1. Purpose

The purpose of this Compliance Policy is to ensure that all members strictly comply with laws and regulations in the conduct of all business and operational activities, and to contribute to sound industrial development through transparent and fair business practices.

2. Governance

Dongkuk Steel defines “compliance” as adherence to fair trade regulations and obligations applicable to the company (such as the prohibition of unfair subcontracting practices, collusion, and unfair support activities), and refers to the series of activities designed to implement this in practice as the “Compliance Program,” which is operated according to an annual plan.
To establish a culture of compliance, Dongkuk Steel has designated the Legal Affairs Team as the Compliance Office. The Compliance Office is responsible for the overall operation of the Compliance Program, including assessing the company’s compliance risks and conducting compliance training for executives and employees. Additionally, departments related to fair trade—such as Sales and Purchasing—are organized into compliance management units, and staff members at the Deputy Director level or higher are appointed as “Compliance Managers” within their respective departments.

3. Scope of Application

This Compliance Policy applies to all executives and employees of Dongkuk Steel. Furthermore, Dongkuk Steel executives and employees shall comply with this Compliance Policy in their business dealings with partners, suppliers, and others, and shall encourage all stakeholders to respect the Compliance Policy.

4. Code of Conduct for Compliance

1) Dongkuk Steel operates and adheres to the company’s compliance program to ensure fair and transparent business practices.
2) Dongkuk Steel makes judgments and acts based on principles and laws, and does not compromise on unethical choices.
3) Dongkuk Steel respects existing customs but carefully considers their legality and works together to improve them within the bounds of the law.
4) Dongkuk Steel aims to supply the best products at competitive prices and pursues fair competition based on mutual respect.
5) 5) Dongkuk Steel conducts its business through legitimate means, promotes sustainable shared growth with its business partners, and pursues the value of giving back to society.

5. Compliance with the Four Key Principles

Dongkuk Steel respects the human rights of all employees and has established a human rights risk management process to prevent and address risks; it discloses the results of this process to stakeholders through its Sustainability Report and other channels.

1) Compliance with Guidelines for the Fair Selection (Registration) of Business Partners
Dongkuk Steel establishes fair selection criteria and procedures for the selection and management of business partners, provides equal opportunities to commence business transactions, and transparently discloses the results of registration or deregistration.
2) Compliance with Guidelines for the Establishment and Operation of a Subcontracting Review Committee
The company shall establish and operate an internal review committee to independently review and deliberate on matters such as legal compliance to ensure fair subcontracting transactions.
3) Compliance with practices for proper issuance and retention of written documents
In the process of concluding subcontracting agreements and conducting transactions, the company shall specifically set forth in writing key information necessary for the transaction and the requirements the company must comply with, and shall retain such documentation.
4) Compliance with practices for proper contract execution
The company shall select the method of contract execution in accordance with certain standards, taking into account the nature of the transaction, and shall enter into and fulfill contracts that specify desirable terms to be included by the contracting parties, while ensuring the other party’s right to self-determination is guaranteed.

6. Risk Assessment

Dongkuk Steel appropriately and effectively controls risks by identifying, analyzing, and evaluating compliance obligations and risks to determine priorities.

1) Risk Identification
a. The Company identifies the compliance obligations—such as the Fair Trade Act and the Subcontracting Act—that must be observed in the course of conducting business.
b. The risk assessment officer analyzes situations where compliance risks may arise for each business activity and stage, and records them in the compliance risk assessment form.
2) Risk Analysis and Assessment
The identified risks are classified into three levels (high, medium, low) based on their likelihood of occurrence and severity of impact, and priorities are determined.
3) Establishment and Implementation of Control Measures
Establish control measures for compliance risks and evaluate their suitability and effectiveness. If existing control measures are deemed insufficient, identify areas for improvement, take corrective actions, and continuously monitor whether the control measures are functioning properly.

7. Compliance Training

The Company may conduct compliance training at least once a year to strengthen the ability of employees to independently recognize and assess compliance risks while performing their duties.

8. Inquiries and Reports

Anyone who has questions regarding this Compliance Policy or becomes aware of a violation of this Compliance Policy by a Dongkuk Steel employee may make an inquiry or file a report as described below; violations will be addressed and punished in accordance with Company regulations.

a. Inquiries regarding the Compliance Policy: Legal Affairs Team
b. Tips and Reports: Ethics Reporting Center

     [Web] www.dongkuk.com/ko/csr/report
     [MMS] 1666-1954
     [Mail] Ethics Management Team, 12th Floor, 19 Euljiro 5-gil, Jung-gu, Seoul (Zip Code 04539)

Supplementary Provisions
These regulations shall take effect on May 7, 2026.