THE E&M

THE E&M Co., Ltd. (hereinafter referred to as the "Company") is committed to fulfilling its social responsibility towards all stakeholders, including customers, shareholders, employees, the nation, and society, which form the

foundation of our survival through trusted ethical management.

The Company enhances its competitiveness through transparent management and innovation. To achieve this, the Company has established and implemented a Code of Ethics and Rules that apply to all employees.

Code of Business Ethics

THE E&M Co., Ltd. (hereinafter referred to as the "Company") is committed to fulfilling its social responsibility towards all stakeholders, including customers, shareholders, employees, the nation, and society, which form the foundation of our survival through trusted ethical management.

The Company enhances its competitiveness through transparent management and innovation. To achieve this, the Company has established and implemented a Code of Ethics and Rules that apply to all employees.

1.	Customer Satisfaction: The Company and its employees strive to supply quality products at reasonable prices to ensure customer satisfaction.
2.	Integrity and Compliance: The Company and its employees conduct business with sincerity and integrity, complying with laws and respecting business customs and order.
3.	Fair Opportunities and Treatment: The Company provides all employees with equal opportunities and ensures fair and equal treatment based on their abilities and achievements.
4.	Protection of Company Assets: Employees do not use the Company’s assets for personal gain and prioritize the Company’s interests when personal conflicts of interest arise during the performance of their duties.
5.	Prohibition of Improper Benefits: Employees must not request or accept any monetary or non-monetary benefits from stakeholders in relation to their work.
6.	Continuous Self-Development: Employees commit to continuous self-development to align with the Company’s talent ideals and lead business innovation through passion, excellence, and professional knowledge.
7.	Active Participation in Innovation: Employees actively participate in innovation activities and lead efforts to improve and innovate within the Company.

Chapter 1: Fair Competition and Equal Treatment

1.

Employees must engage in fair and honest competition both inside and outside the Company.

2.

Employees must provide fair opportunities to companies or individuals who have or seek business relationships with the Company, ensuring that business transactions meet the Company's quality and service standards.

- When purchasing goods and services from business partners, employees must provide fair opportunities and strive for cost reduction and quality improvement.

- Discriminatory treatment, such as price discrimination, must not be applied to business partners without just cause.

- Employees must not engage in unreasonable discriminatory treatment against other employees based on gender, education, religion, physical disability, or any other reason.

3.

Employees must not engage in unreasonable discriminatory treatment against other employees based on gender, education, religion, physical disability, or any other reason.

Chapter 2: Gifts, Entertainment, and Financial Transactions

1.	Employees must not accept gifts, money, or financial conveniences from business partners, nor accept excessive entertainment. However, exceptions can be made for small amounts that are generally accepted by societal norms.
2.	Employees must not offer or provide gifts, money, or entertainment to business partners or public officials in connection with Company business. However, exceptions can be made for small amounts generally accepted by societal norms.
3.	Employees must not provide excessive support or gifts beyond societal norms among colleagues and are prohibited from gambling inside or outside the Company.
4.	Excessive financial transactions or loan guarantees among employees are prohibited. In unavoidable cases, prior or subsequent written notification must be made to the Audit Office.

Chapter 3: Transparent Management

1.	All transactions of the Company must be accurately reflected in the Company's financial statements and accounting records in accordance with accounting principles.
2.	The Company’s assets must not be used for personal gain.
3.	The know-how and information that constitute important assets of the Company must not be disclosed externally without the Company’s approval, and all employees must do their best to protect them.
4.	Employees must not disclose significant information related to the Company that could influence stock prices or investors' decisions without permission, nor use it for personal gain, such as stock trading.

Chapter 4: Employees' Responsibilities and Compensation

1.	Employees must perform their duties to the best of their ability to maximize the Company's value, and the Company will appropriately compensate employees based on their abilities and achievements.
2.	The Company must ensure that employees can work in a safe and comfortable environment.
3.	The Company encourages employees' self-development activities to contribute to the growth of both the Company and the employees.
4.	Employees must not use illegal software.

Chapter 5: Implementation

1.	All Company employees must comply with this Code of Ethics.
2.	If an employee violates these rules, the head of the Human Resources Department shall issue a warning to the violator, and if the violation is deemed to be a significant breach of morality, the Human Resources Committee may be convened to request disciplinary action.
3.	The head of the Human Resources Department shall report violations of the Code of Ethics to the Human Resources Committee.
4.	This Code of Ethics and Rules will be implemented as of May 1, 2005.

1. Prohibition of Personal Use of Company Resources

1.	Employees are prohibited from using the company's time, assets, information, or resources for personal gain, including during working hours. Employees must do their utmost to protect the company's assets and information.
1.1	Employees must not disclose confidential information, trade secrets, or work-related knowledge (intangible assets, patents, proprietary technologies, etc.) acquired during their work to external parties.
1.2	Employees must not collect internal documents or critical business technologies for future personal profit. They must recognize that the materials and technologies gathered during work are the company's intangible assets and should be shared with the entire organization.
1.3	After leaving the company, employees must not engage in profit-seeking activities that contradict the company’s interests by using the work skills and know-how acquired during their employment.
1.4	Employees are prohibited from holding other jobs, including side jobs. If there are unavoidable circumstances, the employee must report to the Audit Office in writing within one week. The Audit Office Manager will file the document after obtaining the CEO's approval.
1.5	Employees are prohibited from trading stocks using internal information.
1.6	Employees must make efforts to protect internal information, particularly by safeguarding data on computers and IT systems.

3. Gifts, Entertainment, and Financial Transactions with Business Partners

3.1	Employees are prohibited from accepting excessive entertainment (over 100,000 KRW per person) from business partners in relation to their duties.
3.2	Employees must not accept excessive gifts or money (including cash or gift certificates) from business partners in connection with their duties.
3.3	Employees are prohibited from requesting any form of gifts, entertainment, or hospitality from business partners. Violations will be subject to disciplinary action according to the procedures of the Personnel Committee, and the relationship with the business partner who provided the gifts or hospitality will be immediately terminated.
3.4	Employees must not accept financial favors, such as loans or rental agreements, from companies they have business relationships with, including those owned by close relatives (up to cousins on both the paternal and maternal sides and in-laws).
3.5	Employees are prohibited from engaging in investment, loan, or employment relationships with companies that have business ties with the Company.
3.6	If employees unavoidably receive excessive entertainment, they must report it in writing (including via email) to their immediate superior within three days. The superior must then report it to the Audit Office (or Audit Manager), who will inform the CEO in writing, and actions will be taken based on the CEO's decision.

Detailed Ethical Guidelines

1. Prohibition of Personal Use of Company Resources

1.	Employees are prohibited from using the company's time, assets, information, or resources for personal gain, including during working hours. Employees must do their utmost to protect the company's assets and information.
1.1	Employees must not disclose confidential information, trade secrets, or work-related knowledge (intangible assets, patents, proprietary technologies, etc.) acquired during their work to external parties.
1.2	Employees must not collect internal documents or critical business technologies for future personal profit. They must recognize that the materials and technologies gathered during work are the company's intangible assets and should be shared with the entire organization.
1.3	After leaving the company, employees must not engage in profit-seeking activities that contradict the company’s interests by using the work skills and know-how acquired during their employment.
1.4	Employees are prohibited from holding other jobs, including side jobs. If there are unavoidable circumstances, the employee must report to the Audit Office in writing within one week. The Audit Office Manager will file the document after obtaining the CEO's approval.
1.5	Employees are prohibited from trading stocks using internal information.
1.6	Employees must make efforts to protect internal information, particularly by safeguarding data on computers and IT systems.

3. Gifts, Entertainment, and Financial Transactions with Business Partners

3.1	Employees are prohibited from accepting excessive entertainment (over 100,000 KRW per person) from business partners in relation to their duties.
3.2	Employees must not accept excessive gifts or money (including cash or gift certificates) from business partners in connection with their duties.
3.3	Employees are prohibited from requesting any form of gifts, entertainment, or hospitality from business partners. Violations will be subject to disciplinary action according to the procedures of the Personnel Committee, and the relationship with the business partner who provided the gifts or hospitality will be immediately terminated.
3.4	Employees must not accept financial favors, such as loans or rental agreements, from companies they have business relationships with, including those owned by close relatives (up to cousins on both the paternal and maternal sides and in-laws).
3.5	Employees are prohibited from engaging in investment, loan, or employment relationships with companies that have business ties with the Company.
3.6	If employees unavoidably receive excessive entertainment, they must report it in writing (including via email) to their immediate superior within three days. The superior must then report it to the Audit Office (or Audit Manager), who will inform the CEO in writing, and actions will be taken based on the CEO's decision.

2.1	Excessive monetary transactions or loan guarantees between employees are fundamentally prohibited.
2.2	Employees must not request personal favors for promotion or other HR matters and are prohibited from offering excessive financial support or gifts to colleagues.
2.3	Employees are prohibited from offering excessive gifts (over 100,000 KRW per person) or excessive entertainment (over 100,000 KRW per person) to their superiors.

2.1	Excessive monetary transactions or loan guarantees between employees are fundamentally prohibited.
2.2	Employees must not request personal favors for promotion or other HR matters and are prohibited from offering excessive financial support or gifts to colleagues.
2.3	Employees are prohibited from offering excessive gifts (over 100,000 KRW per person) or excessive entertainment (over 100,000 KRW per person) to their superiors.