Anti-Corruption and Bribery Policy

Anti-Corruption and Bribery Policy

Woori Financial Group has established and implemented the "Anti-Corruption and Bribery Policy" targeting all employees, including contract workers, as well as related parties such as collaborative and transaction partners, to maintain a clean and ethical corporate culture. The Anti-Corruption and Bribery Policy is based on Woori Financial Group's Code of Ethics and Group Internal Control Policy. It is specifically applied through employee codes of conduct and compliance manuals for global anti-corruption laws within the group.

1. Fair Business Practices   


- We strive to treat stakeholders such as customers, shareholders, employees, partner companies fairly and work together for mutual development.

- We lead by example to establish a fair financial order by complying with regulations and market principles, rejecting any misconduct (such as monopolistic or anti-competitive behavior) that hinders sound corporate activities, and guaranteeing customers' diverse choices.

- We provide necessary information to shareholders fairly and in a timely manner according to relevant regulations, and do not selectively provide undisclosed information to specific shareholders.

- We create a work environment that avoids unfair treatment and allows employees to be evaluated fairly and demonstrate their abilities.

- We ensure that transactions with partner companies are conducted based on objective standards and procedures.

2. Prohibition of Unfair Trading Practices  


- We do not engage in unfair trading practices such as using or disclosing internal undisclosed information acquired in the course of business, except for those with legitimate rights to access such information.

- We do not spread false information or engage in acts that promote stock price manipulation by causing misunderstandings for the purpose of gaining unfair profits.

- We do not disrupt sound financial order by unfairly increasing customers' financial costs or infringing upon their rights.

- We accurately record and manage accounting data in accordance with accounting principles to maintain accuracy and reliability.

- We do not abuse our dominant position in transactions with customers and stakeholders, and do not engage in unfair business practices through false or exaggerated labeling and advertising.

3. Prohibition of Conflicts of Interest


- We make efforts to avoid situations that create conflicts of interest between the company and the customers. In cases where conflicts of interest arise, we prioritize the interests of the company or the customers, or we refrain from performing the related tasks. - We do not use company assets, intellectual property rights, trade secrets, or other intangible assets for purposes other than business objectives. - We do not engage in other profit-making activities or work in other professions without the company's permission.

- After resignation, we take appropriate follow-up measures such as returning work-related materials and do not engage in actions that harm the interests of the company or customers.

4. Prohibition of Gifts and Entertainment


- We do not accept gifts, entertainment, or other benefits from customers, employees of affiliated companies, employees of partner companies, nor make unreasonable requests. We also do not provide benefits to stakeholders.

- We comply with various domestic and international laws and agreements, and do not provide gifts, entertainment, travel expenses, employment, or engage in illicit solicitation to public officials. 

- We do not engage in monetary transactions, lending, intermediation, guarantees, or collateral provision, directly or indirectly, regardless of whether payment is made to partner companies or employees.

- We do not notify stakeholders of ceremonies for the purpose of providing money for congratulations and condolences, nor do we give or receive excessive money for congratulations and condolences between employees.

5. Prohibition of Bribery


- We prohibit all forms of bribery and customary fees related to contract amounts, including rebates.

6. Clean Contracts


- We do not engage in unfair practices such as demanding gifts or entertainment, coercing transactions, imposing unfair trade conditions, or transferring costs based on our dominant position when dealing with collaborating partners.

- We perform our duties in a fair and transparent manner throughout the process of public notices, bidding, evaluation, contract conclusion, and execution, in accordance with relevant laws and regulations.

- We do not incur expenses for overseas business trips or training that potential contracting parties bear before the contract is executed. If there are expenses for overseas business trips or training that are incurred as external costs, we consult with the compliance officer in advance.

- We include clean contract provisions in contracts with external companies or receive a commitment to comply with clean contract execution.


*  Example of Clean Contract Clause
 

Article XX (Clean Contract, etc.)

① The "Company" shall not provide, directly or indirectly, gifts, entertainment, monetary transactions (including intermediation), or any other unfair benefits to employees of "Woori Financial Group" involved in the contract execution and implementation process.

② Even if the "Company" faces contract termination, cancellation, or any other disadvantageous measures due to a violation of Clause 1, it shall not raise any objections against "Woori Financial Group."

③ The "Company" acknowledges and agrees to comply with the main contents of the Group’s Code of Ethics and Woori Financial Holdings' Employee Code of Conduct, which are publicly disclosed on the Woori Financial Group website, and will make the best efforts not to violate the main contents.

7. Anti-Corruption Contract


- When entering into a contract with an external company that is related to the duties of public officials*, the contract shall include an anti-corruption clause**.

* Public officials: (national or local) government officials, employees of state-owned enterprises and public institutions, etc.

** Example of an anti-corruption clause
 

Article XX (Anti-Corruption)

① The "Company" shall comply with all laws and Woori Financial Group's global anti-corruption compliance manual and ensure that third parties acting on behalf of the business in the course of the relationship also comply with them.

② Employees, actual owners, subcontractors, and other agents of the "Company" shall not propose, promise, or approve the payment of money with the intention of providing improper benefits to relevant public officials in the performance of their service duties.

③ The "Company" has no history of bribery, money laundering, corrupt practices, or sanctions by the government or other institutions. If any violations occur in the future, the "Company" shall promptly notify "Woori Financial Group."

④ Even if the "Company" violates the aforementioned provisions, it shall not raise objections against measures such as bidding restrictions, contract termination, or suspension of transactions, and shall promptly compensate "Woori Financial Group" for any damages incurred as a result.

8. Donation-related


- We shall not engage in any actions that violate political neutrality by expressing support for or providing assistance to specific political parties or candidates, and political or charitable donations shall be executed in compliance with relevant laws and regulations.