POSCO E&C

POSCO E&C exerts effort for respecting the human rights of its executives, employees and stakeholders. POSCO E&C strives to prevent human rights violation risks in advance by establishing an internal process and periodical conducting human rights due diligence.

Principles of Human Rights Management

Article 1 Purpose

During the course of its business, the Company exerts effort for respecting the human rights of its executives, employees and stakeholders, and has codified POSCO’s Code of Ethics and POSCO Group Supplier Code of Conduct. We strive to prevent human rights violation risks in advance, and to further strengthen the will of human rights management through this Charter.

Article 2 Definition

The meanings of the terms used in this Charter are as follows.

The term "human rights" means the fundamental rights of a person as used in domestic and international human rights standards and criterion, such as the Constitution and laws of the Republic of Korea, the Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises.
The term "executive and employees" means all executives and employees working at POSCO E&C.
The term "stakeholder" means a person related to the corporate management activities of the Company, such as, among others, business partners, customers, and local residents.

Article 3 Scope of application

This Charter applies to all executives and employees of POSCO E&C and to all places of business where POSCO E&C carries out its business activities. In the event it is found that this Charters is inconsistent with local laws, the local laws shall prevail, provided, however, that if complying with the local laws may raise international human rights issues, the Company shall seek the ways to comply with both the local laws and the global human rights standards.

Article 4 Roles and Responsibilities of executives and employees

Executives and employees of POSCO E&C shall endeavor to comply with the following responsibilities for the implementation of human rights management.

Executives and employees of POSCO E&C shall respect and comply with the contents specified in this Charter.
In the event of human rights violations committed to oneself, colleagues, customers, partners, or local residents, executives and employees of POSCO E&C shall take appropriate measures, such as reporting to the internal reporting center.
Executives and employees of POSCO E&C will suggest ideas to promote human rights management and, and where necessary, support for the implementation of such suggested ideas.
The leader of each department shall carry out a pivotal role for the prevention of human rights violations, such as counseling and providing education support in regard to respecting and protecting human rights of his/her department members.

Article 5 Basic Principles

POSCO E&C hereby sets up and shall comply with the following basic principles in consideration of current domestic and international human rights issues.

Prohibition of Discrimination and Harassment
- No unfair treatment in an employment situation because of race, nationality, sex, age, religion, region of origin, disability, marital status, or gender identity shall be committed.
Freedom of Association and Guarantee of Right to Collective Bargaining
- POSCO E&C abides by the Constitution and the Trade Union and Labor Relations Adjustment Act (Labor Relations Act), which are the basis of our human rights policy, and strives to observe and guarantee the rights of its executives and employees.
Prohibition of Forced and Child Labor
- POSCO E&C is committed to ensuring that work is not performed involuntarily through psychological or physical coercion.
- With regard to the working conditions for minors and the minimum age requirements, POSCO E&C complies with the applicable domestic labor laws and international labor standards.
Occupational Safety Guarantees
- POSCO E&C fosters a culture that is committed to workplace safety by ensuring a safe working environment and takes adequate measures to address any safety risk that has been identified
Workplace anti-bullying
- POSCO E&C endeavors to foster a working environment that prevents bullying behaviors, such as taking advantage of superiority or dominance beyond the appropriate work-related scope and thereby inflicting physical or mental pain of other employees or deteriorating the working environment.
- POSCO E&C endeavors to foster a working environment to prevent verbal, physical, and visual behaviors that offend other employees, including sexual harassment that violates individual human rights.
Responsible supply chain management
- POSCO E&C respects its suppliers and assist them for their implementation of the human rights managements such as support for education
Protection of Local Residents' Human Rights
- POSCO E&C manages its business activities in a way that does not infringe the local residents’ rights to life, freedom of residence, and safety. Further, POSCO E&C collects the opinions of the local residence in compliance with the relevant laws and regulations, and endeavors to resolve the issues raised.
Environmental Right Guarantees
- POSCO E&C recognizes the seriousness of climate change and endeavors to make the transition to a sustainable low-carbon business.
- POSCO E&C endeavors to promote the sustainable economy and environment by reducing greenhouse gas, noise, waste water, and waste from POSCO E&C’s construction sites and by actively developing and introducing eco-friendly design and construction technologies.
- POSCO E&C endeavors to restore natural habitats and preserve biodiversity by an efficient use of natural resources and by-products produced during the course of its business.
Protection of Customers' Human Rights
- POSCO E&C exercises due care in compliance with statutory requirements for the prevention of harm to customer’s safety and health.
- POSCO E&C protects customer data and complies with the applicable data protection laws.

Human Rights Management System

Article 6 Organization and Roles

For efficient and systematic human rights management, POSCO E&C’s ESG Section operates Human Rights Working Group. The members of the Working Group shall be selected by the person in charge of the applicable department for each area of human rights, and the roles of the Working Group shall be as follows:

Enactment and amendment of the Charter of Human Rights
Establishment and implementation of human rights management plan
Establishment and implementation of human rights due diligence plans
Support for grievance remediation
Support for internal and external education
Responding to human rights issues
Stakeholder communication support
Other duties necessary for the implementation of human rights management

Article 7 Risk Management Process of Human Rights

For the protection of human rights of its executive and employees and the minimization of the negative impact on human rights, POSCO E&C establishes the Human Rights Risk Management Process to evaluate and manage human rights risks and to communicate with the stakeholders.

The Human Rights Risk Management Process considers the following;

Official announcement of POSCO E&C’s commitment to human rights management through the declaration of this Charter;
Establishment and implementation of a system for human rights management.
Operation of Reporting and Consultation Center and periodical conduct of human rights due diligence to identify actual and potential human rights risks.
Preventive activities such as education and campaigns to prevent human rights violations, and in the event of human rights violations, appropriate remedies.
The overall evaluation of the implementation status of human rights management, indicated by, among others, human rights due diligence methods, education, and remedies; and disclosing internally and externally the results of such evaluation; and
Continuous monitoring of the implementation of the remedial actions, and, when it is found, through a performance assessment or otherwise, that the improvements are required, taking improvement actions.

Article 8 Internalization and Improvement of the system

POSCO E&C will (i) educate its executives and employees on prevention of human rights violations; (ii) inform its executives and employees the results of the human rights due diligence and the reported cases of human rights violation through education programs and campaigns targeted for prevention of reoccurrence. When it is determined that certain improvements are required on the internal system, POSCO E&C will work on such improvements.

POSCO E&C will endeavor to internalize human rights management as an organizational culture by (i) educating its executives and employees on human rights sensitivity, domestic and international human rights regulations, exemplary cases for human rights management, and case studies for the remedial actions (both successful and unsuccessful); and (ii) continuous human rights violation prevention campaigns.
POSCO E&C will identify improvable aspects through professional consultations, human rights due diligence, and by communicating with the stakeholders, and will continuously improve its human rights management system.

Human Rights Due Diligence

Article 9 Human Rights Due Diligence Process

POSCO E&C (i) conducts human rights due diligence to identify cases of human rights violations and potential human rights risks; and (ii) implements, including, among others, remedies, improvements, and preventive measures based on the results of such due diligence.

Human rights due diligence process is carried out in consideration of the following;

Identifying and being informed of internal and external corporate human rights issues, and analyzing the place and size of each place of business, human rights related risks, the nature and substance of each business, the political and cultural conditions of the country where the business is located.
Developing a checklist by referring to, among others, UNGC due diligence guidelines, OECD due diligence guidance for responsible business conduct.
Conducting human rights due diligence through online or in writing, and if necessary, with the support from the external experts.
Deriving causal analysis and improvement plans based on the result of the human rights due diligence, and if necessary, obtaining objectivity and further information through site inspection when required.
Publishing the results of the due diligence on human rights to those involved and carrying out improvement activities.

Human rights violation cases discovered through human rights due diligence shall be resolved in compliance with the Company's internal regulations, and for an efficient response, commencement of an internal decision-making process will be requested, and external professional consultation and the budget required therefor will be provided where necessary.
Monitoring of the remedial actions and enforcement status of the improvement actions. Where not enforced, taking additional measured required for the enforcement the improvement actions

Human Rights Grievance Remediation Process

Article 10 Human Rights Grievance Remediation Process

POSCO E&C operates a Reporting and Consultation Center (the “Center”) to which its executives, employees and stakeholders may report human rights related issues. Once such issues are reported, the Center prepares specific remedies with consideration for the characteristics of the reported issues and endeavors to resolve them reasonably.

The Center is operated at all times and strives to process the reported case with promptness.
The Center conducts consultation and investigation of related individuals based on the reported claim, and prepares appropriate remedies.
The Center will notify the claimant of the result of the reported case and, when necessary, stakeholders such as the related departments will be informed of the same.
The Center will continuously monitor the result of the cases and, based on operation analysis, identify problems that may exist in the Company’s human rights policy or in the grievance remediation process, and take measures to address such problems so identified.

Stakeholder Communication

Article 11 Disclosure of Information

POSCO E&C shall endeavor to ease concerns that its executive, employees, and stakeholders may have on human rights related risks by informing them of the human rights management status.

POSCO E&C communicates with stakeholders, including individuals and investors, based on with accountability and transparency, and for the ease of access to information, POSCO E&C provides the stakeholders, among others, with the information on the human rights management status and the results of the human rights due diligence conducted.
If necessary, POSCO E&C will provide, though separate channels of communications, the stakeholders with related information that may assist them for assessing the Company’s response to human rights issues.

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.