SK on tech plus Co., Ltd.(hereinafter “the Company”), basing on SKMS as the foundation for their business management, shall create value for the Company’s customers, members, shareholders, the society, and other various interested parties, thereby playing a major role in the social and economic development and, furthermore, contributing to the well-being of all humans.
To this end, the Code of Ethics (hereinafter this“Code”) has been established to serve as the criteria for all decision-making and actions in business management.

BASIC ETHICAL STANDARDS OF MEMBERS

“As Members of the Company, we take pride in ourselves and diligently perform our duties in our position with an understanding that we are representing the Company.”

• • We perform our duties in a fair and transparent manner by drawing a sharp line between public and private matters.
• • We ensure that all members of the Company have respect for one another and develop with a sense of achievement in their work.

ATTITUDE TOWARDS CUSTOMERS

“We gain our customers’ trust by ensuring consistent customer satisfaction, and ultimately achieve development along with our customers.”

• • We make continuous effort to provide our customers with the necessary products and services.
• • We respect our customers’ various opinions, and apply their opinion to the Company’s business management.
• • We protect our customers’information and property in accordance with the relevant laws/regulations and the Company regulations.

RESPONSIBILITY FOR SHAREHOLDERS

“We increase our corporate value so as to create shareholder value, while enhancing the level of both transparency and efficient management toward this end.”

• • We maximize our corporate value through efficient management basing on continuous innovation and share the results with our shareholders.
• • We practice independent, transparent and responsible management centered on our board of directors and respect righteous demands and suggestions from our shareholders.
• • We draw up the management documents according to the various laws/regulations and standards and make a public announcement on them to protect shareholders’ interests in accordance with the laws/regulations.

RELATIONSHIP WITH BUSINESS PARTNERS

“We pursue mutual development and cooperation with our business partners and compete fairly with our competitors.”

• • We provide fair trade opportunities to our business partners and will not conduct the unfair practice by using our dominant position. We pursue mutual benefits and development.
• • We compete in good faith with our competitors based on mutual respect.

OUR ROLE IN THE COMMUNITY

“We not only contribute to the economic development but also grow together with our society by engaging in social activities to create social values.”

• • We strive for the happiness of society as a whole by actively pursuing social values.
• • We build trust in our community, and develop and grow together with our community through the pursuit of disaster-free and eco-friendly management.
• • We give fair trading opportunities to partner companies, do not engage in unfair practices based on superior bargaining position, and seek mutual benefits and common development.
• • We comply with the local laws and respect the traditions and cultures of the communities in which we engage in business.

SCOPE OF APPLCAITION

This Code applies to all Members (including contract, dispatched employee) of the Company and its affiliates (foreign or domestic).
For those affiliates whose shares are partially owned by the Company and for those business partners who are in business or contractual relationship with the Company, we recommend that they comply with this Code of the Company.

Addenda (September 1, 2023)

1. 1. This Code shall come into effect on September 1, 2023.
2. 2. A Separate “Code of Ethics Guidelines”has been established so that members of the Company may properly interpret this Code and act upon it.

1.Guiding Principles

1-1 Scope of Application

The Code of Ethics Guidelines (hereinafter these “Guidelines”) apply to all members (including contract, dispatched employee) of SK on tech plus Co., Ltd.(hereinafter the “Company”) and the Company’s affiliates (foreign or domestic).
For those affiliates whose shares are partially owned by the Company and for those business partners who are in business or contractual relationship with the Company, we recommend them to comply with the Company’s Code of Ethics.

1-2 Purpose

These Guidelines aim to provide the criteria for decision making and action regarding ethical dilemmas, which may arise in the course of work, to assist the Members to understand and properly act upon the Company’s Code of Ethics.

1-3 Principles of ethical decision-making and conduct

All Members shall act in accordance with the Code of Ethics and these Guidelines in case of an ethical dilemma faced in the course of work.
In case these Guidelines lack clear guidance for a particular case, Members shall act in accordance with the following principles of decision-making, and if one is uncertain of his or her judgment, such Member shall seek the advice of his or her leader or that of the ethics department for correct interpretation and shall act in accordance with such interpretation.

• • Legitimacy: Can the action be interpreted as a violation of laws/regulations or the Company regulations?
• • Transparency: Can the process of decision-making and outcome be disclosed?
• • Rationality: Would other Members make the same decision under the same circumstances?

2.Responsibility of the Members

2-1 Diligent execution of duties

Members must be fully aware of their rights and responsibilities and work in good faith.

2-2 Resolving conflict of interest

1) Members must do their best to prevent the circumstances that may violate their duty of loyalty to the Company due to the conflict of interest with the Company in relation to the performance of their duties.

2) The following circumstances shall be considered as conflict of interest. Members shall note that since this is not an exhaustive list of all conflict of interest cases, strict judgement and application of these Guidelines for actual cases are required.

• • Prohibited Actions
  1. - Using the Company’s assets or information to obtain personal gains.
  2. - Abusing one’s position in the Company as means to exert improper influence on the Company’s business partners such as solicitation of any personal management, request for provision of various advantages, etc.
  3. - Engaging in secondary jobs to such extent that it impedes one’s diligent execution of duties.


• • Cases where one must disclose conflict of interest to his/her leader and obtain the Company’s approval in accordance with the relevant Company procedures such as the arbitrary decision regulation
  1. - One directly or indirectly enters into a contract with, or engages in business transactions with, the Company.
  2. - One owns shares of, or engages in management activities of, the Company’s business partner, which can be put under his or her direct or indirect influence through business relations.

2-3 Appropriate use and protection of the Company’s assets and information

Members must safeguard and properly use the Company’s tangible and intangible assets.

1) One shall not use the Company’s assets or transfer/lease the Company’s assets to a third party for personal gains without the Company’s authorization or approval.

2) One shall not use the Company’s budget for personal use. The Company’s budget must be used only for the purpose set by the Company, and such use must be accurately recorded in the Company’s accounting books.

3) One shall not exploit the Company’s computers, Internet, e-mail, phone, fax, etc. for personal use.

4) One shall strictly protect the Company’s intellectual property rights, including but not limited to patents, trade secrets, trademarks, copyrights, and other proprietary information. The intellectual property rights of third parties shall also receive the same protection, and in particular, illegal software shall not be used.

5) The Company’s proprietary information, including information related to business or technology, shall be strictly managed in accordance with the related Company regulations. The decision of whether or not to disclose information assets and the scope of such disclosure shall be determined according to the relevant laws/regulations and the Company regulations and policy, and the same applies to the interviews with the media.

6) One shall not trade stocks based on the confidential information acquired during the course of work or disclose it to third parties.
Especially in cases such as large-scale supply contracts or facility purchase contracts, taking private profits or avoiding losses using important undisclosed information should be strictly prohibited.

7) Information necessary in the course of performing duties shall be obtained by legitimate means.

2-4 Offer or receipt of gifts, hospitality, etc.

1) Members shall conduct all business activities in a fair and transparent manner. No one shall offer any gifts, hospitality, etc. to any interested parties, regardless of such offer’s connection to his/her duties or the motive for such offer.

2) Members shall not accept any gifts, hospitality, etc. from the Company’s business partners or interested parties, regardless of such acceptance’s connection to his/her duties or the motive for such acceptance.

3) Any forms of offer or receipt of gifts, hospitality, etc., whether delivered directly or indirectly, are prohibited, except such offer or receipt of reasonable level of hospitalities within the scope generally permitted under the relevant laws/regulations and in the context of social norms to maintain healthy and friendly relationship. Each department or division in the Company may establish and enforce more detailed guidelines for the foregoing in accordance with the relevant laws/regulations.

2-5 Mutual respect between the Members of the Company

Members shall treat each other with respect and maintain propriety and dignity as SK members.

No Member shall be discriminated against for the reason of gender, educational background, birthplace, marital status, race, nationality, religion, etc.

Members shall not engage in any acts (i.e. sexual harassment, verbal abuse, etc.) that violate a person’s human rights and disrupts a healthy work environment.

3.Compliance with Laws/Regulations and Business Policy

Members shall have clear understanding of domestic and foreign laws related to the Company’s business activities as well as the Company’s policy and other regulations and shall perform their duties accordingly.

3-1 Quality management and the protection of customer information

1) The Company has responsibility to meet the customers’ demands with respect to quality, reliability and safety of its products and to supply products satisfying standards required by the relevant laws/regulations and contracts, and, in order to achieve this, Members shall comply with all requirements set by the Company’s quality management system.

2) Members shall provide accurate information regarding a product’s functions and risks to the customers, and shall not make any false or exaggerated advertisements.

3) Members whose duties involve handling of customers’ personal information shall establish procedures and guidelines to protect such information in accordance with the relevant laws/regulations and the Company policy, and shall safeguard such personal information accordingly.

3-2 Preparation and disclosure of management information

1) Accounting practice shall strictly adhere to the generally accepted accounting principles, related laws/regulations and the Company regulations to accurately record and maintain the accounting information. Accounting information of the Company shall not be distorted or concealed in any way.

2) All management information including financial information shall accurately reflect all relevant facts and details of business transactions to support the management in making business decisions.

3) The disclosure of management information to the external interested parties shall be made in a fair and transparent manner according to the relevant laws/regulations and the Company regulations.

4) Members shall not commit, or direct others to commit, any acts to distort management information (e.g. by falsifying, concealing, exaggerating, withholding, or delaying reports).

3-3 Fair trade and competition

1) Members shall have clear understanding of, and comply with, the laws related to fair trade and competition as well as the Company’s fair trade voluntary compliance management regulation.

2) For matters that may be interpreted as violation of fair trade and competitions laws, Members must seek prior consultation of the legal team or business compliance team of the Company to handle such matters and Members shall not make any arbitrary decisions with regards to such matters.

3-4 Policies on safety, health, and environment

1) Members shall observe domestic and foreign laws/regulations and international treaties related to safety, health, and environment. Members shall strive to continuously make improvements in these domains.

2) Members shall adhere to safety regulations and foster a safe working environment.

3) Members shall acknowledge the importance of environmental issues and actively seek to protect the environment.

3-5 Compliance with international anti-corruption conventions and related domestic and foreign laws

1) Members shall not improperly solicit any public officials in the course of their works in violation of the Improper Solicitation and Graft Act.

2) Members shall not offer, promise to offer, or express any intention to offer any financial or other advantages to any public officials in violation of the Improper Solicitation and Graft Act.

3) Members shall comply with international anti-corruption (including bribery and money laundering) conventions and domestic and foreign laws including OECD Anti-Bribery Convention, UN Convention against Corruption, U.S. Foreign Corrupt Practices Act, UK Bribery Act, and Act on Combating Bribery of Foreign Public Officials in International Business Transactions of Korea.

4) For matters that may be interpreted as violation of anti-corruption laws, Members must seek prior consultation of the Comliance team, legal team or ethics management department of the Company, and Members shall not make any arbitrary decisions with regards to such matters.

3-6 Policies on donation and sponsorship

The Company may make donations or offer sponsorships only to the extent permitted under the relevant laws/regulations and in the context of social norms and by obtaining official approval of the Company pursuant to the established Company procedures. In any event, donations and contributions for any political purposes are strictly prohibited.

4. Execution of these Guidelines

4-1 Responsibility

1) All Members are obligated to comply with the Code of Ethics and these Guidelines, and shall seek and follow interpretation of his/her leader or ethics management department of the Company for any matters that are questionable.

2) Leaders shall ensure that their members and other interested parties related to their work have a sufficient understanding of the Company’s Code of Ethics and these Guidelines. Also, leaders shall diligently and responsibly observe the Code of Ethics and these Guidelines in their decision making and actions at all times to set standards for the conducts of other Members.

4-2 Reporting non-compliance and protection of whistleblower

1) Any Member who becomes aware of a violation of the Code of Ethics or these Guidelines shall immediately report such incident to his/her leader or to the ethics management department of the Company so that the Company can promptly make appropriate resolutions to protect itself and the Members from consequences of such violation.

2) Members shall not receive any disadvantage in any manner for reporting acts of violation or non-compliance.

3) “The Procedure for Ethics Counselling and the Management of Non-Compliance Report”shall govern the process of non-complicance or violation reports and any inquiries related to this matter can be made via the following channels.

• • Webpage: http://ethics.sk.co.kr
• • Email : skme.ethics@sk.com
• • Mail : Management Supporting team (person in charge of Ethics Management), SK on tech plus Co., Ltd., 207, Seongyeon-myon, Seosan-si, Chungcheongnam-do, the Republic of Korea

Addenda (September 1, 2023)

1. Effective Date

These Guidelines shall come into force on September 1, 2023.

2. Punishment against non-compliance

Any violation of these Guidelines shall be treated in accordance with the Company regulations.

3. Interim measures

Any cases of non-compliance with these Guidelines including conflict of interest with the Company shall be reported to a senior officer or to the ethics department by October 31, 2023 and the Company shall not hold such Member responsible for his/her actions.

1. General Matters of of ethics counseling & report handling

1-1 Resolving questions regarding ethical matters

1) If executives and staff members have any question s about the interpretation or application of the C ode of E thics , Practice Guideline or FAQ , they shall ask them to the leader of the organization or the department in charge of ethical management or have counseling and follow the ir interpretation.

2) The leader of the organization shall re solve the matters asked by the executives and staff members under his/her control according to the standard s and policies of the Company. If it is difficult to re solve the matter s by himself/herself , the leader shall handle them through consultation with the department in charge of ethical management

3) The department in charge of ethical management shall conduct counselin g according to the procedures of “Ethics Counselingunseling.”

1-2 Reporting and handling of violations

1) An executive or a staff member who noticed violations of the Code of Ethics, Practice Guideline or FAQ shall report the case to the leader of the organizationor the department in charge of ethical management.

2) If the leader of the organnization receives a report about violations, he/she shall resolve it according to the standards and policies of the Company or through consultation with the department in charge of ethical management If the leader of the organization has solved the matter personally, it is necessary to inform the department in charge of ethical management of the result of the measures.

3) The department in charge of ethical management shall handle a reported matter according to the procedures of“Report Handling .”

1-3 Installation and operation of ethics counseling & report ing channel

1) The department in charge of ethical management shall operate the counseling & reporting channel to facilitate easy counseling and reporting of ethical management for interested parties and systematic handling of the matters.

2) The department in charge of ethical management shall operate the counseling & reporting channel to facilitate easy counseling and reporting of ethical management for interested parties and systematic handling of the matters.

• • Online at: Integrated online report channel of the Group , available 24/7(https://ethics.sk.co.kr/advice/report_kor.aspx)
• • E-mai : skme.ethics@sk.com ,available 24/7
• • Mail : Person in charge of ethical management of Audit Office SK On Co., Ltd. 51, Jong-ro, Jongno-gu, Seoul, Republic of Korea

2. Ethics Counseling

2-1 Processing the applications for counseling

1) Ethics counseling shall be offered for the following inquiries.

• • The Company’s standards and policies for ethical management
• • Interpretation of the Code of Ethics, Practice Guideline and FAQ
• • General knowledge regarding ethical management, etc.

2) Measures to be taken for simple customer complaints

• • Among the received matters, customer complaints shall be directed to the customer service department of the concerned business.
• • The customer service department shall take measures of the customer complaints and notify the department in charge of ethical management of the result of measures.

3) The contents of counseling shall be maintained and managed using a separate form.

2-2 Counseling

1) The department in charge of ethical management shall provide appropriate and consistent interpretation and guidelines for the matters of counseling according to the Code of Ethics , Practice Guideline , FAQ and the ethical management policies of the Company.

2) When it is necessary to ask counseling of the relevant department or when there is no established policy of the Company on the matters of counseling, it is required to establish policies of the Company through consultation with the related department and provide counseling.

2-3 Notification and follow-up management

1) The result of ethics counseling shall be notified to the counselee in an appropriate manner.

2) The department in charge of ethical management is required to prevent disclosure of the identification of the counselee or the contents of counseling against the will of the counselee.

3) The contents of counseling shall be maintained and managed using a separate form.

3. Report Handling

3-1 Acceptance of report

1) Reporting means providing information about violations of Code of Ethics, Practice Guideline or FAQ by executive or a staff member.

1. - Dereliction of duty, Conflict of interest, Inappropriate usage of the Company’s assets and information, Improper offer or receipt of gifts/ hospitability/etc., Violation of mutual respect between the members of the Company (discrimination, sexual harassment, verbal abuse, etc.), Distortion of management information, Violation of Fair trade and competition, Violation of policies on safety/ health/environment, Violation of Compliance, Violation of protecting personal information, and The company’s other policies and working principle etc.

2) For fact check, the department in charge of ethical management shall receive the report based on the principle of 5W1H and secure related evidentiary materials as many as possible.

3-2 Fact Verification

1) In principle, fact verification of a report shall be conducted only for a report submitted under the Informant(including whistle-blower)’s real name. However, fact verification can also be allowed to an anonymous report depending on circumstances in consideration of the character and materiality of the report.

2) The department in charge of ethical management shall conduct fact verification of the report.

3-3 The department in charge of ethical management shall conduct fact verification of the report.

1) If violations are confirmed to be true upon the investigation results , measures shall be taken against the violators (the violators (execuexecutivetive,,staff staff or aor a membermember partner companypartner company) under pertinent under pertinent Company regulations. Company regulations.

2) If it is confirmed that a report has been made for soley personal purposes including libel, slander and falsehood, appropriate measures shall be taken against the involved Informant(including whistle-blower) according to relevant Company regulations.

3) If no violation is found, the case shall be concluded by the department in charge of ethical management.

3-4 Reporting and follow-up actions

1) If any disciplinary measures are needed, the case shall be reported to the person who has the approval right for the matter.

2) The result of the measure shall be notified to the Informant(including whistle-blower) in an appropriate manner.

3) The result of the measure shall be concluded after registering it in the online report channel.

4. Informant(including whistle-blower) Protection Policy

4-1 Protection policies

1) An Informant(including whistle-blower) should not suffer from retaliatory action in any form by other executives or department to which he/she belongs for having reported a possible violation or or submitting related statements or materials.

• ① If an Informant(including whistle-blower) has received disadvantageous measures due to the report, he/she can request the department in charge of ethical management to rectify the disadvantages and take protective measures including transfer to another department.
• ② If there is a request for corrective action and protection from an Informant(including whistle-blower), the department in charge of ethical management shall take measures to minimize the disadvantages of the Informant(including whistle-blower) and establish and implement measures to prevent recurrence of such an incident including sanctions against the person involved.

2) It is required to keep the identity of the Informant(including whistle-blower) and the contents of the report confidential to prevent them from being revealed against the Informant(including whistle-blower)’s will.

3) A person who cooperates with the investigation by submitting statements or materials during the process of fact verification of the report shall be protected in the the same way as that of the Informant(including whistle-blower).

4) A report made for solely personal purposes including libel, slander and falsehood shall not be protected.

4-2 Sanctions and reduction & exemption

1) If a person violates the “Informant(including whistle-blower) protection policies,” measures shall be taken according to the Regulation.

• • A retaliatory action giving disadvantages to the Informant(including whistle-blower) reporting possible violation
• • Disclosure of identity of the Informant(including whistle-blower) or the contents of the report obtained officially or accidently
• • Tracking down the Informant(including whistle-blower) or instructing to track down the Informant(including whistle-blower)

2) If a person who was involved in an action violating the code of ethics, Practice Guideline or FAQ or an illegal action reports it voluntarily, sanctions against such an action can be reduced or exempted.