Ethical Management

1. Conflict of Interest

Employees shall not have personal interests that come into conflict with the company’s interests in treating subcontractors, customers, and other persons who do business with the company. This requirement is commonly applied to business relationships and personal activities.

① Direct and indirect financial interests or interest in the stockholding of subcontractors, customers, or competitors of Mercury
② Act of receiving money, valuables, or entertainment, or borrowing money from subcontractors, customers, or competitors that do or intend to do business with Mercury
③ Act of participating in political activities, holding a director position in another company or organization for profit, or working or providing voluntarily service without the prior approval of Mercury
④ Act of using confidential or nonpublic information that can be obtained through work-related activities
⑤ Act of disclosing/leaking trade secrets without permission or incurring disadvantage to Mercury through bid rigging, etc.

2. Receipt of Money or Valuables

In principle, all forms of bribery in relation to the business of the company are prohibited. Even if it is inevitable, receipt of money or valuables that exceed KRW 50,000 shall be promptly reported to a director in charge through a head of the department in charge and be left to the company’s care (refer to the attached table).

3. Quality and Safety of Products

Mercury is responsible in the design, production, and supply of excellent products, as well as in conducting all required tests and inspections.

4. Marketing and Sales

It is our responsibility to provide excellent products and services at better terms and affordable prices to better understand and meet the needs of our customers. We will provide our products and services fairly based on these strong points, and will not commit to any sales activity that violates this Code of Ethics.

5. Subcontractors and Retailers

It is Mercury’s policy to purchase all equipment, supplies, and services based on their strong points. Mercury will treat its subcontractors and retailers fairly and without discrimination.

6. Correction of Errors

It is Mercury’s policy to inform its customers and suppliers of clerical and computational errors, and to promptly correct such errors through replacement, refund, or other reasonable means.

7. Equal Opportunity in Employment

It is Mercury’s policy to provide equal opportunity in employment to qualified individuals regardless of age, gender, physical disability, or other factors not relevant to just business interest.

8. Employees’ Privacy

Mercury fully respects the privacy and beliefs of its employees. It is the company’s policy to collect and retain employees’ personal information only when it is necessary for the effective operation of the company or when it is required by laws or regulations. Only persons who are authorized to be informed of such personal information have access to them. In particular, employees’ salary shall be kept strictly confidential, and employees themselves shall not disclose their salary or try to know others’ salaries.

9. Open Communication

Mercury will provide, in time, employees with information such as sales results, productivity, customer relations, employees’ performance, etc. Moreover, the company will provide a communication channel to promote a working environment where employees can freely express their opinions, suggestions, and concerns.

10. Protection of Property

• Tangible property
  All employees are responsible for the proper use, preservation, and protection of the company’s properties such as facilities, equipment, etc. The management of each affiliated company of Mercury shall have its employees know and understand the company policies and procedures required to fulfill the said responsibility.
• Intellectual property
  Mercury’s employees will have the opportunity to receive the company’s intellectual properties, such as inventions including computer programs, product design or manufacturing technology, sensitive business information, sensitive technical intelligence, etc. All employees are obliged to properly use and protect such properties

11. Accuracy of Company Records

All business transactions shall be properly approved in accordance with general accounting practices and the company’s financial policies, and shall be recorded in the company’s books and records accurately. Budget applications and economic evaluations shall fairly reflect all information related to requests or proposed decisions. Mercury shall not create or possess any secret or unrecorded funds or properties for whatever purpose.

12. Support for the Local Community

It is Mercury’s policy to support, as a good corporate citizen, the organizations and activities of the local community to which it belongs. The company encourages its employees to personally participate in local community events, and will endeavor to support excellent local community events and charity works.

13. Company Information

Employees shall not leak, without the prior approval of the company, information with regard to the company’s technology, manufacture, sales, and finances, as well as other employees’ personal information that they become to know in conducting their duties.

14. Marketing, Sales, and Advertisement

Mercury will advance into the global market based on its products and services. The company will conduct its marketing affairs fairly and honestly within the scope of legitimate and ethical thinking. It shall conduct its marketing and sales activities based solely on the excellence of its products. Mercury will be careful not to criticize its competitors with incorrect information

15. Purchasing Activity

• Purchase only from qualified vendors.
• Approve in advance and maintain a list of vendors.
• A purchaser will work on rotation (every three years).
• Two or more quotations are required for every purchase (competitive bidding).
• Comply with fair payment terms.
• Prohibit the receipt of money, valuables, gifts, or entertainment.

16. Business Trip Expenses

• In principle, for overseas business trips, airline tickets shall be “Economy Class.” However, an officer may use “Business Class,” and the president may use “First Class.”
• Expenses for other business trips shall be governed by the rules for overseas business trips.

17. Entertainment Expenses

• All expenditures shall have receipts
• For purchases of KRW 100,000 or more, a credit card shall be used.
• A corporate credit card shall be used for entertainment expenses.

18. Processing of Expenses

The rules and policies for expenditures shall be strictly complied with. Where expenses are incorrectly processed, such activity shall be deemed as the embezzlement of company funds and may serve as a ground for dismissal.

19. Reporting and Compensation

• Acts subject to reporting: If an act violates this Code of Ethics
• How to report: Report by personally visiting or meeting with the person in charge of ethical management, or via e-mail, phone call, or the company website
• Use of real name: We guarantee the anonymity of whistleblowers and reduce his/her responsibility. In case of voluntary reporting, we guarantee his/her anonymity.
• The reporting shall be based on facts. False or slanderous reporting will not be accepted.
• Compensation: Where the reporting is related to the receipt of money or valuables, or the reporting has an effect on the increase of the company’s profit or on the decrease of the company’s loss, compensation may be provided.

– Supplementary Provisions –

This provision shall enter into force beginning December 01, 2024