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Ethics

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Ethics

SK Networks takes not only its economic and legal responsibilities seriously, but also ethical responsibility is vital in its management processes. By establishing a fair and transparent corporate culture, we aim to earn the trust of our stakeholders and contribute to the happiness of society as a whole through the continuous growth and development of the company. In this regard, SK Networks established and released the Code of Ethics in 2007, based on SKMS, SK's management philosophy. The Code provides employees with directions on proper behaviors and judgement and requests suppliers to understand and comply with the Code of Ethics.

Ethical Management System

To fulfill its ethical responsibilities and to enhance stakeholders' trust, SK Networks is striving to foster a fair, transparent corporate culture by establishing an ethical management system consisting of 3Cs (Code, Compliance, and Consensus). Our Internal Audit Division, an organization in charge of ethical management, operates the ethical management system and runs various systems and programs to establish and spread the ethics culture.
01 Code, 02 Compliance, 03 Consensus

  • Code of Ethics
    Code of Ethics Practice Guideline
    FAQs on the Code of Ethics
    Practice Guidelines

  • Exclusive organization for ethical management (Internal Audit Division)
    Self-monitoring & correction system
    Reporting channel and Whistleblower protection

  • Ethics training
    Ethics practice workshop
    Ethics practice surveys
    Ethics Management Practice Pledge

Ethical Management Targets and Roadmap

SK Networks vows to establish an ethical management system living up to global expectations and empowering the ethical management systems of its subsidiaries and suppliers as well. To that end, SK Networks defines and tries to accomplish the following targets regarding ethical management policy and training.

2024 ~ 2025

Upgrade the ethical
management system to
global standards

Policy

  • Disseminate and support ISO 37001 certification across subsidiaries
  • Establish ethical management control standards for subsidiaries

Training

  • Develop/Implement ethical education and anti-corruption training content reflecting organizational characteristics
  • Expand ethical education content for suppliers
2026 ~ 2027

Spread the ethical
management system to
global standards

Policy

  • Stabilize/Disseminate ISO 37001 certification across subsidiaries
  • Increase the coverage of ethical management control targets across subsidiaries

Training

  • Continue developing ethical education content to reflect changes in the business environment
  • Implement pilot training programs tailored to each target (leader/member)
  • Provide support for developing ethical education content to reflect the characteristics of subsidiaries
2028 ~

Ensure the ethical
management system at
the global top-level

Policy

  • Maintain ISO 37001 certification for the head office and subsidiaries and evaluate expanding the certification scope
  • Improve the quality of ethical management control for subsidiaries

Training

  • Update education content for ethical education and anti-corruption training
  • Establish an education system tailored to each target
  • Continue supplementing/improving ethical education content for suppliers
  • Provide support for improving ethical education content to reflect the characteristics of subsidiaries

Code

SK Networks developed in 2007 a code of ethics modeled from SKMS (SK Management System) epitomizing SK Group’s management philosophy and has continued to update it ever since. The code of ethics contains provisions governing good practices and decisions to be upheld by SK Networks people in terms of customer relations, basic employee ethics, accountability to shareholders, relations with business partners, and roles to play in favor of the society at large. In addition, SK network has rolled out a guideline for ethical practices to ensure that the code of ethics is correctly understood and complied with as intended. The guideline for ethical practices spells out practices to be upheld by SK Networks people in terms of anti-corruption, mutual respect, protection of corporate and customer data, avoidance of conflict of interest, arm’s-length transaction, safety/environment/health responsibilities, obligations to report irregularities and protect whistleblowers among others In particular, the guideline contains a series of provisions to monitor and eliminate non-compliance of anti-corruption laws including the Improper Solicitation and Graft Act (Anti-graft Act in short). The code of ethics and the guideline for ethical practices are shared with not only SK Networks people but also business partners, with ethical practice training programs provided and compliance agreements from them required. Furthermore, SK Networks had its anti-corruption management system certified (ISO 37001) in December, 2022 to promote ethical compliance, vowing to bolster up ethical practices ever more.

Download <Code of Ethics> Download <Guidelines for the Code of Ethics> Download <Business Partner Ethical Practices Agreement>

Compliance

Organization of the Ethical Management Council
This is an image of the organization of the ethical management council. Please refer to the bottom for more information. This is an image of the organization of the ethical management council. Please refer to the bottom for more information.
SK Networks Audit Committee
  • Chief of Ethical Management Council : SK Networks Audit Division Head
  • Steering Committee : Walkerhill Management Supporting Division Leader, SK Networks service Management Strategy Division Leader, SK Magic Risk Management Division Leader
  • Ethical Management Council
    • SK Networks (Secretary) : Ethics & Audit Team Leader, The person in charge of Ethical Management
    • Walkerhill : The person in charge of Ethical Management
    • SK Networks service : Compliance Management Team Leader, The person in charge of Ethical Management
    • SK Magic : Corporate Audit Team Leader, The person in charge of Ethical Management
  • New Subsidiaries : SK Electlink, En-core, MINTIT
Operating the Ethical Management Council

SK Networks has been operating an Ethical Management Council since 2018 to establish a systematic framework and elevate the standard of ethical management practices between the head office and its subsidiaries. The council, primarily composed of working-level personnel from each company, holds quarterly meetings where they collaboratively plan and implement ethics training and workshops. Additionally, the council supports various activities such as establishing ethics regulations for each company, conducting audits, investigating reports, and enhancing the competencies of those responsible for corporate ethics. Through the activities of the Ethical Management Council, SK Networks aims to continuously strengthen the independent ethical management functions of its subsidiaries.

Self-Regulatory Examination System

SK Networks is conducting an annual in-house examination to enhance autonomy in practicing ethical management. A checklist has been created for ethical risks covering a range of areas, including HR management, cost management, purchasing/business partner management, sales/receivables management, investment management system, inventory management, and unusual risk management. The checklist is designed to assess and evaluate risks specific to each business area.

Ethical Management Reporting Channels

SK Networks operates a channel for all stakeholders to report unethical behavior in order to monitor and manage the current status of ethical management. Reports received through this reporting channel are investigated by the audit team and the dedicated ethical management organizations of each subsidiary, ensuring a transparent and systematic response and handling.

Web

http://ethics.sk.co.kr

Address

SK Networks Internal Audit Team, 85, Cheonggyecheon-ro, Jongno-gu, Seoul, 03190, Republic of Korea

Go to website

Consensus

  • Ethics Education Policy

    SK Networks provides ethics education annually to its people including contractors and part- timers, aiming to ensure that all of them attend and finish the ethics education programs. A separate ethics education program has been available for management leaders and board members since September 2021, with another ethics education program intended for business partners rolled out from 2022 to boost awareness of ethical management practices. The ethics education programs cover major ethical management issues in SK Networks, including anti-corruption, office bullying, and work ethics. We also survey the ethics education program takers on the effectiveness, difficulty and logistics of the education programs to inform our efforts to improve the programs and contents of feedback from SKN people. SK Networks also plan to upgrade the ethics education programs for management leaders, board members and business partners annually in quantitative/qualitative terms in line with the rapidly changing business landscape both at home and abroad.

    Ethics Training History
    The table provides results of ethics training and consists of categories (SK Networks and its subsidiaries and partners), 2019, 2020, 2021, 2022, and 2023.
    Category 2019 2020 2021 2022 2023 2024
    SK Networks, subsidiaries, and second-tier subsidiaries* No. of employees completed training
    (Unit : person)**    		 4,635 4,922 4,866 4,913 4,862 3,361
    Percentage of employees completed training
    (Unit : %)    		 98.4 97.8 98.5 99.2 99.4 99.5
    Partner companies*** Implementation
    (Unit : Y/N)    		 N N N Y Y expected
    No. of partner companies completed training
    (Unit : number)    		 32 19 expected

    * From 2019 to 2021, the Ethics Practice Survey had been implemented in six companies (SK Networks (incl. Walkerhill), SK Networks service, SK Magic, SK Magic service, SK Rent-a-car, SK Rent-a-car service). From 2022 to 2023, Ethics Practice Survey was expanded to eight companies (the existing six companies + MINTIT and Cartini) From 2024, the Ethics Practice Survey has been implemented in five companies (SK Networks (incl. Walkerhill), SK Networks Service, SK Magic, MINTIT, SK Electlink).
    ** Independent directors and non-regular employees were included from 2022.
    *** Business partners in direct transactions with SK Networks headquarters have been subject to a pilot ethics training program since 2022.

  • Ethics Practice Survey

    SK Networks conducts an Ethics Practice Survey for employees at the headquarters and its subsidiaries to assess compliance with the Code of Ethics and the level of ethical practice culture. Ethical management for employees is supported by handling critical implications from survey results, including mutual ethics among employees, inspection of Social Value-degrading elements, and continuous improvement of the ethical management practice system.

    Ethics Practice Survey History
    The table provides the results of the Ethics Practice Survey and consists of categories (SK Networks and its subsidiaries/subsidiaries), 2019, 2020, 2021, 2022, and 2023.
    Category 2019 2020 2021 2022 2023 2024
    SK Networks, subsidiaries, and second-tier subsidiaries* No. of participating employees
    (Unit : person)    		 3,705 3,537 4,125 3,985 3,963 2,883
    Percentage of participating employees
    (Unit : %)    		 76.0 68.8 82.1 79.7 81.8 85.9

    * From 2019 to 2021, the Ethics Practice Survey had been implemented in six companies (SK Networks (incl. Walkerhill), SK Networks service, SK Magic, SK Magic service, SK Rent-a-car, SK Rent-a-car service). From 2022 to 2023, Ethics Practice Survey was expanded to eight companies (the existing six companies + MINTIT and Cartini) From 2024, the Ethics Practice Survey has been implemented in five companies (SK Networks (incl. Walkerhill), SK Networks Service, SK Magic, MINTIT, SK Electlink).

  • Ethics Management Practice Pledge

    On the first business day of each year, all employees are encouraged to participate in the Ethics Practice Pledge. Along with the employees’ voluntary actions, we aim to enhance awareness of ethical management and establish a transparent corporate culture.

  • Ethics Practice Workshop

    Each year, SK Networks holds an Ethics Practice Workshop for all employees to elevate the level of their ethical management. During the Ethics Practice Workshop, participants watch videos or have discussions after reviewing pre-distributed materials related to ethical issues such as workplace bullying and conflict of interest at work, followed by sharing areas of improvement for practicing ethical management. In addition, organizations are selected and awarded the Ethics Management Workshop Excellence to internalize the ethical practice culture in each company, including subsidiaries.

    Ethics Practice Workshop History
    The table provides the implementation results of the ethical management practice workshop and consists of categories (SK Networks and its subsidiaries/subsidiaries), 2019, 2020, 2021, 2022, and 2023.
    Category 2019 2020 2021 2022 2023 2024
    SK Networks, subsidiaries, and second-tier subsidiaries* No. of participating organizations
    (Unit : number)    		 414 393 549 419 393 414
    Percentage of participating organizations
    (Unit : %)    		 95 98 98 98 99.8 100

    * From 2019 to 2021, the Ethics Practice Survey had been implemented in six companies (SK Networks (incl. Walkerhill), SK Networks service, SK Magic, SK Magic service, SK Rent-a-car, SK Rent-a-car service).
    * From 2022 to 2023, Ethics Practice Survey was expanded to eight companies (the existing six companies + MINTIT and Cartini)
    * From 2024, the Ethics Practice Survey has been implemented in five companies (SK Networks (incl. Walkerhill), SK Networks Service, SK Magic, MINTIT, SK Electlink).

Internal Audit

SK Networks conducts internal audits comprising routine audits, compliance checks, self inspection system, and investigations into ethical violations. To conduct its routine audit, SK Networks annually develops and evaluates a risk pool encompassing all of its business sites, subsidiaries and supporting organizations at home and abroad. This process reflects measurement and diagnosis results from SK Group and third-party institutions, risk check findings conducted through the voluntary inspection system and ethical practice surveys. Subsequently, an annual routine audit plan is developed for businesses and organizations identified as having high risks, with audit targets being finalized upon reporting to and approval by the Audit Committee. Furthermore, beyond mere audit execution, we systematically monitor compliance with recommendations and regularly report our findings to the Audit Committee to ensure adherence to applicable guidelines. Throughout the routine audit, we assess and enhance the effectiveness of governance structure, risk management, and control processes to assist the Company in meeting its business targets. Additionally, we inspect unethical issues as they arise.

The self inspection system was established in 2011 with the aim of creating risk inspection manuals for each business area and conducting annual inspection of all SK Networks’ businesses and supporting organizations. Updated annually, these manuals are configured to assess and evaluate risks specific to each business area, including HR management, cost management, procurement/business partner management, revenue/credit management, investment management system, inventory management, extraordinary risk management. The scope of the inspection encompasses not only financial risks in each area but also scenarios that may be linked to unethical issues. These include situations such as solicitation of employment, unethical issues that could arise from businesses or positions competing with the Company, moral hazards related to the abuse or misuse of the Company properties by executives or employees, self-approval of expenditures by individuals with authority, illegal fund expenditures, and violation of procurement policy. High-risk items identified during the self inspection system process are directly examined by the Audit Office, which also verifies the adequacy of the self inspection system results and evidence provided by all businesses and supporting organizations.

SK Networks, along with all its subsidiaries, operate a range of ethical reporting channels both online and offline, including website, face-to-face counseling, and mailing services. Counseling requests and informant reports are managed with transparency and fairness in accordance with established reporting procedures. Customer complaints regarding services are directed to the relevant business units, while all other informant reports, including unethical issues, are directly investigated by the Audit Office. *Reports concerning subsidiaries are investigated in cooperation with the applicable subsidiary.

SK Networks conducts internal audits of all domestic and international business sites and subsidiaries, regularly reporting audit findings to the Audit Committee. Depending on the inspection results, opportunities for improvement are integrated into management activities, and corrective actions are promptly taken upon discovery of violations. In addition, comprehensive response strategies are developed and implemented in consultation with relevant departments as necessary. In 2023, violations of internal control guidelines were identified in areas such as information protection (document security) and inappropriate business handling, leading to corrective actions and process improvement. The Audit Committee also received reports on findings and results of corrective actions for each quarter. At the same time, violation findings and action results are communicated enterprise-wide and incorporated into internal ethical management program materials including ethics education and ethical practice workshop to prevent the recurrence of identical issues.

* For cases received by subsidiaries, investigations are conducted in cooperation with the respective subsidiary

Overview of Internal Audits
This table provides Overview of Internal Audits information and consists of year, audit target business, and audit details.
Category 2021 2022 2023
Routine audit / Compliance Check Voluntary Inspection Ethical Violation Report Investigation Routine audit / Compliance Check Voluntary Inspection Ethical Violation Report Investigation Routine audit / Compliance Check Voluntary Inspection Ethical Violation Report Investigation
SK Networks O 6 O 14 O 18
ICT Marketing O O O O O
Speedmate O O O
Global Trading O O O
Global Investment O O O O
Staff O O O O O
Walkerhill O O O O
SK Magic O O 23 O 27 O 16
SK Rent-a-car O O 26 O 13 O 24
SK Networks Service O 1 O O 1 O O 3
MINTIT N/A - O -
Cartini N/A - O O 1
Total 56 55 62

* The number of report investigations does not include customer complaints regarding services, which are forwarded to the relevant business organizations.
* MINTIT and Cartini were incorporated in October, 2021 and classified as ‘subsidiaries spun off less than a year ago’ during the voluntary inspection in July, 2022. Therefore, they were excluded from the scope of the inspection at that time and included in the scope starting from 2023.
* Over the past three years, all business sites and subsidiaries underwent one or more internal audits (routine audits, compliance checks, voluntary inspections, ethical violation report investigation, etc.), as these audits are required to be conducted at least once every three years.

Fair Trade Compliance Program

SK Networks’ Fair Trade Compliance Program (CP) is an internal compliance system established and operated with the goal of fair trade-related compliance. SK Networks introduced the CP in 2002 and has been presenting CP operation as an agenda for the BOD every year. Through the CP operation, we propose clear and concrete fair trade-related codes to our employees and minimize the risk of legal violations that can occur during business through preventive activities.

Operating Compliance Council

SK Networks operates the SK Networks Compliance Council, which includes the head office (including Walkerhill) and seven subsidiaries and sub-subsidiaries. This council ensures that all participating companies are committed to fulfilling their social responsibilities in compliance management and fair trade, continuously striving to elevate their compliance levels. The council is structured around three areas: Legal Affairs, Fair Trade, and SHE (Safety, Health, Environment). Through its activities, the council facilitates the sharing of necessary regulatory information, educational resources, and lessons learned among the member companies. These interactions strengthen proactive prevention and enhance the ability to respond to issues effectively.

* SK Networks Service, SK Magic, SK Magic Service, Mintit, SK Electlink, En-core, SK Speedmate

SK Networks Compliance Council

  • Participants

    SK Networks(including Walkerhill) and seven first and second-tier subsidiaries

  • Modules

    Legal / CR / SHE

  • Members

    48
    (as of 2024)

  • Key Activities

    Improvement of compliance sensitivity and response capacity, education and information sharing

Fair Trade Compliance Committee

SK Networks appoints a compliance officer from the BOD and operates an organization dedicated to compliance management. Through the voluntary compliance committee, we are preparing a foundation for compliance by deriving key ethical issues and consequently inspecting the status of fair trade-related compliance for each business, promoting fair economy, enhancing trade transparency, and sharing the key Fair Trade policies with the relevant divisions.

This is an image of an anti-corruption policy. Please refer to the following for an explanation.
Anti-Corruption Policy

SK Networks has specified and developed the following Anti-Corruption Policy in a bid to ensure sustainable happiness of its people and stakeholders and foster a fair and transparent corporate culture.

  1. All SK Networks people do not engage in corrupt acts.
  2. All SK Networks people uphold domestic and international anti-corruption laws as well as corporate regulations/guidelines that are applicable to their business practies.
  3. SK Networks implements anti-corruption control systems in conformity of global standards and continues to improve anti-corruption controls by monitoring the operation of the control systems.
  4. SK Networks strictly disciplines its people in a transparent manner when they fail to comply with ethical standards and anti-corruption policies.
  5. SK Networks guarantees the authority and independence of organizations and individuals responsible for enforcing anti-corruption controls.
  6. All Members of SK Networks' management leadership spare no support in ensuring the efficient operation of anti-corruption control systems.

CEO & President
Lee, Ho-jeong