SMART LIFE IN COMMAX

Making the value of life and safety professional smart home industry. COMMAX

HELP-LINE SYSTEM

Subjects of reporting

Any irrationalities, corruptions, and demeaning behaviors of executives and employees related with their jobs, and any behaviors becoming subject of social criticism and damaging company image

  • Prohibit reporter’s identity from being disclosed (provided that, consent of that reporter required, as necessary)
  • Behavior of making deal with company in the name of interested parties (him/herself, family member, or relatives)
  • Co-investment, co-acquisition of properties, and financial lending behaviors with interested parties (colleagues, customers, and suppliers), guarantee of future, repayment or warranty of debts
  • Behavior of leaking or using company assets illegally
  • Behavior of seeking personal interest using closed information of the company
  • Behavior of manipulating documents and figures
  • Unreasonable management causing loss of the company, intentional neglect of executives and employees, neglect of supervision, arrogation and unfair transaction
  • Behavior of disclosing business secrets and information on the customers
  • Other Behaviors causing injury to personal dignity and honor of the company

Behaviors of unfair profit related with job, such as bribery, embezzlement, and malpractice

Illegal or unreasonable order of senor staff regarding jobs

Behavior of damaging company image by distributing false facts such as canards, or behavior of hindering organizational atmosphere by slandering specific executive or employee

Illegal, unreasonable business handling of executive or employee

Behaviors violating Fair Trade Act

  • Unfair collaborative behavior and unfair support
  • Unfair transaction
  • Behavior of violating Act on the Clause
  • Behavior of unfair advisement
  • Other behaviors violating laws on fair competition

Any opinions on improvement of inefficient working process by management and senior staffs, false financial report, and unfair, discriminative activities

How to report

Whistle-blowing can be selected among following methods at convenience of the reporter.

  • Home page
    Access to Ethic Management website of company home page to report
  • E-mail
    Report by email to ethics@COMMAX.co.kr
  • Report by mail
    Committee of Ethical Management of COMMAX Co. Ltd., Doonchondaero 494, Jungwongu, Seongnam, Gyeonggidom South Korea
    ※ Document incoming & outgoing system is available in the company
  • Visit or face-to-face talk with member of Ethical Management
    report by visit or face-to-face talk with member of Ethical Management

Reward to the reporter

Subjects

  • It includes people involved in transactions or outsiders having connection with executives and employees, or reported issues.
  • The issues being reported subject to reward are limited to followings:
    • - Report on behavior of giving and taking money or goods by other executives and employees
    • - Report on the issues affecting to increase or decrease of profit
  • Reward shall be given to first reporter, if multiple reports being filed for same issue.

Payment of reward

  • The general director of ethics practice organization receives it and deliver in such way that secrecy being secured and recipient wants.
  • Personal information on the reporter, a real recipient of the reward, shall not be recorded on the accounting book.

Exemptions

The reward shall not be paid for following cases:

  • Where the report has been proved as not true, or it is difficult to verify whether the report is fact or not, due to lack of evidence
  • Where it has been reported already, or investigation is under progress by audit team, related department, or external authority who has recognized it already, along with punishment or disciplinary measure being taken
  • Where it has been reported by mass media
  • Where the immoral behaviors reported are have nothing to do with business of the company
  • Any matters regarding simple improvement of work process
  • Where the employee of audit team or ethnic management team has report it
  • Any other cases where reward is considered as inappropriate

Calculating reward

  • The amount of reward for report on taking money and goods shall be 5 times more than amount taken, provided that additional amount identified during investigation shall be excluded.
  • The amount of reward shall be calculated as following, if there is effect of increase/decrease of company profit.
    • - Effective amount of less than 100 million Won: 5% of the effective amount
    • - 100 million ~ 500 million Won: 5 million + 5% of the amount exceeding 100 million Won
    • - 500 million ~ billion Won: 17 million + 2% of the amount exceeding 500 million Won
    • - More than billion Won: 27 million + 1% of the amount exceeding billion Won
  • With respect to Clause 3.2.2. above, it shall be entire of appropriate amount, while calculating it as amount being occurred for first 1 year for long-term effect.
  • With respect to Clause 3.2.1, 3.2.2. above, the amount of reward shall be less than 50 million Won, and is shall be paid after permission of CEO has been granted.
  • 3.2.5. In a case where the reason of reward duplicates, larger amount shall be basis.

Protecting reporter

Protection policy

  • Secrecy of reporter should be guaranteed in any way, and there should be no penalty resulted from matters reported. However, the report aiming to slander or defame others shall be exempted.
  • Reported matters should be managed strictly as confidential, making sure reporting system being protected by means of safe and reliable security scheme.
  • The person in charge of accepting report should pledge to keep secrecy of the reports.
  • For the executives and employees of the company who were involved in corruption and irregularity but report it voluntarily shall be treated reasonably through sufficient extenuation.

Person subject to protection

Protection of reporter should be made with regard to accurate evidences submitted based on the fact in principle. Also, the information on reporter and people concerned should be protected thoroughly, and the subjects are as followings. Provided that, anyone whose corruptions have been revealed already or audit is under progress should be exempted.

  • Reporter inside/outside the company
  • Voluntary reporter

Protected matters

Password

  • Prohibit reporter’s identity from being disclosed (provided that, consent of that reporter required, as necessary)
  • Prohibit behavior of searching for the reporter: It is prohibited reported personnel or department of the reported personnel from taking measures to find out who has reported.
  • Prohibit disclosing of evidences or information submitted by reporter
  • Suspected personnel, suspected organization, or sectors

Guarantee of status and treatment

  • Prohibit imposing penalty with respect to status of reporter or discriminating
  • Grand benefit with respect to contribution of the reporter, such as increase of company profit, as well as prohibition of penalty with respect to promotion and transference
  • Head of department of reporter is expected to consider request of that reporter as top priority

Request for the guarantee of status

  • The reporter can request measures for guaranteeing status to ethics practice organization, if penalty expected to be imposed to that reporter.
  • The general director of ethics practice organization demands measures for guaranteeing status or recommendations regarding it to head of appropriate department upon investigation.
  • In a case where identity of reporter is disclosed on the contrary of his/her intention, ethics practice organization investigates path of disclosure to submit who disclosed it to personnel committee.

Exemption from responsibility

  • Voluntary reporter could be released from responsibility, considering degree of corruption at disciplinary measure, working attitude at normal time, and degree of introspection.
  • Voluntary reporter who notified behavior of taking money and goods shall be exempted from responsibility in principle.
  • Even if one does not report voluntarily but actively cooperate with investigation, in such way of voluntary report and confession, they could be released from responsibility, considering degree of corruption at disciplinary measure, working attitude at normal time, and degree of introspection.

Dealing procedure

Accepting report and verifying fact

  • Department of accepting reports shall be ethics practice organization.
  • Ethics practice organization verifies if those facts are true within shortest term as possible as it can.
  • Ethics practice organization notifies to executive departments immediately for violation of Fair Trade Act.

Reporting and auditing

  • Any matters reported and whether they are true or not should be reported to executive auditor.
  • Any matters reported shall be reported to executive auditor considering degree of corruption to determine whether audit should be conducted or not, and could be transferred to appropriate department, as necessary.

Processing result and notifying

  • Request for measures resulting from audit shall be based on the regulations on audit.
  • Result of audit should be notified to the reporter within 60 days, transferring reasons in advance if it is difficult to notify within such period of time.

Self-termination

  • Closely examine reported matters and self-terminate the case if degree is insignificant and there would be no actual benefit from audit.
  • The reason of self-termination should be notified to the reporter as well.

Complementary rules

Penalty

The general director of ethics practice organization requests to have person violated regulations, disclosed information intentionally, or delayed audit being submitted to personnel committee.

Faithful fulfillment

In a case where there are articles stipulated on other regulations or rules separately with regard to report on, or reporter of immorality, illegal actions, this rules shall takes precedence.