Code of Ethics

  • 1Chapter 1. General

    Neo Trans is committed to improve competitiveness and fulfill its corporate social responsibility through Inhwa, customer-focused
    business philosophy, transparent business operations and innovation, thereby fostering Neo Trans' continuous growth. To this end,
    Neo Trans adopt and implement the Code of Ethics (the “Code”) as our guiding principles.

    The Code applies to all directors, officers, and employees (“employees”) of Neo Trans and its subsidiaries and affiliates.
    Third parties working with Neo Trans are also encouraged to comply with the Code.

    All employees shall be responsible for understanding and complying with the Code and applicable supplementary policies.
    Any articles and items not provided in the Code or lack of specific explanations can be found from the Code of Conduct as well as
    Company's Legal Department.
    To the extent any provision of this Code or supplementary policies conflict with applicable laws, the latter shall take precedence.

    Any violations of the Code, supplementary policies and applicable laws can be reported in accordance with the procedure established
    by the Company. The Company will take every reasonable precaution to protect anonymity of the reporter. Reporting such violations in
    good faith is not subject to undergo any forms of disadvantage.

  • 2Chapter 2. Code of Ethics

    • Article 1. Inhwa

      Respect, Teamwork and Openness: “Inhwa” of Neo Trans indicates teamwork in the truest sense based on fairness and warmth.
      Employees believe that competitiveness of the Company comes from human and recognize individual differences and treat each
      other with respect.

      1. 1. Employees are unreservedly committed to the principle of non-discrimination with respect to race, color, gender, age, disability, religion, ideology, political opinion, nationality, ethnicity, health, physical appearance, sexual orientation, education and social,
        family or marital status.
      2. 2. Words and conduct detrimental to Inhwa, including offensive remarks, verbal and physical abuse, and sexual harassment are not accepted in any circumstances
      3. 3. Fairness, transparent criteria and sound principles strictly guide how employees are hired, evaluated, developed, and promoted
      4. 4. Employees are encouraged to share reasoned ideas and good-faith opinions under open communication.
      5. 5. Employees pursue solid teamwork based on fairness and warmth. We treat one another in accordance with fair and equitable standards and principles.
    • Article 2. Integrity and Transparency

      Integrity and Transparency : Integrity and transparency must be applied to every aspect of Neo Trans' organization and business.

      1. 1. Employees must not, directly or indirectly, offer, give, promise to give, receive, agree to receive, or request improper financial or other advantage (including gifts, meals, and entertainment) in dealings with public officials and individuals in the private sector.
      2. 2. Employees must ensure the integrity and accuracy of business and financial records, consistent with applicable laws, accounting principles and the Company's supplementary policies.
      3. 3. Employees must provide material information to the Company's investors in a truthful, reliable and timely manner consistent with applicable laws.
      4. 4. Employees must not act in any manner that creates, or appears to create, a conflict between Neo Trans' interests and personal interests. Employees must not engage in any activities, including activities outside of the Company's employment, which may undermine
        Neo Trans' interests and reputation.
      5. 5. We must not use, or provide to someone else, inside, confidential information of Neo Trans for personal benefit or that of someone else. Employees must not trade, or facilitate another person’s trade, in Neo Trans’, or any other company’s, securities based on any inside,
        non-public information.
      6. 6. Employees must safeguard the Company’s assets from loss, damage, theft, misuse and abuse.
      7. 7. Neo Trans’ assets may be used only for proper business purposes and for the benefit of the Company.
      8. 8. Employees must protect Neo Trans' confidential or proprietary information and must not share it with any third party without the Company’s permission.
      9. 9. Employees must safeguard the security and confidentiality of personal information in Neo Trans' possession in accordance with applicable laws.
    • Article 3. Fair Competition

      Fair Competition: Neo Trans is committed to complying with relevant antitrust and competition laws and regulations where it conducts
      business.

      1. 1. Employees value suppliers, contractors and distributors as business partners, and strive to build trusting relationships with them for mutual growth.
      2. 2. Neo Trans is committed to conducting business in ways that do not restrict fair and free competition. Employees must not unfairly restrict competition by agreeing with, or exchanging information or opinions with, the Company's competitors regarding prices, types and
        standards of the products and services, supply levels, markets and territories, customers, suppliers, distributors, terms and conditions of
        transactions, and bidding conditions and methods.
      3. 3. Employees must not use Neo Trans' dominant market position to exert undue influence on those who deal with us.
    • Article 4. Focus on Customers, Innovation, Growth

      Customer-Focused: Customers are the reason why Neo Trans exist. Neo Trans' business decisions and activities are thoroughly customer-focused.

      1. 1. Employees are driven to offer customers the best value by understanding and satisfying their needs. Employees will listen to our customers and treat them fairly and respectfully.
      2. 2. Employees will provide customers with truthful information about our products and services.
      3. 3. Innovation & Growth : Employees pursue sustainable growth through continuous innovation.
      4. 4. Employees are committed to continuously improving our technologies, products, services, processes and systems. To this end, we will actively pursue new and diverse technologies, knowledge, ideas, and information.
      5. 5. Employees will constantly set new and challenging goals, thereby improving individual capabilities and sustaining Neo Trans’ growth.
    • Article 5. Community Development

      Community Development, Safety and Environment: We are committed to building Neo Trans as a trusted company that grows with
      community. As responsible members of communities, it is the Company's duty to safeguard the life and safety of everyone in our
      communities and protect the environment.

      1. 1. Employees take corporate social responsibility seriously and contribute to the development of the community though carrying out corporate activities and actively fulfilling our corporate social responsibilities.
      2. 2. Employees are dedicated to maintaining safe working environments and complying with all applicable environmental, health, and safety standards and regulations.
      3. 3. Employees are committed to the health and safety of people, customers, and the members of communities in all aspects of Neo Trans' business, including product development, manufacturing and sales activities.
      4. 4. Employees are committed to achieving environment-friendly growth by actively improving the Company's technology and pursuing innovation.
  • 3Supplementary Policies

    • Supplementary Policies
      1. The Code is implemented from 22 January, 2014
      1. The Code is implemented from 1 March, 2017