Kumho Tire is committed to managing transparent and efficient ethical management by establishing and maintaining a Code of Ethics and detailed ethical guidelines. The Code of Ethics encompasses attitudes toward customers, the basic ethics of employees, attitudes toward shareholders and investors, competitors, and suppliers. It also includes guidelines for handling improper gains such as gifts, as well as specific principles for consultations and reporting, all aimed at fostering an ethical corporate culture.

🔗Code of Ethics    🔗Detailed Rules of Ethics

Fair Trade Policy

As a directive for practicing the Code of Ethics, Kumho Tire has established a Fair Trade Policy, providing standards for employees to comply with fair trade-related laws and regulations. In accordance with this policy, all employees must compete fairly with competitors based on the principles of free competition and strive for mutual growth through fair transactions based on mutual trust and respect. We have established and implemented educational plans to ensure the adoption of fair trade practices and take necessary actions in case of any violations of the Fair Trade Policy.

🔗Fair Trade Policy

Anti-Corruption and Compliance Policy

In 2023, Kumho Tire established an Anti-Corruption and Compliance Policy that all employees are required to adhere to and practice. This policy has been distributed and posted across all departments, and has been published on the official website to demonstrate our leadership and commitment to anti-corruption both internally and externally. The Audit Planning Team, Legal Affairs & Compliance Team, HR Operations Team, Strategic Planning Team, and Information Security Management Team are participating in the Ethics Management Working Group, which plans activities to prevent corruption. They strictly manage compliance and code of conduct violations by incorporating them into performance evaluations and applying penalties such as salary deductions.

🔗Anti-Corruption and Compliance Policy

Kumho Tire is committed to implementing a 2024 action plan under the strategies of strengthening prevention audits, enhancing internal management audits, and reinforcing operational risk management to ensure transparent and reliable ethical management.

ISO 37301 and ISO 37001 Certification

With the enforcement of the Serious Accidents Punishment Act and the strengthening of ESG requirements, the need for a a company-wide compliance management system has increased. Consequently, in 2023, we obtained ISO 37301 (Compliance Management System) and ISO 37001 (Anti-Corruption Management System) certifications for all domestic business sites. Kumho Tire is managing potential risk factors regularly at the corporate level by establishing risk assessment tables by departments and writing monitoring reports.

Compliance Management

Self Inspection Activities on Compliance

Kumho Tire conducts its own compliance inspections to prevent risks. Led by a compliance officer appointed by the board of directors, each department regularly carries out voluntary compliance inspections covering 17 areas and 348 clauses across all domestic and international operations. The compliance officer develops corrective action plans for any non-compliance, continuously monitors their resolution and reports the inspection results to the board of directors at least once a year.

Internal Diagnostic System

Kumho Tire has established an internal control system by introducing an internal diagnostic system alongside a legal-based internal accounting management system and a compliance officer system. This internal diagnostic system allows each department to check risk items that may arise during approval processes and routine operations, supporting all employees in proactively managing risks.

Compliance and Anti-Corruption Risk Assessment

Kumho Tire established its own risk assessment tables to manage potential risks related to compliance and corruption. Risk elements with concerns for company regulations and law violations are evaluated using a heat map, in terms of inherent and residual risk levels and importance. Appropriate inspection procedures and control measures are established for each risk. Additionally, to raise employee awareness and ensure efficient operation, we have provided integrated auditor and internal auditor training to relevant personnel.

Major Self-Inspection Items

Implementation of Clean Contract System

Kumho Tire is implementing the Clean Contract System to prevent improper practices throughout the entire process from contracting to purchasing. Contract managers submit pledges to promise fair and transparent performance of their duties and adhere to fairness and transparency during the contract execution process.

Educational Activities

Ethics Training

Kumho Tire conducts annual Code of Ethics training for all office working employees. Through online training, employees learn about the contents of the Code of Ethics the importance of adherence, and how to handle cases and violations of the policies. Subsequently, employees sign a pledge to comply with the code and complete self-assessment forms to evaluate and improve the level of ethical management within the organization.

Compliance Management Education

In addition to training on the policies, Kumho Tire also provides training on compliance management. Custom-tailored training sessions are conducted for employees in safety, HR, and financerelated departments, addressing potential issues related to compliance management. This training aims to prevent illegal activities and enhance employees’ compliance capabilities.

Fair Trade Education

To raise awareness of fair trade and prevent violations, Kumho Tire regularly conducts fair trade law training for sales managers and employees of relevant departments. External legal experts in various fields, including the Fair Trade Act, the Subcontracting Act, transfer pricing regulations, and the Agency Act, are invited to provide training on related laws and updates from the Fair Trade Commission. Additionally, prohibited practices and case studies related to agencies are shared with sales employees, including the Head of Sales, at domestic business sites to emphasize the importance of fair trade.

Ethical Management Campaigns

Kumho Tire encourages employees to practice ethical management through campaigns such as ‘a Clean Holiday Season.’ These campaigns are actively promoted via the groupware, and employees and suppliers who receive gifts, money, or other undue benefits are encouraged to self-report and return them through the gift return center.

Ethical Audits

Kumho Tire emphasizes internal audit activities for proactive risk management. Regular and ad-hoc audits are conducted to diagnose and manage company-wide risks related to ethical management, corruption, and transparency in purchasing. Identified violations and improvement areas from these audits are discussed with each department to strengthen the company-wide risk management system. Through routine audits and internal diagnostic systems, we continuously monitor departmental processes and regulatory compliance. Special and report-triggered audits are conducted as needed to ensure adherence to internal procedures.

Ethical Reporting

Kumho Tire provides various channels for stakeholders, including employees, business suppliers, and customers, to report any unethical behavior. Reports can be made through a Cyber Reporting Center, phone, mail, and email, with anonymity guaranteed for the reporters. We regularly inform stakeholders of the reporting channels and methods every six months through the internal system to encourage reporting. For better accessibility, especially in overseas operations, information is also provided in Chinese and English. To protect whistleblowers and internal informants, the Audit Committee restricts access to internal reports and ensures anonymity in handling reports.

Reporting Channels

Reward System for Whistleblowers

Kumho Tire operates a reward system for whistleblowers, providing rewards ranging from a minimum of KRW 500,000 to a maximum of KRW 1 billion, based on the recovered amount and the whistleblower’s contribution. The company continuously informs employees about the whistleblower reward system via groupware.