InBody has established an ethics policy that all employees must comply with when working.We morally resolve conflicts that may arise between employees and the company, the company and other partners, and fulfill our social responsibilities through transparent and fair compliance and ethics management.
Chapter 1: Introduction
Our company strives to enhance corporate value through enterprising and efficient management activities, growing and developing together with all stakeholders, including shareholders. As a publicly listed company, we diligently fulfill our obligations and responsibilities to become a trusted corporation. We respect all domestic and international laws and market orders, lead by example in establishing fair trade, respect social values and customs, and contribute to national and societal development through various social contribution activities. To this end, our company establishes and actively practices a code of ethics to foster a healthy and fair corporate culture.
Chapter 2: Attitude Towards Shareholders and Investors
- ①Protection of Shareholder Rights
- The company protects the rights of shareholders and respects their legitimate demands and suggestions.
- The company discloses management information faithfully to build a mutual trust relationship with shareholders and investors, striving for the maximization of shareholder interests.
- ②Equal Treatment
- The company treats all shareholders, including minority shareholders, fairly and equally.
- The company always considers the interests of all shareholders when making management decisions, ensuring that the rights and interests of minority shareholders are not unfairly infringed.
- ③Proactive Information Provision
- The company records and manages accounting data according to generally accepted accounting principles, providing transparent financial status and management performance.
- The company provides accurate management information in a timely manner according to relevant laws, enabling investors and other information users to make rational investment decisions.
Chapter 3: Attitude Towards Customers
- ①Customer Respect
- The company always thinks and acts from the customer's perspective, striving to achieve customer satisfaction by providing the best products and services that customers can trust and be satisfied with.
- The company provides customers with accurate information about products and services without engaging in excessive promotion or advertising.
- ②Customer Protection
- The company protects the interests, safety, and personal information of customers, refraining from unfair practices.
- The company respects and complies with consumer protection laws.
Chapter 4: Attitude Towards Competitors and Partner Companies
- ①Fair Competition with Competitors
- The company respects the fair and free market economy order based on the principle of free competition and competes fairly with competitors.
- The company respects fair trade order and complies with fair trade laws.
- ②Fair Transactions with Partner Companies
- Through fair transactions with partner companies, the company builds mutual trust and cooperation for joint development.
- The company does not coerce any form of unfair practices or exert influence using its dominant position.
Chapter 5: Responsibility Towards Employees
- ①Fair Treatment
- The company does not discriminate unfairly against employees and provides fair opportunities based on abilities and qualities.
- ②Work Environment
- The company strives for the health and safety of employees in the work environment.
- The company respects the autonomy and creativity of each employee, offering fair opportunities for skill enhancement, supporting self-actualization along with talent development.
- The company respects the independent personality and fundamental rights of employees, creating an environment where they can freely make suggestions and proposals.
Chapter 6: Responsibility Towards Society
- ①Compliance with Domestic and International Laws
- As a member of the national and local communities, the company not only complies with various laws but also adheres to internationally recognized regulations.
- ②Contribution to National Economy and Social Development
- The company contributes to the national economy and social development through productivity improvement, job creation, faithful tax payment, and social contribution.
- ③Environmental Protection
- The company strives to protect nature and preserve a clean environment.
Chapter 7: Basic Ethics for Employees
- ①Establishing a Healthy Corporate Culture
- Employees share the company's management philosophy and empathize with the company's goals and values, faithfully performing the missions assigned to them according to the company's business policies.
- Employees foster an organizational culture based on smooth communication and mutual trust among superiors, subordinates, and colleagues.
- Employees perform their given duties to the best of their ability through legitimate means and comply with all relevant laws and company regulations related to their work.
- ②Prohibition of Conflicts of Interest
- Employees strive to prevent any actions or relationships that could conflict with the company's interests and prioritize the company's interests in case of a conflict between the company, individuals, or departments.
- ③Prohibition of Insider Information Usage
- Employees do not trade stocks using internal information obtained through their duties.
- Employees do not provide unpublished significant information that could affect stock prices to third parties without following legal procedures.
- ④Protection of Company Assets and Important Information
- Employees must protect the company's tangible assets, intellectual property rights, trade secrets, etc., and not use them for personal purposes.
- Employees do not engage in activities that use
- ⑤Prevention of Sexual Harassment
- Executives and employees are prohibited from engaging in any form of language or behavior that undermines healthy relationships among colleagues. This includes any physical, verbal, or visual actions that are recognized as sexually humiliating or inappropriate.
- ⑥No Political Involvement
- During working hours, executives and employees are not to engage in political activities within the company nor use the company's resources, personnel, or property for political purposes. While the company respects each employee's political rights and views, it is important that these views and activities are not perceived as representing the company's stance.
- ⑦Prohibition of Receiving Money, Valuables, or Entertainment
- Executives and employees must not accept money, gifts, or entertainment from business partners or other stakeholders. Similarly, they are prohibited from offering money, gifts, or entertainment that exceed social norms to stakeholders in connection with company business. Additionally, the exchange of money or excessive gifts or entertainment among employees is not permitted.
- ⑧Compliance with the Code of Ethics
- All executives and employees are required to adhere strictly to the Code of Ethics. Violations will result in accountability and appropriate actions. Any executive or employee who is compelled to act against the Code of Ethics, or becomes aware of any unfair practices, must report such incidents to the Ethics Department. In the event of a violation, the company will conduct a thorough investigation to prevent future occurrences and will implement necessary educational measures.
Chapter 1: General Provisions
Article 1 (Definitions)
The terms used in these Ethical Conduct Guidelines (hereinafter referred to as "Guidelines") are defined as follows:
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- 1. "Employees" refers to executives and staff of InBody Co., Ltd. (hereinafter referred to as "the Company"), including regular and contractual workers, and dispatch workers as defined by the Dispatch Workers Protection Act.
- 2. "Valuables" include, but are not limited to, money, securities, real estate, tangible goods, accommodation vouchers, membership cards, admission tickets, discount coupons, invitation cards, rights to use real estate, and any other forms of property benefits; food, beverages, entertainment such as golf, or provision of convenience such as transportation and lodging; debt forgiveness, employment opportunities, rights, and other tangible or intangible economic benefits.
- 3. "Sexual harassment" is defined as any sexual behavior or language by a superior or employee, exploiting their workplace status or related to work, that induces sexual humiliation or aversion in another employee.
Article 2 (Scope of Application)
- ①These Guidelines apply to all employees of the InBody Group affiliates.
- ②In specific cases defined by these Guidelines, they also apply to employees of partner companies.
Article 3 (Compliance Obligation and Responsibility)
All employees must be familiar with and adhere to these Guidelines, bearing responsibility for any violations.
Chapter 2: Fair Performance of Duties
Article 4 (Exclusion of Favoritism)
Employees must not grant undue favors or discriminate based on personal connections, such as familial, academic, religious affiliations, or other unjust reasons in the performance of their duties.
Article 5 (Prohibition of Personnel Requests)
- ①Employees must not induce others to make requests to personnel managers to influence unjustly their appointment, promotion, or transfer.
- ②Employees must not use their position to unjustly intervene in the appointment, promotion, or transfer of other employees.
- ③Employees must not solicit employment for themselves or others through clients.
Article 6: Prohibition of Job-related Commercial Activities, etc.
- ①Executives and employees are prohibited from engaging in any of the following activities related to their duties, except in cases where such activities are permitted under other regulations:
- 1. Privately providing labor or offering advice/consultation to individuals associated with their job functions and receiving remuneration for such services.
- 2. Acting on behalf of or providing advice, counsel, or information to opposing parties in disputes involving the company or in matters where the company has a direct interest.
- 3. Engaging in representation of foreign governments, institutions, corporations, and organizations, except when authorized by the Chief Executive Officer (CEO).
- 4. Assuming a role in another position that is related to their job duties, except when authorized by the CEO.
- 5. Conducting job-related actions deemed by the CEO as potentially hindering the fair and ethical execution of duties.
- ②Should the CEO ascertain that the actions of any executives or employees fall within the purview of the activities outlined in paragraph 1, they are required to instruct said executives or employees to cease or terminate such actions.
Article 7: Restrictions on Hiring Family Members
- ①Executives are strictly prohibited from exerting undue influence, such as directing the company to employ their family members.
- ②Employees responsible for personnel matters (including those with the capacity to influence personnel decisions) are strictly prohibited from exerting undue influence, such as directing the company to employ their family members.
- ③Employees responsible for the direction, supervision, regulation, or support of subsidiaries, etc., are strictly prohibited from exerting undue influence, such as directing the employment of their family members in the company's subsidiaries or related entities.
Article 8: Restrictions on Sole-Source Contracting
- ①Executives shall not enter into sole-source contracts (hereafter referred to as "sole-source contracts") for goods, services, or construction with the company, nor shall they allow their family members or related business entities to enter into sole-source contracts with the company.
- ②Employees responsible for contracting tasks shall not enter into sole-source contracts with the company, nor shall they allow their family members to enter into such contracts with the company.
- ③Employees responsible for directing, supervising, regulating, or supporting subsidiaries, etc., shall not enter into sole-source contracts with the company’s subsidiaries, nor shall they allow their family members to do so.
Article 9: Prohibition on Misuse of Budget
- ①Employees must not use the budget allocated for business purposes, such as travel expenses or business promotion expenses, for purposes other than its intended use, causing financial loss to the company.
- ②Employees must primarily use corporate cards for expense execution, ensuring that the use aligns with the purpose of the budget and complies with relevant laws and regulations.
Article 10: Handling of Unfair Orders Affecting Fair Job Performance
- ①Employees (including those of partner companies) must not give subordinates unfair orders that violate laws or regulations for their own or others' benefit, hindering fair job performance. Subordinates must follow legitimate orders related to their superiors' tasks.
- ②Criteria and types for determining unfair orders affecting fair job performance are as outlined in Appendix 1.
Article 11: Handling of Improper Requests from Politicians, etc.
- ①Employees must not be coerced into performing their duties improperly by public officials, politicians, or political parties, nor should they accept improper solicitations.
- ②Employees must not engage in election campaigning or activities influencing elections in violation of laws.
- ③Employees engaging in lawful political activities must take care not to be misconstrued as engaging in political activities of a specific political party.
Article 12: Transparent Accounting Management, etc.
- ①Employees (including those of partner companies) must manage accounting transparently and accurately, based on facts and in accordance with related laws and generally accepted accounting principles.
- ②Employees (including those of partner companies) must protect personal information obtained and managed in the course of their duties by faithfully performing all procedures according to related laws and regulations.
Article 13: Prohibition of Information Leakage
Employees must not disclose important information obtained in the course of their duties to third parties without prior permission or approval from the CEO.
Article 14: Legitimate and Transparent Acquisition and Management of Information
Employees must acquire all information through legitimate means, accurately record and report it, and must not manipulate or destroy information for the benefit of specific individuals or groups.
Article 15: Transparent Disclosure of Information
Employees responsible for information disclosure must respond faithfully and honestly to requests for disclosure of management information from the media and the public, in order to ensure transparency in management and build trust in external relations, in accordance with related laws and regulations.
Chapter 3: Prohibition of Receiving Undue Benefits, etc.
Article 16: Prohibition of Intervening in Rights
Employees shall not use their positions directly to gain undue benefits for themselves or enable others to do so.
Article 17: Prohibition of Private Use of Position
Employees (including those of partner companies) must not use or allow others to use the company's name or their position for personal gain in ways that are beyond the scope of their duties, such as public announcements or postings.
Article 18: Prohibition of Unfair Practices Using Job Authority
Employees shall not engage in unfair acts by exercising their job authority or the influence derived from their position or title.
Article 19: Prohibition of Mediation and Solicitation
- ①Employees (including those of partner companies) must not engage in mediation or solicitation that adversely affects the fair performance of duties of other employees for their own or others' undue benefits.
- ②Employees must not introduce job-related individuals to other job-related individuals for their own or others' undue benefits in relation to their duties.
Article 20: Prohibition of Private Use or Profit from Public Property
Employees must not use or profit from public property for private gain beyond the scope of their duties, such as using the company's name or position for private use, using budget-provided benefits like airline miles or reward points for private purposes without valid reasons, or using company vehicles for private purposes.
Article 21: Restrictions on Transactions Using Job-related Information
Employees (including those of partner companies) must not engage in transactions or investments related to stocks, real estate, or other property interests, or assist others in such transactions or investments using information obtained during the performance of their duties.
Article 22: Prohibition of Receiving Gifts, etc.
- ①Employees must not receive or solicit gifts, regardless of their connection to their duties or under any pretext such as donations
- ②Employees must ensure that their spouses or direct relatives do not receive or solicit prohibited gifts related to the employee's duties.
- ③Employees must not provide or promise to provide prohibited gifts to other employees or their spouses or direct relatives.
Article 23: Prohibition of Soliciting Private Labor
Employees (including those of partner companies) must not solicit or promise to solicit private labor from job-related individuals or employees based on the influence derived from their job authority, position, or title, except in cases permitted by other regulations or social norms.
Article 24: Integrity in Contracting and Performance
- ①Employees (including those of partner companies) must conduct all construction, services, and goods procurement bidding, contracting, and execution processes fairly and transparently, in accordance with the procedures established by relevant laws.
- ②Employees (including those of partner companies) must not demand prohibited gifts or impose unfair trade conditions or management interference using their dominant trading position during the bidding and contracting process.
Article 25: Prohibition of Forced Purchasing, etc.
Employees (including those of partner companies) must not coerce subcontractors to purchase or use specified goods or equipment designated by the employee, except for legitimate reasons related to maintaining or improving the quality of the subject matter.
Chapter 4: Fostering a Healthy Public Service Atmosphere
Article 26: Establishment of a Healthy Culture for Congratulatory and Condolence Occasions
- ①Employees (including those from partner companies) must lead by example in establishing a healthy culture for congratulatory and condolence occasions.
- ②Employees must not inform job-related individuals of personal congratulatory or condolence events, except in the following cases:
- 1. Informing relatives as defined in Article 767 of the Civil Code.
- 2. Informing current or former members of organizations where the employee has worked.
- 3. Announcing through internal communication networks, newspapers, or broadcasts that are accessible only to employees mentioned in the second point above.
- 4. Informing members of religious or social clubs to which the employee belongs.
Article 27: Prohibition of Sexual Harassment
Employees (including those from partner companies) must not engage in any of the following acts that cause sexual temptation or shame to each other:
- 1. Physical contact actions such as kissing, hugging, or embracing from behind
- 2. Touching specific body parts such as the chest or buttocks.
- 3. Forcing massages or caresses.
- 4. Making lewd jokes or talking about sexually explicit and offensive topics (including phone conversations).
- 5. Making sexual comparisons or evaluations about someone's appearance.
- 6. Asking about sexual facts or intentionally spreading sexual content.
- 7. Forcing or coercing into sexual relationships.
- 8. Forcing someone to sit beside them and serve them drinks excessively at dining occasions.
- 9. Displaying or showing pornographic photos, drawings, graffiti, publications (including those through computer communications or facsimile).
- 10. Deliberately exposing or touching one's own specific body parts related to sexuality.
- 11. Any other behavior or language recognized as inducing sexual humiliation or disgust according to social norms.
Article 28: Limitation on Speculative Activities
- ①Employees must not engage in speculative activities such as gambling or betting on golf, which deviate from social norms.
- ②Employees must not participate in activities such as playing mahjong, card games, golf, private overseas trips, or visiting entertainment establishments with job-related individuals.
Article 29: Compliance with Working Hours and Prohibition of Private Affairs During Work
- ①Employees must adhere to working hours and not engage in hobbies, religious activities, or other personal matters unrelated to work during these hours, causing disruptions to their job performance.
- ②Employees must not use the company's information and communication systems for any of the following acts:
- 1. Accessing pornographic sites, engaging in unhealthy chatting, gambling, gaming, etc.
- 2. Any other inappropriate use unrelated to work.
Article 30: Prohibition of Dignity-Damaging Behaviors
Employees must not engage in any acts that damage their dignity, regardless of whether these acts occur inside or outside the scope of their duties.
Article 31: Prohibition of Acts Detrimental to a Healthy Organizational Climate
Employees must not engage in any of the following acts that cause physical, mental, or psychological discomfort to other employees or deteriorate the work environment:
- 1. Physical aggression such as assault or injury.
- 2. Use of oppressive or derogatory language that infringes upon personal dignity.
- 3. Repeatedly spreading false information to tarnish someone's honor.
- 4. Filing false complaints, denunciations, or slandering that harm the company or an individual's rights.
- 5. Forming cliques or private organizations that hinder fair job performance due to school ties, regional connections, or familial relationships.
- 6. Assigning tasks well below an employee's ability or experience without reasonable justification or consistently excluding them from work without valid reason.
- 7. Deliberately not sharing work-related information, thereby continuously and repeatedly isolating someone with intent and aggressiveness.
- 8. Disregarding legitimate orders from superiors, thereby undermining the organizational hierarchy.
- 9. Neglecting, avoiding, or shifting assigned duties without a valid reason.
- 10. Any other act that severely damages an employee's physical, mental, or psychological health or infringes upon personal dignity.
Chapter 5: Measures in Case of Violation
Article 32: Reporting and Handling of Violations
- ①Anyone (including employees from partner companies) who becomes aware of a violation of these guidelines by an employee may report it to the HR department using the prescribed violation report form.
- ②The reporter must specify their own and the violator's personal details and the nature of the violation in detail on the report form.
- ③The HR department head must verify the reported violation, attach any explanatory materials received from the involved employee, and report to the CEO and the auditor.
Article 33: Protection of Reporter's Identity
- ①The CEO, auditor, and HR department employees must ensure the confidentiality of the reporter and the contents of the report, protecting the reporter from any disadvantage due to the report.
- ②Despite the foregoing, a reporter who has suffered disadvantages can request protective measures or redress from the HR department head, CEO, auditor, or the National Human Rights Commission of Korea. In such cases, the CEO and HR department head must take appropriate actions.
- ③If a reporter's own violation is discovered through their report, disciplinary actions against the reporter may be mitigated or exempted.
Article 34: Investigative Committee for Violation of Guidelines
- ①The CEO may operate the personnel committee as an investigative committee for a fair investigation of an employee's violation of the guidelines, if necessary.
- ②The investigative committee shall operate in accordance with the regulations of the personnel committee.
Article 35: Disciplinary Actions
- ①Based on the investigative committee's findings, the CEO may take necessary disciplinary actions against employees who have violated these guidelines.
- ②The types, procedures, and effects of such disciplinary actions shall follow the company's "Personnel Regulations."
Addendum (2022. 1. 11) Article 1 (Effective Date)
These guidelines shall be effective from September 1, 2022.
[Appendix 1] (Related to Article 9, Paragraph 7)
Criteria and Types of Unfair Orders
1. Criteria:
- • Whether the order violates laws, internal rules (regulations, rules, directives, etc.).
- • Whether the order could cause financial loss to the company.
- • Whether the order pursues private interests rather than public interests.
- • Whether the order abuses one's position or authority.
- • Whether the order coerces behavior despite guaranteed autonomy.
- • Any other significantly unreasonable forced behavior.
- • Directing the selection of a specific company for goods purchases or various contracts without a valid reason.
- • Directing the execution of budgets for personal purposes.
- • Giving orders for personnel matters based on irrational considerations such as regional ties, familial relationships, or school ties.
- • Directing the notification of personal events to job-related individuals, etc.
2. Types of Unfair Orders:
- • Orders that violate regulations or deviate from their original intent.
- • Orders to use company vehicles or other public property for personal purposes.
- • Orders to select a specific company for goods purchases or various contracts without a valid reason, or to change contract conditions and methods.
- • Orders to execute budgets contrary to these guidelines.
- • Orders influencing specific employee recruitment, promotion, or transfer, unduly affecting personnel matters.
- • Orders to handle personal affairs using the superior's position or authority.
- • Orders requesting favors, mediation, or conveniences from job-related individuals.
- • Orders to notify job-related individuals of personal events.
- • Any other orders that violate laws or regulations and significantly harm the fair performance of duties.
- Whistleblowing Guidance
- We are accepting reports on unethical behavior that contradicts the ethical management of the company and its employees. The confidentiality of the whistleblower is absolutely protected. Please provide the information based on facts and write in detail according to the 5W1H principle.
- Whistleblowing Processing Procedure
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Receipt Content Verification Investigation Initiation Investigation Completion Conclusion Processing Results