Article 1 [Purpose]

This Code of Ethics (hereinafter referred to as the "code") aims to provide employees with proper decision-making guidelines and ethical standards.

Article 2 [Subject to application]

The Code shall apply to all employees of Adeka Korea Co., Ltd. (hereinafter referred to as the "Company").

Article 3 [Definitions]

1. "Employee" refers to all executives and staff who are currently employed or on leave within the Company, including interns and contract employees.
2. "Partner" refers to all individuals or entities that have a business relationship with Chapter 2 Basic Ethics of Employees the Company, such as cooperating companies, suppliers, and clients.

Article 4 [Basic Ethics for Employees]

1. Employees shall carry themselves with pride and integrity as members of the Company, maintaining an honest and diligent attitude at all times.
2. Employees shall uphold high ethical values and strive to uphold and enhance their personal dignity as well as the Company's reputation.
3. Employees shall perform their duties in accordance with all applicable laws and regulations and act in a manner that is consistent with their conscience.

Article 5 [Fulfillment of Mission]

Employees shall share the Company's management philosophy and vision, empathize with its goals and values, and fulfill their responsibilities with creativity and diligence.

Article 6 [Fair Performance of Duties]

1. Employees must perform their duties fairly in compliance with all relevant laws and regulations.
2. Employees shall not engage in unethical or illegal actions, such as giving or receiving improper instructions, facilitating or requesting undue influence, or granting preferential treatment, that could hinder fair job performance for themselves or others and result in societal criticism.

Article 7 [Avoidance of Conflicts of Interest]

1. Employees should make efforts to avoid actions or relationships that conflict with the interests of the Company while performing their duties.
2. In cases where conflicts of interest arise between the Company and individuals or departments, employees should prioritize the interests of the Company.

Article 8 [Prohibition of Undue Benefits]

Employees shall not provide or receive monetary benefits, gifts, or favors beyond socially acceptable limits that could undermine fairness to or from parties related to their job duties.

Article 9 [Employee Interactions]

1. Employees must maintain basic courtesy in their interactions with each other in the workplace and should refrain from engaging in disrespectful speech or actions that cause distress, such as criticizing other employees.
2. Employees must not engage in creating factions or discrimination based on educational background, gender, religion, lineage, place of origin, or any other factors.
3. Employees must refrain from engaging in actions such as improper requests, excessive gift-giving, or financial transactions that go beyond societal norms when interacting with each other.
4. Superiors must not give unfair orders to subordinates, and subordinates must comply with legitimate instructions from superiors while refusing to follow unfair directives.
5. Executives and employees shall not engage in acts that induce sexual temptation or sexual shame between each other.

Article 10 [Transparent Information and Accounting Management]

1. Employees must acquire and manage all information in a fair and transparent manner, and information such as accounting records must be accurately and honestly recorded and managed.
2. Employees must not disclose or improperly use job-related acquisition information to external parties without prior authorization or approval.
3. Employees must not engage in false or exaggerated reporting for the benefit of specific individuals or departments, and they must not hide or monopolize important information.
4. The company shall disclose management information in accordance with relevant laws and regulations to enhance the transparency and credibility of its operations.

Article 11 [Prohibition of Collusion and Unfair Competition]

Employees must not engage in any actions that hinder fair trade, especially collusion with competitors regarding pricing or any unfair competitive practices that go against sound market economic principles. They must not tolerate or overlook such behaviors.

Article 12 [Respect for Partners]

Employees shall respect partners, consider their perspectives, and make efforts to promote mutually beneficial collaboration with partners.

Article 13 [Protection of Partners' Interests]

1. Employees shall value the protection of partners' assets, intellectual property rights, trade secrets, customer information, and other related matters. They shall not compromise the interests of partners through unethical actions.
2. Employees shall accurately and promptly provide partners with information that partners need to know or that is appropriate for them to know.

Article 14 [Fair Treatment]

The company shall provide equal opportunities based on individual abilities and qualifications of employees for education, promotions, and other matters. Performance and achievements shall be evaluated and rewarded fairly, without discrimination based on gender, education, age, religion, place of origin, physical disabilities, and other factors.

Article 15 [Promotion of Talent Development and Creativity]

The company actively supports the professional and creative development of employees to cultivate skilled and innovative talents. To promote independent and autonomous thinking and actions among employees, the company creates an environment where all employees can freely suggest and express their opinions.

Article 16 [Prohibition of Unlawful Political Activities]

1. The company shall not engage in unjust political involvement and shall not provide unlawful donations or expenses to political parties, politicians, election candidates, etc.
2. The company respects employees' individual political opinions. However, employees should be cautious to ensure that their personal political views are not misunderstood as representing the company's political stance.

Article 17 [Safety and Risk Prevention]

Employees must comply with all relevant laws and regulations related to safety and follow established standards, making their best efforts in disaster prevention and risk management to ensure that their actions do not compromise civic safety and the environment.

Article 18 [Creation of Social Value]

The company should strive to contribute to the development of the nation and society by creating tangible and intangible social value through ethical corporate activities and community service efforts.

Article 19 [Obligation and Responsibility to Comply]

1. All employees must be familiar with and comply with the code of conduct, and they shall bear responsibility for any violations thereof.
2. The CEO is responsible for managing and supervising the compliance of his/her executives and employees with the Code.

Article 20 [Rewards and Disciplinary Measures]

1. CEO may implement rewards commensurate with the contribution, such as incorporating them into performance evaluations, for employees who adhere to the code of conduct and contribute to the establishment of ethical management.
2. The CEO must take necessary actions, including disciplinary measures, against employees who engage in actions that violate the code of conduct.
3. The types, procedures, and effects of disciplinary measures under the provisions of Paragraph 2 shall be in accordance with the disciplinary regulations stipulated in Chapter 9 of the company's employment regulations.

Article 21 [Operation of the Code]

The CEO must continuously enhance and operate the code's contents in alignment with the organization's progress and environmental changes.