Ethical Misconduct
- Act of accepting bribes or lavish treatments offered by external stakeholders to influence business decision.
- Use of one’s position of power to gain unjustified personal benefit; using unjust means and/or harbouring wrongful intent to cause harm to the company.
- Other ethical misconduct involving external stakeholder(s). Please note that your report may be excluded from the investigation if:
- you report about an employee’s personal life and/or private disputes that the company cannot get involved in;
- you request preferential treatment in connection with the report or make the report for unjustifiable purposes;
- or you slander others with unfounded, malicious reports or falsehoods or one-sided allegations.
Confidentiality of Reporters Identity
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.
How to File a Complaint
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.
- Employees shall not be disadvantaged in any way for legitimate reporting.
- The reporting channels for violations:
- Email: pipc.ethics@posco.net
- Telephone: 9684808728
- Postal Address: Central Compliance Team, POSCO India Pune Processing Center Pvt. Ltd. Plot No. A-9, Talegaon MIDC, Navlakh Umbre, Maval, Pune.
Reward for Reporting
Reward for Reporting Ethical Misconduct:
With the goal to build a sound corporate culture by preventing ethical misconduct, we reward those who report ethical misconduct.
We receive information about POSCO employees and their unfair business practice, unreasonable demands made using positions of power and other ethical misconduct.
Filed reports are kept strictly confidential.
For qualifying reports, cases are processed as quickly as possible; their outcome can be tracked through the channel used to file the complaint. Upon the request of the reporter, results can be provided by e-mail.
Rewards, Penalty and Sanctions (disciplinary action)
The Company may award part of the claw back resulting from an ethical misconduct investigation to the informant as compensation in accordance as per following criteria:
Rewards
| Classification | Increase in Revenue or Decrease in Loss Amount (INR) | Reward | |
|---|---|---|---|
|
|
|
Monetary Reward (INR) One Time |
Non-Monetary Reward (Performance Appraisal % Addition One Time) |
|
Level 1 |
Upto ₹1,00,000 |
₹5,000 |
+ 3% added to Quarterly Incentive |
|
Level 2 |
₹1,00,000 to ₹5,00,000 |
₹10,000 |
+ 4% added to Quarterly Incentive |
|
Level 3 |
Above ₹5,00,000 |
₹20,000 |
+ 6% added to Quarterly Incentive |
|
Non-Quantifiable / Preventive Impact |
Not Measurable |
₹2,500 |
+ 2% added to Quarterly Incentive |
* Cases Excluded from the Reward
- Cases which proven to be incorrect
- Cases which is Not proven
- Cases which were investigated earlier or identified by the Central compliance so that the investigation is going on/disciplinary action is taken
- Cases which are already announced to public by media and etc.
- Cases related to personal welfare and benefits
- Other cases which doesn’t deserve the reward by the management’s judgement
* In all the cases, the Committee reserves the right to make any decision regarding the reward which will be given to the Ethics complainant.
Penalty
| Classification of Proven False Reporting | Description | Penalty |
|---|---|---|
|
1st Instance |
Intentional or malicious false submission |
Caution Letter (5% Deduction from Quarterly Incentive) |
|
2nd Instance |
Repeated false or misleading claims |
Warning Letter (10% Deduction from Quarterly Incentive) |
|
3rd Instance |
Continued misuse or fabricated allegations |
Severe Warning Letter (15% Deduction from Quarterly Incentive) |
- From second instance of misleading or improper claims, employees may face performance and promotion demerits based on management review.
- Anonymous disclosures are permitted; however, monetary or appraisal rewards apply only when identity is voluntarily disclosed to enable verification.
- Penalties for false or malicious submissions by external parties. The company may take appropriate action.
Consultation Service
Please do not hesitate to reach out to us if you are facing an ethical dilemma at your workplace, for example, if you have any concerns regarding the ethical nature of POSCO’s business practices or if you are struggling to practice the Code of Ethics.
- The consultation channels for violations:
- Email: pipc.ethics@posco.net
- Telephone: 9684808728
- Postal Address: Central Compliance Team, POSCO India Pune Processing Center Pvt. Ltd. Plot No. A-9, Talegaon MIDC, Navlakh Umbre, Maval, Pune.
General Human Rights Issues
- Non-discrimination in Employment: No discrimination is made based on individual characteristics such as race, gender, age, disability, or nationality in employment, and equal opportunities are provided.
- Guarantee of Freedom of Association and Collective Bargaining: Workers’ freedom of association and collective bargaining rights are guaranteed, and unfair treatment due to union activities is prohibited.
- Prohibition of Forced and Child Labor: Forced labor and child labor are prohibited, and all workers are guaranteed the right to work of their own free will.
- Guarantee of Industrial Safety: Workplace safety equipment and facilities are maintained, and essential protective gear is provided to ensure industrial safety for workers.
- Responsible Supply Chain Management: Management is in place to prevent cases of human rights violations such as forced labor and child labor in the supply chain.
- Protection of Local Residents (including Indigenous Peoples): Opinions are collected to prevent human rights violations in local communities due to the company’s business activities, and the impact on the local environment, residents’ safety, health, and economic activities is considered to minimize human rights violations.
- Guarantee of Environmental Rights: Legal standards related to environmental protection are observed.
- Protection of Consumer Rights: Products and services that do not threaten consumers’ health are provided.
How to File a Complaint
Employees who become aware of a violation of the Human Rights shall actively protect the Company and employees from the violation by reporting:
- The consultation and reporting channels for violations:
- Email: humanrights_ipc@posco.net
- Telephone: 9684808730
- Postal Address: Central Compliance Team, POSCO India Pune Processing Center Pvt. Ltd. Plot No. A-9, Talegaon MIDC, Navlakh Umbre, Maval, Pune.
We Respect Your Courage
If you witness behaviour that goes beyond incivility and violates our Code of Conduct, please report it through official channels so we can take action.
Direct Reporting Channels to HQ
- Online
- Visit POSCO website (www.posco.co.kr) and go to Ethics & Reporting → click Report
- Link to HQ Website reporting page: POSCO HQ Ethical Misconduct Reporting
- Telephone
- External: 080-390-3366; Seoul – 02-3457-3366
- Internal: Pohang – 054-220-3366; Gwangyang – 061-790-3366
- Mail
- (Postal code) 06194 / POSCO Center, 440, Teheran-ro, Gangnam-gu, Seoul (892, Daechi 4-dong, Gangnam-gu, Seoul), Head of Corporate Audit Office
- Email
- Human Rights violations: humanrights@posco.com
- Ethical Violations: ethics@posco.com
Scan the QR Code (Website Reporting Center)
Reports can be submitted in any language. Professional translation support is provided. If you prefer another language,
please use the real-time translation feature by pointing your Google camera at the screen.
We guarantee strict confidentiality and a fair investigation process.