SOCIAL RESPONSIBILITY MANAGEMENT

LEENO will have strong competitiveness by ethical and responsible management activities and aim to grow together with employees, shareholders and all stakeholders.

Each of employee will comply the domestic and international laws and regulations and conduct “Right-Path-Management” in accordance with global standards through fair transactions based on ethical values. The Code of Conduct will be treated as a standard for employees’ behaviors and values in management activities.

1. Compliance with Laws
   LEENO complies with international standards and national fair trade laws and compete freely and fairly in order to become trusted company by providing fair opportunity in transparent competition.
2. Creation of the Sound Corporate Culture
   LEENO creates an organizational culture that provides the best value to stakeholders such as customers, employees, and shareholders by respect dignity and diversity of individuals and strives to create value through continuous innovation activities.
3. Customer Satisfaction
   In order to satisfy customers, LEENO complies with customer requests and treats customers in a legal and reasonable manner. LEENO will continue to make efforts to improve its own products by listening from the customer needs and complaints for being a trusted company to the customers.
4. Social Responsibility
   LEENO contributes to society with company growth, and strives to protect the environment and maintenance of clean and safe work place as the safety & health is considered as a top priority value.
5. Increase Shareholder Value
   LEENO strives to increase the profit through ”RIGHT-PATH-MANAGEMENT”. LEENO respect each of shareholder and strive to manage its assets fairly and genuinely.

1. LEENO treats each employee with compassion, and places a high value on individual human dignity. The company shall take active steps to prevent physical and/or emotional mistreatment of employees.
2. LEENO does not offer nor authorize discriminatory hiring, wages and promotions based on gender, race, color, age, sexual orientation, gender identity & expression, ethnicity, national origin, disability, marital status, religion, pregnancy, political orientation, or social status.
3. LEENO does not compel any employee to work against their will either by assault or threat or by physical and mental confinement and freedom of movement. LEENO will not demand that employees surrender any government-issued identification, passport or working permit to the company as a condition of employment. LEENO will not require employees to pay any recruitment fees or related fees for their employment.
4. LEENO does not hire children under age of 15. Juvenile workers are not to be hired for internship or probation and LEENO must comply with relevant laws and regulation for their hiring. And LEENO does not permit employees under the age of or pregnant employees to perform tasks that jeopardize their safety or health.
5. Working hours should not be more than 52 hours per week including regular and overtime hours. Employees shall be allowed at least one day off every seven days unless there is emergency or unexpected situation. In addition, LEENO does not force employees to work overtime which is against his or her own free will and does not put employees under age of 18 to work overtime during night of holidays.
   < Amendment by Labor Standards Act, Jul. 01. 2018 >
6. LEENO will offer wages that are higher than the minimum prescribed by labor law including the payment of overtime rates under the same labor law. Deductions from wages as a disciplinary measure will not be permitted.
7. In order to promote an environment of trust and mutual respect, LEENO will provide sufficient opportunities for employees to communicate with the company. LEENO also guarantees the right of employees to form and join trade unions as governed by labor law, and will not cause any employee to be disadvantaged because of this activity.
8. LEENO will faithfully follow both domestic & international labor laws and its requirements.

1. Healthy and Safe Workplace
   Identify of hazards factors in workplace through employee’s consultation and participation, provide the human/physical resources to eliminate the risks and hazard factors and pursue to continuous improvement.
2. Operation of sustainable safety and health management system
   Establish the safety and health management objectives and create the detailed plan to be achieved, and operate the safety and health management system through regular monitoring and improvement.
3. Compliance with Laws and Other Requirements
   Domestic and International safety and health law and other requirement would be complied faithfully.
4. Make safety and health Culture
   All employees have the right to refuse the hazardous work and also report unhealthy work condition.
   Enhance the employee’s awareness of safety and health by educating and communication and prevent the industrial accidents by actively carrying out accident prevention and response activities.

1. All required environmental permits, approvals and registrations are to be obtained, maintained and complied.
2. LEENO creates the systematic work processes for the identification, management, abatement and practices proper disposal and recycling of hazardous substances and continues to make improvement efforts.
3. LEENO strives to save resources to minimize environmental pollution and improving the environment constantly.
4. LEENO will faithfully follow both domestic & international environmental laws and its requirements.

1. LEENO practices Customer-First Principle through management based on ethics, responsibility and customer satisfaction.
2. LEENO prohibits corruption and bribery through corruption-free & zero-tolerance policies and strives to create a transparent organizational culture.
3. LEENO always handles work fast & fairly based on the creative challenging spirit & high ethical sense of values, and also eliminates any kind of absurdity & corruption with compliance of anti-corruption law.
4. LEENO treats the customer values as the top priority of the management and provides the highest quality products and services to the customer.
5. LEENO respects all intellectual property rights and puts forth an effort to protect customer’s information.
6. LEENO promotes the harmony & solidarity of organization through mutual respect, equal opportunity and fair evaluation of its employees.
7. LEENO shall provide an anonymous complaint mechanism for each employee to report workplace grievances, protect whistleblower’s confidentiality and prohibit any retaliation against whistle blowing.
8. LEENO contributes to the national & social development through active participation in public beneficial activities as a member of society and through constant value creation.

REPORT
You can report any irregularities or disadvantages caused by Leeno executives or employees in relation to any transaction.
The report of such incidences can be emailed to : audit.leeno@leeno.co.kr
For a proper and in depth investigation, please specify the name, details of the case including date, contents, related materials and accurate contact information of the person reporting the incident.
This report may be made anonymously. However, the result of handling process is not advised for the anonymous report.

1. LEENO protects the valuable information property through periodic monitoring and measurement. Each employee shall practice information protection and constantly improve for information protection activities.
2. LEENO complies with laws and regulations related to information protection, and establishes education& training in order for its employees to take responsibility and to be faithful to its role for their information protection activities.
3. LEENO secures and protects personal information in accordance with the Personal Information Protection Act.

The Code of Conduct (hereinafter referred to as the “Code of Conduct”) of LEENO Industrial Co., Ltd. (hereinafter referred to as “LEENO”) is established to apply the standard to ensure working environment to be respectful for the employee to achieve mutual growth through compliance & ethical management. All the suppliers maintaining business relationship with LEENO are required to put their best efforts to comply the below contents in order to realize satisfaction of LEENO & its customers.

1. Respect for basic human rights of employees
   Supplier will protect employees’ human rights from their recruitment to retirement by the following the below rules.
   • Supplier provides fair opportunities to each employee and treat them equally, regardless of race, color, national origin, social status, disability, sexual orientation, political or religious beliefs, gender, or age.
   • Supplier shall not restrain its employees through physical contact or mental cruelty.
   • Sexual harassment (including sexual and physical contact or sexual language use) is prohibited.
   • Supplier complies with working hours limit according to the relevant laws and regulations.
   • Supplier shall offer the wages fairly and guarantee the minimum wages prescribed by the laws.
   • Supplier does not violate the human rights of others.
2. Protection of Minor Workers
   Supplier will protect minor workers by compliance with the followings.
   • The employment of worker under the age of 15 (Children Workers) shall be strictly prohibited.
   • Workers under the age of 18 should not do any hazardous work (including overtime, night shift) in consideration of safety & health.
3. Worker’s Safety & Health
   Supplier strives to create a healthy work environment by ensuring safety & health in all activities performed by employees in the work place from employee’s recruitment to retirement by following the below contents.
   • In order to prevent industrial accidents, supplier shall create a safe work process and provides sufficient training course to be followed the process to raise the safety consciousness of employees.
   • In order to prevent the occupational disease, supplier shall identify the risk factors and implement right countermeasures such as special medical check.
   • Supplier shall establish the occupational safety & health system to ensure the employee’s safety & health.
4. Ethics Management
   Supplier strives to maintain a high level of ethical standards and to maintain integrity and fair trade by compliance with the following.
   • Supplier shall create the sound of corporate culture by prohibits corruption and bribery in accordance with corruption-free and zero-tolerance policies.
   • The transfer of technology and know-how is to be done in a manner that protects intellectual property rights and LEENO information is to be safeguarded.
5. Environmental
   Supplier shall comply with the following the below rules to manage the environmental pollutants generated from the industry, and complies with environmental laws and regulations to prevent environmental pollution.
   • All required environmental permits, approvals and registrations must be obtained and maintained.
   • Supplier needs to minimize environmental pollution and is required to continuously improve activities for environment.

All suppliers must agree to above contents to be complied as well as being audited. The contents above may be revised based on changes in Global Trading Environment.

Regulations on conflict minerals, which is a part of economic sanctions, are in place in order to eradicate social problems of infringement upon human rights such as exploitation of child labor or abuse of women that are perpetrated throughout troubled regions in Africa (10 Countries: Democratic Republic of Congo, Congo, South Sudan, Rwanda, Burundi, Uganda, Zambia, Angola, Tanzania, Central Africa).
Developed countries defined 4 major minerals (3TG: Tin, Tungsten, Tantalum and Gold) mined in the troubled regions as conflict minerals and prohibit enterprises from usage of conflict minerals in order to prevent earnings of mining from inflow of the sinews of war into rebels.

In 2010, the U.S. Congress enacted the law (Dodd-Frank Wall Street Reform and Consumer Act) of mandatory reporting usage of conflict minerals. According to the provision 1502 of the before-mentioned law, listed enterprises on American stock exchange market must investigate usage of conflict minerals & country of origin, inspect their supply channel and report the result to SEC (U.S. Securities and Exchange Commission).

Conflict Mineral Policy

LEENO, as a responsible company, will not include conflict minerals, which are associated with the armed forces in troubled area, in its supply channel to produce its products.

1. LEENO will establish work process in order to comply the international regulations for conflict minerals, and will actively cooperate with the activities of EICC and GeSI(Global e-Sustainability Initiative) to prohibit usage of conflict minerals.
2. By utilizing CMRT(Conflict Minerals Reporting Template) provided by EICC and GeSI, LEENO will identify names and locations of smelters who supplies Tin, Tungsten, Tantalum and Gold.
3. LEENO will require its suppliers/partners which use 3TG minerals (Tin, Tungsten, Tantalum and Gold) to submit CMRT as well as declaration not to use conflict minerals.
4. LEENO will guide its suppliers/partners to procure conflict minerals from the certified smelters through Conflict-Free Smelter Program.
5. Based on internal regulation, LEENO will implement regular audit for its suppliers/partners regarding conflict minerals.