Dear employees of Dongkuk Steel,

I would like to extend my sincere gratitude and encouragement to all of you for fulfilling your responsibilities in your respective roles, even amidst the challenging internal and external business environments.

Recently, the business environment in the steel industry has become increasingly complex due to global economic trends and changes in market structures. In times like these, we must focus our capabilities on verifying whether the principles and foundations that Dongkuk Steel has upheld are functioning properly and further solidifying the basics of our corporate operations.

Among these basics, "ethical management" serves as the fundamental base.
Ethical management is not a new challenge; rather, it is the process of more rigorously practicing the principles we have maintained and ensuring they take firm root in our daily operations. While Dongkuk Steel continuously monitors ethical risks across all business areas, we must also consistently supplement and operate our ethical management system so that every employee can judge and act under ethical responsibility. To ensure the practical settlement of ethical management, I would like to emphasize the following:

First, all employees must work together to foster a healthy corporate culture based on ethical awareness.
To ensure that our Code of Ethics operates effectively in the field, we are continuously strengthening employees' familiarity with and adherence to ethical norms through the operation of ethical practice programs and the signing of ethical pledges by all employees. I ask all employees to remain vigilant to ensure that no actions occur that undermine the health of our organization, such as financial transactions, excessive gifts/congratulatory expenses, personal use of company assets, abuse of authority, verbal abuse, or violations of sexual ethics.

Second, we must establish ethical and fair relationships in all transactions with external stakeholders, including customers and partners.
We are managing our processes to ensure that ethical standards are applied not only to internal employees but also to overall external transactions, such as through the inclusion of special clauses for ethical practice in contracts with partners. Please always remain mindful that improper acts—such as receiving unfair money, goods, entertainment, or favors, as well as solicitation or inappropriate behavior using one's position—can lead to risks for the entire company beyond individual judgment. We must engage in all external transactions with a fair and responsible attitude.

Dear employees, ethical management is not an optional choice, but the very way we work. For the standards and systems established by the company to hold meaning in the field, the judgment and actions of each and every one of you must, above all, align with those standards. Please remember once again that small differences in judgment determine the trust of the organization and eventually lead to corporate competitiveness. Dongkuk Steel will continue to build trust with stakeholders through management faithful to basics and principles. I ask all of you to join us in this process through responsible practice in your respective positions.

January 2026 Sam young Choi, CEO

• We, Dongkuk Steel, have the following management philosophy as the basis of our Ethics Charter: “We produce products and services necessary for the advancement and improvement of human life, and furthermore, contribute to the development of culture.”
• As a member of the international community, we abide by social ethics and norms and aim to become a top-notch company in the 21st century that pursues common prosperity for employees, customers, business partners, shareholders, the nation, and human society.
• We pursue ethical management that secures legitimate profits and supports long-term growth in order to seek sustainable growth.
• We conduct business in an honest and fair manner according to a high level of ethics, and strive to prevent corruption and create a clean business climate.
• We respect the personality of each employee, do not discriminate against them, provide fair opportunities and evaluation, and strive to improve their health and quality of life.
• Accordingly, we have established the Dongkuk Steel Ethics Charter and use it as the standard for all Dongkuk people's behavior and value judgment.

Classification	Main Content
Purpose	The purpose of this Code of Ethics (hereinafter referred to as the 'Code') is to provide executives and employees withe the right decision-making and ethical judgment standards to comply with the Ethics Charter
Target	The Code applies to all executives and employees (including non-regular workers, hereinafter referred to as “Dongkuk people”) belonging to Dongkuk Steel (hereinafter referred to as the “company”).
Company's Basic Policy	1. Our principle is to nurture talented people, have equal opportunities, and make equal efforts. 2. The company shall recognize the dignity and value of human beings and create a workplace atmosphere where employees can work freely and creatively in a safe and pleasant workplace. 3. The company shall contribute to customers, partners, peers and society through fair business activities based on market economy principles. 4. The company shall strive to reduce costs, improve productivity, and contribute to the interests of shareholders through rational investment and sound management. 5. The company shall provide reasonable treatment according to ability, effort, and contribution regardless of gender, educational background, religion, or region of origin through fair personnel management.

Classification	Main Content
Purpose	The purpose of this Practice Guidelines for Code of Ethics (hereinafter referred to as ‘Practice Guidelines’) is to prescribe matters necessary for decision-making, behavioral standards, and reporting procedures regarding ethical issues Dongkuk people face in their duties and daily lives.
Definitions	1. Money and valuables: It refers to securities such as cash, checks, and gift certificates, as well as all items such as gifts and souvenirs 2. Entertainment and hospitality: It refers to benefits such as eating, drinking, sports, watching plays, etc. 3. Convenience: It refers to support other than money and valuables and entertainment and hospitality, such as transportation, lodging, and event support 4. Reporters: It refers to all executives and employees who are obliged to report in relation to receipt of money, valuables, etc. and recognition of such fact 5. Interested parties: It refers to all internal and external natural persons, corporations, and organizations, such as business partners, suppliers, and partner companies, that are affected by the actions or decisions of executives and employees in relation to work. 6. Department heads: It refers to more than the executives and team leaders in charge as a position manager. 7. . Improper solicitation: It refers to 15 types of solicitation or brokerage acts stipulated in the Anti-Solicitation and Graft Act in relation to anti-corruption regulations that impede the performance of duties with integrity and fairness, such as causing public officials, etc. to violate laws or abuse their position or authority. 8. . Prohibition of giving money and valuables: It refers to the prohibition of giving money, valuables, etc.stipulated in the Anti-Solicitation and Graft Act to public officials, etc. in relation to the anti-corruption regulations, regardless of whether they are related to their duties, under the pretext, or in return. However, matters recognized as exceptional under the Improper Solicitation and Graft Act are excluded.

Classification	Main Content
Prohibited Cases	Cases of receiving money, valuables, entertainment, hospitality, convenience, etc. from customers
Code of Conduct	1. We shall not directly or indirectly receive, promote, or tolerate inappropriate money, valuables, entertainment, or convenience from customers. 2. If there is an offer as above, we shall politely decline it. 3. However, souvenirs that are acceptable in terms of social norms provided to attendees at events organized by the customer, such as souvenirs marked with the customer's company logo, are excluded. 4. If we receive without being aware of it, we shall return it immediately. 5. If we unavoidably receive it against our will or it is difficult to return, we shall submit it to the Ethics Management Team within 3 working days from the date of receipt.

Classification	Main Content
Prohibited Cases	1. An act in which superiors and persons in higher ranks/positions demand money and valuables, or entertainment from subordinates by using their position 2. An act of a subordinate employee providing money, valuables, gifts, entertainment, etc. to his/her superiors and persons in higher ranks/positions in private 3. An act of giving to the inspector (department) or receiving from the examinee (department) unfair convenience when performing various evaluation and inspection tasks 4. An act of mobilizing subordinates for private affairs by superiors and persons in higher ranks/positions 5. An act of suggesting or inducing the provision of money, valuables or entertainment between executives and employees
Code of Conduct	1. It is prohibited to personally give gifts to superiors and persons in higher ranks as it may affect promotion, performance, and annual salary However, money and valuables provided by superiors and persons in higher ranks to persons in lower ranks for the purpose of boosting morale, such as consolation, encouragement, and rewards, are permitted. 2. We shall report to the Ethics Management Team if the superiors or persons in higher ranks ask for money, valuables, entertainment, etc. 3. If persons in lower ranks provide personal money, valuables, entertainment, etc., superiors or persons in higher ranks shall firmly reject them and fully explain the purpose of the company's ethical management to the employee concerned.

Classification	Main Content
Prohibited Cases	1. Financial transactions between executives and employees shall be prohibited, regardless of whether interest is received or not. 2. Loan guarantees between executives and employees shall be prohibited. 3. We shall not give or receive money and valuables (under any name), such as farewell money, when superiors and persons in higher ranks/positions are on overseas business trips or transferred to affiliates.
Code of Conduct	1. Financial transactions between executives and employees shall be prohibited, regardless of whether interest is received or not. 2. Loan guarantees between executives and employees shall be prohibited. 3. We shall not give or receive money and valuables (under any name), such as farewell money, when superiors and persons in higher ranks/positions are on overseas business trips or transferred to affiliates.

Classification	Main Content
Prohibited Cases	1. An act of personally embezzling or temporarily using the company's public funds, such as income, etc. 2. An act of using corporate cards and company-owned securities (parking cards, gift certificates, etc.) for personal use
Code of Conduct	1. Private use of the company's public funds, such as income, etc., shall be prohibited regardless of the excessive amount or reason. 2. The public funds, such as income, etc. shall be managed with a bank account under the name of the company. 3. Income shall be processed without delay, and expenditure shall be thoroughly documented. 4. We shall not falsely claim the company budget for personal gain. 5. We shall not purchase goods and services for private use using corporate cards or company-owned securities (parking cards, gift certificates, etc.).

Classification	Main Content
Prohibited Cases	1. Executing the budget in a manner that differs from the initial goal without following due procedure 2. An act of failing to handle irregular income following due procedure 3. Budget waste due to inappropriate usage or over-execution 4. An act of turning corporate cards and company-owned securities (parking cards, gift certificates, etc.) into cash
Code of Conduct	1. The budget must be utilized for its intended purpose, and if diversion is inevitable, it shall be carried out according to an appropriate procedure. 2. Irregular income from the sale of equipment and damage compensation must be regarded as income in line with the company's standards and processes. 3. Efforts must be placed to guarantee that the budget is carried out in a reasonable and efficient manner 4. The cashing of corporate cards or securities (parking cards, gift certificates, etc.) is strictly forbidden.

Classification	Main Content
Prohibited Cases	1. An act of accepting or receiving money, valuables, gifts, travel (expenses), entertainment, etc. from interested parties 2. An act of demanding or inducing money, valuables, entertainment, etc. from interested parties 3. An act of receiving excessive money for congratulations and condolences from interested parties
Code of Conduct	1. Receipt of money, valuables, gifts, entertainment, etc., beyond the level accepted by social norms, shall be prohibited, regardless of whether it is in return, and receipt through family, relatives, or acquaintances shall also be regarded as an employee's own act. 2. If there is a proposal as above, we shall explain the company's ethical management policy and politely decline. However, souvenirs that are acceptable in terms of social norms provided to attendees at events organized by interested parties are excluded.