POSCO E&C complies with fair and transparent transactions that meet the market competition.
"POSCO E&C will continue to make steady efforts to establish a safe, fair, and transparent corporate culture."
Greeting from Song Ki-won, Compliance Officer and Compliance Program Manager at POSCO E&C:
POSCO E&C has been operating a Compliance Program (CP) for fair trade since July 2003 to establish a safe, fair, and transparent corporate culture.
The fair trade compliance program is a core compliance management system directly prepared and continuously developed by the company, embodying the commitment to establishing a fair trading culture.
In January 2023, POSCO E&C introduced the compliance officer system under the Commercial Act—even though it is not a listed company—to further strengthen the company's legal compliance activities.
As a result of these efforts, POSCO E&C achieved the top rating (AAA, Excellent) for two consecutive years in 2023 and 2024 by the Fair Trade Commission's CP rating evaluation for the first time in the construction industry, solidifying its status as a compliance model company.
This was made possible by the spirit of coexistence and symbiosis and the firm commitment to compliance practice shared by all stakeholders, partner companies, and employees.
In the future, our company will continue to actively carry out self-compliance activities for fair trade, expanding the value of coexistence and symbiosis, and contributing to the realization of a better society.
Compliance and fair trade go beyond simple compliance with laws and regulations; they are core values of ESG management and essential practical tasks for a responsible enterprise.
POSCO E&C will continue to carry out compliance activities, such as fair trade self-compliance activities, more substantially and maintain sincere communication with stakeholders to further strengthen the compliance support system.
We ask for the continued interest and cooperation of all executives and
employees, and wish you all health and happiness in the future.
Thank you.
Compliance Officer and Fair Trade Compliance Program Manage
Fair Trade Compliance Program (CP)
(CP, Compliance Program)
It is an internal law-abiding system that is autonomously established and operated by a company in order to prevent the violation of the Fair Trade Act. It includes the willingness of CEO to practice, the director who manages the operation of the program, the surveillance system for violations, education/training, compliance guidebook, sanctions on those who breach the law, document management, etc.
Requirements for CP Introduction
CP is a program that is voluntarily operated by a corporation. It can be run differently
according to type of business and company’s characteristic.
However, in order for CP to be operated effectively, the company must satisfy eight
introduction requirements below.
- 02 Willingness and support of CEO for compliance
- 01 Preparation and practice of CP criteria and process
- 04 Publication and usage of compliance guidebook
- 03 Appointment of compliance director to take charge of the operation of CP
- 06 Building the internal surveillance system
- 05 Implementation of continuous and systematic compliance education and training
- 08 Evaluation of effectiveness and improvement measures
- 07 Sanctions on executives and staff members who breach the law related to fair trade
CP Ratings Evaluation System
Compliance Program (CP) Rating System: A system that objectively evaluates the CP operation level of CP-adopting companies based on their performance, calculates and announces corporate grades, and grants differential incentives accordingly. The evaluation is managed by the Korea Fair Trade Mediation Agency (KOFTMA). The final grade announcement is hosted by the Fair Trade Commission (FTC).
CP Ratings Evaluation System
| Grounds for evaluation | Article 120-2 of the Fair Trade Act (Propagation of Fair Trade Compliance Culture), Article 120-3 of the Fair Trade Act (Designation of Compliance Evaluation Institutions, etc.), Article 90-2 of the Enforcement Decree of the Same Act (Criteria and Procedures for Fair Trade Compliance Evaluation, etc.), Article 90-3 of the Enforcement Decree of the Same Act (Designation Criteria and Procedures for Fair Trade Compliance Evaluation Institutions) |
|---|---|
| Evaluation target | Eligible Companies: Companies for which more than one year has passed
since introducing the CP and that have applied for evaluation. Evaluation Adjustment: For companies that have violated fair trade-related laws and regulations within the last two years, the evaluation grade is downgraded and finalized as the ultimate grade when determining the final CP rating. |
| Evaluation items | 7 Evaluation Categories, 20 Evaluation Indicators, and 48 Detailed
Measurement Indicators (※ Based on Large Enterprises) - Comprehensive evaluation covering the CEO's commitment and policy regarding compliance practice, support for human resources and budget by top management including the appointment of a compliance manager, production and utilization of a compliance manual, implementation of CP education and training, operation of a preliminary monitoring system for compliance, operation of personnel sanctions and incentive systems, and matters concerning the evaluation and improvement of CP operations. |
| Ratings | Evaluation Grades: Classified into 3 tiers from AAA to A (AAA, AA,
A). - Validity Period: The validity period of the evaluation grade is two years, starting from January 1st of the year following the application, and the assigned evaluation grade is stated in writing and notified. |
CP Operation and Excellent Enterprise Incentives
Companies that introduce the Fair Trade Compliance Program (CP) and operate it excellently can receive benefits such as exemption from ex officio investigations and reduction of corrective measures or surcharges, depending on the evaluation and grade acquisition results.
CP Operation
| CP Ratings | AAA | AA | A |
|---|---|---|---|
| Surcharge Reduction | Within 15/100 (An additional reduction of 5/100 for detecting and halting the law violation prior to the commencement of an investigation) | Within 10/100 (An additional reduction of 5/100 for detecting and halting the law violation prior to the commencement of an investigation) | - |
| Exemption from ex officio investigations | 2 years | 1 year 6 months | - |
| Publication (Size and Number of Media Outlets) | Two-stage Reduction | One-stage Reduction | - |
| Awarding of Evaluation Certificates | The Fair Trade Commission awards evaluation certificates to companies that receive a grade of A or higher. | ||
| Fair Trade Commission Chairman's Commendation | Companies that have maintained an evaluation result of AA or higher for two consecutive years or more | ||
Compliance Council
It deliberates on important matters of the Compliance Program (CP) and serves in an advisory role to the Compliance Manager. Each member conducts self-inspections for potential law violations in their respective areas and coordinates tasks among related departments.
˙ Each member selects a leader for implementing fair trade, manage them, and make the practical operation of the compliance council feasible (leaders for implementing fair trade practically backs up the compliance activities of the members of the compliance council).
CP Operation Results
POSCO E&C has introduced the Compliance Program (CP) since July 2003 and operates it exemplary as a company leading fair trade order.
| CP operation results | |
|---|---|
| July 2026 | 20th Revision of the Fair Trade Compliance Manual |
| December 2025 | 19th Revision of the Fair Trade Compliance Manual |
| July 2025 | 18th Revision of the Fair Trade Compliance Manual |
| December 2024 | Acquired the Highest 'AAA' Grade in CP Evaluation (2 consecutive years, a first in the construction industry) |
| December 2024 | 17th Revision of the Fair Trade Compliance Manual |
| October 2024 | Acquired 'Highest' Grade in Fair Trade Agreement Implementation Evaluation and Shared Growth Index Evaluation (3 consecutive years, selected as a Highest Honor Enterprise) |
| July 2024 | 16th Revision of the Fair Trade Compliance Manual |
| December 2023 | Acquired the Highest 'AAA' Grade in CP Evaluation (A first in the construction industry) |
| September 2023 | Acquired 'Highest' Grade in Fair Trade Agreement Implementation Evaluation and Shared Growth Index Evaluation (2 consecutive years) |
| July 2023 | Launched Fair Trade Short-Form Education Campaign |
| July 2023 | 14th Revision of the Fair Trade Compliance Manual |
| December 2022 | Acquired 'AA' Grade in CP Evaluation (The only company in the construction industry to achieve AA grade or higher for 2 consecutive years) |
| December 2022 | 13th Revision of the Fair Trade Compliance Manual |
| October 2022 | Developed Online Price Reduction Written Notice Issuance System |
| September 2022 | Acquired 'Highest' Grade in Fair Trade Agreement Implementation Evaluation and Shared Growth Index Evaluation |
| August 2022 | Regularized External Disclosure on Fair Trade Compliance (Linked to periodic disclosure) |
| July 2022 | 12th Revision of the Fair Trade Compliance Manual |
| May 2022 | Reorganized CP-in-charge department for legal response synergy (Management Innovation Office -> Legal Office) |
| December 2021 | Acquired 'AA' Grade in CP Evaluation (The only construction company in Korea) |
| December 2021 | 11th Revision of the Fair Trade Compliance Manual |
| June 2021 | 10th revision of Fair Trade CP guidebook |
| September 2020 | Awarded the Prize of the Minister of Land, Infrastructure and Transport (category: win-win development) |
| June 2020 | Acquired the “most excellent” rating from the evaluation of execution of fair trade convention |
| March 2020 | Enactment of standard purchasing specifications in all fields |
| December 2019 | Awarded the Prize of the Fair Trade Commission (category: establishment of fair trade order) |
| December 2019 | Awarded the Prize of the Minister of Land, Infrastructure and Transport (category: win-win management) |
| June 2019 | Acquired “excellent” rating from the evaluation of execution of fair trade convention |
| April 2019 | Introduction of standard supplier agreement to all fields |
| January 2011 | Acquired “AA” rating from the CP evaluation (best ratings among current evaluated companies) |
| February 2010 | Establishment of a fair trade compliance inspection system |
| April 2009 | Acquired “A” rating from the evaluation of execution of fair trade convention in subcontract |
| December 2006 | Acquisition of Grade “A” in Compliance Program evaluation |
| April 2005 | Establishment of a dedicated organization for fair trade (Ethics Practice Bureau) |
| July 2003 | Introduction and operation of fair trade CP |
Results by Pursuit of Requirements for CP Introduction
Results by Pursuit of Requirements for CP Introduction
| Requirements of introduction | Results |
|---|---|
| 1. Preparation and practice of CP criteria and process |
|
| 2. Willingness and support of CEO for compliance |
|
| 3. Appointment of compliance director to take charge of the operation of CP |
|
| 4. Publication and usage of compliance guidebook |
|
| 5. Executing continuous and systematic compliance education and training |
|
| 6. Building an internal surveillance system |
|
| 7. Sanctions on executives and staff members who breach the law related to fair trade |
|
| 8. Evaluation of effectiveness and improvement measures |
|
CCTV Operation policy
CCTV Policy for the Protection of Personal Information
CHAPTER I GENERAL PROVISIONS
Article 1 (Purpose)
The purpose of this Policy is to fulfill appropriate duties and comply with applicable laws by setting matters POSCO E&C Ltd. (the “Company”) must comply with in relation to the installation and operation of closed-circuit televisions and protection of footages.
Article 2 (Definitions)
The terms used in this Policy shall be defined as follows:
- 1. The term closed-circuit television (“CCTV”) is a type of communication network, in which the footages recorded from the CCTVs located in specific sites are collected and transmitted to exclusive receivers through wired/wireless closed-circuit channels.
- 2. The term “footage” refers to CCTV recordings of which the recorded subject can be identified.
- 3. The term “data subject” refers to an individual who can be identified from the footage; that is, the subject of footage.
- 4. The term “processing” refers to the act of handling data collected through CCTVs, such as inputting, saving, editing, deleting, playing, and other similar acts, excluding the collection of such data.
Article 3 (Scope of Application)
- (1) In relation to the installation and operation of CCTVs needed for crime prevention, facility security, and fire safety, as well as the protection of footages that are collected and processed by the aforementioned reasons, the provisions of this Policy shall be observed, unless special provisions are stipulated in other laws.
- (2) Use of auxiliary cameras for CCTVs installed and operated by the Company shall also comply with this Policy, regardless of the fact whether their recordings are treated as actual footages or not.
Article 4 (Protection of Footages)
- (1) The Company shall collect minimum scope of footages that meets the purpose of CCTV installation.
- (2) The Company must have the data subject clearly aware of the installation purpose as mentioned in paragraph (1) of this Article. The footages shall not be used for other purposes than the said purpose.
- (3) The Company shall secure accurate and the latest footages and manage them in a safe manner.
- (4) The Company shall disclose general matters in relation to the handling of footages and protect the rights of data subjects.
CHAPTER II REQUIREMENTS FOR CCTV INSTALLATION
Article 5 (Notification of Installation Plans, etc.)
In the event of installing a CCTV, the Company shall prepare a CCTV installation and operation plan (“Plan”) that includes the following items:
- 1. Purpose of CCTV installation;
- 2. Division in charge of CCTV control: Handling officer and contact details;
- 3. Number of cameras, locations, performance, and scope of recording of the CCTV to be installed and operated;
- 4. Standard of the caution sign to be installed and the installation location in accordance with Article 7(1);
- 5. Contents, procedures, and methods regarding the data subject's exercise of rights and means of objection;
- 6. CCTV recording time, retention period of footages, methods of storage, management, and deletion of footages, and storage location of footages;
- 7. Actual location where footages transmitted from CCTVs are accessed and played, and access control to the said location;
- 8. Grounds, procedures, and methods of providing or granting access to footages to a third party; and
- 9. Other matters recognized to be necessary for the protection of footages
Article 6 (Designation of CCTV Managers)
- (1) The head of the division in charge of the installation and operation of CCTVs shall be designated as the CCTV General Manager, while his or her staff shall be designated as CCTV Operation Manager(s) (“CCTV Manager(s)”).
- (2) The CCTV Manager shall take charge of duties in relation to the installation and operation of CCTVs, reception and handling of complaints, and collection and processing of footages.
- (3) The CCTV Manager shall designate and manage a separate Personal Information Handler and inform the CCTV General Manager of relevant information in the event of CCTV installation and/or other changes.
Article 7 (Installation of Caution Signs)
- (1) In the event of installing a CCTV, the Company shall put up caution signs regarding CCTV operation and the collection of footages for the recognition of data subjects.
- (2) The signs in relation to paragraph (1) of this Article shall mention the following items:
- 1. Purpose of CCTV installation;
- 2. Recording scope and time; and
- 3. Information on the CCTV handling division, CCTV Manager, and contact details
- (3) The signs in relation to Paragraph (1) of this Article shall be installed within the recording scope where they are easily visible and understood by data subjects.
- (4) Notwithstanding Paragraph (2), in the event of installing several CCTVs in the Company’s building, the sign that complies with Paragraph (1) may mention that the whole building is within the recording scope and can be attached only on the building exits.
CHAPTER III REQUIREMENTS FOR HANDLING FOOTAGES
Article 8 (Limitation on Collection)
- (1) CCTVs shall not be arbitrarily manipulated or shoot other places beyond the purpose of their installation during collection of footages.
- (2) Footage rotation and zooming features that have no relation to the purpose of CCTV installation may not be used during collection of footages.
Article 9 (Limitation on Processing)
Footages of a data subject may not be used for other purposes than the CCTV installation purpose or be granted access or provided to a person who has no access authority: Provided, That this shall not apply in any of the following circumstances:
- 1. Where consent is obtained from the data subject;
- 2. Where the data is given access or provided to the data subject;
- 3. Where special provisions exist in other laws;
- 4. Where the data is provided in a pseudonymized manner when it is required for the purposes of reporting by the media through newspapers or broadcasting;
- 5. Where there is an urgent reason for not obtaining the data subject's consent when the risk that the rights and interests of the data subject may be infringed is clear and present;
- 6. Where it is necessary for the investigation of a crime, indictment, and/or prosecution; or
- 7. Where it is necessary for the enforcement of punishment, probation, and custody.
Article 10 (Safeguards, etc.)
- The Company shall designate a place where footages transmitted by CCTVs are actually accessed and played (“Control Center”) as a restricted zone and strictly limit the access of individuals apart from those who have been granted the authority.
- (2) The Company shall limit the authority to access footages to CCTV Managers and the minimum number of designated personnel.
- (3) The Company shall regularly inspect and check the normal operation of CCTVs and keep an accurate record regarding the matters.
- (4) The Company shall seek for technical and managerial safety measures in response to illegal access, alteration, leakage, and damage of footages.
- (5) The Company shall prepare a training course on the personal information protection of data subjects for those who are granted authority to access footages.
Article 11 (Request for Access, etc.)
- (1) A data subject may request to confirm the existence, access, and/or delete footages to the Company.
- (2) In relation to the request as mentioned in the paragraph (1) of this Article, the Company shall take immediate action in accordance with Article 5(5).
- (3) Notwithstanding Paragraph (2) of this Article, the Company may refuse to take action in the event of any of the following circumstances. In this case, the grounds for refusal and objection method shall be informed (including information and communications networks) to the data subject within seven (7) days.
- 1. Where it may cause grave difficulties in performing investigation of crimes, prosecution, and conduct of trials;
- 2. Where deleting only the footages of a specific data subject is extremely difficult in technical manner;
- 3. Where taking appropriate action as prescribed in Paragraph (1) of this Article may infringe upon other's privacy rights; or
- 4. Where there are appropriate grounds to refuse the request for access, etc., that meet the public interest.
Article 12 (Retention and Deletion)
Footages collected through CCTVs shall be deleted without delay once the data retention period mentioned in the Plan expires: Provided, That when it is difficult to determine the minimum period of time required to achieve the purpose of data retention due to the nature of a division, the retention period shall be within thirty (30) days after the collection of footages.
CHAPTER IV SUPPLEMENTARY PROVISIONS
Article 13 (Consignment of Duties)
- (1) In the event of consigning the duties in relation to the installation, operation, and management of CCTVs, the Company shall take necessary safety measures to prevent the abuse of footages and supervise the consignee.
- (2) The consignee who is granted authority to access footages in relation to paragraph (1) of this Article shall undergo a training course as mentioned in Article 10(5).[lh1]
Article 14 (Confidentiality)
Those who handle or have handled footages shall not use the obtained data for inappropriate purposes, such as revealing, processing without authority, and/or providing for the use of another person.
Article 15 (Exclusion)
This Policy shall not be applied to CCTVs installed and operated to supervise the duties of individuals who are with the military regardless of their duties.