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Ethical Management

Ethical Management is the cornerstone fueling our sustainable growth and progression.

“ At SK On, we leverage the SK Management System (SKMS) as the foundation of our operations, aspiring to generate value for all stakeholders and drive towards creating a happier world. ”

SK On’s Commitment to Ethical Management

Anchored in the principles of SKMS, SK On is dedicated to generating value for a broad range of stakeholders, including customers, employees, shareholders, and the community. Our efforts play an instrumental role in stimulating social and economic progress and, ultimately, contributing to the well-being of humanity.

To achieve these objectives, we have formulated a code of ethics that guide our team members' actions and judgments, further reinforced by detailed practice guidelines.

Code of Ethics

These are the benchmark for decision-making and conduct across all our business activities.

Core Ethics of
Team Members

As proud representatives of SK On, our team members dutifully fulfill their roles and responsibilities, always embodying the company's ethos.

Our Approach towards Customers

Our commitment to ongoing customer satisfaction allows us to earn their trust and fosters mutual growth.

Responsibility for
Shareholders

We continuously strive to elevate the company's value to generate returns for our shareholders, emphasizing transparency and efficiency in our business operations.

Our Role
in Society

Beyond contributing to economic growth, we aim to grow in tandem with the community by creating social value.

Learn More About Code of Ethics
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SK On Corporation (hereafter "the Company") stands on the foundation of SKMS, driving value creation for a broad spectrum of stakeholders, including customers, team members, shareholders, and the wider community. In doing so, we cement our role as a linchpin in societal and economic progression, aiming to advance human happiness and well-being. To anchor this vision, we've crafted ethical standards that guide our business judgments and actions across all operations.

1. Ethical Pillars for Our Team
"As representatives of the Company, we take pride in our roles, consistently championing the Company's ethos through diligent and responsible execution of our duties."
- We draw a firm line between professional and personal, ensuring fairness and transparency in all business undertakings.
- We foster an environment of mutual respect, enabling team members to find satisfaction and avenues for personal growth through their roles.
2. Customer-Centric Approach
"We're committed to fostering unyielding trust with our customers, ensuring mutual growth and success at every step."
- We are relentless in our pursuit to cater to customer needs with unmatched products and services.
- Customer insights are invaluable; we actively integrate their feedback into our strategic operations.
- We prioritize the protection of customer assets and data, strictly adhering to relevant legal and corporate guidelines.
3. Commitment to Shareholders
"We prioritize amplifying corporate value, setting the stage for enhanced shareholder returns, underpinned by our dedication to transparency and operational efficiency."
- Through continuous innovation and streamlined management, we aim to optimize our corporate value, sharing the ensuing success with our shareholders.
- The Company's governance is rooted in board-led autonomy and responsibility, ensuring shareholder voices are heard and respected.
- We produce business reports strictly aligned with regulatory standards, guaranteeing shareholder interests through meticulous, lawful disclosures.
4. Societal Role
"Our contribution to economic growth is paralleled by our dedication to fostering societal value, enabling us to grow in harmony with the communities we serve."
- We champion the creation of societal value, endeavoring to elevate happiness across communities.
- Our commitment to safety and environmental stewardship fortifies our bond of trust with society, fostering collective growth and prosperity.
- We ensure our partners and collaborators experience fair business opportunities, prohibiting unfair practices, leveraging our dominant position, and promoting shared success. Respecting local regulations, traditions, and cultures is non-negotiable in our areas of operation.
5. Scope of Application
These ethical standards are binding for all individuals associated with the Company, spanning our global subsidiaries. While our ethical standards are recommended for investment entities with partial Company ownership and business associates with trade or contractual ties to the Company, it is not mandated.
Supplementary Provisions (Jan. 1, 2006)
1. These ethical standards were implemented on January 1, 2006.
2. For clarity and coherence, we introduced separate 'Practice Guidelines for Ethical Standards' to facilitate accurate interpretation and adherence.
Supplementary Provisions (Oct. 24, 2016)
1. These ethical standards were implemented on October 24, 2016.
Supplementary Provisions (Apr. 28, 2017)
1. These ethical standards were implemented on April 28, 2017.
Supplementary Provisions (Jun. 1, 2019)
1. These ethical standards were implemented on June 1, 2019.
Supplementary Provisions (August 7, 2023)
1. This Code shall come into effect on August 7, 2023.
Code of Ethics

Practice Guidelines for Code of Ethics

These guidelines provide decision-making and action standards for potential ethical conflicts
that may arise during business operations.

  • Principles of Ethical Decision-making and Conduct

    Compliance with the Law / Transparency / Fairness
  • The Stance of Our Team Members

    Commitment to diligent performance / Prohibition of conflicting interests / Protection of company assets / Regulations on gifts and entertainment / Encouraging respect among team members
  • Adherence to Laws and Company Management Policies

    Quality and customer information / Management information / Fair trade and competition / Safety, health, and environmental standards / Anti-corruption measures / Donations and sponsorships
  • Operation of Practice Guidelines

    Departments responsible / Channels for reporting and consultation, along with whistleblower protection
Learn More About the Practice Guidelines for Code of Ethics
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1. Guiding Principles
1.1 Scope of Application
The Code of Ethics Guidelines (hereinafter these“Guidelines”) apply to all Members (hereinafter “Members”) of SK i nnovation Co., Ltd., SK energy Co., Ltd, SK globalchemical Co., Ltd., SK lubricants Co., Ltd., SK incheonpetrochem Co., Ltd., SK trading international Co., Ltd .., and
SK ie technology Co., Ltd (hereinafter the “Company) and the Company's affiliates (foreign or domestic).
For those affiliates whose shares are partially owned by the Company and for those business partners who are in business or contractual relationship with the Company's, we recommend them to comply with the Company's Code of Ethics.

1.2 Purpose
These Guidelines aim to provide the criteria for decision making and action regarding ethical dilemmas, which may arise in the course of work, to assist the Members to understand and properly act upon the Company’s Code of Ethics.

1.3 Principles of ethical decision-making and conduct
All Members shall act in accordance with the Code of Ethics and these Guidelines in case of an ethical dilemma faced in the course of work. In case these Guidelines lack clear guidance for a particular case, Members shall act in accordance with the following principles of decision-making, and if one is uncertain of his or her judgment, such Member shall seek the advice of his or her leader or that of the ethics department for correct interpretation and shall act in accordance with such interpretation.

• Legitimacy: Can the action be interpreted as a violation of laws/regulations or the Company regulations?
• Transparency: Can the process of decision-making and outcome be disclosed?
• Rationality: Would other Members make the same decision under the same circumstances?
2. Responsibility of the Members
2.1 Diligent execution of duties
Members must be fully aware of their rights and responsibilities and work in good faith.

2.2 Resolving conflict of interest
1) Members must do their best to prevent the circumstances that may violate their duty of loyalty to the Company due to the conflict of interest with the Company in relation to the performance of their duties.
2) The following circumstances shall be considered as conflict of interest. Members shall note that since this is not an exhaustive list of all conflict of interest cases, strict judgement and application of these Guidelines for actual cases are required.

• Prohibited Actions
- Using the Company’s assets or information to obtain personal gains;
- Abusing one’s position in the Company as means to exert improper influence on the Company’s business partners such as solicitation of any personal management, request for provision of various advantages, etc.; and
- Engaging in secondary jobs to such extent that it impedes one’s diligent execution of duties.

• Cases where one must disclose conflict of interest to his/her leader and obtain the Company’s approval in accordance with the relevant Company procedures such as the arbitrary decision regulation:
- One directly or indirectly enters into a contract with, or engages in business transactions with, the Company; and
- One owns shares of, or engages in management activities of, the Company’s business partner, which can be put under his or her direct or indirect influence through business relations.

2.3 Appropriate use and protection of the Company’s assets and information
Members must safeguard and properly use the Company’s tangible and intangible assets.
1) One shall not use the Company’s assets or transfer/lease the Company’s assets to a third party for personal gains without the Company’s authorization or approval.
2) One shall not use the Company’s budget for personal use. The Company’s budget must be used only for the purpose set by the Company, and such use must be accurately recorded in the Company’s accounting books.
3) One shall not exploit the Company’s computers, Internet, e- mail, phone, fax, etc. for personal use.
4) One shall strictly protect the Company’s intellectual property rights, including but not limited to patents, trade secrets, trademarks, copyrights, and other proprietary information. The intellectual property rights of third parties shall also receive the same protection, and in particular, illegal software shall not be used.
5) The Company’s proprietary information, including information related to business or technology, shall be strictly managed in accordance with the related Company regulations. The decision of whether or not to disclose information assets and the scope of such disclosure shall be determined according to the relevant laws/regulations and the Company regulations and policy, and the same applies to the interviews with the media.
6) One shall not trade stocks based on the confidential information acquired during the course of work or disclose it to third parties.
Especially in cases such as large-scale supply contracts or facility purchase contracts, taking private profits or avoiding losses using important undisclosed information should be strictly prohibited.
7) Information necessary in the course of performing duties shall be obtained by legitimate means.

2.4 Offer or receipt of gifts, hospitality, etc.
1) Members shall conduct all business activities in a fair and transparent manner. No one shall offer any gifts, hospitality, etc. to any interested parties, regardless of such offer’s connection to his/her duties or the motive for such offer.
2) Members shall not accept any gifts, hospitality, etc. from the Company’s business partners or interested parties, regardless of such acceptance’s connection to his/her duties or the motive for such acceptance.
3) Any forms of offer or receipt of gifts, hospitality, etc., whether delivered directly or indirectly, are prohibited, except such offer or receipt of reasonable level of hospitalities within the scope generally permitted under the relevant laws/regulations and in the context of social norms to maintain healthy and friendly relationship. Each department or division in the Company may establish and enforce more detailed guidelines for the foregoing in accordance with the relevant laws/regulations.

2.5 Mutual respect between the Members of the Company
1) Members shall treat each other with respect and maintain propriety and dignity as SK members.
2) No Member shall be discriminated against for the reason of gender, educational background, birthplace, marital status, race, nationality, religion, etc.
3) Members shall not engage in any acts (i.e. sexual harassment, verbal abuse, etc.) that violate a person's human rights and disrupts a healthy work environment.

3. Compliance with Laws/Regulations and Business Policy
Members shall have clear understanding of domestic and foreign laws related to the Company’s business activities as well as the Company’s policy and other regulations and shall perform their duties accordingly.

3.1 Quality management and the protection of customer information

1) The Company has responsibility to meet the customers’demands with respect to quality, reliability and safety of its products and to supply products satisfying standards required by the relevant laws/regulations and contracts, and, in order to achieve this, Members shall comply with all requirements set by the Company's quality management system.
2) Members shall provide accurate information regarding a product’s functions and risks to the customers, and shall not make any false or exaggerated advertisements.
3) Members whose duties involve handling of customers’ personal information shall establish procedures and guidelines to protect such information in accordance with the relevant laws/regulations and the Company policy, and shall safeguard such personal information accordingly.

3.2 Preparation and disclosure of management information
1) Accounting practice shall strictly adhere to the generally accepted accounting principles, related laws/regulations and the Company regulations to accurately record and maintain the accounting information. Accounting information of the Company shall not be distorted or concealed in any way.
2) All management information including financial information shall accurately reflect all relevant facts and details of business transactions to support the management in making business decisions.
3) The disclosure of management information to the external interested parties shall be made in a fair and transparent manner according to the relevant laws/regulations and the Company regulations.
4) Members shall not commit, or direct others to commit, any acts to distort management information (e.g. by falsifying, concealing, exaggerating, withholding, or delaying reports).

3.3 Fair trade and competition
1) Members shall have clear understanding of, and comply with, the laws related to fair trade and competition as well as the Company's fair trade voluntary compliance management regulation.
2) For matters that may be interpreted as violation of fair trade and competitions laws, Members must seek prior consultation of the legal team or business compliance team of the Company to handle such matters and Members shall not make any arbitrary decisions with regards to such matters.

3.4 Policies on safety, health, and environment
1) Members shall observe domestic and foreign laws/regulations and international treaties related to safety, health, and environment. Members shall strive to continuously make improvements in these domains.
2) Members shall adhere to safety regulations and foster a safe working environment.
3) Members shall acknowledge the importance of environmental issues and actively seek to protect the environment.

3.5 Compliance with international anti-corruption conventions and related domestic and foreign laws
1) Members shall not improperly solicit any public officials in the course of their works in violation of the Improper Solicitation and Graft Act.
2) Members shall not offer, promise to offer, or express any intention to offer any financial or other advantages to any public officials in violation of the Improper Solicitation and Graft Act.
3) Members shall comply with international anti-corruption (including bribery and money laundering) conventions and domestic and foreign laws including OECD Anti-Bribery Convention, UN Convention against Corruption, U.S. Foreign Corrupt Practices Act, UK Bribery Act, and Act on Combating Bribery of Foreign Public Officials in International Business Transactions of Korea.
4) For matters that may be interpreted as violation of anti- corruption laws, Members must seek prior consultation of the legal team or ethics management department of the Company, and Members shall not make any arbitrary decisions with regards to such matters.


3.6 Policies on donation and sponsorship
The Company may make donations or offer sponsorships only to the extent permitted under the relevant laws/regulations and in the context of social norms and by obtaining official approval of the Company pursuant to the established Company procedures.
In any event, donations and contributions for any political purposes are strictly prohibited.

4. Execution of these Guidelines
4.1 Responsibility
1) All Members are obligated to comply with the Code of Ethics and these Guidelines, and shall seek and follow interpretation of his/her leader or ethics management department of the Company for any matters that are questionable.
2) Leaders shall ensure that their members and other interested parties related to their work have a sufficient understanding of the Company’s Code of Ethics and these Guidelines. Also, leaders shall diligently and responsibly observe the Code of Ethics and these Guidelines in their decision making and actions at all times to set standards for the conducts of other Members.

4.2 Reporting non-compliance and protection of whistleblower
1) Any Member who becomes aware of a violation of the Code of Ethics or these Guidelines shall immediately report such incident to his/her leader or to the ethics management department of the Company so that the Company can promptly make appropriate resolutions to protect itself and the Members from consequences of such violation.
2) Members shall not receive any disadvantage in any manner for reporting acts of violation or non-compliance.
3) “The Procedure for Ethics Counselling and the Management of Non-Compliance Report” shall govern the process of non- complicance or violation reports and any inquiries related to this matter can be made via the following channels;

• Webpage: http://ethics.sk.co.kr/advice/advice.aspx
• Email : skon.ethics@sk.com
• Mail : Audit Office (person in charge of Ethics Management), SK on Co., Ltd., Jongro Tower, 51 Jong-ro, Jongno-gu, Seoul, the Republic of Korea

Addenda (January 1, 2006)
1. Effective Date
These Guidelines shall come into force on January 1, 2006.
2. Punishment against non-compliance
Any violation of these Guidelines shall be treated in accordance with the Company regulations.
3. Interim measures
Any cases of non-compliance with these Guidelines including conflict of interest with the Company shall be reported to a senior officer or to the ethics department by February 28, 2006 and the Company shall not hold such Member responsible for his/her actions.
Addenda (October 24, 2016)
1. Date of enforcement
These Guidelines shall come into force on October 24, 2016.
Addenda (April 28, 2017)
1. Date of enforcement
These Guidelines shall come into force on April 28, 2017.
Addenda (June 1, 2019)
1. Date of enforcement
These Guidelines shall come into force on June 1, 2019.
Addenda (August 7, 2023)
1. Date of enforcement
These Guidelines shall come into force on August 7, 2023.
Practice Guidelines for Code of Ethics

Ethical norms for the stakeholders

SK on established Purchasing Ethics and Code of Conduct in order to achieve mutual development
through fair trade in an equal relationship with suppliers.
This is in line with SK’s philosophy of ethical management that seeks to continue mutual growth and
development based on the trust of stakeholders.

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Code of Purchasing Ethics
The Code of Conduct for suppliers