Anti-Corruption Policy

Objective

Hana Financial Group conducts business with ethical values as its top priority to realize finance that grows together and shares happiness based on morality and responsibility. In particular, the group prohibits all forms of corruption and bribery and does not deliberately tolerate or overlook suspected corruption and bribery.

Hana Financial Group has established this policy based on Code One, Group Internal Control Regulations, and domestic and international anti-corruption laws and regulations, and applies it to the management activities of all affiliates. Also, the group uses this policy as a standard for judging the behavior and value of all employees.

Scope of Application

This policy applies to all employees (including full-time, temporary, and dispatched employees) and suppliers of all affiliates of Hana Financial Group. Each Affiliate may establish a separate anti-corruption policy including the contents of this policy. If there is a conflict between the anti-corruption policy of the affiliate and the contents of this group policy, a stricter standard shall be followed.

Reporting

If an employee becomes aware of or suspects that the self or another employee has violated the ethical standards, including this policy, Code One, or Group Internal Control Regulations, he or she shall immediately report such facts to the Compliance Team or Compliance officer of the respective affiliate.

Whistleblower Protection

Under the provisions of the internal reporting system, personal information and details of giving report are strictly protected. Also, disadvantageous measures against the whistleblowers and other relevant persons are prohibited.

Supervision and Management

This policy is managed by the Group Compliance Officer and the Compliance Team. Each affiliate shall internalize the principles of anti-corruption based on this policy and perform management and supervision for its effective implementation.

Anti-Corruption Action Policy

1. Fair Business Practices

(Fair Competition) Employees shall follow the relevant fair-trade laws and standards and refrain from using unfair business measures, which hinder the desirable market order.

(Prohibition of the Use of Undisclosed Important Information) Employees shall not engage in unfair transactions, such as trading financial investment products or providing them to third parties, using undisclosed information or materials learned in business.

(Prohibition of Unsound Business Activities) Employees shall not abuse their superior position with various transactions with customers and stakeholders or conduct unsound business activities based on false and exaggerated signs and advertisements.

2. Prohibition of Conflict of Interest

(Prohibition of Conflicting Activities) Employees shall prioritize the protection of the interests of customers at work and refrain from engaging in any activities that conflict with the interests of customers or the company.

(Prohibition of Pursuing Personal Interest) Employees shall not engage in other profit-seeking activities and concurrent duties to pursue personal interests without the approval of the company. Also, employees shall not use the company’s information or materials to pursue personal or third-party benefits or compensation through improper means.

3. Prohibition of Accepting Bribery and Entertainment

(Prohibition of Solicitation and Bribery) Employees shall not offer or promise gifts, entertainment, or any form of benefits to public officials or others in violation of relevant laws and regulations.

(Restrictions on Gifts) Employees are strictly prohibited from obtaining unfair profits that impede the fairness and objectivity of their work. Also, employees shall not receive or demand tangible or intangible benefits such as money or gifts from all stakeholders, including employees.

4. Integrity Agreement

(Integrity Obligation) Employees shall engage in transparent and fair transactions with suppliers. Employees also shall not use their superior position to force unfair transaction conditions, transfer costs, conduct unfair practices, or demand direct or indirect money or entertainment.

(Concluding an Integrity Contract) Employees will require the counterpart to conclude an integrity contract for compliance with integrity obligations* when concluding a contract with an external company.

* The contract may include prohibition of promises such as money·entertainment for contract personnel, prohibition of prior consultation and collusion of bid prices, prohibition of acts that interfere with fair competition through mediation, etc.

5. Charitable Giving

(Operation of Grants) Hana Financial Group operates the 'Internal Charitable Giving Policy,' including the standards, handling procedures for efficient management of grants.

(Prohibition of Political Contributions) Hana Financial Group complies with the Political Funds Act in Korea and prohibits the use of company resources for making any donation to political parties.