POSCO PRTECH

POSCO GYS Tech takes responsibility for respecting human rights to meet stakeholders' expectations and adopts the following as its basic stance regarding human rights management:

• · We comply with laws applicable everywhere POSCO GYS Tech conducts business activities and adheres to globally recognized human rights standards.
• · When faced with conflicting regulations in local countries, we seek ways to adhere to global human rights standards.
• · Serious risks of human rights violations are treated as significant management issues by the company.

POSCO GYS Tech respects the human rights of all employees and shares the results of preparing guidelines and risk management systems for human rights management according to international standards and company regulations for risk prevention and improvement.

• · Establishing a chemical management system based on the MSDS system for proper use of chemical substances
• · Identifying and improving harmful factors through work environment measurement and evaluation
• · Investigating and controlling harmful factors for the prevention of musculoskeletal disorders
• · Resolving discomfort and improving the performance of personal protective equipment from the user’s perspective

The human rights policy of POSCO GYS Tech applies to all employees, and the company encourages and, when necessary, supports partners, such as suppliers and collaborators, to comply with international standards and POSCO GYS Tech’s human rights management policy. The company respects the human rights of all members and endeavors to prevent any acts that constitute human rights violations.

• ① Prohibition of Discrimination/Harassment
  • - We do not discriminate in employment conditions such as employment, promotion, education, compensation, and welfare based on race, nationality, gender, age, education, religion, region, disability, marital status, or gender identity.
  • - We ensure employment conditions that allow for a dignified life, abiding by the statutory working hours, maintaining reasonable working hours, and providing adequate overtime compensation.
  • - We offer educational opportunities to employees, respect various cultural differences, and maintain an appropriate working environment conducive to focus on tasks.
  • - We refrain from language, physical, and visual behaviors that cause discomfort to others, including acts of sexual harassment infringing on individual rights, and protect privacy and personal information.
  • - Disciplinary procedures are based on procedural fairness, referencing employment rules, personnel regulations, rewards, and penalties guidelines, and considering the facts of employee misconduct.
  
  
• ② Prohibition of Forced Labor and Child/Adolescent Labor
  • - We prevent work from being performed involuntarily under mental or physical duress.
  • - We comply with national labor laws and international standards regarding minors' labor conditions and minimum working age.
  
  
• ③ Assurance of the Right to Collective Action and Collective Bargaining
  • - We comply with the constitution and labor relations laws that form the basis of human rights policy. We strive to respect and ensure employees' rights and protect the freedom of association and the right to collective bargaining.
  
  
• ④ Industrial Safety Assurance
  • - We build a safety culture enabling all employees to work in a safe environment and take appropriate measures against identified risks. Additionally, we support the establishment of safety management systems at partner companies.
  
  
• ⑤ Environmental Rights Assurance
  • - As responsible corporate citizens, we recognize environmental and energy concerns as critical elements of business activity and strive for sustainable, low-carbon, eco-friendly economic development.
  • - We efficiently utilize natural resources and by-products and strive to restore natural ecosystems and preserve biodiversity.
  
  
• ⑥ Protection of Local Residents’ Human Rights
  • - We ensure that the rights of residents, such as environment, occupational health and safety, and freedom of residence, are not infringed upon by the company’s business activities. Also, we respect local communities' autonomy and traditional values, complying with relevant laws/regulations and considering their opinions.
  • - Security personnel at the business location must refrain from behavior that infringes on human rights, causes discomfort, and comply with relevant local laws and international standards.
  
  
• ⑦ Protection of Customers’ Human Rights
  • - We take the necessary precautions according to legal standards to not harm customers’ life, health, and safety while providing products and services.
  
  
• ⑧ Responsible Supply Chain Management
  • - We require all key suppliers and partner companies to comply with their obligations to protect human rights.
  
  

POSCO GYS Tech conducts Human Rights Due Diligence to identify and mitigate any adverse impacts on human rights and to fulfill its responsibilities regarding its activities. This process includes identifying and assessing actual and potential effects on human rights, addressing identified issues, documenting responsive actions, and communicating how effects have been managed with relevant stakeholders.

POSCO GYS Tech identifies and reviews actual and potential adverse impacts on human rights that can arise from domestic and international business activities according to the following process:

• - When human rights-related risks are detected in primary domestic and international operations, we conduct Human Rights Due Diligence to analyze the situation and derive improvement measures.
• - Internal experts principally conduct the Due Diligence; however, external expert assistance can be sought if needed.
• - In this case, substantive interviews may be conducted with potentially affected groups and relevant stakeholders.
• - During Human Rights Due Diligence, it is essential to identify both potential and actual impacts. Potential impacts are shared across the company and addressed through relevant procedures to prevent and mitigate. In contrast, real impacts that have already occurred must be subjects of remedy and resolution.
• - The Human Rights Due Diligence utilizes a checklist to assess critical elements related to human rights management.

Based on the facts discovered during Human Rights Due Diligence, a response system is established to prevent and mitigate adverse impacts on human rights, and follow-up measures are implemented.

• ① Establishment of an Internal Response System
  • - The roles and responsibilities of relevant departments are clearly defined to address identified issues.
  • - Internal decision-making, budget allocation, and monitoring procedures are applied to respond to such impacts effectively.
  • - Issues identified through Human Rights Due Diligence are communicated to relevant departments and managed as essential matters.
  
  
• ② Follow-up Measures and Remedies
  • - Necessary measures are taken to prevent and mitigate any adverse impacts on human rights that have occurred or have the potential to occur.
  • - Even with the best policies and procedures, efforts are made to improve any unforeseen adverse impacts, whether alone or in collaboration with other entities.
  • - Even if POSCO GYS Tech has not directly violated human rights, it plays a specific role in improvements when adverse human rights impacts are related to the company’s operations, production, or services through relationships with other entities (e.g., suppliers), although it has no direct responsibility.
  • - When the company influences to prevent and mitigate human rights violations, it must be utilized; if not, cooperation with relevant entities can enhance influence.
  • - A grievance redressal system is operated as an effective remedy, targeting stakeholders.
  
  

When stakeholders, including individuals and investors, raise concerns regarding human rights impacts, the company provides responsible explanations.

• - We conduct communications based on responsibility and transparency with stakeholders, considering various forms of communication such as face-to-face meetings, issuing official reports (e.g., audit reports), and utilizing online channels (e.g., the company’s official website) so stakeholders can easily access information.
• - When issuing official reports, we include actual and potential negative impacts and consider independent verification procedures to enhance the reliability of the report content.
• - We provide information that helps stakeholders assess whether the company appropriately addresses specific human rights impacts.

By internalizing human rights due diligence results into organizational culture and system improvement activities, we induce substantive improvements in human rights management.

• - We conduct activities to internalize human rights management as organizational culture, including education on the necessity of human rights management for all employees, training on relevant norms, and sharing success and failure cases.
• - We continuously improve the human rights management system through expert consultation, communication with stakeholders, and identifying areas for improvement through system execution.

POSCO GYS Tech operates a grievance redressal system targeting stakeholders as an adequate remedy. The raised issues are discussed promptly, and utilizing existing means such as the Unethical Behavior Counseling and Reporting Center; we strive for quick and reasonable solutions for individuals and communities affected by negative impacts. [Contact: ethicsgys@poscogystech.com] The grievance redressal system performs the following essential functions related to the company’s responsibility to respect human rights:

• - Facilitates the easy identification of negative impacts on human rights and provides a pathway for directly affected stakeholders to raise issues.
• - Addresses the reception of grievances and the redressal of victims promptly to prevent the spread of human rights damages.
• - Analyzes operational status to identify and improve issues in human rights policies and procedures.