In accordance with the Group's ethical management policy of "doing the right thing the right way," POSCO A&C has been introducing and operating a Fair Trade Compliance Program since 2009 to establish fair subcontractor transactions and achieve balanced development from mutually equal positions between companies.
As a result of these efforts, following 2023, we achieved an AA grade in the Korea Fair Trade Commission's CP evaluation in 2024, being recognized as a company that has established an exemplary fair trade compliance system.

In 2025, we will continue our efforts so that all employees practice compliance management based on ethical consciousness and further spread the fair trade compliance culture, enabling mutual prosperity and sustainable development with all stakeholders. We request the following:

First, let us remain faithful to principles and fundamentals for compliance with fair trade-related laws and regulations.
To prevent legal violations, we must remain faithful to principles and fundamentals. Fair trade compliance is a core value and behavioral standard that all employees must observe, beyond legal requirements.
We must establish standards for fair transactions and legal compliance, uphold principles, prevent legal violations, and achieve company trust and sustainable growth.

Second, let us establish a foundation for sustainable development through mutual prosperity with stakeholders.
Fair trade compliance is an essential foundation for mutual prosperity with all stakeholders, including partner companies.
We build a trustworthy business environment through fair and transparent transactions and support long-term partnerships and growth with partner companies.
Through this, let us strive to become a company that grows together with sustainable development.

Third, let us spread a fair trade compliance culture by practicing the values of fairness, transparency, and ethics across all fields.
Our company aims to become a transparent and trusted organization by promoting a fair trade compliance culture.
Let us strengthen our fair transaction and ethics compliance culture by ensuring all employees can actively practice compliance through participation in fair trade education and improving incorrect practices, thereby preventing the recurrence of the same problems.

In 2025, a year of greater uncertainty than any other, we must remain faithful to the principles and fundamentals for fair trade compliance in any situation.
By practicing fair trade compliance with responsibility in our respective positions, we will be able to achieve stable and sustainable growth.
We ask all employees to keep these essential principles in mind and do their best to practice them, turning crises into opportunities.


January 2025
POSCO A&C CEO Jeon Huntai

An internal compliance system including education and supervision that companies independently establish and operate to comply with fair trade-related laws and regulations.

The Fair Trade Act seeks to promote the balanced development of the national economy by promoting fair and free competition between companies, encouraging creative business activities, and protecting consumers.

POSCO A&C published the Fair Trade Manual to comply with the Fair Trade Act and provided employees with the conduct standard for compliance with the Fair Trade Act. We have been endeavoring greatly to eliminate business practices that breach the Fair Trade Act cyclically.

As part of such endeavor, we adopted the Compliance Program (CP) in 2009. The CP manager responsible for CP operation is appointed by the board of directors.

Article 16 (Obligation)
③ Each Office head and CP practice leader shall report to the CP manager immediately, when they detect any legislature violation in carrying out their duties.

As a pre-monitoring system of law violations using checklists, this inspection is to let staff inspect violations of fair trade for themselves on their work so as to prevent the Fair Trade Act violations in advance.

포스코A&C는 11년 6월에 공정거래 자율준수편람을 자체 제작하여 임직원들에게 공정거래법 준수를 위한 행동기준을 제공하였으며, 이후 포스코패밀리사가 공동으로 법개정 및 실무사례를 보완하여 12년 9월과 14년 7월에 걸쳐 개정함으로써 편람의 적극적 활용을 지원하고 있습니다.

또한 편람의 보완자료로 [하도급부문 공정거래준수편람], [불공정거래부문 공정거래준수편람], [마케팅부문 공정거래준수 행동 가이드라인], [구매부문 공정거래 준수 행동 가이드라인], [사업관리 업무 지침서]를 발간하였으며, 14년에는 공정거래 관련 주요 이슈를 반영하여 [입찰담합예방 행동 가이드라인]을 제작하여 공정거래관련 실무에 실질적 도움이 되도록 하였습니다.
임직원들이 효율적으로 공정거래 관련 업무수행 시 활용할 수 있도록 22년 8월 최신 법 개정사항과 사례, 판례로 새롭게 구성한 편람 개정본을 발행하여 배포하였습니다.