1.
Concentration on Work, Prohibition of Leaving the Workplace, and False Reporting
a.
All officers and employees shall not engage in personal activities unrelated to their work during working hours without the Company’s permission.
b.
All officers and employees shall not leave the workplace during working hours without the approval of their supervisor in order to devote themselves to their duties.
c.
All officers and employees shall not be absent without authorization and must comply immediately with any orders to return to work.
d.
All officers and employees shall report work accurately and shall not submit false data or reports that are inconsistent with the facts.
2.
Sound Leisure Activities and Frugal Lifestyle
All officers and employees shall strive to improve their quality of life through healthy leisure activities after work and maintain a wholesome and frugal lifestyle.
3.
Prohibition of Unfair Instructions and Requests
a.
All officers and employees shall not give unfair orders to subordinates and shall not follow unfair orders from superiors.
b.
All officers and employees shall not make unfair solicitations or engage in unfair transactions in connection with their duties.
4.
Reporting of Violations and Protection of Reporting Employees
All officers and employees who discover or suspect a violation of laws or the Code of Ethics in relation to their duties shall immediately report it to their supervisor or the relevant department. The Company shall strictly protect the confidentiality of the reporting employee and shall not impose any disadvantage as a result of the report.
5.
Protection of Internal Information and Prohibition of Insider Trading
a.
Internal information regarding the Company and customers obtained in connection with the performance of duties shall not be shared or disclosed except when lawful procedures are taken, and may be used only when related to duties. In addition, trading of specific securities or other insider transactions using internal information of the Company and customers is prohibited, and such information shall not be leaked or utilized to third parties for the purpose of seeking economic benefit.
b.
Information acquired during business activities shall be recorded and reported based on facts, and shall be stored and managed as the Company’s intellectual property.
c.
Patents, copyrights, trademarks, and other intellectual property rights of others shall be respected, and no acts of infringement such as unauthorized use, reproduction, distribution, or alteration shall be committed.
d.
Care shall be taken not to violate the Company’s intellectual property protection and security duties during conversations or telephone calls (including internet communication) with outsiders or acquaintances.
*External leakage of new product information, sales, costs, discount rates (hospitals), sales materials, customer data, and inventory-related data is prohibited.
6.
Prohibition of Conflict of Interest Acts
All officers and employees, except as permitted by law, employees shall not engage in activities, business transactions, or external activities that conflict with the interests of themselves, the Company, or its customers, and shall not hold concurrent positions in other businesses without the Company’s approval.All officers and employees are required to complete and sign the ‘Declaration on Conflict of Interest’ attached as Annex 1 to this Policy once a year and submit it to the Legal Team upon request.
7.
External Activities
All officers and employees shall not express opinions through publications, lectures, or external media regarding matters related to their duties or the Company without prior approval of the Company.
8.
Restriction of Political Activities and Donation Acts
All officers and employees shall not engage in political activities such as supporting or endorsing a specific political party or candidate by using their duties or positions. All donations, contributions, and expenditures made in the name of the Company, including political donations and donations for social contribution, shall be subject to the Company’s approval.
9.
Prohibition of Bribery and Prevention of Corruption
All officers and employees shall not, directly or indirectly, propose, promise to provide, or actually provide any money, gifts, conveniences, or other benefits to public officials, public servants, persons performing public duties (the “Public Officials, etc.”), related third parties, or their employees, customers, organizations (or their relatives or acquaintances) in order to influence the performance of duties. Executives and employees, when dealing with Public Officials, etc. and third parties, shall comply with all relevant anti-bribery and anti-corruption laws, including the Improper Solicitation and Graft Act of Korea (the “Anti-Graft Act”), the U.S. Foreign Corrupt Practices Act, and the U.K. Bribery Act.
10.
Restriction on Receiving Money, Real Estate, Gifts, and Entertainment (the “Money and Other Benefits”)
All officers and employees shall not demand or receive money and other benefits that are not permitted in connection with their duties from other employees or external persons (such as business partners).
a.
“Gift” means securities, real estate, goods, accommodation vouchers, membership rights, admission tickets, discount coupons, invitation tickets, viewing tickets, rights to use real estate, and other similar items provided without compensation (including cases where the compensation is significantly lower compared to market price or customary transaction practices).
b.
“Entertainment” means hospitality such as food, alcoholic beverages, golf, entertainment, or conveniences such as transportation and accommodation.
However, in any of the following cases, this shall not apply (provided that compliance with the Improper Solicitation and Graft Act is required):
①
Money and Other Benefits provided under legitimate rights such as the performance of obligations.
②
Simple meals and conveniences such as communication and transportation provided only when unavoidable in the performance of duties (within the scope of social norms).
③
Transportation, accommodation, or food uniformly provided to participants by the organizer at official events related to duties.
④
Souvenirs or promotional items distributed to an unspecified number of people.
⑤
Money and Other Benefits publicly provided to help employees in difficult situations due to illness or disaster.
⑥
Simple gifts such as flowers or fruits unavoidably provided in the performance of duties (within the scope of social norms).
⑦
Money and Other Benefits publicly provided by an employee’s mutual aid association or similar organization.
⑧
Money and Other Benefits provided by superiors to subordinates for the purpose of consolation, encouragement, or rewards to raise morale.
⑨
Simple gifts such as wreaths or souvenirs publicly received on occasions such as inauguration, retirement, or resignation.
11.
Prohibition of Illegal Rebates
Providing economic benefits to medical professionals, founders of medical institutions, employees of medical institutions, and their special related persons is prohibited unless it falls under exceptional cases permitted by relevant laws. All officers and employees shall comply with all domestic and international laws related to rebates, as well as the Fair Competition Code of the Korea Pharmaceutical and Bio-Pharma Manufacturers Association (KPBMA), the Fair Competition Code of the Korea Medical Devices Industry Association (KMDIA), and the codes of conduct of international associations and national healthcare industry associations such as the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA), the Pharmaceutical Research and Manufacturers of America (PhRMA), and the Advanced Medical Technology Association (AdvaMed). In addition, executives and employees shall comply with all relevant laws, industry rules, and codes of conduct, including the Pharmaceutical Affairs Act, the Medical Device Act, and the U.S. Sunshine Act, to ensure transparent disclosure of economic benefits provided to healthcare professionals.
12.
Compliance with Research Ethics
All officers and employees, in conducting research, shall comply with research ethics in accordance with relevant laws such as the Bioethics and Safety Act. Specifically, they shall not infringe upon human dignity and value, shall sufficiently consider the safety of research subjects to minimize risks, shall provide adequate information to research subjects and obtain their voluntary consent, and shall protect the privacy of research subjects and properly handle personal information.
13.
Compliance with Research Ethics
The use of expenses by executives and employees shall be carried out solely for the purpose of performing company business at a reasonable and necessary level. All officers and employees shall not commit any misconduct such as embezzling, misappropriating, or stealing company funds or assets, or irregularly processing expenses, thereby seeking private gain by using their position or duties.
14.
Private Monetary Lending, etc.
All officers and employees shall not establish private monetary lending relationships with customers or engage in gambling acts accompanied by the exchange of money and goods. Excessive guarantee and borrowing acts shall require the Company’s approval.
15.
Mutual Respect
All officers and employees shall respect each other’s character and observe courtesy, shall recognize each other’s diversity, and shall not engage in discriminatory acts.
16.
Transparency in Business Relations
All purchases of goods and services required by the Company shall be determined based on criteria such as quality, ease of use, price, and contribution to the Company. Decisions on purchases shall be based on objective judgment of the supplier’s reliability and sincerity, long-term and short-term consideration of the value of the supplied items, and the purpose of the purchase.
17.
Prohibition of Sexual Harassment
All officers and employees shall not, by using their position in the workplace or in connection with their duties, cause employment disadvantages to other executives and employees through sexual language or behavior, or cause sexual humiliation by such acts or by making them a condition.
18.
Fair Competition
All officers and employees shall not engage in unfair transactions or cause the Company to engage in them.
19.
Cooperation among Members
All officers and employees shall faithfully cooperate when cooperation among departments or individuals is required for the common interest of the Company.
