Policies
Environmental Policy
The purpose of this policy is to establish an environmental management system that realizes sustainable management, improve its ability to respond to environmental risks, and contribute to protecting the environment and overcoming the climate crisis through cooperation among POSCO International and its stakeholders.
More Info
Human Rights Policy
This policy aims to ensure that POSCO International complies with international human rights standards such as UN Guiding Principles on Business and Human Rights, UN Global Compact, Universal Declaration of Human Rights, and OECD Guidelines for Multinational Enterprises and implements human rights management based on respect for labor principles recommended by the International Labor Organization and ratified by the government.
More Info
Supply Chain Policy
This policy enables POSCO International to promote fair trade based on mutual trust with its supply chain and partners, build a sustainable supply chain, and ultimately create an inclusive business environment where POSCO International can coexist and grow together with its stakeholders.
More Info
Biodiversity Policy
The purpose of this policy is to establish a system whereby POSCO International can protect and promote biodiversity while performing its business activities and establish a code of conduct and action plans in order to develop a business model that can promote sustainable growth with the natural environment.
More Info
Responsible Minerals Policy
This policy prohibits the use of conflict minerals such as tin, tantalum, tungsten, and gold (“3TGs”) that have been used to fund warlords and rebel groups in African countries affected by civil wars such as the Democratic Republic of Congo and other minerals such as cobalt that are linked to human rights abuses and environmental issues during the mining process. This policy outlines POSCO International’ commitment to using only “responsible minerals” mined in a way that respects human rights and protects the environment without financing armed conflict and sets out the code of conduct and action plans for achieving the above goal
More Info
Green Procurement Policy
This policy aims to preventing the waste of resources and environmental pollution while abiding by applicable laws and regulations in the entire business conduct of POSCO INTERNATIONAL. This policy illustrates the definition of green products, scope of procurement, basic guidelines, and action plans to support effective policy implementation.
More Info
close
Environmental Policy
Purpose
The purpose of this policy is to establish an environmental management system that realizes sustainable management, improve its ability to respond to environmental risks, and contribute to protecting the environment and overcoming the climate crisis through cooperation among POSCO International and its stakeholders.
Scope of Application
This policy applies to POSCO International. POSCO International shall encourage all of POSCO International’s affiliates and partners to comply with this policy or establish an equivalent policy.
Basic Principles
1. Compliance with Environmental Laws and Mitigation of Environmental Impacts
  • We shall comply with international conventions and applicable laws on the environment and energy and endeavor to mitigate environmental impact throughout our entire process of development, production, use, and disposal of products.
  • We shall minimize emissions of pollutants by implementing eco-friendly production methods and the best available technology.
2. Response to Climate Change
  • We shall establish a risk self-assessment framework in response to climate change, set achievable goals, and self-evaluate performance.
  • We shall endeavor to reduce greenhouse gas emissions by reducing our dependence on fossil fuels and fossil raw materials, improving energy efficiency, and developing and using renewable energy.
3. Protection of Biodiversity and Restoration of the Natural Environment
  • We shall endeavor to restore the natural ecosystem and protect biodiversity by using natural resources and by-products in an efficient manner.
  • In order to minimize damage to the environment, including green areas, forests, wetlands, and oceans, we shall conduct risk assessments when constructing or expanding workplaces and endeavor to restore the existing natural environment through reforestation and afforestation efforts when withdrawing from work sites.
4. Raw and Subsidiary Materials and Water
  • We shall take into account the amount of resources used to manufacture finished products and endeavor to replace traditional materials with eco-friendly ones, such as raw materials that are renewable or with fewer impurities. We shall also endeavor to reduce the amount of resources used in production activities by adopting new facilities that consume less resources, such as water saving machines, and by implementing clean technologies.
5. Waste and Wastewater
  • We shall minimize waste and wastewater generated during the production process and recycle inevitably generated waste and wastewater as much as possible. We shall also establish waste management and/or water treatment facilities required to minimize the impact that waste and wastewater from our workplaces may have on the environment.
6. Hazardous Chemicals
  • We shall systematically manage hazardous chemicals to prevent chemical accidents, such as chemical leaks or spills, and endeavor to use and release less hazardous chemicals.
Action Plans
1. Establishment of Environmental Management System
  • We shall establish an environmental management system (“EMS”) to assess and respond to environmental risks unique to our business activities, set specific environmental performance targets, and continually improve such targets.
  • The board of directors and the executive management shall actively participate in the decision-making and management/supervision of the EMS and provide ample support in both human and material resources, such as assigning dedicated working-level employees, to ensure that the EMS is fully installed and operated.
  • For the operation of the EMS, we shall incorporate environment-related factors in existing policies with specific consideration of each company’s business situation and, if necessary, establish and comply with specific policies, guidelines, and bylaws on specific environmental concerns such as biodiversity, forest, wetland, and climate risk.
  • We shall discuss the importance of environmental protection and response to climate change with stakeholders, such as contractors, suppliers, and counterparties, and provide support so that they can establish their own EMS.
  • The officers and department heads shall provide training to the officers/employees under their supervision so that they can recognize the importance of environmental management and comprehend the EMS.
2. Response to Climate Change
  • We shall integrate transition and physical risk related to climate change into company-wide risk assessments and business strategies and document and manage such risk.
  • We shall ensure that risks, strategies, and assessments related to climate change are properly reported to the board of directors and executive management.
  • We shall establish and implement concrete and feasible plans to mitigate greenhouse gas emissions and achieve carbon neutral goals.
  • We shall apply environmental certification and disclosure frameworks related to climate change (e.g. the TCFD), or establish a comparable reporting framework to disclose to a reasonable extent our ongoing efforts and achievements in responding to climate change.
3. Management of Production and Workplace Environment
  • We shall ensure that the production and workplace environment is properly managed through processes including KPIs and other performance management indicators, education/training, establishment and management of guidelines, internal inspections, etc.
  • We shall apply eco-friendly production processes and the best available technology to minimize the amount of pollutants and the impact of pollutants on the environment.
  • We shall establish and operate environmental management manuals tailored to the specific needs of production facilities and workplaces and continually monitor and strive to improve the environmental impact of our operating facilities.
  • We shall endeavor to thoroughly assess risks and achieve a zero net environmental impact in order to protect the ecosystem and the environment when building, expanding, and closing down our workplaces. We shall not engage in business activities that destroy forests and wetlands but pursue and implement the best available measures to mitigate the impact on the ecosystem, e.g. through engaging in forest and wetland restoration activities.
4. Development and Distribution of Products and Services
  • We shall identify the challenges and opportunities in the process of transitioning to a low-carbon economy, increase the supply of eco-friendly products and by-products, and assess environmental risks in the transportation and logistics process. By doing so, we shall minimize the environmental impact throughout the entire process of developing and providing goods and services.
  • We shall enhance our competitiveness by developing low-carbon, eco-friendly, and new and renewable energy products.
5. Supply Chain Management, and Selection and Evaluation of Suppliers
  • When selecting our partners (suppliers, contractors, service providers, etc.), we shall evaluate their level of environmental management to minimize environmental impact.
  • We shall provide support to suppliers and contractors so that they can establish their own EMS at a superior level and preemptively manage environmental risks throughout the entire supply chain by conducting performance evaluations regarding suppliers’ environmental management levels.
  • We shall procure materials and equipment in compliance with the green procurement policy.
6. New Projects and M&A
  • We shall review environmental management plans and environmental impact assessments when reviewing new projects/investments to minimize environmental risks that may arise from projects.
  • We shall conduct due diligence when reviewing potential M&As to identify and respond to environmental risks in advance.
Enactment Date: June 16th, 2023
Management Organization: Corporate Citizenship Bureau
Deliberation: ESG Council
close
Human Rights Management Policy
Purpose
This policy aims to ensure that POSCO International complies with international human rights standards such as UN Guiding Principles on Business and Human Rights, UN Global Compact, Universal Declaration of Human Rights, and OECD Guidelines for Multinational Enterprises and implements human rights management based on respect for labor principles recommended by the International Labor Organization and ratified by the government.
Scope of Application
This policy applies to POSCO International and its officers/employees. POSCO International shall encourage all of POSCO International’s affiliates and its officers/employees as well as its partners and their officers/employees to comply with this policy or establish an equivalent policy.
Code of Conduct
1. General Principles
  • We shall respect the UN Guiding Principles on Business and Human Rights and acknowledge that all human beings have the right to dignity, including the following related rights: right to life and physical safety; freedom of thought, expression, and religion; freedom of association; freedom of family life and privacy; right to food and water; freedom from torture, slavery, or forced labor; right to fair and decent working conditions; and anti-discrimination.
  • To this end, we shall prevent infringement on the human rights of others and take appropriate measures to prevent and address negative impacts on human rights that may occur in the course of our business activities.
  • To meet the expectations of stakeholders by fulfilling our responsibility to respect human rights, our officers/employees shall comply with the following recommendations regarding human rights management:
  • ① We shall comply with applicable laws and internationally recognized global human rights standards wherever we operate our business;
  • ② When faced with conflicts with local regulations, we shall pursue ways to comply with global human rights standards; and
  • ③ We shall treat the risk of serious human rights violations as an important management issue of the company.
2. Major Human Rights Issues
  • We shall manage human rights risks that may occur in the following areas of human rights at the company-wide level and fulfill its responsibility to respect human rights.
  • ①Anti-discrimination
    We shall not discriminate or harass anyone on the ground of race, nationality, gender, age, educational background, religion, region, disability, marital status, gender identity, etc. We shall provide equal employment opportunities to those with appropriate qualifications and abilities to perform the duties assigned to them and respect cultural diversity. We shall not discriminate against people on the ground of gender and employment type. We shall provide equal wages to workers for equal work to prevent disparities in wages and working conditions without reasonable reasons. We shall fairly evaluate officers/employees’ individual capabilities and performance and systematically reflect the evaluation results to provide appropriate compensation.
  • ②Prohibition of Forced Labor and Child Labor
    We shall not coerce anyone to work against his/her free will by means including human trafficking, intimidation, confinement, and other unreasonable restriction of mental or physical liberties. We shall not sign a labor contract that requires the other party to pay a penalty if he/she fails to perform the labor contract. In addition, we shall prohibit child labor and comply with labor conditions for minors and minimum working age standards under national labor laws and international standards.
  • ③Guarantee of Freedom of Association and Collective Bargaining
    In accordance with the basic labor rights under domestic laws and regulations and as defined by the International Labor Organization, we shall recognize workers’ freedom of association and membership, including the freedom to unionize. We shall not penalize workers for joining labor unions or engaging in union activities. In addition, we shall not reject collective bargaining without reasonable grounds and shall respect and fully implement the results of collective bargaining.
  • ④Guarantee of Occupational Safety
    Under the principle that all kinds of accidents and work-related diseases must be prevented, we shall establish a company-wide health and safety policy, fully comply with international safety rules and regulations, and take appropriate measures for any identified occupational hazards.
  • ⑤Prevention of Workplace Harassment
    We shall strive to strictly prevent any cases of employees taking advantage of their positions or relationships at work to cause unwarranted physical or mental distress to another employee or cause harm to the work environment. We shall prevent any employee from violating the human rights of others or engaging in verbal, physical, or visual behavior that is offensive to others, including sexual harassment, and create a workplace culture in which everyone is respected.
  • ⑥Responsible Supply Chain Management
    In order to monitor and manage forced labor and violations of children’s rights in our supply chain, we shall manage human rights risks of our suppliers, subcontractors, subsidiaries, and other key partners under our influence. In addition, we shall ensure fair trade with our partners based on mutual respect and equality and support partners to comply with fair trade laws and regulations.
  • ⑦Anti-corruption and Anti-bribery
    In order to maintain fair trade in all areas, we shall comply with all domestic and international anti-bribery and anti-corruption laws and regulations, including the Improper Solicitation and Graft Act, the UN Convention against Corruption, the Foreign Corrupt Practices Act, and the Act on Combating Bribery of Foreign Public Officials in International Business Transactions.
  • ⑧Guarantee of Environmental Rights
    We shall endeavor to reduce greenhouse gas emissions by reducing the use of fossil fuel and fossil fuel-derived raw materials and improving energy efficiency. We shall strive to restore the natural ecosystem and protect the biodiversity by using natural resources and by-products in an efficient manner. In addition, we shall establish an EMS, improve our ability to respond to environmental risks, and conduct eco-friendly management through open communication.
  • ⑨Protection of Human Rights of Local Residents
    If a human rights violation occurs in the local community due to the company’s business activities, we shall collect opinions and endeavor to resolve such human rights issues. In addition, we shall minimize and prevent human rights risks as we may have a social and environmental impact on local residents and the region in the process of running our business. We shall also evaluate the impacts on the safety, health, food, and economic activities of the local environment and local residents and take into account protection of the local culture and biodiversity issues in the region.
  • ⑩Protection of Human Rights of Consumers
    We shall operate a customer-centric business in which we listen to and respect our customers. We shall actively accept customers’ legitimate requests and reasonable suggestions. We shall not provide products and services that threaten their safety and health based on considerations for the safety and health of customers in our business activities. We shall also protect customer-related information.
3. Establishment of Policies and Procedures
  • We shall prepare the following policies and procedures to fulfill our responsibility to respect human rights.
  • ① Implementation of appropriate policy regimes, including enactment of rules containing the company’s responsibility to respect human rights
  • ② Human rights due diligence procedures to identify, prevent, and mitigate any negative impact on human rights and inspect and investigate any activities that affect human rights
  • ③ Procedures to remedy the negative impact on human rights that the company has had
Action Plans
1. Human Rights Management Governance
  • The ESG Committee, an expert committee under the board of directors, shall set overall policies and directions related to human rights management and monitor the implementation of such human rights management. The Corporate Citizenship Bureau shall support the ESG committee to facilitate the performance of duties and provide human rights training, disclose information, conduct human rights due diligence, and provide relief to victims.
2. Human Rights Due Diligence
  • A. Key Considerations
  • Officers/employees shall identify, prevent, and mitigate any negative impact on human rights and conduct human rights due diligence when considered necessary to fulfill their responsibilities. Such due diligence shall include identifying and evaluating any actual and potential impact on human rights, responding to problems identified, recording response activities, and communicating with stakeholders. Human rights due diligence shall consider the following:
  • ①Include negative impacts on human rights that may be directly or indirectly triggered in the course of the company’s business activities;
  • ②Consider the location and size of workplaces, human rights risk exposure, characteristics and features of business, and other various matters depending on the political and economic conditions and characteristics of the host country; and
  • ③Recognize that human rights risks gradually change as the company’s activities and business environment change, and continue to conduct due diligence.

  • B. How to Conduct Due Diligence
  • We shall endeavor to identify and inspect any actual and potential negative impact on human rights related to their business activities at home and abroad according to the following process.
  • ①If human rights risks are identified in major domestic and foreign workplaces, we shall conduct human rights due diligence, analyze the situation, and make improvement plans;
  • ②In principle, due diligence shall be carried out by internal experts, and if necessary, it may be conducted with the support from external experts;
  • ③In some cases, groups and stakeholders who may be potentially affected may be interviewed;
  • ④We shall identify any potential and actual impact during due diligence, share the evaluation results at the company-wide level regarding the potential impact, take measures to prevent or mitigate such impact by carrying out relevant procedures, and endeavor to remediate and resolve any existing impact; and
  • ⑤We shall conduct due diligence using a checklist that identifies key elements related to human rights management.

  • C. Response and Follow-up
  • We shall establish a response system and take follow-up actions based on findings from human rights due diligence to prevent and mitigate any negative impact on human rights.
  • ①Establishment of Internal Response System
  • i.We shall clarify roles and responsibilities with relevant departments to solve identified problems.
  • ii.We shall apply internal decision-making, budget allocation, and monitoring procedures to effectively respond to the above impact.
  • iii.We shall accurately explain the problems identified through human rights due diligence to the relevant departments and respond to the problems by managing them as important issues.
  • ②Follow-up and Remedies
  • i.We shall take the necessary steps to prevent or mitigate any potential or existing adverse impact on human rights.
  • ii.In cases of unexpected negative impact on human rights despite our best policies and procedures, we, alone or in collaboration with other entities, shall endeavor to address such negative impact.
  • iii.When we have not directly contributed to negative impacts on human rights but the negative results are related in a complex way to our operations, production, and services through our relationship with other entities (e.g., suppliers), while we are not directly responsible for devising plans for systematic improvement, but we shall play a certain role.
  • iv.We shall use the influence that the company has to prevent or mitigate the negative impact on human rights, and otherwise may strive to strengthen our influence by collaborating with the relevant entities to protect human rights.
  • v.We shall operate a grievance mechanism that shall serve as an effective remedy for potentially affected stakeholders.

  • D. Communication with Stakeholders
  • When stakeholders raise concerns about human rights impacts, we shall take responsibility in communicating with them.
  • ①We shall communicate responsibly and transparently with our stakeholders, including affected groups, individuals, and investors. To facilitate stakeholders’ access to information, we may consider various forms of communication, such as face-to-face meetings, publication of official reports, and online channels (e.g., the company’s official website and Helpline).
  • ②We shall include actual and potential negative impacts in the official reports we publish and may consider independent verification procedures to enhance the credibility of the reports.
  • ③We shall provide stakeholders with information so that they can better assess whether the company is responding appropriately to specific human rights impacts.

  • E. Internalization and Program Improvement
  • Based on the results of human rights due diligence, we shall contribute to the actual improvement of human rights management through internalization of organizational culture and activities for improving programs.
  • ①We shall carry out activities to internalize human rights management into the organizational culture by providing training on rapport-building and human rights management norms to all officers/employees and sharing successes and failures.
  • ②We shall continue to improve the human rights management system by consulting with experts, communicating with stakeholders, and discovering areas for improvement through implementing programs.
3. Grievance Mechanism
  • A. Key Considerations
  • We shall operate a grievance mechanism for negatively affected individuals and communities so that their grievances can be promptly discussed and addressed.
  • We shall endeavor to address grievances swiftly and reasonably by using existing methods such as the Ethics Counseling Center (Helpline) and the Unethical Conduct Reporting Center (Hotline). We shall not penalize those who file a complaint, victims, and cooperators on the ground that they apply for counseling or investigation and provide cooperation.
  • The grievance mechanism shall perform the following important functions in relation to the company’s responsibility to respect human rights:
  • ①Facilitation of the identification of negative impacts on human rights and acceptance of concerns raised by those directly affected or likely to be affected. Affected persons may report their human rights concerns to the Corporate Citizenship Bureau in person, by mail, by phone, or by email and apply for grievance handling;.
  • ②Collection of grievances and provision of early relief to victims in order to prevent the spread of human rights violations; and
  • ③Analysis of operations progress to identify and solve problems in human rights policies and procedures.
Enactment Date: June 16th, 2023
Management Organization: Corporate Citizenship Bureau
Deliberation: ESG Council
close
Supply Chain Policy
Purpose
This policy enables POSCO International to promote fair trade based on mutual trust with its supply chain and partners, build a sustainable supply chain, and ultimately create an inclusive business environment where POSCO International can coexist and grow together with its stakeholders.
Scope of Application
This policy applies to suppliers and their subcontractors (hereinafter referred to as 'suppliers') that provide products and services (including general services) to POSCO International and its subsidiaries, joint ventures, etc., and it is recommended that POSCO International’s partners also comply with this policy or a policy of similar standards.
Partner Code of Conduct
1. Labor Human Rights
Suppliers shall not tolerate illegal underage labor, human trafficking, including sexual exploitation, forced labor, etc. in accordance with the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, and the International Labor Standards of the International Labour Organization (ILO), and shall do their best to respect and protect the human rights, working hours, association and collective bargaining freedom of all workers. Also, workers should not be discriminated against on the grounds of race, nationality, sex, age, academic background, religion, region, disability, marital status, or gender identity.
(1) Voluntary Employment
  • All duties and duties shall be voluntary, and employees shall be free to retire after giving reasonable notice of severance.
  • It complies with the Modern Slavery Prevention Act and other similar laws to prevent forced labor (all involuntary labor, such as slavery, human trafficking, and debt repayment).
  • Suppliers shall not force employees to hand over any government-issued identification cards, passports, or work permits as a condition of employment.
  • The Supplier shall provide in writing to all workers an employment contract, including the terms and conditions of employment, in the native language of the worker when hiring or changing the labor contract.
(2) Prohibition of Child Labor
  • Supplier shall not employ any employee under the age of 15 or the age at which compulsory education ends, or the minimum age of employment in the applicable country, whichever is higher.
  • If a child worker is found, the supplier shall immediately suspend the employment and take immediate action, such as improving the process of identifying age in the employment process.
  • Workers under the age of 18 (Aged Workers) shall not engage in any work threatening their health or safety, including night duty, overtime work, and shall comply with all laws and regulations when using the workplace apprenticeship system.
(3) No Discrimination
  • In employment practices such as employment, promotion, compensation, and training opportunities, treatment shall be equal without discrimination based on race, skin color, religion, sex, sexual orientation, age, health, political views, nationality, ethnicity, and marital status.
  • Medical examinations and physical examinations that may be used as discriminatory means by workers or prospective workers shall not be required, except as required for local law or workplace safety.
(4) Working Hours
  • Except for emergency situations, working hours shall comply with the working hours requirements prescribed by the Act, including overtime work. All overtime work shall be voluntary and shall be reimbursed with allowances at an appropriate level.
(5) Wages
  • Consideration paid to employees shall comply with all applicable wage-related laws, including benefits prescribed by law, such as minimum wage and overtime allowance.
(6) Humanitarian Treatment
  • There shall be no harsh and inhumane treatment or intimidation of an employee, including sexual harassment, sexual abuse, physical punishment, mental or physical coercion, or abusive language, and there shall be no illegal interference with the employee's family or family.
(7) Freedom of Association
  • Respect the lawful freedom of association and workers' rights to collective bargaining by means of negotiating the working environment, wages and other matters; workers should be able to openly communicate with management without fear of discrimination, retaliation, threat, and harassment against working conditions and management practices.
2. Environment
Suppliers shall not only comply with environmental regulations and laws, but also endeavor to improve environmental impacts throughout the entire process of product development, production, and use by establishing an environmental management system to evaluate the impact and risks of business activities on the environment and systematically manage and analyze environmental management performance. Suppliers shall endeavor to reduce greenhouse gas emissions by reducing the amount of fossil fuels and fossil fuel materials used and improving energy efficiency, and restoring natural ecosystems and conserving biodiversity by efficiently utilizing natural resources, by-products, etc.
(1) Environmental License and Report
  • Suppliers shall obtain and maintain all environmental licenses and licenses (e.g., emission monitoring, installation, operation, modification, and reporting of air emission facilities, etc.) and registrations necessary for the operation of the enterprise, and shall comply with the operation and reporting requirements.
(2) Resource Savings and Rotation
  • Natural resources, such as water, fossil fuels, minerals, and primeval forest products, shall be conserved through the improvement of the production process, the use of alternative materials, the recycling of materials, or other means.
(3) Energy and Greenhouse Gases
  • Suppliers are recommended to calculate and record energy consumption and greenhouse gas emissions (direct emissions of Scope1 and indirect emissions of Scope2) by company and business unit.
  • Find ways to increase efficiency in energy use and minimize greenhouse gas emissions, and encourage the establishment of reduction targets for enterprise-wide greenhouse gases.
(4) Wastewater, Solid Wastes and Air Pollution
  • Wastewater generated from plant operation, industrial process and sanitary facilities, and solid wastes, volatile organic chemicals, mist, corrosive agents, particulate powders, ozone layer-depleting substances, and combustion byproducts generated in the process must be identified, controlled, and treated to the extent permitted by law prior to discharging or disposing.
(5) Biodiversity
  • Efforts shall be made to prevent or minimize the impact on biodiversity that may occur at all stages of the project, and where biodiversity is damaged, efforts shall be made to recover it through methods such as restoration and closure of habitats and land. If biodiversity damage is expected, efforts shall be made to minimize the loss of biodiversity, such as creating alternative habitats in other places, and the project shall not be operated in areas with high biodiversity value.
(6) Harmful Substances
  • Suppliers shall identify and label chemicals, wastes and other substances that pose a risk to humans or the environment and comply with all laws and customer requirements relating to the prohibition and restriction of the use of certain substances in the production and manufacturing process to ensure the safe handling, transport, storage, use, recycling, or reuse and disposal of such substances.
3. Safety and Health
Suppliers should recognize that a safe and healthy work environment is a factor that can not only minimize the occurrence of work-related disasters and illnesses, but also enhance the quality of products and services, the consistency of production, and employee service and morale. In addition, efforts should be made to identify and resolve health and safety problems in the workplace in accordance with local laws and regulations.
(1) Industrial Safety
  • Design, technical, and administrative control of safe processes, preventive maintenance, preparation of safety regulations, establishment of safety work measures, and continuous education shall be conducted to ensure that employees are not exposed to potential safety hazards (e.g. electricity and other energy sources, fire, vehicles, falls, etc.). If these measures do not sufficiently control the risk factors, appropriate personal protective equipment should be provided to the worker.
  • In addition, reasonable measures should be taken, such as removing or reducing harmful elements, without placing them in the urea working environment for pregnant women and nursing women, and convenience facilities should be provided for nursing female workers.
  • Suppliers shall assess safety hazards in production and other machinery. In the event that there is a risk of injury to an employee due to mechanical equipment, physical protection equipment, safety devices, and protective walls must be provided and properly maintained.
(2) Industrial Hygiene and Health Management
  • Suppliers shall establish and comply with the procedures and systems for the prevention, management, tracking, and reporting of workers' occupational accidents and illnesses, including provisions for encouraging workers to report, classifying, and recording cases of injury and disease, providing medical treatment, conducting corrective measures to investigate cases and eliminate causes, and facilitating return to work.
  • Suppliers shall identify, assess, and control workers' exposure to chemical, biological, and physical factors used in the workplace. If a potential risk is identified, it should be able to eliminate and/or reduce risk and should be controlled through appropriate design, engineering, and administrative control. If these measures do not provide sufficient control over the risk factors, appropriate personal protective equipment should be provided free of charge to workers, and protection programs should be provided that include educational materials related to these risks.
  • Suppliers shall create a hygienic and pleasant working environment, and dormitories provided to workers shall maintain cleanliness and safety, and shall be provided with lighting, appropriate emergency exits, air conditioning and ventilation facilities, personal lockers, and appropriate personal space at a reasonable level.
  • Suppliers shall provide workers with appropriate workplace health and safety information and training in a language that workers can understand for all workplace risks, including machinery, electricity, chemistry, fire, and physical risks, and shall post the health and safety information so that it is clearly visible within the facility.
(3) Emergency Response
  • Suppliers should minimize damage by identifying and assessing potential emergency situations and incidents and implementing emergency measures and response procedures. These emergency measures and response procedures include emergency reporting, employee notification and evacuation procedures, worker training and training, and emergency training shall be conducted at least annually or as required by local law.
  • Contingency plans shall include appropriate fire detection and suppression equipment, cleared and apparent exits, appropriate exit facilities, emergency response contact information, and recovery plans, and these contingency plans and procedures shall focus on minimizing human and environmental and property damage.
4. Ethics
Suppliers shall not engage in any form of fraud, corruption, solicitation of money or valuables, and solicitation, etc., shall comply with domestic and foreign bribery and anti-corruption laws and regulations, and shall endeavor to establish an ethical corporate culture through management activities that are thorough and uphold principles. In addition, by complying with international standards and relevant laws and regulations related to fair trade in each country, it shall not engage in any unfair joint act with a competitor, such as collusion on production, price, bidding, market division, etc., or any unfair trade act that is likely to impede fair trade. It shall respect the rights and property of others, including intellectual property rights, shall not make transactions or profits in a manner that infringes on them, and shall acquire and utilize corporate information, including information on competitors, only through legitimate methods. In addition, Suppliers must comply with laws to prevent the laundering of illegal funds and the financing of tax evasion funds both at home and abroad.
(1) Business Integrity
  • In all forms of transactions, the highest level of integrity must be maintained, and inappropriate acts such as bribery, corruption, coercion, extortion, and embezzlement are strictly prohibited.
(2) Compliance with the Special Terms and Conditions for Ethical Practice
  • Suppliers are obligated to comply with the provisions of the POSCO Group's ‘Special Terms and Conditions for Ethical Practice’, and if they violate this, they will be sanctioned in accordance with the terms and conditions and contract-related regulations.
(3) Prohibition of Unjust Profits
  • Not promise, offer, permit, provision or accept bribes or other means to obtain undue or improper benefits, and shall comply with anti-corruption laws and take measures to prevent corruption.
(4) Responsible Mineral Procurement
  • Minerals such as cobalt, tin, titanium, tungsten, gold, etc. used or sold by suppliers themselves shall be mined in a manner that does not constitute a source of funding for disputes, respects human rights and the environment, and fulfills social responsibilities.
(5) Management and Protection of Confidential Information
  • Technical data, information, and intellectual property acquired in the course of supplying products and services to POSCO International shall be used only to the extent permitted by POSCO International and shall be actively protected.
(6) Protection of Intellectual Property
  • The supply of goods and services to POSCO International shall not infringe or unlawfully use any intellectual property, such as any other person's patent, software, design, or trademark.
(7) Protection of Personal Information
  • Efforts shall be made to protect the personal information of employees and all persons related to their duties at a reasonable level of privacy protection. Privacy and information security requirements must be observed when collecting, storing, processing, transmitting, and sharing personal information.
(8) Prohibition of Money Laundering
  • Suppliers should not be directly or indirectly involved in money laundering and should continue to monitor for suspicious transactions related to this.
(9) Prevention of Funding Related to Terrorism and Weapons of Mass Destruction
  • Not provide, raise, transport, or store funds, recognizing that they will be used for the purpose of terrorism and proliferation of weapons of mass destruction.
5. Management System
Suppliers shall adopt or establish a management system related to the content of this Code. The Management System should be designed to identify and mitigate the relevant laws and regulations, compliance with customer requirements, compliance with this Code, and risks associated with this Code, and should continue to improve.
(1) Corporate Willingness to Comply
  • A statement of corporate social and environmental responsibility policy expressing the supplier's willingness to comply and continue to improve should be prepared and posted in local language with the approval of management.
(2) Establishment of Channels and Procedures for Grievance Settlement
  • Suppliers shall establish channels and processing procedures to provide information to interested persons who identify or witness violations of the Code, laws, or ethical regulations, or who have been adversely affected by their business activities in relation to human rights, the environment, etc., and shall actively implement mitigation and improvement of the adverse effects.
(3) Protection of Identity and No Retaliation
  • The supplier must thoroughly ensure that the informant, victim, or collaborator is not subject to retaliation, threats, or discrimination.
(4) Risk Assessment and Management
  • In connection with the business operation of suppliers, procedures for verifying compliance, environment, health, safety, labor practices, and ethical risks shall be established.
(5) Request Data
  • If the material or potential adverse effects of human rights, environment, product safety, etc. are identified, POSCO International may request the relevant supplier for relevant materials, and the supplier shall be obliged to provide such materials.
(6) On-Site Inspection
  • If actual or potential adverse effects on human rights, environment, product safety, etc. are identified, POSCO International may conduct an on-site due diligence of the supplier, evaluate the level of compliance with the supplier's code of conduct through the due diligence, and require the supplier to establish and implement a plan to improve and mitigate the adverse effects of the supplier's business activities based on the results.
  • Transactions with suppliers may be reevaluated or suspended if efforts to improve the actual or potential adverse effects of suppliers on human rights, environment, product safety, etc. are insufficient and the adverse effects of suppliers are deemed unlikely to be mitigated.
(7) Education
  • To implement the supplier's policies, procedures, improvements and to operate training programs for managers and workers to comply with applicable laws and regulatory requirements.
6. Other
(1) Quality Control
  • Suppliers shall endeavor to supply products of quality verified by themselves so that POSCO International can produce/supply world-class products.
(2) Shared Growth
  • To create a sound corporate ecosystem, it should not only actively participate in shared growth activities, but also do its best to spread fair trade and shared growth to secondary and tertiary suppliers who deal with suppliers.
(3) Social Contribution
  • Actively perform social contribution activities for continuous job creation and community and economic development.
7. Reporting Unethical Conduct
Suppliers shall promptly report to POSCO International any violations of applicable laws, regulations, or this Code, using any of the following channels:
  • Website - www.poscointl.com/reportCenter.html
If one chooses to remain anonymous, we ask that you provide sufficient detail and factual information to allow POSCO International to effectively follow up on the concerns raised.
8. Violations of the Code
Where a Supplier is found to have violated the Code, POSCO International may take a range of actions, including suspending business activities and/or payments, terminating the business relationship, and/or requiring the Supplier indemnify POSCO International for any damages, losses, liabilities, costs, or expenses. Such measures will be determined by POSCO International based on the facts and circumstances of each case.
Code of Conduct
1. Risk Management and Due Diligence of Supply Chain
  • We shall identify partners’ failure to comply with the basic principles of this policy and resultant risks that may undermine sustainability in the supply chain and prepare a system to manage and monitor the above risks in order to minimize any negative impacts.
  • When selecting a partner, we shall check whether the candidates are complying with the Partner Code of Conduct in this policy.
  • When entering into contracts with a partner in the supply chain, it shall be clearly stated in the contract that the partner shall comply with this policy and ensure that the partner includes a similar clause in its contract with its own partners.
  • We may identify negative impacts on human rights, the environment, and product safety in the process of managing supply chain risks. We may conduct supply chain due diligence to the extent permitted by law, as is necessary to prevent or mitigate such risks.
  • Supply chain due diligence shall include identification and evaluation of actual or potential negative impacts on the supply chain, preparation and implementation of action plans to prevent/mitigate/address negative impacts, communication with stakeholders about the process and results of due diligence, and procedures through which stakeholders can express their grievance.
  • We may determine the scope of the supply chain subject to due diligence at our own discretion in consideration of expected group-wide effects. Depending on the situation, the scope of due diligence may be limited to direct contractors or be expanded to include entities further up/down the supply chain.
  • We may evaluate a partner’s level of implementation of this policy through supply chain risk management and due diligence. Based on the evaluation results, we may request the partner to establish and implement a plan to address and mitigate negative impacts caused by the partner’s business activities. Regardless of the above, if it is determined that such negative impacts are unlikely to be mitigated due to the partner’s insufficient efforts, we may suspend business with the partner.
2. Co-prosperity with Partners and Establishment of Mutually Beneficial Relationship
We shall endeavor to promote fair trade based on mutual trust with its partners and create an inclusive business environment where we can coexist and grow together with its partners.
  • We shall respect the rights of its partners (intellectual property rights, property rights, etc.) and endeavor to ensure fair trade with partners based on mutual respect and equality.
  • We shall share achievements with partners and pursue mutual benefits. We shall further ensure smooth communication and mutual cooperation with partners so that the latter can provide high-quality products and services.
  • We shall endeavor to improve payment procedures for partners and to establish a stable supply chain by providing technical and financial support. We shall also support partners to help comply with fair trade laws and regulations.
  • We shall continue to expand the scope of partners subject to our co-prosperity efforts for the promotion of mutually advantageous coexistence in the business ecosystem.
Enactment Date: June 16th, 2023
Amendment Date: June 25th, 2024
Management Organization: Corporate Citizenship Bureau
Deliberation: ESG Council
close
Responsible Minerals Policy
Purpose
This policy prohibits the use of conflict minerals such as tin, tantalum, tungsten, and gold (“3TGs”) that have been used to fund warlords and rebel groups in African countries affected by civil wars such as the Democratic Republic of Congo and other minerals such as cobalt that are linked to human rights abuses and environmental issues during the mining process. This policy outlines POSCO International’s commitment to using only “responsible minerals” mined in a way that respects human rights and protects the environment without financing armed conflict and sets out the code of conduct and action plans for achieving the above goal.
Scope of Application
This policy applies to POSCO International. POSCO International shall encourage all of POSCO International’s affiliates and partners to comply with this policy or establish an equivalent policy. Furthermore, POSCO International expects partners to encourage their partners to comply with this policy as well.
Code of Conduct
  • 1.We shall endeavor to prevent negative impact on society and the environment by preventing human rights violations such as child labor and forced labor in the mining process and minimizing environmental destruction.
  • 2.We shall disclose information on partners using minerals that cause conflict, including 3TGs and cobalt, in the Democratic Republic of Congo and neighboring countries.
  • 3.We shall comply with regulations related to conflict minerals, including the Dodd-Frank Act of the United States and the Conflict Minerals Regulation of the EU. We shall endeavor to ensure that due diligence is conducted in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Due Diligence Guidance”), which provides a framework for detailed due diligence to identify and mitigate risks in the supply chains for 3TG and cobalt.
  • 4.We shall require our partners to purchase 3TG and cobalt from smelters that meet the Responsible Minerals Assurance Process (“RMAP”) standards under the Responsible Minerals Initiative (“RMI”) or any other similar standards. We shall also require smelters included in POSCO Group’s supply chains that have failed to meet the RMAP standards to meet the above standards.
Action Plans
Based on the five-step framework recommended by the OECD Due Diligence Guidelines for responsible resource procurement in consideration of human rights protection and conflict risk, we shall manage as follows so that minerals can be mined in a way that respects human rights and protects the environment:
  • 1.Establish an internal management system to manage risks related to minerals mined in conflict-affected and high-risk areas;
  • 2.Identify and evaluate risks that may arise from mining, trading, and exporting minerals in conflict-affected and high-risk areas;
  • 3.Establish and implement a risk management system and strategy to manage and respond to identified risks, monitor implementation performance and improve the management system and strategy on an ongoing basis;
  • 4.Conduct due diligence on smelters in the supply chains in conflict-affected and high-risk areas and plan and conduct independent audits, if necessary; and
  • 5.Publicly report the results of the due diligence every year.
Enactment Date: June 16th, 2023
Management Organization: Corporate Citizenship Bureau
Deliberation: ESG Council
close
Biodiversity Policy
Purpose
The purpose of this policy is to establish a system whereby POSCO International can protect and promote biodiversity while performing its business activities and establish a code of conduct and action plans in order to develop a business model that can promote sustainable growth with the natural environment.
Scope of Application
This policy applies to POSCO International. POSCO International shall encourage all of POSCO International’s affiliates and partners to comply with this policy or establish an equivalent policy.
Code of Conduct
  • 1.We shall shift away from a linear economy where we exploit resources to produce and use products only to eventually discard them, and move instead toward a business model based on a circular economy which is decoupled from the consumption of finite resources and promotes recycling and sustainability.
  • 2.We shall identify the potential impact on biodiversity at each stage of our business, endeavor to prevent or minimize such impact, and in cases of damages to biodiversity, strive to recover previous levels of biodiversity through restoration, closure, etc. of affected habitats and land areas.
  • 3.When the loss of biodiversity is inevitable, we shall endeavor to minimize the loss of biodiversity, such as creating alternative habitats in other places, and shall not operate in areas of high biodiversity value.
  • 4.We shall designate areas where our business activities directly or indirectly affect biodiversity, monitor designated reservation areas inside and outside of workplaces and other areas of high biodiversity value, and evaluate and manage the impact on biodiversity.
  • 5.We shall identify factors that may threaten endangered animals and plants discovered in our workplaces as well as partners’ workplaces and develop strategies to protect such species.
  • 6.We shall carry out ecosystem restoration projects in areas where our business activities directly or indirectly affect the biodiversity and disclose the process of establishing and implementing plans, local communities’ participation efforts, and the results of the projects.
  • 7.We shall actively participate in research and development using biological resources, projects to promote biodiversity and protect animals, and international initiatives related to biodiversity.
Action plans
  • 1.We shall establish procedures and governance where biodiversity issues are considered in our business strategies, decision-making process, and long-term risk analysis, and the board of directors shall monitor the above.
  • 2.We shall integrate biodiversity management into the Group’s EMS and set goals and standards to control and monitor the EMS.
Enactment Date: June 16th, 2023
Management Organization: Corporate Citizenship Bureau
Deliberation: ESG Council
close
Green Procurement Policy
Purpose
This policy aims to prevent the waste of resources and environmental pollution while abiding by applicable laws and regulations in the entire business conduct of POSCO INTERNATIONAL. This policy illustrates the definition of green products, the scope of procurement, basic guidelines, and action plans to support effective policy implementation.
Scope of Application
This policy applies to POSCO INTERNATIONAL and our subsidiaries. We recommend that suppliers and partners doing business with POSCO INTERNATIONAL comply with this policy or other equivalent policies.
Definition of Green Procurement and Green Products
The terms used in this policy are defined as below.
  • 1)‘Green procurement’ refers to purchasing activities undertaken in line with the definition of green products to prioritize eco-friendliness in procuring products required for our business and sales operations, including but not limited to traded products, raw materials, and equipment.
  • 2)‘Green products’ may fall into one of the following categories:
    • A.Products certified for their eco-friendliness pursuant to the pertinent laws and regulations of the Republic of Korea and the policies of government public institutions, or products recognized for their compliance with the certification standards therein
      • -Green products specified in conformity with 「the Environmental Technology and Industry Support Act」, 「the Act on the Promotion of Saving and Recycling of Resources」, 「the Framework Act on Carbon Neutrality and Green Growth for Response to Climate Crisis」, and 「the Energy Use Rationalization Act」, and products certified under the certification programs newly adopted by other public institutions
    • B.Eco-friendly products that qualify under the EU-Taxonomy
    • C.Other products that meet the green procurement eligibility criteria of POSCO Group (GP Grade*)
      • *GP Grade: Green Purchase Grades that apply as green procurement eligibility criteria within POSCO Group
        ※ Refer to [Attachment 1] for the specific details.
Action Plans
Basic Guidelines
  • A.We shall perform regular supply chain ESG assessments* and mitigate our environmental impact in relation to business operations, and shall not do business with suppliers/partners identified for environmental risk as a result of such assessment.
    * ESG assessment according to the ‘Supplier ESG checklist’ and others
  • B.We shall do business with suppliers that consider the environmental impact of their operations (workshop, production site) in terms of protecting ecosystems, preserving bio species, conserving water resources, and managing chemical substances.
  • C.We shall do business with suppliers/partners that abide by our NDPE (No Deforestation, Peat, Exploitation) policy and produce and process products that are free from deforestation, peat destruction, and exploitation of people and communities.
Strong Recommendation for Green Procurement
  • A.We shall proactively procure green products and set priorities in our procurement of green products to prioritize green products in our procurement procedures. Exceptions are allowed, however, in any of the followings:
    • -Green products are not available in the category of products to be purchased
    • -Reliable supply of green products is not possible
    • -Procurement of green products is unfeasible within the set budget limit due to their markedly low price competitiveness
    • -Intended purpose of procurement is hardly fulfilled for reasons such as significantly low quality of green products
    • -Procurement of certain products other than green products is justified at the request of the ordering party or the pertinent business division and/or site-specific conditions
  • B.If green certification programs or green-certified products are not available in the market and the procurement of green products is not available for such reasons among others, we shall opt for products as eco-friendly as possible by drawing on the accessible information including but not limited to their environmental impact such as the content of recycled raw materials and hazardous chemicals, the recyclability of these products and their packaging, and carbon emissions generated from their process and distribution.
Operation of the Green Procurement System
We shall operate a green procurement system to monitor the status of green procurement, identify and introduce green products and their suppliers, assess green procurement performance, and set mid/long-term green procurement goals with an aim to effectively advance green procurement and pursue continuous improvement for green procurement activities. We shall also develop measures to share information on our green procurement performance and goals with stakeholders.
  • A.Green product procurement plan
    • -We shall develop basic plans for the procurement of green products, which will include the followings:
      • Green product procurement targets
      • Analysis of the green product procurement performance of the previous year and plans to expand green procurement
      • Matters on cooperation with relevant departments in relation to green products
  • B.Green product procurement performance
    • -We shall aggregate data on our green product procurement performance measured against the set procurement plan on a semi-annual basis, and if any discrepancies occur between the plan and the actual performance, we shall perform analysis to develop countermeasures.
    • -We shall continuously upgrade our procurement system for the automated, systemic aggregation of green procurement performance data.
  • C.Request for cooperation to expand the procurement of green products
    • -We may request cooperation from relevant departments to expand the procurement of green products.
  • D.Training for procurement personnel and others
    • -We shall appoint the green procurement manager, and provide regular training to managers and departments working in relation to procurement.
Encouragement of Green Procurement within Supply Chains
  • A.We shall encourage affiliates, partners, suppliers, and transaction parties to implement green procurement within the legally allowable boundary, and consider the establishment and implementation of specific green procurement policies in selecting partners.
[Attachment 1]
  • 1)Eco-labeled products pursuant to the Environmental Technology and Industry Support Act
  • 2)Good Recycled (GR) products pursuant to the Act on the Promotion of Saving and Recycling of Resources
  • 3)Low-carbon products that minimize the input of energy and resources as well as the generation of GHG emissions and pollutants pursuant to the Framework Act on Carbon Neutrality and Green Growth for Response to Climate Change
  • 4)High-efficiency energy equipment and products graded 1~2 pursuant to the Energy Use Rationalization Act
  • 5)Products bearing HB (Healthy Building Material) Mark granted under the green building material organizational standard certification program
  • 6)Eco-friendly products that qualify under the EU-Taxonomy
    • A.Agricultural products that satisfy the requirements of sustainable organic product certification standards
    • B.Products that conserve energy and reduce carbon emissions to mitigate climate change
      • -Fuel cells, biomass, biogas, bioethanol, biodiesel, biofuel oil, and other products that help reduce carbon emissions
  • 7)Other products that satisfy POSCO Group’s green procurement eligibility criteria (GP Grade)
    GP Grade Products Description
    GP 1 Eco-labeled Products Eco-labeled products as defined by the laws and regulations related to environmental technology development and resources
    GP 2 Good Recycled (GR) Products Recycled products certified by the laws and regulations on the promotion of resource saving and recycling
    GP 3 Energy-saving Products Products with energy efficiency grades 1 to 2, energy-saving marks, and high-efficiency energy equipment defined by the laws and regulations on energy use rationalization
    GP 4 Products Reducing Six Harmful Substances Products that reduce harmful substances such as lead, mercury, cadmium, chromium, PCB (Polychlorinated Biphenyl), and asbestos
    GP 5 Waste Reduction Products Products that reduce waste through lightweight packaging units, refills, container recovery, etc.
    GP 6 Others (Flame Retardant, Foreign Environmental Labels) Flame retardant products, recycled products using waste raw materials, products with foreign environmental labels, and other products recognized as eco-friendly
    GP 7 Products Requiring Environmental Consideration Products requiring environmental consideration (compliance with environmental regulations, etc.)
Enactment Date: June 7th, 2024
Management Organization: Corporate Citizenship Bureau
Deliberation: ESG Council