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Fair trade


CP Overview

Overview of Fair Trade Compliance Program

  • Fair Trade CP(Compliance Program)
  • Prevention of corporate losses
  • Incentives including reduction of penalty
  • Enhancement of internal and external credit rating
  • Global standard
  • Risk management

What is Fair Trade CP?

It means internal compliance system including education/training and supervision system established and operated
by the company itself in order to comply with Fair Trade Act and Regulations.

Why CP is needed?

  • consolidating fair competition and CP operation
    - The expansion of CP operation is one of the major goals of the Fair Trade Commission, and CP is especially intended to be expanded to
      small and medium businesses through collective adoption by large corporations’ primary partner firms.
  • Preventing corporate losses according to the violation of the Fair Trade Act
  • Enhancing internal and external images as a transparent company based on management by principle
  • Minimize damage from violations of the law

Eight Major Components of CP

Eight Components

  • Establish and implement CP standards and procedures
  • CEO's willingness and support for compliance
  • Appoints a compliant manager to oversee CP operations
  • Production and utilization of compliance manuals


  • Conduct continuous and systematic compliance training for executives and employees
  • Establishment of an internal monitoring system to prevent violations of the law
  • Sanctions against executives and employees who violate fair trade laws
  • Effectiveness evaluation and improvement measures




The Fair Trade Act seeks to promote the balanced development of the national economy by promoting fair and free competition
between companies, encouraging creative business activities, and protecting consumers.

POSCO A&C published the Fair Trade Manual to comply with the Fair Trade Act and provided employees with the conduct
standard for compliance with the Fair Trade Act. We have been endeavoring greatly to eliminate business practices that breach
the Fair Trade Act cyclically.

As part of such endeavor, we adopted the Compliance Program (CP) in 2009. The CP manager responsible for CP operation is
appointed by the board of directors.

Operation Status

CP Operation Progress

2003.  06    Declared ethical standard / Clarified fair trade compliance will and notified the declaration and will to all employees

2009.  04    Introduced and implemented Internal Deliberation Committee of Subcontracting

 10    Introduction of CP(Compliance Program)

2010.  01    Appointed CP manager in the board of directors

 12    Production of compliance manuals

2011.  01    Established of CP operating regulations and guidelines
Introduction of standard supplier agreement

 02   Changed CP manager in the board of directors

 04   Change the department dedicated to the CP(Management Support Office → Internal Control Department)

 06    The 1st revision of compliance manuals

 12    Signed partnership agreement/ Organized partnership support group
External assessment of CP operations (acquired CP rating “BBB”)​

2012.  11    External assessment of CP operations (acquired CP rating “A”)

2014.  03    Changed CP manager in the board of directors

 04    Establish a stakeholder meeting process

 06    Expanded CP organization (Marketing sector)

 12    External assessment of CP operations (acquired CP rating “A”)

2015.  07    Construction of a reporting center

2016.  01    Introduction of Clean POSCO system

 06    Revision of CP operating regulations and guidelines

 12    External assessment of CP operations (CP grade assessment corresponding to "A" grade)​

2017.  03    Changed CP manager in the board of directors

2019.  03    Changed CP manager in the board of directors

2022.  01    The 2nd revision of CP operating regulations and guidelines

 02    Revision of a reporting center

 03    Changed CP manager in the board of directors

 05    The 3rd revision of CP operating regulations and guidelines

 08    The 10th revision of compliance manuals

2023.  01    The CEO's willingness to comply with the CP is declared again
Implementation of a pledge to comply with CP for all executives and employees

 03    The 4th revision of CP operating regulations and guidelines

 05    Conduct a self-compliance council(1st) organized by the CP manager

 07    CEO asks employees to 'settle a culture of fair competition' in 53rd anniversary speech of the company's foundation

 09    Certified by the Anti-Corruption Management System (ISO37001)

 10    Conduct a self-compliance council(2nd) organized by the CP manager

 12    External assessment of CP operations (acquired CP rating “AA”)
Conduct CP related rewards

Frequently   Conduct fair trade education in consideration of business relevance
Implementation of internal deliberation on subcontracting transactions
Pre-audit of private contract
Sanctions on executives and staff members who breach the law related to fair trade​

Quarterly     Report the status of CP operation

Reporting Procedure upon Detecting the Fair Trade Act Violating Activity

Relevant Regulations (Regulations of Fair Trade CP Operation)

- Article 15 (Obligation)
3. Each Office head and CP practice leader shall report to the CP manager immediately, when they detect any legislature violation in carrying out their duties.

Reporting Process

  • Staff in charge (law violation detector)
  • Members of self-compliance council (Department Head and CP Practice Leader)
  • CP Manager or Department in charge of CP

    Executive in charge

Reporting Method and Details

Reporting method and details table
Details Reporting Timing Subject to Report
in the First Phase
Subject for
Final Report
Reporting Method
Fair Trade Act
after Recognition
Members of
self-compliance council
(Department Head
and CP Practice Leader)
CP Manager
or Department
in charge of CP,
First Phase Reporting
: Telephone
Final Reporting
: In Writing

What is Fair Trade Autonomous Inspection?

As a pre-monitoring system of law violations using checklists, this inspection is to let staff inspect violations of fair trade for themselves
on their work so as to prevent the Fair Trade Act violations in advance.

Autonomous Inspection Diagram

  • Drawing up and distribution of Fair Trade Autonomous Inspection Checklist (CP manager)

    Distribution of checklist by sector and violation type

  • Autonomous inspection by department (CP Council member, practice leader)

    Execution in line with department characteristics using the checklist

  • Counseling·Consultation (Internal Control Department)
  • Synthesizing and evaluation of autonomous inspection results (CP manager)
  • Fair trade audit (CP manager)

    Auditing at least once a half year, centered on weak sector

  • CP operation improvement·supplementation (CP manager)


CP Manual

POSCO A&C produced its own Fair Trade Self-compliance Manual in June 2011 and provided executives and employees with behavioral standards for compliance with the Fair Trade Act. Since then, POSCO Family has jointly revised the law and its practical cases to support active use of the manual throughout September 2012 and July 2014.

In addition, as supplementary materials for the manual, [Subcontracting Fair Trade Compliance Manual], [Fair Trade Compliance Manual in the Fair Trade Sector], [Marketing Division Fair Trade Compliance Action Guidelines], and [Business Management Guidelines] were published. In 2014, [Bidding Compensation Prevention Action Guidelines] were produced to reflect major issues related to fair trade.

In August 22, we issued and distributed a newly organized manual revision with the latest law revisions, cases, and precedents so that executives and employees can use it when performing subcontracting-related tasks.


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