Anti-corruption

ESG MANAGEMENT

Anti-corruption

Anti-Corruption

Anti-Corruption Policy

PUcore has established and complies with the following Anti-Corruption Policy to pursue sustainable growth together with its employees and all stakeholders and to create social value through ESG management.

All PUcore employees are prohibited from engaging in any form of corruption.
All PUcore employees shall comply with domestic and international anti-corruption laws applicable to their business activities, as well as the Company’s regulations and guidelines.
The Company establishes an anti-bribery management system aligned with global standards and continuously improves its anti-corruption management practices through implementation and monitoring by all employees.
The Company operates an effective reporting system and implements protective measures for good-faith informants so that employees can participate in anti-corruption activities without undue concern.
The Company takes strict action, in accordance with applicable regulations, against employees who fail to comply with the Anti-Corruption Policy and discloses the results to employees.
The Company ensures the authority and independence of the organization and personnel responsible for anti-corruption management.
All PUcore executives fully support the effective implementation of the anti-bribery management system.

CEO of PUcore

Anti-Corruption Practice Guidelines

Specific provisions required for the implementation of anti-corruption practices

Basic Principles

Compliance with anti-corruption laws / Compliance with these Guidelines throughout all business processes
Prohibited Conduct

Improper solicitation / Facilitation payments / Travel expense support
Compliance with Laws and Regulations

Compliance with domestic and international anti-corruption laws and regulations

1. Purpose

These Anti-Corruption Practice Guidelines (the “Guidelines”) set out the specific requirements for implementing the principles of the Code of Ethics of PUcore Co., Ltd. The Guidelines aim to prevent corrupt practices that may undermine the fair performance of duties and thereby promote the Company’s sustainable development.

2. Scope of Application

All employees of PUcore Co., Ltd. and its major investee companies over which PUcore Co., Ltd. exercises management control (collectively, the “Company”) shall familiarize themselves with and comply with these Guidelines.
Third-party representatives, including consultants, attorneys, accountants, and lobbyists, who perform work or provide services on behalf of the Company shall also familiarize themselves with and comply with these Guidelines.

3. Basic Principles

All employees of the Company, both in Korea and overseas, shall comply with all applicable domestic anti-corruption laws, including the Criminal Act, the Act on the Aggravated Punishment of Specific Crimes, the Act on Combating Bribery of Foreign Public Officials in International Business Transactions, and the Improper Solicitation and Graft Act, as well as all applicable foreign anti-corruption laws and regulations, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, the OECD Anti-Bribery Convention, the Malaysian Anti-Corruption Commission Act 2018, and the anti-corruption laws and regulations of the countries in which the Company conducts business (collectively, the “Domestic and International Anti-Corruption Laws”).
Employees shall conduct business ethically and honestly and comply with these Guidelines throughout all decision-making processes, including those related to securing contracts for projects commissioned by government agencies, public institutions, and other public-sector procuring entities.
An exception may apply where an employee faces an imminent threat to their fundamental rights and has no reasonable alternative but to prioritize their own safety. In such cases, however, the employee shall notify the department responsible for ethical management as soon as practicable.

4. Definitions

“Domestic and Foreign Public Officials, etc.” means any individual in Korea or overseas who falls under any of the following categories, as well as the spouse or immediate family member of such public official.
- a. Officials of national or local governments (persons engaged in the legislative, administrative, or judicial functions of a government, whether appointed or elected)
- b. Candidates for public office in any country
- c. Employees of political parties in any country
- d. Officers and employees of state-owned enterprises in any country (where the government exercises substantial control over overall operations)
- e. Officers and employees of public organizations or public institutions established to perform public functions
- f. Officers and employees of public international organizations (associations of countries established for a specific purpose, including both IGOs and NGOs)
- g. Official agents or consultants of any government
- h. Officers and employees of other public service organizations or persons entrusted with public duties
“Improper Business Advantage” means any benefit obtained by improperly influencing or inducing Domestic and Foreign Public Officials, etc. Such benefit includes securing any of the following or obtaining favorable treatment in relation thereto.
- a. Obtaining or retaining business (contracts)
- b. Confidential information concerning bids, business opportunities, or competitors’ business activities
- c. Approval of licenses or permits
- d. Assessments of customs duties, taxes, or fines
- e. Administrative or civil proceedings
“Providing, Offering, or Promising” includes not only the actual provision of Money or Other Benefits, but also an offer or promise to provide such benefits even where no actual provision has occurred. It also includes providing, offering, or promising tangible or intangible benefits to a third party where a person knows or reasonably should know that all or part of the Money or Other Benefits provided to that third party will be passed on to a Public Official, etc.
“Money or Other Benefits” means any of the following.
- a. Any property or financial benefit, including money, securities, real estate, goods, accommodation vouchers, memberships, admission tickets, discount coupons, invitations, event tickets, usage rights, and congratulatory or condolence money
- b. Hospitality or entertainment, including meals, alcoholic beverages, and golf
- c. Benefits or conveniences, including transportation, accommodation, event support, and domestic or overseas travel
- d. Debt forgiveness, employment opportunities, or the granting of rights or interests
- e. Any other tangible or intangible economic benefit
“Facilitation Payment” means a small payment made to a public official engaged in routine or repetitive duties for the purpose of expediting the lawful performance of those duties. Typical examples of such duties include receiving and processing administrative documents, such as visa applications, and customs clearance, shipping, and unloading related to the transportation of products.
Any term not separately defined in these Guidelines shall have the meaning prescribed by the applicable anti-corruption laws and regulations of the relevant country.

5. Prohibition on Providing Money or Other Benefits

Employees shall not, directly or indirectly, provide, offer, or promise Money or Other Benefits to Domestic or Foreign Public Officials, etc. in any of the following circumstances.
- a. Where the provision or receipt of Money or Other Benefits is prohibited under the anti-corruption laws and regulations of the country to which the Domestic or Foreign Public Official, etc. belongs
- b. Where the Money or Other Benefits are provided for the purpose of obtaining an Improper Business Advantage
- c. Where Money or Other Benefits are provided repeatedly to the same individual
- d. Where the provision is at a level that is contrary to generally accepted social norms
If an employee is uncertain whether the provision of particular Money or Other Benefits violates these Guidelines, the employee shall consult the Legal Department or the department responsible for ethical management.

6. Prohibition on Improper Solicitation

In addition to complying with the requirements prohibiting the provision of Money or Other Benefits, employees shall comply with the provisions prohibiting improper solicitation under the Improper Solicitation and Graft Act when interacting with domestic public officials.
For purposes of this Section only, “domestic public officials” shall be defined as the persons covered by the Improper Solicitation and Graft Act.

7. Prohibition on Travel Expense Support

Employees shall not provide travel expenses to Domestic or Foreign Public Officials, etc. in any of the following circumstances.
- a. Where the provision or receipt of travel expense support is prohibited under the anti-corruption laws and regulations of the country to which the Domestic or Foreign Public Official, etc. belongs
- b. Where the travel is not directly related to the Company’s business purposes
- c. Where the travel expense support is not permitted under the internal regulations of the institution to which the relevant public official belongs
- d. Where travel expenses unrelated to the purpose of the trip are also provided
- e. Where payment is made directly in cash to the relevant public official rather than directly to a service provider such as a hotel or airline
If an employee is uncertain whether particular travel expense support violates these Guidelines, the employee shall consult the Legal Department or the department responsible for ethical management.

8. Prohibition on Political Contributions

Employees shall not make or authorize political contributions in any form to any government agency, political party, or other organization on behalf of or in the name of the Company.
Exceptions to the prohibition on political contributions shall be limited to cases where prior written approval has been obtained from the employee’s immediate supervisor at the executive level or above and the Legal Department, while complying with applicable laws and regulations, including the relevant country’s political finance laws, election laws, and local anti-corruption laws.

9. Limited Charitable Donations

Employees may make charitable donations or provide sponsorships to legitimate charitable organizations affiliated with international organizations, provided that such contributions comply with applicable laws and regulations and the Company’s internal rules. However, donations that may damage the Company’s reputation, may be perceived as bribes, or are intended to secure any other improper benefit are not permitted.

10. Prohibition on Facilitation Payments

The Company treats facilitation payments as equivalent to bribes regardless of the amount. Accordingly, employees shall not make facilitation payments to Domestic or Foreign Public Officials, etc. However, where facilitation payments are permitted due to local cultural practices or under local laws and regulations, and an employee receives a request for such payment from a local public official, the employee shall obtain prior written approval from their immediate supervisor at the executive level or above and notify the Legal Department and the department responsible for ethical management.
If an employee is uncertain whether a proposed payment constitutes a facilitation payment, the employee shall consult the Legal Department or the department responsible for ethical management.

11. Compliance Requirements for Mergers and Acquisitions

When acquiring another company, the Company may incur legal liability for bribery and corrupt practices previously committed by the target company in relation to Domestic or Foreign Public Officials, etc. Accordingly, the Company shall make efforts to identify and address legal risks in advance.
Following the acquisition of a target company, the Company shall operate an anti-corruption management system, including anti-corruption training, inspections and monitoring, and a reporting system, to establish a culture of integrity.

12. Books and Records Management

The Company shall maintain detailed and accurate books and records reflecting all transactions and ensure that such records are properly documented and retained.
Employees shall prepare accounting records and financial reports fairly and appropriately in accordance with applicable laws and internal regulations. They shall not, for any purpose, record false, forged, altered, or manipulated information or omit information that is required to be recorded.

13. Ethics Compliance Pledge

Employees shall submit an Ethics Compliance Pledge to the department responsible for ethical management, including a commitment to comply with Domestic and International Anti-Corruption Laws.

14. Training and Consultation

Employees shall complete anti-corruption compliance training as instructed by the department responsible for ethical management.
Employees shall consult the department responsible for ethical management if they have any questions regarding these Guidelines in connection with the performance of their duties.

15. Investigation and Monitoring

Employees shall actively cooperate with periodic or ad hoc audits or investigations conducted by the Company to verify compliance with these Guidelines.

16. Reporting and Informant Protection

Employees are responsible for identifying corruption risks while performing their duties. They shall report to the department responsible for ethical management any actual or suspected violations of applicable laws or these Guidelines.
The Company strictly protects informants and prohibits any disclosure of their identity, retaliation against them, or attempts to identify them, and shall not subject informants to any disadvantage in employment or otherwise.

17. Disciplinary Action for Violations of the Guidelines

Any violation of these Guidelines by an employee may be deemed a violation of the Company’s internal regulations and may constitute grounds for disciplinary action, including dismissal.
If an employee’s corrupt conduct is suspected of violating Domestic and International Anti-Corruption Laws, the Company may report the matter to the relevant law enforcement authorities.

※ Operation of the Anti-Bribery Management System

The department responsible for ethical management operates the Anti-Bribery Management System, and the chief executive officer shall grant the department sufficient authority to ensure the system operates effectively.
To ensure it can perform its duties independently, the responsible department should, to the extent practicable, not be involved in activities of organizations exposed to corruption risks.
The responsible department shall perform the following roles.
- - Establish clear objectives for the Anti-Bribery Management System, review potential corruption risks that may arise in each of the Company’s business processes, and establish a system designed to mitigate such risks and achieve the established objectives.
- - Develop specific implementation measures for each business process to ensure the Company’s compliance with anti-corruption legal requirements.
- - Ensure the continuous improvement of the suitability, adequacy, and effectiveness of the Company’s Anti-Bribery Management System.
- - Where expert assistance is required, including for legal interpretation, the responsible department may seek advice from the Legal Department.
- - Detailed Activities
  - a. Review, establishment, revision, and repeal of relevant regulations and guidelines, including the Anti-Corruption Practice Guidelines
  - b. Establishment, distribution, and training regarding anti-bribery and anti-corruption policies and guidelines
  - c. Interpretation of and consultation on Domestic and International Anti-Corruption Laws and these Guidelines
  - d. Administration of anti-corruption pledges and training for employees
  - e. Establishment and operation of the reporting system
  - f. Establishment and operation of an ongoing corruption risk monitoring system
  - g. Appropriate disciplinary measures against employees who violate these Guidelines

[Supplementary Provisions]

· a. These Anti-Corruption Practice Guidelines shall take effect on June 10, 2026.