anyone who violates our fair trade policy or individuals responsible for violations may be subject to penalties pursuant to our CP Disciplinary rules and the Code of Ethics.