Ethical Management

Fair Trade Compliance Program

Compliance Program Guideline
Internal Law-abidance Program for Self Compliance

It is an internal law-abidance program prepared and operated for the company to abide the Fair Trade Act voluntarily. This program includes the will of CEO, the organization in charge of program administration, the manual of checklist about management activities violating the Fair Trade Act, the plan of consultation and training, internal audit, and the measure to prevent recurrence.

Major Contents

The Compliance Program is a corporate voluntary implementation program, and it may vary among industries and companies. Yet, for effective administration of the Compliance Program, the following seven core components shall be fulfilled.

Lower area reference
  • Declaration of will for autonomous compliance by executives
  • Designated administration of manager of Compliance Program
  • Preparation and distribution of Compliance Program manual
  • Implementation of training program
  • Establishment of monitoring system
  • Restriction on executives or employees violating laws or regulations on the Fair Trade Act
  • Establishment of document management system
Code of conduct for executives and employees
  • - One shall not talk about price or trade condition with competitors.
  • - One shall not share the market with competitors.
  • - One shall not attend any gathering with competitors.
  • - One shall walk out from any agenda regarding group-fixing behavior within a meeting with competitors.
  • - One shall not enforce the sales price.
  • - One shall keep the Compliance Program Guideline for the Fair Trade Act.
  • - If doubtful, one shall have a discussion with the CP manager in the planning and adjustment department in advance.
Benefit from administration of Compliance Program
Exemption from Ex Officio Investigation

Subject: Any violation defined by the Monopoly Regulation and Fair Trade Act, the Act on Fair Indication and Advertisement, the Door-to-door Sales, etc. Act, the Act on the Consumer Protection in Electronic Commerce, etc., the Regulation of Standardized Contracts Act, and the Type and Standard of Unfair Transaction and Monopoly Power abuse in Journalism

Benefit from administration of Compliance Program
CP Grade (grade evaluation of A or above) Period of Exemption from Ex Officio Investigation
Grade A or higher 1 Year
Grade AA or higher 1 Year and 6 Months
Grade AAA or higher 2 Years
Background of Implementation
Promotion of balanced development through liberal competition

The Fair Trade Act is to promote fair and liberal competition among companies to form creative business activities and to protect consumers to induce balanced development of national economy.

To keep the Fair Trade Act, Binggrae has published the fair transaction guideline to provide the behavioral standard to keep the Fair Trade Act to employees and regularly put much effort to eliminate any work practice violating the Fair Trade Act. As a part of such effort, Binggrae has introduced the Compliance Program from 2008 and selected the manager of Compliance Program to be in charge of practical operation at the Board of Directors to implement the Compliance Program.

Accomplishment of Corporate Compliance Program
Accomplishment of Corporate Compliance Program
Recommended Item Accomplishment of Corporate Compliance Program
Declaration of will for autonomous compliance by CEO
  • - Declaration of will for compliance of fair transaction by executive officers and announcement to all employees (Aug. '08)
  • - Reinforcement of will for fair transaction at internal training such as marketing school
Designation and administration of Compliance Program manager
  • - Resolved at the Board of Directors, amendment of designating the managerial member for fair transaction (Jan. '11)
  • - Sending out the declaration by the manager of Compliance Program (Feb. '11)
  • - Sending out the instruction of fair transaction (Mar. '11)
Preparation and distribution of Compliance Program manual
  • - The initial design of the guideline for Compliance Program in 2008 and fragmentation into guidelines for each section in 2011 (revision)
Administration of training program
  • - Two annual internal trainings about the Fair Trade Act and Compliance Program in 2008 ~ 2010
  • - Establishment of training curriculum for E-learning fair transaction (Apr. '11)
  • - Participation in outside training
Establishment of internal monitoring system
  • - Administration of autonomous monitoring system of department under the fair transaction checklist
  • - Parallel implementation of direction/consultation and inspection of status in vulnerable section
  • - Selection and administration of fair transaction leader in each section
Establishment of restriction system against violator of laws
  • - Administration of penalty regulations for seriousness of violation
  • - Implementation of quick restriction against legal violator
Administration of document regarding fair transaction
  • - Administration of penalty regulations for seriousness of violation
  • - Implementation of quick restriction against legal violator
Composition of Compliance Program Committee
  • - Administration of 「Compliance Program Committee」 with 9 heads of departments regarding fair transaction
Compliance Program Guideline

The Fair Trade Act is to promote fair and liberal competition among companies to form creative business activities and to protect consumers to induce balanced development of national economy. To keep the Fair Trade Act, Binggrae has published the fair transaction guideline to provide the behavioral standard to keep the Fair Trade Act to employees and regularly put much effort to eliminate any work practice violating the Fair Trade Act. As a part of such effort, Binggrae has introduced the Compliance Program from 2008 and selected the manager of Compliance Program to be in charge of practical operation at the Board of Directors to implement the Compliance Program.

Training for Guideline of Compliance Program

For improvement of perspective to comply with fair transaction by executives and employees, Binggrae has performed the internal training from 2008 to 2010 and cyber training from 2011 and has been participating the outside training by the expert of fair transaction. Binggrae will continue training for improvement on comprehension about fair transaction by executives and employees.

Compliance Program system
Checklist to confirm and prevent in advance

Through the checklist in each section, Binggrae is performing autonomous monitoring of fair transaction.
Autonomous monitoring is the most effective method to confirm and prevent any violation of fair transaction in advance, and it assures the practical operation of the guideline for Compliance Program.

Scope of autonomous monitoring: violation in fair transaction
  • A. Violation of the Monopoly Regulation and Fair Trade Act
  • B. Violation of the Fair Transactions in Subcontracting Act
  • C. Violation of the Regulation of Standardized Contracts Act
  • D. Violation of the Act on Fair Indication and Advertisement
Compliance Program Committee and Fair Transaction Leader
A. Compliance Program Committee
Compliance Program Committee
Role
  • - Evaluation of important matters in the Guideline for Compliance Program and consultation of manager for Compliance Program
  • - Each member implements autonomous monitoring about any violation of corresponding laws.
Composition
  • - Opening of regular meeting in every quarter and opening of temporary meeting if required
  • - Each member selects fair transaction leaders and supervise them, and each member administrates the practical operation of the Compliance Program Committee.
B. Fair Transaction Leader
Fair Transaction Leader
Purpose of Administration
  • - An exclusive agent in each department to support fair transaction and guideline for Compliance Program
  • - Reconsideration of administrative efficiency of the Compliance Program Committee and expansion of abidance of fair transaction
Role
  • - Overall administration of autonomous monitoring by the corresponding department
  • - Consultation and instruction on fair transaction by the corresponding department
  • - Exploration of issues and solutions for administration of Compliance Program
C. Roles and Responsibilities
Roles and Responsibilities
Subject of Implementation Main R&R
Compliance Program Committee
  • - Evaluation of significant matters in Compliance Program and consultation for manager of Compliance Program
  • - Evaluation and resolution on restriction against violator of Compliance Program
Compliance Program Manager
  • - Chairperson of the Compliance Program Committee
  • - Selection of members for the Compliance Program Committee
  • - Overall administration of 7 factors on Compliance Program
  • - Report of administration to the Board of Directors every half year
  • - Collection of information on establishment of network for the Fair Trade Commission
Compliance Program Committee Member
  • - Overall administration of Compliance Program for the corresponding organization
  • - Autonomous monitoring of any violation of Compliance Program by the corresponding organization
  • - Supervision of confinement for investigation by the Fair Trade Commission on the corresponding organization
  • - Selection of fair transaction leader of the corresponding organization
  • - Participation of the Compliance Program Committee every quarter
  • - Completion of 2 hours of training in every half year
  • - Confinement 2 for internal audit on Compliance Program
Compliance Program Committee Leader
  • - Job assistance for members of the Compliance Program Committee
  • - Practical point of contact with main department
  • - Submission of collected data for the corresponding organization
  • - Overall administration of field work for autonomous monitoring for the corresponding organization
  • - Consultation about administration of Compliance Program and exploration of solutions
  • - Completion of 2-hour education in every half year
Member
  • - Abidance by laws regarding fair transaction
  • - Report of any violation of laws regarding fair transaction
Main Department
  • - Report of job performance by the manager of Compliance Program
  • - Planning and administration of Compliance Program of the entire company
  • - Legal consultation and support
  • - Regular/irregular inspection on administration
  • - Maintenance and sharing of various laws and regulations and cases
  • - Administration of communities and documents
  • - Electronic notice of major administrative status
  • - Evaluation and management of Compliance Program grades
Overview
Compliance Program Guideline
Internal Law-abidance Program for Self Compliance

It is an internal law-abidance program prepared and operated for the company to abide the Fair Trade Act voluntarily. This program includes the will of CEO, the organization in charge of program administration, the manual of checklist about management activities violating the Fair Trade Act, the plan of consultation and training, internal audit, and the measure to prevent recurrence.

Major Contents

The Compliance Program is a corporate voluntary implementation program, and it may vary among industries and companies. Yet, for effective administration of the Compliance Program, the following seven core components shall be fulfilled.

Lower area reference
  • Declaration of will for autonomous compliance by executives
  • Designated administration of manager of Compliance Program
  • Preparation and distribution of Compliance Program manual
  • Implementation of training program
  • Establishment of monitoring system
  • Restriction on executives or employees violating laws or regulations on the Fair Trade Act
  • Establishment of document management system
Code of conduct for executives and employees
  • - One shall not talk about price or trade condition with competitors.
  • - One shall not share the market with competitors.
  • - One shall not attend any gathering with competitors.
  • - One shall walk out from any agenda regarding group-fixing behavior within a meeting with competitors.
  • - One shall not enforce the sales price.
  • - One shall keep the Compliance Program Guideline for the Fair Trade Act.
  • - If doubtful, one shall have a discussion with the CP manager in the planning and adjustment department in advance.
Benefit from administration of Compliance Program
Exemption from Ex Officio Investigation

Subject: Any violation defined by the Monopoly Regulation and Fair Trade Act, the Act on Fair Indication and Advertisement, the Door-to-door Sales, etc. Act, the Act on the Consumer Protection in Electronic Commerce, etc., the Regulation of Standardized Contracts Act, and the Type and Standard of Unfair Transaction and Monopoly Power abuse in Journalism

Benefit from administration of Compliance Program
CP Grade (grade evaluation of A or above) Period of Exemption from Ex Officio Investigation
Grade A or higher 1 Year
Grade AA or higher 1 Year and 6 Months
Grade AAA or higher 2 Years
Overview of Implementation
Background of Implementation
Promotion of balanced development through liberal competition

The Fair Trade Act is to promote fair and liberal competition among companies to form creative business activities and to protect consumers to induce balanced development of national economy.

To keep the Fair Trade Act, Binggrae has published the fair transaction guideline to provide the behavioral standard to keep the Fair Trade Act to employees and regularly put much effort to eliminate any work practice violating the Fair Trade Act. As a part of such effort, Binggrae has introduced the Compliance Program from 2008 and selected the manager of Compliance Program to be in charge of practical operation at the Board of Directors to implement the Compliance Program.

Accomplishment of Corporate Compliance Program
Accomplishment of Corporate Compliance Program
Recommended Item Accomplishment of Corporate Compliance Program
Declaration of will for autonomous compliance by CEO
  • - Declaration of will for compliance of fair transaction by executive officers and announcement to all employees (Aug. '08)
  • - Reinforcement of will for fair transaction at internal training such as marketing school
Designation and administration of Compliance Program manager
  • - Resolved at the Board of Directors, amendment of designating the managerial member for fair transaction (Jan. '11)
  • - Sending out the declaration by the manager of Compliance Program (Feb. '11)
  • - Sending out the instruction of fair transaction (Mar. '11)
Preparation and distribution of Compliance Program manual
  • - The initial design of the guideline for Compliance Program in 2008 and fragmentation into guidelines for each section in 2011 (revision)
Administration of training program
  • - Two annual internal trainings about the Fair Trade Act and Compliance Program in 2008 ~ 2010
  • - Establishment of training curriculum for E-learning fair transaction (Apr. '11)
  • - Participation in outside training
Establishment of internal monitoring system
  • - Administration of autonomous monitoring system of department under the fair transaction checklist
  • - Parallel implementation of direction/consultation and inspection of status in vulnerable section
  • - Selection and administration of fair transaction leader in each section
Establishment of restriction system against violator of laws
  • - Administration of penalty regulations for seriousness of violation
  • - Implementation of quick restriction against legal violator
Administration of document regarding fair transaction
  • - Administration of penalty regulations for seriousness of violation
  • - Implementation of quick restriction against legal violator
Composition of Compliance Program Committee
  • - Administration of 「Compliance Program Committee」 with 9 heads of departments regarding fair transaction
Compliance Program Guideline

The Fair Trade Act is to promote fair and liberal competition among companies to form creative business activities and to protect consumers to induce balanced development of national economy. To keep the Fair Trade Act, Binggrae has published the fair transaction guideline to provide the behavioral standard to keep the Fair Trade Act to employees and regularly put much effort to eliminate any work practice violating the Fair Trade Act. As a part of such effort, Binggrae has introduced the Compliance Program from 2008 and selected the manager of Compliance Program to be in charge of practical operation at the Board of Directors to implement the Compliance Program.

Training for Guideline of Compliance Program

For improvement of perspective to comply with fair transaction by executives and employees, Binggrae has performed the internal training from 2008 to 2010 and cyber training from 2011 and has been participating the outside training by the expert of fair transaction. Binggrae will continue training for improvement on comprehension about fair transaction by executives and employees.

Autonomous monitoring system and committee
Compliance Program system
Checklist to confirm and prevent in advance

Through the checklist in each section, Binggrae is performing autonomous monitoring of fair transaction.
Autonomous monitoring is the most effective method to confirm and prevent any violation of fair transaction in advance, and it assures the practical operation of the guideline for Compliance Program.

Scope of autonomous monitoring: violation in fair transaction
  • A. Violation of the Monopoly Regulation and Fair Trade Act
  • B. Violation of the Fair Transactions in Subcontracting Act
  • C. Violation of the Regulation of Standardized Contracts Act
  • D. Violation of the Act on Fair Indication and Advertisement
Compliance Program Committee and Fair Transaction Leader
A. Compliance Program Committee
Compliance Program Committee
Role
  • - Evaluation of important matters in the Guideline for Compliance Program and consultation of manager for Compliance Program
  • - Each member implements autonomous monitoring about any violation of corresponding laws.
Composition
  • - Opening of regular meeting in every quarter and opening of temporary meeting if required
  • - Each member selects fair transaction leaders and supervise them, and each member administrates the practical operation of the Compliance Program Committee.
B. Fair Transaction Leader
Fair Transaction Leader
Purpose of Administration
  • - An exclusive agent in each department to support fair transaction and guideline for Compliance Program
  • - Reconsideration of administrative efficiency of the Compliance Program Committee and expansion of abidance of fair transaction
Role
  • - Overall administration of autonomous monitoring by the corresponding department
  • - Consultation and instruction on fair transaction by the corresponding department
  • - Exploration of issues and solutions for administration of Compliance Program
C. Roles and Responsibilities
Roles and Responsibilities
Subject of Implementation Main R&R
Compliance Program Committee
  • - Evaluation of significant matters in Compliance Program and consultation for manager of Compliance Program
  • - Evaluation and resolution on restriction against violator of Compliance Program
Compliance Program Manager
  • - Chairperson of the Compliance Program Committee
  • - Selection of members for the Compliance Program Committee
  • - Overall administration of 7 factors on Compliance Program
  • - Report of administration to the Board of Directors every half year
  • - Collection of information on establishment of network for the Fair Trade Commission
Compliance Program Committee Member
  • - Overall administration of Compliance Program for the corresponding organization
  • - Autonomous monitoring of any violation of Compliance Program by the corresponding organization
  • - Supervision of confinement for investigation by the Fair Trade Commission on the corresponding organization
  • - Selection of fair transaction leader of the corresponding organization
  • - Participation of the Compliance Program Committee every quarter
  • - Completion of 2 hours of training in every half year
  • - Confinement 2 for internal audit on Compliance Program
Compliance Program Committee Leader
  • - Job assistance for members of the Compliance Program Committee
  • - Practical point of contact with main department
  • - Submission of collected data for the corresponding organization
  • - Overall administration of field work for autonomous monitoring for the corresponding organization
  • - Consultation about administration of Compliance Program and exploration of solutions
  • - Completion of 2-hour education in every half year
Member
  • - Abidance by laws regarding fair transaction
  • - Report of any violation of laws regarding fair transaction
Main Department
  • - Report of job performance by the manager of Compliance Program
  • - Planning and administration of Compliance Program of the entire company
  • - Legal consultation and support
  • - Regular/irregular inspection on administration
  • - Maintenance and sharing of various laws and regulations and cases
  • - Administration of communities and documents
  • - Electronic notice of major administrative status
  • - Evaluation and management of Compliance Program grades