POSCO Group’s ethical management is based on our corporate philosophy of “doing the right thing in the right way”.
POSCO Group has achieved remarkable growth with the mission to assist national advancement. In the process, we have engaged in a relentless search to identity what is right for our country and business.
We must charge ourselves with the trust of the people and a stronger belief in ourselves to drive us forward and navigate the future. At this juncture, I would like to share with you the new way forward in our ethical management.
First, ‘my’ actions and decisions should always represent ‘integrity’. We shall not seek personal interests at work and all decisions shall be made with the highest standard of justice and righteousness.
Second, we shall practice the value of respect for ‘others’. We shall protect the human rights of our co-workers and everyone with whom we interact in our business activities, embrace diversity, and treat each other with fairness.
Third, let us exercise ‘mutual empathy’ as a means to extend the boundaries that frame ‘we/us’. We can develop and grow together through mutual trust by paying attention to the voices of our stakeholders and by respecting the perspectives and rights of diverse populations.
POSCO Group will step up our efforts to being a trusted leader in the global market through ethical management.
Ethics Charter
Ethics Principles
Code of Conduct
Practice Guidelines
Programs & Training
Clean POSCO System
POSCO Group aspires to become a trusted and respected enterprise by deeply understanding that ethical management is the greatest value we must uphold in order to co-exist and co-prosper with our many stakeholders as a member of society.
Members of the POSCO family must comply with laws and ethics based on the ethical management philosophy of “doing the right thing in the right way”, while also seeking to achieve Integrity, Respect, and Mutual Empathy and establishing an ethical corporate culture in business activities that cover all the basics and comply with the rules.
At the employee level, we must pursue individual growth and company success by achieving a work-life balance and create a positive work environment by establishing a corporate culture of mutual respect. We must fulfill our duty to respect everyone as human beings and to respect the human rights universally pursued by human society.
For our customers, we must understand that our future depends on customer trust and success. We must respect the customer voice at all times and create value that promotes customer prosperity.
For our shareholders, we must enhance shareholder value by making fair profits through transparent decision making and efficient business activity.
With our business partners, we must establish a fair trading system based on mutual trust and strengthen our corporate ecosystem in which we co-exist with our business partners through mutual growth.
At the community level, we must contribute to the development of society by fulfilling our duties and obligations. We must be deeply aware of the importance of environmental issues and do our best to protect the environment in all of our business activities.
POSCO family members must always be aware of the fact that our actions are directly linked to our self-respect as well as corporate value and reputation. We pledge to comply with the Code of Conduct and to ensure that ethics and integrity are at the heart of our culture and business operations.
July 2024
Ethics Principles
1. Roles and responsibilities of all employees
- We comply with relevant laws and company regulations and guidelines anywhere in the world where POSCO E&C conducts business.
- We endeavor to maintain our dignity as employees and protect our corporate reputation.
- We make our best efforts to establish an ethical culture by taking responsibility for practicing ethical behavior.
- We report to or consult an authority figure or the department in charge of ethical management immediately upon becoming aware of the fact that a situation faced or an action performed by us or another person violates or is likely to violate the Code of Ethics.
- We fully cooperate with investigations conducted by the department in charge of ethical management regarding matters that are likely to violate the Code of Ethics.
- We do not retaliate against informants or individuals who participate in an investigation in relation to Code of Ethics violations.
- We are aware of the fact that by violating the Code of Ethics, soliciting another person to violate the Code of Ethics, failing to report a Code of Ethics violation or cooperate with an investigation, or taking retaliatory action against an informant or individual participating in an investigation, we may become subject to disciplinary action as appropriate.
In particular, we are aware that there is zero tolerance for the four major ethical violations: acceptance of bribery, misappropriation, fabrication of information, and sexual misconduct.
2. Special responsibilities of executives and authority figures
Executives and authority figures have the responsibility to set an example of ethical compliance and prevent ethical misconduct among staff members. To this end, they must be aware of the following principles and put them to practice:
- When the company’s profits and ethics are in conflict, you have a duty to prioritize ethics in your operational and administrative decision making.
- You must exemplify ethical conduct in your work and fulfill your duty as an internal and external role model.
- You must train and guide staff members to understand the provisions of the Code of Ethics and Practice Guidelines and the importance of compliance.
- You must routinely examine your teams for ethical misconduct and proactively prevent unethical behavior that is likely to occur by identifying the causes, improving processes, and taking other measures.
- You must foster an organizational atmosphere that promotes and supports ethically correct behavior where staff members can speak up without worrying about adverse action.
- You must report to or consult the department in charge of ethical management immediately upon becoming aware of the fact that a staff member has violated the Code of Ethics.
- You have unlimited liability for any ethical misconduct you have engaged in, and supervisory liability for the ethical misconduct of a subordinate employee.
Code of Conduct
-
Compliance with basic ethics and relevant laws
- We do not seek personal gain.
- We protect company information and assets.
- We practice fair competition and trading.
-
Developing a culture of trust and human respect
- We foster a wholesome organizational culture.
- We provide equal opportunities.
- We protect and respect human rights.
-
Realizing customer values
- We commit to customer satisfaction.
- We create customer value.
- We build customer trust.
-
Good faith towards investors
- We fulfill our obligations to investors.
- We communicate transparently with investors.
-
Co-prosperity with suppliers
- We build mutual trust with suppliers.
- We pursue co-prosperity with suppliers.
-
Social and environmental responsibility
- We contribute to the development of the nation and society.
- We commit to environmental protection and ecosystem conservation.
Practice Guidelines
Chapter 1. General Provisions
Article 1 (Purpose)
The purpose of these Practice Guidelines is to provide a frame of reference for making decisions and taking action in ethical dilemma situations that may arise during the course of work so that POSCO E&C employees understand and apply the Code of Ethics correctly.
Article 2 (Scope)
These Guidelines apply to the Company and all employees.
Article 3 (Principle of Application)
Employees shall make decisions and take action based on the Code of Ethics and these Practice Guidelines when faced with an ethical dilemma situation in relation to work.
However, if a frame of reference is not clearly prescribed herein, employees shall make decisions and take action according to the following decision-making principles. Employees who are not confident in their judgment shall consult the leader of the organization or the department in charge of ethical management and act accordingly.
<Decision-making Principles>
- • Lawfulness: Is my action likely to be interpreted as a violation of the law, rules, regulations or company Codes?
- • Transparency: Can I disclose my decision-making process and the relevant details?
- • Rationality: Am I making the best possible choice for the company and individuals?
Chapter 2. The Code of Ethics in Practice
1. Restrictions on the provision and acceptance of valuables
- “Valuables” means money (cash, gift certificates, vouchers, etc.), goods, and other articles that may bring about financial gain.
-
Valuables shall not be provided to or solicited or accepted from stakeholders for any reason. However, exceptions shall be made in the following circumstances:
- Marketing or promotional gifts valued at or less than KRW 50,000 or up to KRW 150,000 for agricultural, marine, and processed goods (including ornamental plants)
- Memorabilia bearing the company logo of a stakeholder and memorabilia routinely offered to attendees at stakeholder-organized events, not exceeding KRW 50,000
- Employees shall not solicit or accept gifts from domestic/foreign entities (including any project offices, corporations, branches, etc.) during business trips.
- Valuables that are unanticipated and accepted due to unavoidable circumstances shall be returned, or if this is impracticable, report to the department in charge of ethical management.
2. Principles and restrictions concerning hospitality
- “Hospitality” means various activities that facilitate business-related gatherings and interactions, such as meals, social drinks, golf, performances, and entertainment.
- Hospitality in excess of KRW 100,000 per person shall not be offered to or accepted from stakeholders. If it is necessary to offer or accept hospitality in excess of KRW 100,000 per person in relation to work, prior approval shall be obtained from the head of the department. Hospitality in excess of KRW 100,000 per person that has been offered or accepted due to unavoidable circumstances shall be reported to the department in charge of ethical management.
- Food worth up to KRW 30,000 per person may be provided to public officials, journalists, teachers, and other persons subject to the Improper Solicitation and Graft Act to facilitate work execution or for social, ceremonial, or other legitimate purposes.
- Hospitality at an entertainment and drinks venue that offers services of a sexual nature is prohibited regardless of cost.
3. Principles and restrictions concerning convenience
- “Convenience” means benefits such as transportation, accommodation facilities, sightseeing, event support, etc. provided by or to a stakeholder.
- The provision or acceptance of transportation, accommodation facilities, or other convenience beyond a generally acceptable level is prohibited. However, this shall not include conveniences routinely provided to all attendees at an event, etc.
- A convenience in excess of the permitted range that has been offered or accepted due to unavoidable circumstances shall be reported to the department in charge of ethical management.
4. Principles and restrictions concerning congratulatory and condolence money
- Employees shall not notify stakeholders of their own family events or those of their colleagues. Informing a stakeholder through a third party shall be construed as a notification made by the employee concerned.
- However, employees may inform each other of their family events. Use of the Company's congratulations and condolences channel is advised. For the purpose of family event announcements, the scope of relatives shall be limited to immediate family members, namely the parents, grandparents and children of employees and their spouses. Congratulations and condolence money between employees shall be at a generally acceptable level.
- The maximum limit for congratulations or condolence money paid to an external stakeholder shall be KRW 100,000, including floral wreaths or arrangements. However, congratulations or condolence money paid to a person subject to the Improper Solicitation and Graft Act shall not exceed KRW 50,000, excluding floral wreaths or arrangements.
- Congratulations and condolence money from external stakeholders shall not be accepted under any circumstance. Congratulations or condolence money that has been accepted due to unavoidable circumstances shall be returned or donated to the department in charge of ethical management.
- Employees shall submit the relevant information, such as proof of return of congratulations or condolence money accepted from a stakeholder, when requested by the department in charge of ethical management.
- Condolence flowers from stakeholders shall not be accepted, and those that are accepted due to unavoidable circumstances shall not be displayed.
5. Restrictions concerning solicitations and recommendations
-
Employees shall not make solicitations or recommendations through an internal acquaintance or an external party regarding the following. If an employee has received a solicitation or recommendation, he/she shall register it in the “Clean POSCO System.”
- Requests for preferential treatment regarding various contracts, such as equipment/materials purchases
- Requests for favorable and preferential treatment regarding personnel decisions such as hiring, promotions, rewards and punishments, and transfer of positions
- Requests for excessive convenience, preferential treatment, etc. outside of usual procedures
- Requests to neglect management and supervision tasks such as inspections and tests
- Employees shall not unlawfully solicit favors directly or through a third party in relation to duties subject to the Improper Solicitation and Graft Act.
6. Restrictions concerning Lecture Fee
- A Lecture Fee means the money employees receive as compensation for delivering a lecture at a company, institution, or group other than our company.
- If a lecture involves using knowledge obtained in the line of duty and is held outside the company during business hours, employees shall obtain prior approval from the relevant department related to the lecture content before accepting such request.
- Lecturing at an external venue related to our business implies the use of our company's assets. Therefore, if employees deliver lectures at any company, institution, or organization outside of our company, they shall report this to the head of their department and donate 50% of the Lecture Fee to the department in charge of ethical management.
- Employees may retain the full amount of the Lecture Fee only if the lecture is unrelated to our business and takes place during off-duty hours.
- Employees shall not accept any Lecture Fee from stakeholders, regardless of the lecture’s relation to their business. If any Lecture Fee is received, the full amount shall be donated to the department in charge of ethical management.
- This article shall apply to all other personal proceeds from advice, examination, deliberation, or similar activities related to our business outside the company.
- The donated instructor fees shall be allocated to an Ethics Fund and used for social contribution activities in the lecturer’s name.
- When inviting public officials - such as government officials, journalists, faculty members and other public officials defined under the Improper Solicitation and Graft Act- as a lecturer, Lecture fee shall not be paid in violation of the Improper Solicitation and Graft Act
7. Restrictions concerning monetary transactions
- Employees shall not engage in cash loans, loan guarantees, name lending, leasing of a real estate or other monetary transactions with stakeholders.
- An employee who has engaged in a monetary transaction with a stakeholder due to a personal connection shall report it to the department in charge of ethical management.
8. Restrictions concerning event sponsorship
- Sponsorships from stakeholders shall not be accepted for events funded by the Company, such as department events or club activities.
- The acceptance of vehicles, venues, services, or other conveniences required for an event shall be construed as acceptance of sponsorships.
- A sponsorship that has been accepted due to unavoidable circumstances shall be reported to the department in charge of ethical management.
9. Principles concerning the use and protection of Company assets
- The Company's budget resources, such as meeting expenses and operating expenses, shall be used as intended by the budget and in accordance with legal requirements, and shall not be used for personal purposes.
- As a general rule, business expenses shall be paid with a Company card.
- In addition to the budget, all tangible and intangible assets, including Company supplies and facilities, shall be used for work-related purposes only.
- Ongoing efforts shall be made to protect assets by periodically reviewing asset classification and protection measures.
- All Personal information (such as telephone numbers, email addresses, etc.) of customers or employees shall not be disclosed or used for any purpose other than its intended collection and processing purposes.
10. Principles concerning information protection
- Important or confidential Company information shall be strictly protected and controlled.
- Important information shall be relayed to the intended recipient immediately upon recognition.
- The falsification, concealment, or distortion of work-related information or the reporting or distribution of incorrect information shall be regarded as fabrication of information.
- Employees shall manage internal Company information acquired during the course of work according to the security level, and shall not use the information for personal purposes.
11. Fair trade regulations and building mutual trust with suppliers
- Employees shall comply with international standards and national laws and regulations concerning fair trade to ensure fair competition in domestic and international markets and refrain from engaging in unfair trade practices such as colluding with competitors regarding production, prices, bidding and market segmentation.
- Employees shall fulfill their social responsibility by refraining from using a position of power against a client or supplier to make demands or unlawful requests.
- Employees shall respect the rights and property of others, including intellectual property rights, and shall not infringe upon them to create business or generate profit.
- The information acquired from a supplier shall be strictly protected as stipulated in relevant laws and regulations and contract terms.
- Employees shall support suppliers to comply with laws and regulations concerning fair trade and ESG.
12. Principles concerning the prevention of conflicts of interest
- “Conflict of interest” means a situation where a personal relationship with an employee of a supplier has an improper influence on an employee’s work performance.
- Employees shall not engage in unfair trade practices such as signing unlawful private contracts, making high-price purchases, tunneling work, or leaking trade information to give preferential treatment to a certain individual or corporation.
- Employees shall prevent conflicts of interest by strictly denying improper requests from a supplier’s employee with whom there is a personal connection, including former employees.
- Employees shall not make unofficial contact with a supplier’s employee with whom there is a personal connection, and shall report any unintentional contact to the head of the department or the department in charge of ethical management.
- Employees shall not attend gatherings of former employees without the Company’s approval.
- Where an employee has a personal connection to a supplier’s employee, he/she shall consult the head of the department or ethics officer and adjust his/her duties, etc. accordingly.
- When the head of the department recognizes a work-related conflict of interest involving himself/herself or a staff member, he/she shall adjust the relevant duties or otherwise take action to avoid the conflict of interest. If it is impracticable to avoid the conflict of interest due to the nature of the work, he/she shall consult the department in charge of ethical management.
- 퇴Retired employees shall also prevent conflicts of interest with POSCO E&C and its affiliated companies.
13. Developing an organizational culture of human respect
- Employees shall not engage in verbal, physical, or visual behavior that may offend others, such as the use of profanities, verbal abuse, physical abuse, or sexual harassment that violates the human rights of an individual.
- Violations of human respect may be subject to disciplinary action in accordance with the relevant regulations.
- Employees shall respect each other’s privacy and shall not slander or undermine others or disclose personal information.
- Employees shall comply with national labor laws and international standards, including working conditions for minors and minimum working age requirements.
- Safety rules shall be strictly observed, and any risks identified shall be addressed appropriately.
Chapter 3. Reporting Unethical Conduct and Rewards and Sanctions
- Employees who recognize the fact that he/she or someone else has violated the Code of Ethics or these Guidelines shall actively protect the Company and employees from unethical practices by reporting to or consulting the head of the department or the department in charge of ethical management as quickly and conveniently as possible. However, violations of human respect shall be reported to the department in charge of ethical management without delay.
- Executives and department heads shall report to and consult the department in charge of ethical management immediately upon being informed of a violation of the Code of Ethics by a staff member, and shall not downplay or conceal the incident.
- The department in charge of ethical management may conduct a fact check of the reported incident if necessary, and the employees concerned shall actively cooperate.
- Employees shall not take adverse action against, or disclose the identity of, an informant or whistleblower.
- Where it is likely that an informant or whistleblower may be subject to adverse action in terms of employment, a change of position or other personnel measures shall be taken if so desired by the informant.
- If an employee becomes aware of the fact that an incident has been reported, either by chance or during the course of work, he/she shall keep it confidential or face disciplinary action.
- The Company may award part of the clawback resulting from an ethical misconduct investigation to the informant as compensation in accordance with the relevant regulations.
- The compensation criteria shall be in accordance with the guidelines on compensation and indemnity for informants of ethical misconduct and other relevant regulations.
- The Company shall firmly reprimand employees who violate the Code of Ethics and Practice Guidelines in accordance with the relevant regulations.
- The Company may restrict Company access and business to employees who have been dismissed after violating the Code of Ethics.
- Employees who become aware of a violation of the Code of Ethics or these Practice Guidelines shall actively protect the Company and employees from the violation by reporting it to the head of the organization or department or the department in charge of ethical management for timely resolution.
POSCO E&C operates the Reporting Consultation Center where employees can report unethical behaviors done by executives and staff members, under the motto of “Doing the Right Things Right.”
Reporting Consultation CenterSystem Operation
POSCO E&C has established and is operating a variety of ethics-related policies to help employees be accustomed to ethical practices.
Educational Activities
POSCO E&C is contributing greatly to the establishment of an ethical corporate culture through various channels of ethics education.
Purpose
Creating a corporate culture with “no solicitation” by recording and managing all recommendations and requests
Works as a preventive device against unethical behavior 
- The executive or staff member who received the solicitation. can justify their refusal due to company’s registration policy and
- the person who made the solicitation feels the psychological burden of leaving a solicitation record. This prevents unreasonable solicitations in the future.
Practicing whistle blower spirit 
- Creating an honest and transparent atmosphere in the company by executives and staff members who received the solicitation by conscientiously registering
- Solicitation registration is regarded as a voluntary report. Executives and staff members are protected and exempt from any future problems or responsibilities.
Operation Process
-
Registration subject
- All executives and staff members related to recommendation/solicitation, including recipients, deliverer, and related persons in charge
-
How to register
- Executives and staff members who received recommendation/solicitation should register what happened in accordance with 5W1H principle.
- Solicitor is informed with the registration fact along with his/her personal information (name, company name, position, etc.)
-
Registration time
- Recommendation/solicitation should be registered within 24 hours after it occurs
- However, if there is a special reason such as business trip, registration should be made immediately after the reason has ended.
Process for recommendation/solicitation registration
-
STEP 1
Recommendation/Solicitation should be registered it in the system in accordance with 5W1H principle
-
STEP 2
Company Audit Department receives and reviews the content
-
STEP 3
The information is delivered to the relevant department (HR Office, Equipment & Materials Purchasing Office, etc.)
-
STEP 4
If necessary, Investigation is carried out by the Company Audit Department and necessary measures are taken in case of problems
Detailed Standards
Definition of solicitation
- Solicitation refers to any expression of intention by the solicitor, such as a request that may influence the performance of duties and decision-making of executives and staff members, for the purpose of the solicitor him/herself or others
Standards for judging fairness about the influence on job performance or decision-making (* Regulations of the Anti-Corruption & Civil Rights Commission)
- An act that creates an interest to the executive or staff member who received the solicitation if he/she accepts or rejects the solicitation
- An act (request of the solicitor) that is psychologically burdensome on the person when conducting fair business
Scope of recommendation/solicitation to be registered
- Clean POSCO system is to prevent the occurrence of misconduct by solicitation in advance. Thus, the scope of solicitation is wider than what is defined by the law. All expressions of intention that can undermine fairness should be registered.
- If it is unclear whether it is a solicitation or a normal business, they should be registered in the system
- Executives and staff members who do not register the recommendation/solicitation despite being aware will be severely sanctioned.
- Request for preferential treatment for equipment/material purchase and various contracts
- Request for special and preferential treatment in various personnel matters, such as recruitment, promotion, reward, punishment, and position transfer
- Request for special treatment, such as providing convenience/benefits that breaches standards and principles
- Request to neglect management/supervision tasks such as inspection
- In case where the solicitor withdraws the solicitation facing a refusal in fear of identity exposure due to solicitation registration
- Request for cooperation through official documents
- Acts of requesting cooperation, such as simple confirmation, inquiry, complaint, etc. for doing business in related institutions or departments
How recommendation/solicitation registration is processed
- Recommendation/solicitation results are handled by relevant departments such as HR and the Procurement Department, and penalties may be imposed to related executives and staff members or companies.
CCTV Operation policy
CCTV Policy for the Protection of Personal Information
CHAPTER I GENERAL PROVISIONS
Article 1 (Purpose)
The purpose of this Policy is to fulfill appropriate duties and comply with applicable laws by setting matters POSCO E&C Ltd. (the “Company”) must comply with in relation to the installation and operation of closed-circuit televisions and protection of footages.
Article 2 (Definitions)
The terms used in this Policy shall be defined as follows:
- 1. The term closed-circuit television (“CCTV”) is a type of communication network, in which the footages recorded from the CCTVs located in specific sites are collected and transmitted to exclusive receivers through wired/wireless closed-circuit channels.
- 2. The term “footage” refers to CCTV recordings of which the recorded subject can be identified.
- 3. The term “data subject” refers to an individual who can be identified from the footage; that is, the subject of footage.
- 4. The term “processing” refers to the act of handling data collected through CCTVs, such as inputting, saving, editing, deleting, playing, and other similar acts, excluding the collection of such data.
Article 3 (Scope of Application)
- (1) In relation to the installation and operation of CCTVs needed for crime prevention, facility security, and fire safety, as well as the protection of footages that are collected and processed by the aforementioned reasons, the provisions of this Policy shall be observed, unless special provisions are stipulated in other laws.
- (2) Use of auxiliary cameras for CCTVs installed and operated by the Company shall also comply with this Policy, regardless of the fact whether their recordings are treated as actual footages or not.
Article 4 (Protection of Footages)
- (1) The Company shall collect minimum scope of footages that meets the purpose of CCTV installation.
- (2) The Company must have the data subject clearly aware of the installation purpose as mentioned in paragraph (1) of this Article. The footages shall not be used for other purposes than the said purpose.
- (3) The Company shall secure accurate and the latest footages and manage them in a safe manner.
- (4) The Company shall disclose general matters in relation to the handling of footages and protect the rights of data subjects.
CHAPTER II REQUIREMENTS FOR CCTV INSTALLATION
Article 5 (Notification of Installation Plans, etc.)
In the event of installing a CCTV, the Company shall prepare a CCTV installation and operation plan (“Plan”) that includes the following items:
- 1. Purpose of CCTV installation;
- 2. Division in charge of CCTV control: Handling officer and contact details;
- 3. Number of cameras, locations, performance, and scope of recording of the CCTV to be installed and operated;
- 4. Standard of the caution sign to be installed and the installation location in accordance with Article 7(1);
- 5. Contents, procedures, and methods regarding the data subject's exercise of rights and means of objection;
- 6. CCTV recording time, retention period of footages, methods of storage, management, and deletion of footages, and storage location of footages;
- 7. Actual location where footages transmitted from CCTVs are accessed and played, and access control to the said location;
- 8. Grounds, procedures, and methods of providing or granting access to footages to a third party; and
- 9. Other matters recognized to be necessary for the protection of footages
Article 6 (Designation of CCTV Managers)
- (1) The head of the division in charge of the installation and operation of CCTVs shall be designated as the CCTV General Manager, while his or her staff shall be designated as CCTV Operation Manager(s) (“CCTV Manager(s)”).
- (2) The CCTV Manager shall take charge of duties in relation to the installation and operation of CCTVs, reception and handling of complaints, and collection and processing of footages.
- (3) The CCTV Manager shall designate and manage a separate Personal Information Handler and inform the CCTV General Manager of relevant information in the event of CCTV installation and/or other changes.
Article 7 (Installation of Caution Signs)
- (1) In the event of installing a CCTV, the Company shall put up caution signs regarding CCTV operation and the collection of footages for the recognition of data subjects.
- (2) The signs in relation to paragraph (1) of this Article shall mention the following items:
- 1. Purpose of CCTV installation;
- 2. Recording scope and time; and
- 3. Information on the CCTV handling division, CCTV Manager, and contact details
- (3) The signs in relation to Paragraph (1) of this Article shall be installed within the recording scope where they are easily visible and understood by data subjects.
- (4) Notwithstanding Paragraph (2), in the event of installing several CCTVs in the Company’s building, the sign that complies with Paragraph (1) may mention that the whole building is within the recording scope and can be attached only on the building exits.
CHAPTER III REQUIREMENTS FOR HANDLING FOOTAGES
Article 8 (Limitation on Collection)
- (1) CCTVs shall not be arbitrarily manipulated or shoot other places beyond the purpose of their installation during collection of footages.
- (2) Footage rotation and zooming features that have no relation to the purpose of CCTV installation may not be used during collection of footages.
Article 9 (Limitation on Processing)
Footages of a data subject may not be used for other purposes than the CCTV installation purpose or be granted access or provided to a person who has no access authority: Provided, That this shall not apply in any of the following circumstances:
- 1. Where consent is obtained from the data subject;
- 2. Where the data is given access or provided to the data subject;
- 3. Where special provisions exist in other laws;
- 4. Where the data is provided in a pseudonymized manner when it is required for the purposes of reporting by the media through newspapers or broadcasting;
- 5. Where there is an urgent reason for not obtaining the data subject's consent when the risk that the rights and interests of the data subject may be infringed is clear and present;
- 6. Where it is necessary for the investigation of a crime, indictment, and/or prosecution; or
- 7. Where it is necessary for the enforcement of punishment, probation, and custody.
Article 10 (Safeguards, etc.)
- The Company shall designate a place where footages transmitted by CCTVs are actually accessed and played (“Control Center”) as a restricted zone and strictly limit the access of individuals apart from those who have been granted the authority.
- (2) The Company shall limit the authority to access footages to CCTV Managers and the minimum number of designated personnel.
- (3) The Company shall regularly inspect and check the normal operation of CCTVs and keep an accurate record regarding the matters.
- (4) The Company shall seek for technical and managerial safety measures in response to illegal access, alteration, leakage, and damage of footages.
- (5) The Company shall prepare a training course on the personal information protection of data subjects for those who are granted authority to access footages.
Article 11 (Request for Access, etc.)
- (1) A data subject may request to confirm the existence, access, and/or delete footages to the Company.
- (2) In relation to the request as mentioned in the paragraph (1) of this Article, the Company shall take immediate action in accordance with Article 5(5).
- (3) Notwithstanding Paragraph (2) of this Article, the Company may refuse to take action in the event of any of the following circumstances. In this case, the grounds for refusal and objection method shall be informed (including information and communications networks) to the data subject within seven (7) days.
- 1. Where it may cause grave difficulties in performing investigation of crimes, prosecution, and conduct of trials;
- 2. Where deleting only the footages of a specific data subject is extremely difficult in technical manner;
- 3. Where taking appropriate action as prescribed in Paragraph (1) of this Article may infringe upon other's privacy rights; or
- 4. Where there are appropriate grounds to refuse the request for access, etc., that meet the public interest.
Article 12 (Retention and Deletion)
Footages collected through CCTVs shall be deleted without delay once the data retention period mentioned in the Plan expires: Provided, That when it is difficult to determine the minimum period of time required to achieve the purpose of data retention due to the nature of a division, the retention period shall be within thirty (30) days after the collection of footages.
CHAPTER IV SUPPLEMENTARY PROVISIONS
Article 13 (Consignment of Duties)
- (1) In the event of consigning the duties in relation to the installation, operation, and management of CCTVs, the Company shall take necessary safety measures to prevent the abuse of footages and supervise the consignee.
- (2) The consignee who is granted authority to access footages in relation to paragraph (1) of this Article shall undergo a training course as mentioned in Article 10(5).[lh1]
Article 14 (Confidentiality)
Those who handle or have handled footages shall not use the obtained data for inappropriate purposes, such as revealing, processing without authority, and/or providing for the use of another person.
Article 15 (Exclusion)
This Policy shall not be applied to CCTVs installed and operated to supervise the duties of individuals who are with the military regardless of their duties.