Achieving sustainable, shared growth with business partners
through fair trade relationships based on trust.
Dear POSCO A&C staff!
Our POSCO A&C has coexisted and grown with various stakeholders based on compliance and ethical management.
Compliance with fair trade is now a prerequisite for survival, not an option, and is our firmest competitiveness to continue growing into a company trusted by the market, customers and suppliers.

Since the introduction of the Fair Trade Compliance Program (CP) in 2009, our company has continuously strengthened the foundation of the culture of self-compliance with fair trade based on the active participation and practice of our executives and employees.
As a result, it acquired the "AA grade" in the Fair Trade Commission's CP rating evaluation for three consecutive years from 2023 to 2025, establishing itself as a leading fair trade model company.
Management, including myself, is not complacent with these achievements, and will continue to inspect and play a responsible role so that self-compliance with fair trade can take root in the overall management of the company.

But past performance does not guarantee future performance.
The external regulatory environment is becoming stricter, and a single negligence or conventional judgment can return as a fatal risk to companies and individuals.

Therefore, in 2026, we would like to make the principle of self-compliance in fair trade the top priority of management and make the following three points stronger.

First, let's constitute 'law management' that applies laws and principles without exception.
Achievements that undermine laws and principles for achieving goals and practices are by no means a real success.
All executives and employees should thoroughly review the risks that may arise when performing their duties, and clearly comply with relevant laws and internal procedures to fundamentally prevent possible violations of the law.

Second, let's consolidate our 'horizontal partnership' with our business partners.
Fair Trade Compliance is the starting point for building solid trust with our business partners, our partners. In no case should there be any abuse of superiority, unreasonable demands, or unreasonable transaction conditions.
Let's create a healthy industrial ecosystem that grows with our partners through transparent transactions.

Third, let's spread a 'culture of self-compliance' through autonomous monitoring and education.
Compliance with fair trade is completed by the day-to-day practice of all members, not the work of a specific department.
Please actively participate in regular fair trade training to enhance your expertise and continue self-improvement of wrong practices in the field.
Please establish a transparent communication culture that immediately shares and corrects even minor violations.
In addition, the company will thoroughly protect executives and employees who report issues related to fair trade or concerns about violations from any disadvantages.

As a CEO, I promise to continuously check and support the overall system, organization, and culture so that compliance with fair trade can be at the center of the company's management.
In 2026, let's create POSCO A&C that is trusted by all stakeholders by spreading fair competition and transparent trading culture based on laws and principles.


January 2026
POSCO A&C CEO Jeon, Hun Tai
What is a Fair Trade CP? (CP: Compliance Program)
An internal compliance system including education and supervision that companies independently establish and operate to comply with fair trade-related laws and regulations.

CP 8 Core Elements
Categories
  • 1. Establish and implement CP standards and procedures
  • 2. Top management's commitment and support for compliance
  • 3. Appoint compliance officers responsible for CP operations
  • 4. Develop and utilize compliance manuals
  • 5. Conduct continuous and systematic compliance education
  • 6. Establish internal monitoring systems
  • 7. Sanctions against executives and employees who violate fair trade laws
  • 8. Effectiveness evaluation and improvement measures
Why CP is needed?
  • Strengthen competitiveness and fair trade capabilities
    Corporate competitiveness enhancement and continuous development are possible through fair trade compliance efforts
  • Prevent losses from legal violations in advance
    When legal violations are detected, companies face not only economic burdens such as fines, damages, and litigation costs, but also tangible and intangible losses, such as social image deterioration due to reports of legal violations
  • Enhance internal and external credibility
    By announcing CP adoption internally and externally and operating it substantially, the corporate image is enhanced as a company practicing transparent and fair management
  • Minimize damage from legal violations
    When operational staff accidentally violate fair trade-related laws and regulations, they may receive benefits such as penalty reductions from the competition authorities
Execution Overview
Background
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.
Operation Status
Reporting Procedure upon Detecting the Fair Trade Act Violating Activity
Relevant Regulations (Regulations of Fair Trade CP Operation)
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.
Reporting Process
Reporting Method and Details
Details Reporting Timing Subject to Report
in the First Phase
Subject for
Final Report
Reporting Method
Fair Trade Act
Violations
Immediately
after Recognition
Members of
self-compliance council
(Department Head
and CP Practice Leader)
CP Manager
or Department
in charge of CP,
Executive
First Phase Reporting
: Telephone
Final Reporting
: In Writing
What is Fair Trade Autonomous Inspection?
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.
Autonomous Inspection Diagram