SK실트론

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Compliance

Compliance Program

SK siltron operates its Compliance Program (CP) for voluntary compliance with fair trade legislation.
Consisting of internally developed and operated compliance activities,
the CP enables SK siltron’s fair trade, as part of its industry-leading ESG management.




Eight Core Components of the CP




Formation and Implementation of CP Standards and Procedures
The standards and procedures necessary for the members of SK siltron to clearly understand and practice fair trade-related compliance must be established and implemented. SK siltron’s CP Policy has been in effect since June 2022.
CEO’s Will and Support for the CP
The standards and procedures necessary for the members of SK siltron to clearly understand and practice fair trade-related compliance must be established and implemented. SK siltron’s CP Policy has been in effect since June 2022.
Appointment of a Chief CP Officer
The Board of Directors of SK siltron must appoint a Chief CP Officer to achieve the effectiveness of its CP operations. SK siltron’s Chief CP Officer is indicated below.
– Head of the Business Management Division
Development and Use of a CP Manual
The CP manual for use within SK siltron, prepared under the Chief CP Officer’s responsibility, includes information related to fair trade legislation and the CP standards and procedures. It must be made available in a document or electronic document format for convenient access by all employees. The said CP Manual serves as SK siltron’s official CP Manual.
Ongoing Execution of Systematic CP Training
Effective training in the CP standards and procedures, and compliance with the fair trade legislation, must be provided regularly to the CEO and members of the purchasing and sales operations, as well as to any other operations deemed to be a high risk in relation to fair trade. The Legal Affairs Team of SK siltron, in charge of the SK siltron’s fair trade activities, provides the members of SK siltron with CP training at least once a year.
Operation of Internal Monitoring System
A soundly structured monitoring and audit system is required for the prevention or early detection of infringements. Monitoring and audit results must be reported to the Board of Directors or another chief decision-making body regularly (at least two times a year). For the prevention or early detection of fair trade-related infringements, SK siltron collects and processes reports of fair trade infringements through the SK Group’s ethical management website, and performs compliance diagnoses to identify and address the related risks.
Disciplinary Action for Violations of the Fair Trade Legislation
A company policy defining instances of violation of the fair trade legislation by employees, and the commensurate disciplinary actions entailed, must be established and observed. When such a violation is discovered, steps must be taken to actively respond to it and prevent its recurrence. SK siltron’s company policy prescribes the disciplinary actions in relation to employees found to have violated the fair trade legislation.
Evaluation and Improvement of Efficiency
An evaluation of the CP standards and procedures, including their implementation, must take place regularly and the necessary improvements made to ensure the continuing efficiency of the CP. SK siltron evaluates and updates its CP standards and CP Manual on a regular basis.

CP Operation Overview

SK siltron adopted its Compliance Program in 2022, and has since implemented programs consistent with its eight core components,
including the formation and implementation of company policy, the training of members and suppliers in fair trade, and the assessment of its fair trade activities.



Chief CP Officer


Name Office Roles and powers Term
Lim Ju-hwan Vice President
Corporate Management Department
ㆍCP operations and management of the related training and monitoring
ㆍAssessment of compliance, investigation of infringements, execution of
      improvements and corrections
ㆍReporting to the Board of Directors on CP plans and performance
Three years
(2025.2.7 ~ 2028.2.6)

※ Basis for the appointment: 3.4, ①, Article 8 (Board of Directors’ Decisions) of the Board of Directors Policy: Appointment or dismissal of a chief compliance program officer



Achievements


2024 Dec ㆍAnnual second half performance report to the Board of Directors
Nov ㆍmySUNI online course "Trade Secret Protection and Violation Prevention Course" for member
Oct ㆍFair Trade Act training (for executives)
Jul ㆍAnnual first half performance report to the Board of Directors
Jun ㆍImplementation of Fair Trade Act training (for office workers).
ㆍ"Implementation of Fair Trade Voluntary Compliance Practice Pledge"
Mar ㆍAffiliate Transaction Process Inspection and Improvement
Feb ㆍAppointment of Fair Trade Compliance Manager Change
Jan ㆍNew CEO Fair Trade "Publication of declaration of intention to practice voluntary compliance"
2023 Dec ㆍAnnual second half performance report to the board of directors
ㆍDistribution of newsletters on obligations/prohibitions related to the Anti-Bribery Act
Nov ㆍE-Learning Training on Prohibition of Technology Stealing from Small and Medium Businesses
Oct ㆍEducation on ESG Risk for small and medium-sized companies
ㆍDistribution of newsletters for requests for technical information from small and medium-sized enterprises
Jul ㆍAnnual first half performance report to the Board of Directors
ㆍDistribution of newsletters on obligations/prohibitions related to subcontracting transactions
Jun ㆍConduct subcontracting transaction inspections
ㆍDistribution of newsletters on compliance matters when board approval of large-scale insider transactions is required
May ㆍTraining on the main provisions of the supply unit price linkage system
2022 Dec ㆍAnnual performance board report
Oct ㆍAll members trained in CP
ㆍSeminar on mutual benefit for suppliers held
ㆍCP Manual developed
Sep ㆍFair trade monitoring/whistleblower system upgraded
Aug ㆍDeclaration of Commitment to the CP made by the CEO
Jun ㆍCP policy established
Apr ㆍChief CP officer appointed
ㆍAdoption of the CP approved by the Board
Feb ㆍCP planned

Declaration of Commitment to the Compliance Program

All members of SK siltron, the CEO included, are committed to SK siltron’s pledge for the practice of voluntary fair trade compliance (Compliance Program),
and will actively participate in a full range of CP activities, including training and assessments for infringement prevention.




Declaration of Commitment to the Compliance Program


Dear associates,

It is with a light heart that I inform you that SK siltron is continuing to grow as a semiconductor material company trusted by all, through technological innovations and ongoing and consistent quality controls. SK siltron has always sought fair trade compliance and shared growth, in inspiring the market fairness of competition and a culture of mutual benefits.

As its commitment to dispense with mechanical compliance for the active and voluntary practice of fair trade, SK siltron and its people have unanimously adopted our Compliance Program. I hereby declare our commitment to it, as a solemn affirmation of our will to ensure fair trade.

Through the active practice of the CP, SK siltron will set an example to be followed in the areas of ethical management and fair competition. In this way, the trust of society and of the customers of SK siltron will be stronger than ever, and SK siltron will be able to achieve growth commensurate with the tech giant that it is.

As CEO, I will work right alongside you in achieving the following commitments.

1. We will actively practice fair trade, as a source of SK siltron’s competitiveness.
2. We will seek the transparency of the subcontract work we are involved in, and will shun unfair trade practices, such as exploiting leverage over business partners, as well as the unfair sourcing and use of information, such as unfair demands for technical information.
3. We will never instruct, approve, or facilitate violations of the fair trade legislation.

I ask you to understand to the fullest SK siltron’s unwavering will to embody fair trade, and please stay interested and focused on the establishment of the culture of voluntary fair trade compliance that SK siltron holds in view. Thank you.

Lee Young-wook
CEO
SK siltron
January 1, 2024



Compliance Program Manual



SK siltron instituted its first Compliance Program Manual in 2022. Henceforth, the company will revise it according to regular reviews of the fair trade legislation, revisions of the fair trade legislation, recent infringements, and other items relevant to SK siltron and its operations.


Download the 2022 Compliance Program Manual