Employee Code of Conduct

The Employee Code of Conduct (“this Code”) Woori Financial Holdings

Chapter 1 General provisions

Article 1 (Purpose)

The purpose of this Code is to set forth the details including the specific standards of judgment required to encourage the employees of Woori Financial Holdings (“the Company”) to comply with Woori Financial Group’s Code of Ethics.

Article 2 (Scope of application)

This Code shall apply to all employees (“us,” “we,” “our,” “ours”) of the Company.

Chapter 2 Employees’ work ethics



§1 Basic attitude

Article 3 (Observance of the laws and regulations and the Company’s internal regulations)

① We shall acknowledge that our observance of the laws and regulations should be the basis of all the Company’s business activities; shall comply with the relevant laws and regulations and the Company’s internal regulations in carrying out business as employees; and shall not engage in, or have other employees engage in, any activity that may violate or contravene them. ② We shall comply with the laws prohibiting money laundering, carry out business as Company employees in accordance with the relevant regulations and procedures, and shall not engage in money laundering either directly or indirectly.

Article 4 (Trustworthiness and acting in good faith)

① We shall strive to foster a sound organizational culture in a way that ensures our customers’ trust in us, and shall perform all our assignments in good faith. ② We shall not engage in investment, speculation or borrowing beyond our financial capability.

Article 5 (Maintaining decency and dignity)

We shall always watch our language and behavior. We shall not allow ourselves to become the target of criticism by engaging in immoral acts such as drunk driving or visiting unsound commercial establishments. We shall not engage in any acts that may tarnish the Company’s image or demean our dignity as the Company’s employees.

Article 6 (Respect for mutual dignity, etc)

① We shall respect other employees’ privacy, refrain from unethical language and/or behavior, and strive to foster a mature organizational culture based on mutual trust and understanding. ② We shall strive for personal development and maximize the company’s business performance through smooth communication between ourselves.

Article 7 (Prohibition of discrimination and the formation of private groups)

We shall not provide favorable treatment of or discriminate against specific individuals or groups based on their social status, academic background or blood relationships in carrying out business as employees. We shall not form any private groups that may harm unity in the workplace or the Company’s development.

Article 8 (Prohibition of involvement in politics)

We shall not engage in any act including open expressions of support for a specific political party or candidate that may harm our political neutrality. We shall take care lest individual employees’ political views and/or activities should be mistaken for those of the Company or Woori Financial Group.

Article 9 (Prohibition of unfair instructions)

We shall not issue any unfair commands or instructions to other employees, or ask other employees to commit unjust acts. We shall not accept unfair instructions or requests made by other employees.

Article 10 (Prohibition of speculative acts)

We shall not engage in gambling, computer games, or stock investment or connect to obscene sites during our work hours. We shall not leave the workplace or our designated place or engage in private business during our work hours without obtaining the approval of our superiors.

Article 11 (Reporting violations; protection of whistleblowers)

① In the event that we detect or suspect an illegal or unjust act, we shall report it immediately according to the designated procedure and shall not cover up any wrongdoing.② We shall not disclose or trace the identity of a whistleblower or disadvantage or discriminate against him/her in any way. We shall not take advantage of the whistleblower system to tarnish another person’s honor or reputation or to serve our own personal interests.
 

§2 Prevention of conflicts of interest

Article 12 (Obligation to prevent conflicts of interest)

① We shall strive to prevent conflicts of interest involving the Company or customers in the business that we carry out as employees and to minimize the possibility of such conflicts.② Where it is difficult to minimize such a possibility as stated in the foregoing 1, we shall put the interests of the Company or customer first and shall not engage in such business

Article 13 (Non-engagement in commercial business or additional business)

We shall not engage in any commercial business or work on behalf of any employer other than the Company without obtaining the Company’s prior approval.

Article 14 (Matters to be observed concerning outside activities such as lectures/contributions, etc.)

In the event that we engage in an outside activity such as giving a special lecture or contributing an article to a publisher, etc., we shall consider the impact it could have on the Company and take care lest our personal view should be mistaken for the Company’s or the Company’s internal information should be disclosed.

Article 15 (Obligations surviving termination of employment contract)

Upon our retirement from the Company, we shall take adequate steps to return all the company’s property and not engage in any act that may harm the interests of the Company or its customers.
 

§3 Prohibition of unfair acts of trading

Article 16 (Prohibition of use of undisclosed important information, etc.)

We shall not seek our own or a third party’s benefit by using or disclosing non-public material information acquired in the course of carrying out the Company’s business as its employee, and shall not disclose such information to any unauthorized parties or allow them to access it in any way, other than to employees who have the right to know such information for the execution of the Company's business.

Article 17 (Prohibition of manipulation of securities prices)

We shall not engage in an acts related to the manipulation of securities prices including the distribution of false information to earn profits or mislead people.

Article 18 (Prohibition on disturbing fair trading practices)

① We shall not engage in any acts that may disturb the order of sound financial trade such as unfairly adding to customers’ financial expenses or infringing their rights and interests, etc.② We shall not include, or have others include, false information in any accounting book or records, and shall not engage in any acts that will result in such. ③ We shall reject all monopolistic or anti-competitive acts. We shall ensure our customers’ right for diversity in selection and fair competition in accordance with the prevailing market principles.
 

§4 Protection of the Company’s business opportunities and property

Article 19 (Prohibition of private use of the Company’s property)

e shall not use the Company-designated budget or expenses for anything other than the designated purpose. We shall not use the Company’s assets for our own private purposes

Article 20 (Prohibition of violations of the Company’s secrecy)

① We shall not take out the Company’s information or documents for unauthorized purposes. We shall not ask another employee to provide us with the Company’s secret information in violation of its rules on secrecy. ② We shall not use any of the Company’s business opportunities or information acquired in the course of carrying out business as employees of the Company for our own interest or that of a third party.
 

§5 Prohibition on offering/receiving money, valuables, or entertainment

Article 21 (Prohibition on receiving/offering money, valuables, entertainment)

① We shall not offer or receive money, valuables, entertainment, special favors or unjust interests to/from an employee of a customer business, the Company or a subsidiary of the Company, etc. (including a sub-subsidiary under the control of a subsidiary and any business under the control of a sub or sub-subsidiary). ② We shall not engage in any acts that may obstruct other employees’ fair execution of business including solicitation intended to exercise an unfair influence on our or other employees’ recruitment, promotion or transfer, etc.

Article 22 (Prohibition on offering of money/valuables to government officials)

We shall not offer money and/or valuables to government officials either at home or abroad in compliance with the relevant laws and conventions, such as the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the 「Foreign Corrupt Practices Act」 of the United States, the 「Bribery Act」 of the United Kingdom, and the 「Act on Combating Bribery of Foreign Public Officials in International Commercial Transactions」 and the 「Improper Solicitation and Graft 」.

Article 23 (Transactions with subcontractors; corruption-free contracts)

① We shall not engage in any unfair acts, such as asking subcontractors for money, valuables or entertainment, imposing unjust conditions or offloading expenses on to them, or taking advantage of our superior position. We shall sign and execute corruption-free contracts with our subcontractors.② We shall not arrange a pre-contract overseas business trip or training session for which the expenses are paid by the other party to a contract. With regard to an overseas business trip/training session for which the expenses are to be paid by a party other than ourselves, we shall consult about it with the Compliance Officer in advance according to the designated procedure.

Article 24 (Prohibition on borrowing money from other businesses or between employees)

We shall not engage in any direct or indirect lending/borrowing of money to/from those of a business with which the Company is engaged in a transaction or between the Company’s employees, act as a go-between for such an arrangement or offer a guarantee or collateral regardless of whether the price has been paid in return.

Article 25 (Fostering of a sound culture concerning congratulatory/condolatory events)

We shall not inform stakeholders, including subcontractors, of our congratulatory/condolatory events in order to receive money. We shall not send or receive an excessive amount of congratulatory/condolatory money between employees or offer congratulations bouquet/flower pot or other gifts on the occasion of an employee’s transfer to a new post or promotion.
 

§6 Prohibition of workplace harassment

Article 26 (Prohibition of workplace harassment)

① We shall conduct careful checks at all times to determine whether there is any workplace harassment and strive to encourage effective communication among ourselves. ② We shall treat each other with respect. We shall not engage in any physical and/or mental harassment whatsoever of other employees.

Article 27 (Prohibition of sexual harassment/discrimination)

We shall not tell dirty jokes or engage in acts of sexual harassment/discrimination including making remarks about another employees’ body or about fixed gender roles that may offend persons of either gender.

Chapter 3 Protection of interests of customers/shareholders, etc.

Article 28 (Customer protection)

① We shall fulfill our fiduciary duty in order to protect our customers’ tangible/intangible property including their financial properties, intellectual property rights, and business secrets, etc.② We shall not collect, inquire about, use, or provide information on our customers’financial transactions or their personal credit to a third party without obtaining their prior consent; nor shall we provide information on our customers’ financial transactions to a third party or use it for our own private purposes without obtaining their prior consent, unless otherwise required to do so by law.

Article 29 (Protection of shareholders’ interests, etc.)

① We shall engage in reasonable and responsible management and conduct our business fairly so as to protect and maximize the interests of our shareholders and investors.② We shall treat all our shareholders fairly and equally, and shall not provide undisclosed information only to specific shareholders.

Article 30 (Social responsibility; environmental protection)

① We shall engage in our corporate activities based on the philosophy of socially responsible management and take part in social contribution activities to fulfill our obligations as members of the local community. ② We shall value the importance of environmental issues, comply with the relevant laws and regulations, and do our best to protect the environment, including the prevention of environmental pollution.

Addendum

Article 1 (Enforcement Date) This Code shall center into force on July 1, 2019.

Addendum

Article 1 (Enforcement Date) This Code shall come into force on November 15, 2019.

Addendum

Article 1 (Enforcement Date) This Code shall come into force on April 23, 2021.

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