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 general standards of conduct 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 and General Principles)

① This Code shall apply to all employees (“us,” “we,” “our,” “ours”) of the Company.② We shall make diligent efforts to thoroughly understand and implement this Code in order to make correct judgments during work performance. In case of any questions regarding the interpretation of the Code of Ethics and this Code, or regarding work procedures, we consult with the Ethics Management Office or the Compliance Department.③ We shall comply with the Code of Ethics and this Code, and shall take responsibility for any violations that occur.

Chapter 2 Employees’ Work Standards

§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, and we shall be fully familiar with and comply with the relevant laws and internal regulations during our business activities. 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 (Fulfillment of Duties and Others)

① We shall sincerely fulfill our respective duties in accordance with the Company's objectives and values pursued based on its management philosophy and vision. ② We consider honesty and trust as the most important values, and we shall perform all our assignments diligently and industriously using moral and fair methods.

Article 5 (Maintaining decency and dignity)

① 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.② On personal social media platforms and anonymous social media, we shall adhere to the following subparagraphs to avoid disclosing the Company's and employees' confidential information or damaging the reputation of the Company or its employees: 1. Do not post materials related to the Company, employees, or customers.2. Do not write posts or comments that infringe on the privacy or defame the reputation of employees.3. Avoid using abusive language, sexual expressions, or vulgar language.4. Do not post fake news or information whose accuracy cannot be verified.

Article 6 (Mutual Respect among Employees, 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. ③ We shall share the culture and values of Woori Financial Group (“the Group”) based on mutual respect and consideration with subsidiary employees, and enhance knowledge and expertise through active personnel exchanges.

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

① 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.② We shall not engage in any acts of exerting influence for the benefit of members of a private organization, regardless of the established standards and procedures.

Article 8 (Prohibition of involvement in politics)

① 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. ② While respecting individual employees' right to vote and political views, we shall take care lest individual employees’ political views and/or activities be mistaken for those of the Company or the 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. Employees who receive unfair instructions or requests shall not comply with them.

Article 10 (Establishment of Work Discipline)

① We shall not engage in gambling, computer games, virtual asset or stock investment, long private phone calls, the use of messenger services for non-work purposes, 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 permission.② We shall not engage in excessive investment, speculation, or borrowing beyond our financial capacity.

Article 11 (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.
 

§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, and if performing the business is deemed inappropriate due to a conflict of interest, we shall report to a superior so that another person can handle the business, ensuring it is processed fairly.② Notwithstanding the foregoing in paragraph 1, in the event of a conflict of interest, we shall prioritize the interests of the Company or customer.

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.)

① In the event that we engage in an outside activity such as giving a lecture or contributing an article, in relation to our work, we shall ensure that such activities do not negatively impact the Company by adhering to the following subparagraphs:1. Clearly state that any opinions expressed are personal and not the official stance of the Company.2. Ensure that outside activities do not hinder the performance of our duties.3. Report to the Company if monetary compensation is received for such outside activities.4. Refrain from making definitive statements about uncertain matters or disparaging competitors.② In cases where monetary compensation is received for work-related outside activities, executives must notify the Head of the Ethics Management Office afterward, while employees must register this on the 'Outside Activity Compensation Report' section within the company portal within 10 business days from the date of receiving the compensation.③ If the honorarium, excluding necessary expenses, exceeds 500,000 KRW per month or 3,000,000 KRW annually, employees can either personally donate the excess amount or donate it in their name to a social welfare organization recommended by the Company.
 

§3 Prohibition of unfair acts of trading

Article 15 (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. We shall also comply with related regulations set forth in the Financial Investment Services and Capital Markets Act (hereinafter referred to as the “Capital Markets Act”) and control the access of such information to unauthorized parties, except for those who have the right to know such information for the execution of the Company's business.

Article 16 (Prohibition of manipulation of securities prices)

We shall not engage in any acts related to the manipulation of securities prices including the distribution of false information to earn profits or mislead people. We shall comply with related regulations set forth in the Capital Markets Act.

Article 17 (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 not engage in 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 property

Article 18 (Prohibition of private use of the Company’s property)

We 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 19 (Prohibition of violations of the Company’s secrecy)

① We shall not engage in acts that infringe on confidentiality, such as leaking the Company's information or documents to external parties for non-business purposes, or requesting confidential information from other employees.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.

Article 20 (Management of Internal Information)

① Only employees with proper authority and responsibility within the Company shall share critical information that, if provided or leaked externally, could significantly impact the Company.② We shall not provide information or documents to other employees who do not have access rights, nor shall we disclose related information in open areas within or outside the Company where unspecified individuals gather.③ We must effectively control access to computers or other storage devices containing the Company's important information to prevent unauthorized individuals from accessing them.④ If we receive requests for interviews or provision of materials from external media such as newspapers or broadcasting stations, we shall enhance the accuracy and reliability of the information by consulting with the department responsible for external media beforehand.
 

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

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

① We shall not directly receive or offer, nor allow any third party to receive or offer, money, valuables, entertainment, special favors, or unjust interests beyond generally accepted social norms from/to an employee of a customer business, the Company, or a subsidiary of the Company, etc. (including sub-subsidiaries and companies controlled by sub-subsidiaries, as well as any lower-level entities in the hierarchical structure, hereinafter referred to as "Subsidiaries"). ② We shall not directly engage in, nor allow any third party to engage in, the following subparagraphs that may obstruct the fair execution of duties by employees of subsidiaries, or that might unfairly benefit ourselves or third parties:1. Interfering with or influencing personnel tasks such as recruitment, promotion, or transfer.2. Interfering with or influencing the selection of contract parties or the decision to enter into contracts.3. Interfering with or influencing the selection of award or commendation recipients.4. Interfering with or influencing the manipulation of audit results or concealing violations.5. Engaging in any other acts that obstruct the fair execution of duties by employees of subsidiaries.

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 Act」and the Group Global Anti-Corruption Laws Compliance Manual.

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 When selecting subcontractors, we shall adhere to predetermined fair procedures and methods to ensure fair opportunities and reasonable terms for subcontractors, and to justify the legitimacy of discretionary contracts, we shall clearly state the reasons and objectives.③ We shall respect the autonomy and independence of subcontractors and encourage them to faithfully implement and comply with the Group's "Subcontractor Code of Ethical Conduct" to ensure that they also align with the Company's principles and philosophy of social responsibility management.④ We shall not arrange a pre-contract overseas business trip or training sponsored by potential contractual counter-parties before a contract is concluded. For any overseas trips or training funded by external sources, the relevant department shall consult with the Head of the Ethics Management Office in advance according to pre-established procedures.

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

We shall not engage in direct or indirect financial transactions, including lending, arranging, guaranteeing, or providing collateral, with clients or among employees (including subsidiaries), regardless of whether compensation is involved.

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 treat each other with respect and shall not engage in any physical and/or mental harassment of other employees, regardless of the reason. ② We shall conduct vigilant checks at all times to determine whether there is any workplace harassment and exercise special care in communication among 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.
 

§7 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.③ When providing financial services utilizing artificial intelligence technologies to customers, we must ensure the accuracy and stability of data, and the transparency and fairness of services to uphold the value of human dignity. We must continuously manage these services to prevent any infringement on customer rights.

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.
 

§8 Reporting and Action on Violations

Article 31 (Reporting of Violations)

① In the event that we detect or suspect any illegal or unjust act, we shall report it immediately to the Ethics Management Office and the Compliance Department according to the designated procedure and shall not cover up any wrongdoing.② Reports made under paragraph 1 should aim to prevent fraud and corruption and must not be used to defame others or seek personal gain.

Article 32 (Inspection and Action on Violations)

The Ethics Management Office and the Compliance Department may inspect compliance with the Code of Ethics and this Code by employees. If it is determined that an employee has violated the Code of Ethics or this Code, necessary actions, including disciplinary measures, shall be taken according to the relevant internal regulations.

Addendum <1, 2019.7.1.>

This Code of Conduct shall come into force on July 1, 2019.

Addendum <2, 2019.11.15.>

This Code of Conduct shall come into force on November 15, 2019.

Addendum <3, 2021.4.23.>

This Code of Conduct shall come into force on April 23, 2021.

Addendum <4, 2023.7.31.>

This Code of Conduct shall come into force on July 31, 2023.

Addendum <5, 2025.3.31.>

This Code of Conduct shall come into force on March 31, 2025.