SK leaveo (referred to as the company) adheres to SKMS as the foundation of its corporate management, creating value for various stakeholders including customers, members, shareholders, business partners, and society. The company plays a crucial role in social-economic development and contributes to the happiness of humanity.

Accordingly, SK leaveo establishes the 「Ethical Codes」 to fulfill its roles and responsibilities toward customers, members, shareholders, business partners, and society, using them as the standard for decision-making and actions in all management activities.

01. Attitude Towards Customers 「By practicing customer satisfaction management, we earn trust and grow together with our customers.」
1.1 Customer-Oriented Management
- We respect the diverse opinions of our customers and prioritize incorporating them into the company’s management activities.
1.2 Enhancing Customer Value
- We strive to provide the best products and services that meet our customers’ needs.
1.3 Protection of Customer Privacy and Trade Secrets
- We protect our customers’ assets and information with the same diligence as we protect our company’s assets and information.

02. Fundamental Ethics of Members 「Members perform their duties to the best of their abilities, with a sense of responsibility that each represents the company.」
2.1 Fostering a Healthy Corporate Culture
- Members shall comply with all internal-external regulations that must be observed.
2.2 Fair Business Conduct
- We create an environment where members respect each other and can work voluntarily-enthusiastically.
2.3 Safety of Members
- We enhance our competitiveness through the improvement of individual capabilities, maintaining our own honor and dignity.

03. Responsibility to Shareholders 「We enhance corporate value through transparent and efficient management to create shareholder value.」
3.1 Enhancement of Corporate Value
- We maximize corporate value through continuous innovation and efficient management, sharing the results with our shareholders.
3.2 Protection of Shareholder Rights
- We enhance corporate value through transparent decision-making and efficient management activities.
3.2.1 We practice board-centered transparent management and respect the legitimate demands and suggestions of shareholders.
3.3.2 We prepare management data in accordance with relevant laws and accounting standards, and faithfully disclose it in compliance with legal requirements to protect shareholder interests.

04. Relationship with Business Partners 「We provide fair opportunities to business partners, pursue mutual benefits and joint development, and strive for mutual growth based on trust.」
4.1 Co-Prosperity
4.1.1 We do not engage in unfair practices by exploiting our superior position over business partners, and we provide fair trading opportunities to pursue mutual benefits and joint development.
4.1.2 We must protect the trade secrets of business partners and not use them for any purpose other than the one for which they were provided.

05. Role in Society 「We become a trusted company by adhering to social norm and contribute to society through social and cultural activities.」
5.1 Compliance with Laws - We comply with the regulations of the countries where we operate and respect their traditions and cultures.
5.2 Anti-Corruption
We comply with anti-corruption laws and international agreements of the countries where we operate and strive for the development of a fair society.
5.3 Respect for Human Dignity
We do not engage in unreasonable discrimination against any stakeholders and protect fundamental human rights.
5.4 Eco-Friendly Management
We comply with international environmental standards, relevant laws, and internal regulations, and practice eco-friendly management.
5.5 Compliance with Safety and Health
We take the lead in building a safe society by managing health and safety risks, and complying with international standards, relevant laws and regulations, and internal policies.
5.6 Social Contribution Activities
We actively participate in social contribution activities tailored to the characteristics of the local community, contributing to social development.

06. Application of the Ethical Code 6.1 Scope of Application and Compliance Obligations
6.1.1 This code of ethics applies to the company and all its members. Every member is obligated to comply with this Code of Ethics. Additionally, stakeholders should be made aware of this Code and encouraged to practice it.
6.2.2 Violations of this code of ethics will be addressed in accordance with company regulations.
6.2. Operation of Ethical Management Practice Guidelines
The organization responsible for ethical management will establish and operate the “Ethical Management Guidelines” to ensure that members correctly interpret and implement this Code of Ethics.

[Supplementary Provisions] This Ethical Code shall be effective as of August 1, 2020
The first revision of this Ethical Code shall be effective as of October 1, 2023.

01. Purpose The purpose of these principles for implementing the code of ethics is to establish the necessary guidelines to practice the intent of the company’s code of ethics.

02. Scope ① All members of the company must be familiar with and adhere to the code of ethics and these implementing principles.
② Any questions regarding the code of ethics and implementing principles should be directed to the organization’s leader or the business support office.

03. Basic Duties of Members 3.1 Basic Ethics of members ① All members of the company shall perform their duties based on the principles of good faith and sincerity, and take responsibility for the outcomes.
② Members of the company must clearly understand their roles and diligently comply with the code of ethics and related regulations.
③ Members of the company must promptly report to the company if they violate or are pressured to violate the code of ethics themselves or by others.

3.2 Prohibition of conflict of interest activities ① Members of the company must prioritize the company’s interests when their personal interests conflict with those of the company and avoid situations that may be perceived as a conflict of interest.
② Members of the company must immediately report any actual or suspected conflicts of interest to the company and adhere to the decisions made regarding the situation.

<Examples of conflict of interest activities and situations>
a. Member of the company engaging in contracts or transactions with the company, either directly or through a third party.
b. Member of the company having significant financial interests or rights and obligations, directly or indirectly, with the company’s competitors or business partners.
c. Member of the company using company assets or information for personal gain.
d. Member of company using their position to exert undue influence on subcontractors or distributors, such as through employment requests or providing conveniences.
e. Member of the company engaging into side jobs that require significant effort to the extent that it leads to neglect of duties, unauthorized absences, or leaving the workplace without permission.
f. Employee acquiring shares in non-publicly traded subcontractors of distributors without reporting to the company, to an extent that may raise suspicions of a conflict of interest.

3.3 Prohibition of Receiving and Giving Gifts ① Employees must conduct all business activities transparently. Therefore, employees must not give or receive money, gifts, or entertainment to or from business partners or stakeholders, regardless of the business relevance or purpose.
② If employees receive money or other items against their will, they must return them immediately or report them to the company.

However, meals or small gifts that are within the limits recognized by relevant laws and social norms for maintaining a healthy cooperative relationship may be exchanged.

04. Protection of Company Assets 4.1 Protection of Physical Assets ① Employees must not use the company’s property for personal purposes or transfer or lend it to third parties without approval.
② The company’s budget must be used appropriately for its intended purposes and recorded based on facts according to accounting standards and procedures.
③ If there is a situation that could lead to the loss of company assets, employees must report it to the company immediately and take measures to prevent the loss.

4.2 Protection of Intellectual Property ① Employees must not disclose the company’s internal management information to external parties without prior approval.
② Employees must not illegally provide customer information to third parties or engage in unethical behavior that harms customer interests.
③ Employees must actively protect the company’s intellectual property rights, including patents, trademarks, and copyrights.
④ Confidential information of the company must kept secure according to relevant regulations, and any external disclosure of company information must follow established procedures and receive prior approval.
⑤ The intellectual property rights of third parties, including partners and customers, must be equally protected, and the use of illegal software is strictly prohibited.

05. Compliance with laws and company management policies 5.1 Basic Ethics of Employees ① All business activities must be conducted in compliance with all relevant laws and regulations.
② All transactions must adhere to fair trade laws and related company policies, and must be conducted fairly according to the principles of free competition.
③ Accounting information must be recorded based on facts in accordance with relevant laws, corporate accounting standards, and company policies, and must not be manipulated or falsely reported.
④ Disclosure of management information to external stakeholders must be transparent and fair, in compliance with relevant laws and company policies.
⑤ Do not engage in or instruct others to engage in activities that distort management information, such as false reporting (concealment, exaggeration, understatement, delayed reporting).
⑥ Ensure that the quality and safety management of products meet relevant regulations and customer requirements, and accurately disclose the performance and risks of the products.
⑦ Comply with domestic and international laws and international agreements related to safety, health, and the environment, and actively participate in creating a safe working environment and environmental protection activities.
⑧ Do not offer or promise to offer improper solicitations, money, or valuables to public officials or others performing official duties, in accordance with laws prohibiting improper solicitations and the acceptance of money and valuables.
⑨ Comply with anti-corruption laws related to international commerce, such as the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.

06. Business Handling Procedures 6.1 Responsible Organization ① The organization responsible for the operation of the Code of Ethics and the Principles of Ethical Conduct for employees is the Business Support Office.
② The aforementioned Ethical Management Department shall respond to inquiries from employees, provide guidance and education to employees, and take appropriate disciplinary action against employees who violate the code.

6.2 Protection of Whistleblowers ① Employees who become aware of violations of the Code of Ethics and Principles of Ethical Conduct must immediately report them to their departmental leader or the Ethical Management Department.
② The company shall not subject whistleblowers to any disadvantages in their employment status or discriminatory treatment in their working conditions due to legitimate reporting, statements, or submission of related materials.
③ Individuals who cooperate in the investigation by providing statements or materials during the verification process of the report shall be protected equally as whistleblowers.
④ If a whistleblower faces any disadvantages due to reporting, they can request protective measures such as correction of the issue or transfer to another department from the Ethical Management Department. The Ethical Management Department, upon verifying the facts, must take appropriate measures, including sanctions against those involved and establishing and implementing measures to prevent recurrence.
⑤ Investigators must maintain confidentiality to ensure that the identity of the whistleblower and the contents of the report are not disclosed against the whistleblower's will.
⑥ Individuals who violate the above whistleblower protection regulations shall be subject to action in accordance with relevant regulations, including punitive measures for retaliation, disclosure of the whistleblower's identity or report details, or attempts to identify the whistleblower or orders to do so.

6.3 Principles for Investigators to Protect Whistleblowers Investigators must prioritize the protection of whistleblowers while conducting investigations and must adhere to the following principles:
a. Investigators must not disclose any information or content related to the investigation without the consent of the whistleblower.
b. All investigation-related materials must be accessed only by authorized personnel and stored securely. Paper documents received by mail, fax, etc., must be kept in a separate secure location.
c. When sharing information is necessary for the investigation and processing, it may be provided to relevant departments within the scope of the investigation and processing.

6.4 Consultation and Reporting Channels Inquiries, consultations, and reports regarding the Code of Ethics and Principles of Ethical Conduct can be directed to the following channels. Reports can be made via email, phone, mail, or in person, regardless of the format.

Email : she9606@skc.kr
Phone : 010-9606-8957
Address : (03142) SK Leaveo HR team, Twin Tower, 50 Jongro 1-gil, Jongro-gu, Seoul, Republic of Korea

SK leaveo Privacy Policy covers as follows.
'SK leaveo Co., Ltd. (hereinafter referred to as "the Company") considers customer's personal information important and complies with the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc. The Company hereby states the purpose and method on how the provided personal information is used, as well as the measures taken in order to protect customer's personal information through this Privacy Policy. Should there be any amendments to the Privacy Policy, the Company will notify to its customers through the website's Notices (or individual announcement).
※ This Policy becomes effective on May 31, 2024.

1. Personal information items that Company collects The Company collects personal information as listed below for e-mail consultation, application for IR meeting related to investment information, etc.
* Collected items: personal information such as name, e-mail address, telephone number, mobile phone number, name of organization (company name), department, position, etc.
* How they are collected: through website (information center, investment information, etc.)

2. Purpose of collection and use of personal information The Company uses the collected personal information for the purpose stated as below.
* To provide consultation services to users: For quick and smooth consulting to facilitate business with customers and confirm IR meeting requests
- Membership management : For user identification
- Others: For consultation and recruitment

3. Period of retention and use of personal information In principle, personal information shall be destroyed immediately after the purposes of colleting and using such information are achieved. However, the following information shall be retained for a specified period of time as per reasons stated below.
* Retained items: information collected during customer service, application for IR meeting, etc. (personal information such as name, e-mail address, telephone number, mobile phone number, name of organization (company name), department, position, etc.)
- Period of retention: Two (2) years

4. Procedure and method of destroying personal information In principle, the Company destroys personal information immediately after the purpose of collection and use of personal information has been achieved. The personal information is destroyed as follows.
* Procedure
Once the purpose has been achieved, information entered by members during membership registration shall be transferred to a separate DB (or a separate file, in case of written document) and shall be destroyed after being retained for a certain period of time (refer to the period of retention and use) in accordance with the Company's internal policies and other relevant laws and regulations. The personal information transferred to a separate DB shall not be used for any purpose other than the specified purpose of retention, unless otherwise prescribed by the law.
* Method
- Personal Information stored in the form of electronic file shall be destroyed by a technical method which makes them irrecoverable and
- Any other records, print-outs, documents or any other recording media will be shredded or incinerated.

5. Provision of personal information In principle, the Company shall not disclose user's personal information to third parties. However, following cases shall be an exception.
- In case of prior consent from users
- When an investigating authority asks under the regulations of the law or according to procedures and methods specified in the law for the purpose of investigation

6. Entrusting the collected personal information The Company shall not entrust customer's personal information to third parties without prior consent. Should such a need arisen in the future, the Company shall notify the customers of the commissioned agency and their task, and if necessary, obtain prior consent.

7. Rights of users and their legal representatives and exercise of rights Users and their legal representatives may request the access, correction and deletion of the registered information of themselves or children under the age of 14.
(However, correction during the recruitment process is not accepted.)
To access and correct the personal information of the user or children under the age of 14, click "Edit Personal Information" (or "Edit Membership Information"). To terminate the membership (consent withdrawal), click "Terminate Membership". Browsing, corrections, or termination shall be available after going through the identification process. Should you choose to contact us in writing or via phone or email, our privacy manager shall take the appropriate measures immediately.
In the event of a request of correction of errors in personal information, the relevant information shall not be used or provided until the correction is made. In addition, in case of provision of incorrect personal information to a third party, the Company will notify the third party of the results of the correction immediately so that the correction can be made. For personal information terminated or removed at the request of users or their legal representatives, the Company shall handle the information in accordance with the period of retention and use of personal information and shall not allow it to be read or used for other purposes.

8. Refusal of installation and operation of automatic personal information collecting devices Company uses cookies to keep track of users visit and information. A "cookie" is a small amount of data sent from a Web server to users' browser and stored on their each computer's hard drive. The Company uses cookies for the following purposes.
* Purpose of using cookies
For target marketing and personally customized services offered by analyzing access frequency or visit time of members and non-members; to identify user taste and interest areas; to track traces; as well as to understand the participation levels and visitor frequency during various events, etc. You can choose to install or uninstall cookies. You can control and manage the cookies in your browsers choosing to accept all, warn before accepting, or none of your incoming cookies.
* How to set cookies
For instance, to refuse cookie setting, you can control and manage the cookies in your browsers choosing to accept all, warn before accepting, or none of your incoming cookies. Guidance for Internet Explorer : At the top of browser, click "Tools" > "Internet Options" > "Privacy"
Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

9. Customer service regarding personal information The Company has designated a responsible department and privacy manager as below in order to protect customer's privacy and to handle any related complaints.

[Customer service]
Department: HR Department
Tel: 02-3787-1234
E-mail: she9606@skc.kr

[Privacy manager]
Person in charge: Hang-Bin, Im
Privacy Protection Representative : Ha-Eun, Shin
Tel: 02-3787-1234
E-mail: she9606@skc.kr

The Company shall provide users will a prompt and satisfactory reply.
Please contact the relevant wupervisory authority listed below if you need to report on other personal information infringement issues or to seek consultation.

1. Personal Information Infringement Report Center : 118 without area code (http://privacy.kisa.or.kr)
2. Personal Information Dispute Mediation Committee: 118 without area code (http://privacy.kisa.or.kr)
3. Cyber Crime Investigation Division of Prosecution Service: +82-2-3480-3571, cybercid@spo.go.kr (http://cybercid.spo.go.kr)
4. Cyber Terror Response Center of Korean National Police Agency : 1566-0112 (http://www.netan.go.kr)