New Hope,
Better Life

Code of Ethics

Hugel places top priority on corporate ethics when managing the company and conducting corporate activities, and aims for transparent, fair, and rational business performance. Hugel's code of ethics is the basis of corporate activities and is designed to improve the value of life for all stakeholders such as customers, shareholders, employees, and partners,
and to pursue happiness. To this end, Hugel establishes the code of ethics as the basis for decision-making and behavior.

    • (Scope of application) This code shall apply to all employees working for Hugel Inc. (including affiliated companies).
    • (Compliance obligations and responsibilities) Employees shall fully understand and comply with this code, and shall be responsible for any violations.

    1. Basic principles
    Employees shall perform their tasks with a strong sense of duty and responsibility and shall strive to achieve the following goals based on
    honesty and trust.
    • A.
      Customer satisfaction first
      Employees should always think and act from the standpoint of customers and do their best to provide the best products to customers.
    • B.
      Strengthening ethics
      Employees should always try to maintain a higher level of ethics by fully understanding the contents of this code of ethics and observing it.
    • C.
      Emphasis on employee satisfaction (improving quality of life)
      Employees should respect the dignity and value of each employee and make efforts to create an environment where employees can work pleasantly by providing fair personnel management and opportunities and settling fair assessment and reasonable compensation.
      Hugel is committed to a safe and clean working environment for all its employees and suppliers. Hugel has conducted internal employment engagement and satisfaction surveys, which are not disclosed to the public. As part of commitment to improving Hugel's transparency with stakeholders including the employees, will look to aggregate results for public disclosure and use the results to improve employee satisfaction in the workplace.
    • D.
      Fulfilling social responsibilities
      Employees should faithfully fulfill the social responsibilities and roles required for a corporation and contribute to the development of
      the national economy and society by taking initiative and setting an example in complying with various laws and regulations and by
      establishing a fair financial order. Hugel is committed to prevent, monitor, and mitigate issues around non-compliance across all its employees.
    • E.
      Maximizing shareholders’ profit
      Employees should provide stable long-term profits to shareholders by maximizing corporate value through reasonable investment and
      sound management.
    • F.
      Labor and Human rights
      Hugel does not hire child labor or forced labor in the workplace and ensures a fair and safety working environment based on the commitment between Hugel and all its employee’s (regardless of temporary or full-time workers) commitment in terms of working hours, overtime pay (if applicable), and meeting or exceeding minimum wage in the form of employment contracts. Furthermore, anti-discrimination, freedom of association, and health and safety practices are observed and part of the recruitment and orientation practices. Hugel intends to become a UNGC anti-human trafficking signatory as part of its commitment against trafficking in human beings.
    • G.
      Biodiversity and deforestation
      As part of Hugel’s ongoing commitment to working in harmony with the environment to minimize disturbances and mitigate negative impacts from its operations on biodiversity and deforestation, Hugel will scope and review life cycle assessments (including sourcing, direct operations, downstream impacts) of its products as part of its long-term ESG strategy. Where relevant, Hugel will promote and collaborate with its supply chain on addressing negative environmental impacts and seek certification from international bodies on its business best practice.

    2. Application subjects and interpretation
    This code of ethics shall be applied/interpreted consistently and fairly for all employees of Hugel Inc. in conformity with the basic principles.
    - If this code is found to conflict with other regulations (laws), this code shall take precedence. However, other regulations shall take precedence
    over this code in the following cases.
    • Pharmaceutical Affairs Act, Medical Service Act, Medical Appliances Act, Cosmetics Act, National Health Insurance Act, and Improper
      Solicitation and Graft Act (Solicitation Prohibition Act)
    • Fair Competition Code of the Pharmaceutical Manufacturers Association, Clinical Activity Guidelines of the Korean Research-based
      Pharmaceutical Industry Association (KPRIA), Fair Competition Code of the Korea Medical Devices Industry Association
    • When new policies and guidelines are announced by authorities such as the Fair Trade Commission, Ministry of Health and Welfare, and
      Korea Food & Drug Administration
    • When there is a new internal control operation plan, SOP, etc. that has been approved by representative executives
    • When there is a conflict with the code of ethics due to revision or new establishment of the policy or law of other government agencies
  • 1. Customer respect
    Employees shall endeavor to achieve customer satisfaction by providing the best products and services that customers can always trust and
    find satisfactory, shall provide accurate information on the products and services to customers, and shall not advertise or engage
    in extravagant or intensive promotion.

    2. Customer protection
    Employees shall protect the interests, safety, and personal information of the customer, shall not act unfairly toward the customer, and shall
    respect and observe consumer protection acts.
  • 1. Concentration on work and prohibition of absence of office and false reporting
    - Employees shall not conduct private activities that are not related to work and which are not permitted by the company during office hours.
    - In order to fully concentrate on their duties, employees shall not be late for work or leave the office privately during office hours without their supervisor’s approval.
    - Employees shall not be absent from work without notice, and shall respond immediately to a return-to-work order.
    - Employees shall submit business reports accurately and shall not appropriate false numbers or submit a false report.

    2. Wholesome leisure activities and moderate lifestyle
    Employees shall make efforts to improve quality of life by conducting leisure activities after work, and shall maintain a sound and moderate

    3. Prohibition of unfair instruction and solicitation
    Employees shall not give unreasonable instruction to junior staff and shall not follow such unreasonable instructions from a supervisor.
    - Employees shall not make unreasonable solicitations or unfair transactions in relation to their job.

    4. Reporting a violation and protecting a reporting employee
    When the violation of a law or code of ethics in relation to work is found or the possibility of a violation is recognized, employees shall report it immediately to their supervisors or the related teams. The company shall completely protect the confidentiality of the reporter, and shall not impose any disadvantages on them due to the report.

    5. Protecting internal information and prohibiting insider trading
    Employees shall not share or disclose internal information about the company or customers that was obtained in connection with job
    performance without undergoing the lawful procedure, and employees shall use such information only for matters related to their job.
    Also, trading of specific stocks using internal information of the company or customers or any other insider transactions are prohibited.
    Employees shall not seek economic gains through the use or disclosure of such information to a third party.
    - Employees shall record and report information obtained during work based on facts, and shall store and manage it as intellectual property
    of the company.
    - Employees shall respect the intellectual property rights of others such as patents, copyrights, trademarks, etc. and shall not commit any
    violations such as unauthorized use, reproduction, distribution, or alteration of the corresponding materials.
    - Employees shall be take precautions so as not to violate the company's regulations regarding intellectual property protection and security
    work when talking with an outsider or acquaintance and when talking over the phone (Internet, etc.).
    * External leakage of new product information, sales, costs, discount rates (hospital), sales materials, customer data, or inventory related data
    is prohibited.

    6. Prohibition of conflicts of interest
    Employees shall not conduct an activity, business transaction, external activity, etc. where their interests or the company’s interests conflict
    with that of customers, except in cases of complying with the standards permitted by law. Employees also shall not engage in other
    employment without the approval of the company.

    7. External activities
    Employees shall not express their intentions regarding their work or matters related to the company through publications, lectures,
    or external media without prior approval from the company.

    8. Restrictions on political activities and donations
    Employees shall not engage in politics using their work or job position, such as by supporting a specific political party or candidate.
    All contributions, donations, and expenditures, such as political donations and donations for social contributions made in the name of
    the company, shall be first approved by the company.

    9. Restrictions on receiving money, real estate, gifts, and entertainment (hereinafter “money, goods, etc.”)
    Employees shall not demand or receive from employees or an outside party (customer, etc.) any money, goods, etc. which are not
    permitted in relation to their work.
    - The term “gift” refers to goods or securities, lodging vouchers, membership vouchers, admission tickets, and other equivalents provided
    free of charge (including cases where the price is significantly lower considering market prices or trading practices).
    - The term “entertainment” refers to entertainment provision such as food, golfing, and entertainment, or convenience provision such as
    transportation, accommodations, etc.
    However, these provisions do not apply in any of the following cases.
    • Money, goods, etc. provided on the legitimate grounds of a claim such as fulfillment of an obligation
    • Convenience such as a frugal meal (within socially accepted standard), communication, transportation, etc. that are provided unavoidably in the process of job performance
      * The Improper Solicitation and Graft Act (Solicitation Prohibition Act) shall be observed.
    • Transportation, accommodations, or food that the host provides to attendees uniformly during an official event related to the job
    • Giveaways or PR materials to be distributed among unspecified individuals
    • Money, goods, etc. that are publicly provided to help employees in difficult situations due to illness, disaster, etc.
    • Frugal gifts (within socially accepted standard), such as flowers, fruit, etc. that are provided inevitably in the process of job performance
      * The Improper Solicitation and Graft Act (Solicitation Prohibition Act) shall be observed.
    • Money, goods, etc. that are publicly provided by the mutual aid society of the employees, etc.
    • Money, goods, etc. that the supervisor provides to junior staff for the purpose of enhancing morale, such as consolation, encouragement,
      rewards, etc.
    • Frugal gifts such as a standing wreath, souvenir, etc. that are officially received for the occasion of job transfer, inauguration, resignation, etc.

    10. Execution of expenses
    Employees shall use expenses only for the purpose of performing company business tasks at a reasonable and necessary level, and shall not commit any illegal acts that seek private gains using the job position or duty, such as embezzlement, misappropriation, theft of company funds, inappropriate handling of expenses, etc.

    11. Private money lending, etc.
    Employees shall not enter into a private loan relationship with a customer or to engage in gambling activities that involve the receipt of money, goods, etc. Excessive surety standing and borrowing shall be first approved by the company.

    12. Mutual respect
    Employees should respect each other's personalities and practice good manners, and shall not commit any in discriminatory acts, recognizing each other's diversity.

    13. Transaction transparency
    Any goods and services required by the company shall be purchased based on quality, ease of use, price, and contribution to the company.
    A product purchase decision should be based on the objective judgment of the supplier's reliability and integrity, long-term/short-term
    consideration of the value of the supplied item, and the purpose of purchase.

    14. Prohibition of sexual harassment
    Employees shall not impose disadvantages in employment or conduct any behavior that induces sexual humiliation toward other employees by means of sexual language or behavior, etc. using their job position in the workplace.

    15. Fair competition
    Employees shall not make any unfair transaction or force an affiliated company to do so.

    16. Cooperation between employees
    Employees should cooperate with each other where cooperation is needed between teams and individual employees for the shared interests of the group.
  • 1. Respect for individual creativity
    Employees should endeavor to form a work environment and organizational culture that achieves maximum performance by respecting
    the creativity of each employee and allowing them to fully apply their abilities.

    2. Protection of employees’ information
    The company shall thoroughly manage various information such as personnel information for employees.

    3. Non-discrimination and compensation based on performance and competency
    The company should recognize the diversity of employees, and shall not give preference or discriminate based on an individual's race,
    nationality, religion, place or origin, regional ties, school relations, kinship, gender, or disability. The company shall assess employees fairly
    and compensate properly based on their performance and competency displayed in the field.

    4. Providing opportunities for education and training
    The company should make efforts to provide fair and appropriate opportunities for training and education to improve expertise and
    enhance the work competency of employees.
  • 1. Exemplary enterprise activities
    The company and employees should act as a model for other companies by performing lawful and just enterprise activities and contribute
    to national development by paying taxes faithfully.

    2. Role as a member of society
    The company and employees shall not pursue only profit in all work, but shall always consider publicness in their work and provide useful
    and cost-effective services to society and its members.

    3. Duty as a member of society
    The company and employees should fulfill their obligations as members of society by actively taking part in various cultural and social
    activities of society and in efforts to preserve the environment. Hugel is using FSC paper and will review doing so across all operations (and packaging) in the future where electronic or environmentally-friendly alternatives are not available. Part of long-term plan for stakeholder engagement including contractors, to explore and review relevance as part of Hugel's next steps in ESG disclosure.
  • 1. Preservation of company assets
    Employees shall use all company assets, including the company name, for purposes of the company only, and shall not use them for private
    purposes where not approved by the company. The ownership of all assets and information obtained during the employment period shall
    belong to the company, regardless of whether the employee is employed or the employment relationship has ended.
    - The company assets (goods, etc.) manager (user) shall compensate for losses according to the case if the company asset was damaged
    by mistake or intentionally.

    2. Company records management
    Employees shall accurately prepare and maintain all company records, data, and information. (HR, legal compliance, accounting, purchasing, production, sales, R&D, etc.)

    3. Diligent information provision
    Employees shall actively provide reliable and useful information on the company's present condition and prospects to shareholders.

    4. Protection of shareholders’ interests
    Employees shall protect the interests of shareholders by achieving profits and making rational investments, and shall ensure the stability of
    shareholders' interests by avoiding speculative business expansion or behaviors to serve short term interests of the time.
  • 1. Submission of written oath
    Employees shall receive the “code of ethics” and submit the “written oath (Appendix 1)” to the company CEO if they have newly joined
    the company or transferred from an affiliated company.

    2. Training
    • Each team leader shall establish and implement training plans for team members to comply with this code and shall implement training
      at least once a year. (Sign after training.)
    • Each team leader shall implement training on the code of ethics for a new employee or an employee transferred from an affiliated

    3. Supervisory responsibility
    • Team leaders shall prevent incidents or accidents such as unfair business handling in advance while managing and supervising team
      members, and shall voluntarily identify an inappropriate team member who degrades work disciplines or who shows high inclination
      to commit an offense and take corrective actions internally. If the deviation is severe, the team leader shall report to the person in charge
      of personnel or the representative executive officer.
    • Team leaders shall take responsibility for the careless management of the team member if sufficient prevention efforts were not made
      when an offending incident occurs.

    4. Designation of the person in charge of the code of ethics
    • Team leaders of each company shall be appointed as the person in charge of training and management of the code of ethics.
    • The person in charge of managing the code of ethics shall manage the training/consultation of the “code of ethics” for team members,
      verify compliance, an d receive and handle violation reports.
    • The person in charge of the code of ethics shall not disclose any information regarding consultation with regard to these regulations.