Pursuing shareholder value increase

• - Create profits through transparent decision making and
     efficient business activities and simultaneously increase
  corporate value and shareholder value.

Offering fair investment information

• - Do not offer information that may affect the investor’s
     judgment; do not provide them selectively.
• - Do not trade stocks or marketable securities using internal
     information in relation to the job; do not recommend
     trading to others.

Calculating and offering transparent financial information

• - Financial information needs to be produced through proper
     process and control based on precise trading facts
• - Financial reports need to be drawn up according to generally
     recognized accounting standards.
• - Sufficient and accurate management information should
     be offered for investors to make investment decisions based
     on their own judgment and responsibility.

Building mutual trust

• - Practice fair trade through mutual respect and equal
     relations with trading partners.
• - Strictly protect the information acquired from trading
     partners according to laws, regulations, and terms and
     conditions of agreements.
• - Assist trading partners in complying with laws and
     regulations regarding fair trading.

Promoting win-win growth with trading partners

• - Purse mutual profits by sharing performance with trading
     partners.
• - Enable trading partners to offer excellent-quality products
     and high level of services through smooth communication
     and mutual cooperation with trading partners.
• - Offer fair opportunities to trading partners, guarantee
     rational trading conditions, and consequently develop
     partnership relations.

Continuous support for trading partners' development

• - Make an effort to build a stable supply network through
     technical and financial assistance for trading partners.
• - Expand the scope of trading partners for overall win-win
     cooperation in the corporate ecosystem.

Role and attitude as a corporate citizen

• - Respect the laws and regulations of the local country and
     culture and tradition of the community and endeavor for
     co-development with the nation and society.
• - Strive to communicate through stakeholders’ participation
     in the management activity process related to the nation
     and society.
• - Make an effort for trading partners to take part in activities
     for national and social development.

Contribution to national and social development

• - Fulfill obligations in the community through stable job
     creation and faithful tax payment.
• - Actively participate in social volunteer activities such as
     volunteer service and disaster relief and introduce public
     interest activities in various areas such as culture, arts,
     sports, and academe.
• - Aid in improving the quality of life of community residents
     for them to lead a happy life.

Money and valuables

• - Money and valuables mean something that can bring
     economic profit including money (cash, gift certificate,
     and gift voucher) and goods.
• - Under no circumstances shall employees demand or receive
     money and valuables from stakeholders. Note, however, that
     souvenirs marked with the stakeholder company’s logo and
     those generally offered to the participants in events hosted
     by stakeholders are excluded.
• - If one receives money and valuables inevitably in
     no-recognized state, they must be returned; if return is not
     possible, they must be reported to the Internal Control
     Department.

Entertainment

• - This means various activities conducted for social gatherings
     and exchanges for business such as meals, drinking, golfing,
     performances, and amusements.
• - Entertainment beyond the socially acceptable level cannot
     be offered or received with stakeholders. Offering or receiving
     entertainment beyond the socially acceptable level needs
     to be reported to the Internal Control Department. Note,
     however, that entertainment in bars or other establishments
     by hostesses, etc., is prohibited.
• - If entertainment is offered beyond the socially acceptable
     level at the company’s expense for any stakeholder, or in case
     of participation in the event including entertainment beyond
     the socially acceptable level, the person concerned needs to
     obtain approval from his/her department head in advance.

Convenience

• - Convenience means offering or receiving benefits such as
     transportation means, accommodation, tourism, and event
     support.
• - Convenience including transportation means,
     accommodation beyond the socially acceptable level must
     not be offered or received. Note, however, that convenience
     generally offered to all the participants in an event is
     excluded.
• - If convenience beyond the allowed scope is inevitably
     offered or received, such needs to be reported to the Internal
     Control Department.

Congratulatory and condolatory expenses

• - Any and all congratulatory and condolatory events occurring
     on the part of the person himself/herself or a colleague must
     not be known to stakeholders; any act of letting them know
     through a third party is regarded as the person’s act.
• - For information on congratulatory and condolatory events
     between employees, the internal message board for
     congratulatory and condolatory events should be used;
     sending individual mail and guide cards (invitation card and
     obituary card) is prohibited. The scope of kinship for
     congratulatory and condolatory events is limited to immediate
     family including grandparents, parents, and children of the
     person himself/herself and spouse.
• - Congratulatory and condolatory expenses between
     employees must not exceed KRW 50,000 as the social
     customary level.
• - Congratulatory and condolatory expenses must not be
     received from external stakeholders. If they are received
     inevitably, they need to be returned or donated to the Internal
     Control Department.
• - Employees need to present the relevant data on the return
     of congratulatory and condolatory money received from
     stakeholders as required by the Internal Control Department.
• - Employees must not receive congratulatory and condolatory
     garland/wreath from stakeholders; neither should they
     exhibit it even if the garland/wreath was received inevitably.
• - Employees should not hold a luxurious wedding in a
     five-star hotel.

HR request

• - Employees should not request for their own promotion,
  assignment to a position, and overseas work through an
  acquaintance or an external figure.
• - Any HR-related request for relatives or acquaintances should
  not be made including employment, promotion, and assign-
  ment to a position.

Money trading

• - Money trading must not be conducted with stakeholders
  , such as cash loan, loan guarantee, and real estate lease/rent
  with stakeholders.
• - If money trading was done with a stakeholder inevitably due
  to personal relations, such should be reported to the Internal
  Control Department.

Event sponsorship

• - No support must be received from stakeholders in case
  events supported by POSCO A&C, like department event or
  club activity, are held.
• - Receiving convenience such as car, place, and service neces-
  sary for any event is regarded as receiving sponsorship money
  and valuables.
• - In case sponsorship is inevitably received, such needs to be
  reported to the Internal Control Department.

Unreasonable use of budget and finance

• - The company’s budget and finance like meeting expenses
  and business operating expenses must not be used for
  personal purposes.
• - In the case of expenditure payment, the company card
  should be used, in principle, and in line with the standards for
  budget purpose set forth by laws.

Protection of information and assets

• - The company’s confidential information or material informa-
  tion needs to be protected thoroughly.
• - Material information should be delivered to those who need
  them in business upon recognizing such.
• - Information must not be distorted, or false information must
  not be distributed.
• - Do not use the company’s equipment, supplies, and facilities
  for purposes not directly related to the company’s business.

Fair trade

• - Do not engage in unfair trading including collusion on produc-
  tion, prices, bids, and market division with competitors, con-
  forming instead to international standards and fair trade law
  s and regulations by country.
• - Do not demand any type of compensation or unreasonable
  request to customers or trading partners using one’s advanta-
  geous position.
• - Respect others’ rights and properties including intellectual
  property rights; do not breach them or profit from them.
• - Corporate information including information on competitors
  needs to be acquired and used through justifiable methods
  only.