Kumho Tire

1. Sustainable natural rubber policy or commitment for all its operations?

This indicator is disabled as the company does not operate rubber plantations.

2. Sustainable natural rubber policy or commitment applies to all suppliers?

The company has a policy for sustainable natural rubber however, it is unclear if this policy applies to all suppliers of the company.

3. High-level position of responsibility for sustainability?

The company reports it has an 'ESG Management Committee' in place responsible for decision-making on key ESG issues. This committee comprises a total of 11 members, with the CEO participating as the chair and the heads of major divisions participating as members. However, the high-level responsibility for sustainability within this committee, excluding the board members is unclear.

4. One or more members within the board of the company have responsibility for sustainability?

ESG Management Committee chaired by the CEO.

5. Percentage or number of women in senior management team?

The company reports on the number of 'executives' but has not specified the percentage or number of women on the team.

6. Percentage or number of women board members?

11% - The company reports one woman director on its board out of the total nine board of directors. Data as of 2022.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with natural rubber production?

[Externally verified] UNGC, WBCSD, and WBSD Tire Industry Project.

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with natural rubber production?

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2022.

10. Reports through standardised reporting systems?

The company's latest sustainability report is prepared in accordance with the Core Option of GRI Standards. This information is externally assured by BSI Group Korea.

11. Climate risks assessment available?

The company has conducted and published an assessment of climate-related risks including actual and potential impacts of climate change on the company; metrics, targets, and processes used to assess or manage climate risks; responsibilities. However, the information reported is not externally verified.

12. Lists countries and operations?

Manufacturing (China, USA, Vietnam, the Republic of Korea).

13. Lists countries sourcing from?

14. Total land area managed/controlled for natural rubber (ha)?

This indicator is disabled as the company does not operate rubber plantations.

15. Total natural rubber planted area (ha)?

This indicator is disabled as the company does not operate rubber plantations.

16. Scheme smallholders/outgrowers planted area (ha)?

This indicator is disabled as the company does not operate rubber plantations.

17. Unplanted area (areas designated for future planting) (ha)?

This indicator is disabled as the company does not operate rubber plantations.

18. Conservation set-aside area, including HCV area (ha)?

This indicator is disabled as the company does not operate rubber plantations.

19. Maps of estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

20. Management plans for natural rubber production are available for all estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

21. Monitoring of management plan implementation available for all estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

22. Maps of scheme/outgrower smallholders?

This indicator is disabled as the company does not operate rubber plantations.

23. Names and locations of all third-party supplying industrial estates/management units?

The company reports it has sourced from 530 supplier facilities in 2021. However, the names and locations of these facilities are not reported.

24. List of jurisdictions where sourcing from smallholders?

25. Number of company owned natural rubber processing facilities?

This indicator is disabled as the company does not operate rubber plantations.

26. Names and locations of company owned natural rubber processing facilities?

This indicator is disabled as the company does not operate rubber plantations.

27. Number (or percentage) of company-owned processing facilities that source from company-owned operations and third parties?

This indicator is disabled as the company does not operate rubber plantations.

28. Reports total volumes (or percentages) sourced by company-owned processing facilities that come from company's own operations and third-parties?

This indicator is disabled as the company does not operate rubber plantations.

29. Number of third party supplying processing facilities?

30. Names and locations of all third party supplying processing facilities?

31. Number (or percentage) of third party supplying processing facilities that source from their own plantations and third party plantations?

32. Reports total volume (or percentages) sourced from third-party supplying processing facilities that come from the supplying facilities' own operations and third parties?

33. Total volume (or percentage) sourced for manufacturing that comes from intermediary traders rather than directly from processing facilities?

34. Time-bound commitment to achieve 100% traceability to processing facility level?

The company only commits to supporting the traceability of natural rubber till an appropriate jurisdictional level to confirm or control the conformity of procured natural rubber with the GPSNR Policy components. However, a time-bound commitment for 100% traceability is not reported.

35. Percentage of supply traceable to processing facility level?

36. Time-bound commitment to achieve 100% traceability to industrial plantation level?

The company only commits to supporting the traceability of natural rubber till an appropriate jurisdictional level to confirm or control the conformity of procured natural rubber with the GPSNR Policy components. However, a time-bound commitment for 100% traceability to industrial plantation level is not reported.

37. Percentage of supply from own processing facilities traceable to industrial plantation level?

This indicator is disabled as the company does not operate rubber plantations.

38. Percentage of supply from third-party processing facilities traceable to industrial plantation level?

39. Time-bound commitment to achieve 100% traceability to jurisdictional level for smallholders?

The company only commits to supporting the traceability of natural rubber till an appropriate jurisdictional level to confirm or control the conformity of procured natural rubber with the GPSNR Policy components. However, a time-bound commitment for 100% traceability specifically for smallholder supply is not reported.

40. Percentage of supply from own processing facilities traceable to smallholder at jurisdictional level?

This indicator is disabled as the company does not operate rubber plantations.

41. Percentage of supply from third party processing facilities traceable to smallholders at jurisdictional level?

42. Member of the Global Platform for Sustainable Natural Rubber (GPSNR)?

[Externally verified] The company is a member of GPSNR. This has been verified via the GPSNR website.

43. Submitted self-declaration form for the Sustainable Natural Rubber Initiative (SNR-i)?

44. Percentage area (ha) FSC certified?

This indicator is disabled as the company does not operate rubber plantations.

45. Time-bound plan for achieving FSC FM certification of estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

46. Percentage of scheme/outgrower smallholders (ha) FSC-certified?

This indicator is disabled as the company does not operate rubber plantations.

47. Time-bound plan for achieving FSC certification of scheme/outgrower smallholders?

This indicator is disabled as the company does not operate rubber plantations.

48. Percentage of natural rubber supply (tonnes) from independent smallholders/outgrowers/third-party natural rubber suppliers that is FSC-certified?

This indicator is disabled as the company does not operate rubber plantations.

49. Percentage of all natural rubber products handled/traded/processed (tonnes) that is FSC-certified?

50. Percentage area (ha) PEFC certified (excluding FSC certified area)?

This indicator is disabled as the company does not operate rubber plantations.

51. Certified under voluntary sustainability certification scheme?

[Externally verified] The company is ISO 14001 certified and one of the certificates is available in the latest sustainability report of the company.

52. Commitment to become 100% certified under voluntary sustainability certification scheme?

53. Commitment to zero conversion of natural ecosystems?

This indicator is disabled as the company does not operate rubber plantations.

54. Commitment to zero conversion of natural ecosystems applies to all suppliers?

The company only commits suppliers to support the long-term protection of natural forests and other ecosystems. A clear commitment to zero conversion of natural ecosystems by suppliers is not reported.

55. Commitment to zero deforestation?

This indicator is disabled as the company does not operate rubber plantations.

56. Commitment to zero deforestation applies to all suppliers?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company's own commitment to zero deforestation is unclear if it applies to all suppliers.

57. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

This indicator is disabled as the company does not operate rubber plantations.

58. Criteria and cut-off date for defining deforestation in supplier operations?

The company makes this commitment through the GPSNR Policy Framework. GPSNR defines natural rubber sourced from deforested areas or where HCVs have been degraded after 1 April 2019 to be non-conformant with its policy. The company's own reporting defines deforestation as the degradation of HCV areas and specifies the cutoff date as April 1, 2019. However, it is unclear if this applies to all suppliers.

59. Evidence of monitoring deforestation and/or ecosystem conversion?

This indicator is disabled as the company does not operate rubber plantations.

60. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?

61. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?

This indicator is disabled as the company does not operate rubber plantations.

62. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?

63. Commitment to restoration of deforestation/conversion?

This indicator is disabled as the company does not operate rubber plantations.

64. Commitment to restoration of deforestation/conversion applies to all suppliers?

The company only reports to work with natural rubber suppliers to support the restoration activities of deforested and degraded rubber landscapes. However, a clear commitment to restore ecosystems and their values to their prior condition and/or provide suitable compensation to restore these values in the case of deforestation or conversion is not reported.

65. Implementing a landscape or jurisdictional level approach?

The company makes this commitment through the GPSNR Policy Framework. Partial points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that do not fully meet the SPOTT indicator criteria. A public commitment could not be found by ZSL.

66. Biodiversity policy?

This indicator is disabled as the company does not operate rubber plantations.

67. Biodiversity policy applies to all suppliers?

68. Identified species of conservation concern, referencing international or national system of species classification?

This indicator is disabled as the company does not operate rubber plantations.

69. Examples of species and/or habitat conservation management?

This indicator is disabled as the company does not operate rubber plantations.

70. Commitment to no hunting or only sustainable hunting of species?

This indicator is disabled as the company does not operate rubber plantations.

71. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?

The company commits to only allowing sustainable hunting of species by local communities for subsistence purposes in their operations. However, it is unclear if this commitment applies to all suppliers.

72. Commitment to protect areas from illegal activities?

This indicator is disabled as the company does not operate rubber plantations.

73. Commitment to protect forest areas from illegal activities applies to all suppliers?

74. Evidence of protecting forest areas from illegal activities?

This indicator is disabled as the company does not operate rubber plantations.

75. Commitment to conduct High Conservation Value (HCV) assessments?

This indicator is disabled as the company does not operate rubber plantations.

76. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company's own commitment to conduct HCV assessments is unclear if applies to all suppliers.

77. High Conservation Value (HCV) assessments available for all new plantings since 1st April 2019?

This indicator is disabled as the company does not operate rubber plantations.

78. High Conservation Value (HCV) management and monitoring plans available for all new plantings since 1st April 2019?

This indicator is disabled as the company does not operate rubber plantations.

79. Commitment to the High Carbon Stock (HCS) Approach?

This indicator is disabled as the company does not operate rubber plantations.

80. Commitment to the High Carbon Stock (HCS) Approach applies to all suppliers?

The company reports commitment to the High Carbon Stock (HCS) Approach, however, it is unclear if this commitment applies to all suppliers.

81. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company does not operate rubber plantations.

82. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

This indicator is disabled as the company does not operate rubber plantations.

83. Commitment to conduct social and environmental impact assessments (SEIAs)?

The company only commits to conducting environmental impact assessments.

84. Commitment to conduct social and environmental impact assessments (SEIAs) applies to all suppliers?

85. Social and environmental impact assessment (SEIAs) undertaken, and associated management and monitoring plans?

86. Commitment to no planting on peat of any depth?

This indicator is disabled as the company does not operate rubber plantations.

87. Commitment to no planting on peat of any depth applies to all suppliers?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company's own reporting only mentions preventing the development of peatland and refraining from procuring natural rubber from plantations located on peatland. A definition of peat or the depth of peat is not specified.

88. Landbank or planted area on peat (ha)?

This indicator is disabled as the company does not operate rubber plantations.

89. Implementation of commitment to no planting on peat of any depth?

This indicator is disabled as the company does not operate rubber plantations.

90. Commitment to best management practices for soils and peat?

This indicator is disabled as the company does not operate rubber plantations.

91. Commitment to best management practices for soils and peat applies to all suppliers?

The company only commits to protecting soil quality, preventing erosion, nutrient degradation, subsidence, and contamination. However, a clear commitment to best management practices for soils and peat which applies to all suppliers is not reported.

92. Evidence of best management practices for soils and peat?

This indicator is disabled as the company does not operate rubber plantations.

93. Commitment to best/sustainable tapping practices?

This indicator is disabled as the company does not operate rubber plantations.

94. Commitment to best/sustainable tapping practices applies to all suppliers?

95. Evidence of best/sustainable tapping practices?

This indicator is disabled as the company does not operate rubber plantations.

96. Commitment to zero burning?

This indicator is disabled as the company does not operate rubber plantations.

97. Commitment to zero burning applies to all suppliers?

The company commits to no burning, however, it is unclear if this commitment applies to all suppliers.

98. Evidence of fire monitoring and management?

This indicator is disabled as the company does not operate rubber plantations.

99. Details/number of hotspots/fires in company estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

100. Details/number of hotspots/fires in suppliers operations/jurisdictions?

101. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?

The company reports GHG Emissions Goal to be achieved by 2025 as 249,562 tCO2eq and be carbon neutral by 2045. However, the figures are not reported as intensity.

102. GHG emissions intensity?

The company reports its GHG emission intensity for domestic operations as 0.0038 tCO2eq/Tires for scope 1 emissions per unit and as 0.0073 tCO2eq/Tires for scope 2 emissions per unit (tire). The company reports total emissions from overseas worksites as 224,238 tCO2eq in 2021. However, the figures reported for overseas worksites are not reported as intensity.

103. GHG emissions from land use change?

This indicator is disabled as the company does not operate rubber plantations.

104. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports a reduction in GHG intensity from 2019 (0.0042 tCO2eq/Tires- scope 1 and 0.0080 tCO2eq/Tires- scope 2) to 2021(0.0038 tCO2eq/Tires- scope 1 and 0.0073 tCO2eq/Tires- scope 2) for its domestic operations. For the company's overseas operations, the emissions have increased in 2021 (224,238 tCO2eq) as compared to 2020 (205,507 tCO2eq). Also, the figures reported for overseas operations are not reported as intensity. The company's emissions from domestic operations are externally verified by Creative Sustainable Registar(CSR).

105. Methodology used to calculate GHG emissions?

106. Time-bound commitment to improve water use intensity?

107. Water use intensity?

1450320 - The company reports water use figures for its domestic as well as overseas operations. However, the figures are not reported as intensity.

108. Progress towards commitment on water use intensity?

The company reports progress towards commitment on water use intensity. However, water use has increased for both domestic and overseas operations in 2021 as compared to previous years. Also, the figures are not reported as intensity.

109. Time-bound commitment to improve water quality (BOD or COD)?

110. Progress towards commitment on water quality (BOD or COD)?

The company reports COD figures for its domestic as well as overseas operations. However, the COD for both have increased in 2021 as compared to the previous years.

111. Treatment of effluents from processing facilities?

This indicator is disabled as the company does not operate rubber plantations.

112. Treatment of effluents from manufacturing facilities?

[Externally verified] The company reports that sewage generated at its manufacturing facilities is discharged into the water bodies after physical and chemical treatment as well as biochemical treatment. This information is externally verified by BSI Group Korea.

113. Commitment to protect natural waterways through buffer zones?

This indicator is disabled as the company does not operate rubber plantations.

114. Implementation of commitment to protect natural waterways through buffer zones?

This indicator is disabled as the company does not operate rubber plantations.

115. Reducing odours from natural rubber processing or manufacuring facilities?

The company reports that dust collection facilities and wastewater treatment facilities have been installed in manufacturing plants to maintain air and water pollution levels below 50% of the legal regulations. In addition, the company regularly measures emitted gases, dust, and odor generated during the production process to assess whether legal standards for environmental pollutants are being abided by and to reduce air pollutant emissions. However, the information reported is not externally verified.

116. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

This indicator is disabled as the company does not operate rubber plantations.

117. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

118. Commitment to no use of paraquat?

This indicator is disabled as the company does not operate rubber plantations.

119. Commitment to no use of paraquat applies to all suppliers?

120. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides?

This indicator is disabled as the company does not operate rubber plantations.

121. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers?

122. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

This indicator is disabled as the company does not operate rubber plantations.

123. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers?

124. Chemical usage per ha or list of chemicals used?

This indicator is disabled as the company does not operate rubber plantations.

125. Implementation of commitment to minimise inorganic fertiliser usage?

This indicator is disabled as the company does not operate rubber plantations.

126. Integrated Pest Management (IPM) approach?

This indicator is disabled as the company does not operate rubber plantations.

127. Commitment to human rights?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also reports its own commitment to the Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human rights.

128. Commitment to human rights applies to all suppliers?

The company commits to the Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human rights. However, it is unclear if this commitment applies to all suppliers.

129. Progress on human rights commitment ?

[Externally verified] The company reports conducting human rights training for all its employees. In 2021, the human rights training completion rate was 96% (1,488 persons). This information is externally verified by BSI Group Korea.

130. Commitment to respect Indigenous and local communities' rights?

This indicator is disabled as the company does not operate rubber plantations.

131. Commitment to indigenous and local communities' rights applies to all suppliers?

The company commits to the UN Declaration on the Rights of Indigenous Peoples. However, it is unclear if this commitment applies to all suppliers.

132. Commitment to respect legal and customary land tenure rights?

This indicator is disabled as the company does not operate rubber plantations.

133. Commitment to legal and customary land rights applies to all suppliers?

The company commits to the FAO Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security as well as to respect customary, traditional, and communal land tenure rights of indigenous peoples and local communities. However, it is unclear if this commitment applies to all suppliers.

134. Commitment to free, prior and informed consent (FPIC)?

This indicator is disabled as the company does not operate rubber plantations.

135. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?

The company provides a commitment to free, prior and informed consent (FPIC), but it is unclear if this applies to all suppliers.

136. Details on Free, prior and informed consent (FPIC) process available?

This indicator is disabled as the company does not operate rubber plantations.

137. Examples of local stakeholder engagement to prevent conflicts?

This indicator is disabled as the company does not operate rubber plantations.

138. Details of process for addressing land conflicts available?

This indicator is disabled as the company does not operate rubber plantations.

139. Supports the inclusion of women across natural rubber operations, including addressing barriers faced?

This indicator is disabled as the company does not operate rubber plantations.

140. Commitment to mitigate impacts on food security?

This indicator is disabled as the company does not operate rubber plantations.

141. Progress on commitment to mitigate impacts on food security?

This indicator is disabled as the company does not operate rubber plantations.

142. Commitment to provide essential community services and facilities?

This indicator is disabled as the company does not operate rubber plantations.

143. Progress on commitment to provide essential community services and facilities?

This indicator is disabled as the company does not operate rubber plantations.

144. Commitment to provide business/work opportunities for local communities?

This indicator is disabled as the company does not operate rubber plantations.

145. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also reports its own commitment to all Fundamental ILO Conventions.

146. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?

The company commits to all Fundamental ILO Conventions. However, it is unclear if this applies to all suppliers.

147. Progress on commitment to respect all workers' rights?

[Externally verified] The company reports it has established a labor-management council and in February 2021, the company held a collective bargaining signing ceremony to discuss long-standing litigation issues between labor and management. This information is externally verified by BSI Group Korea.

148. Commitment to eliminate gender related discrimination with regards to employment?

The company provides a commitment to eliminate gender related discrimination with regards to employment.

149. Commitment to eliminate gender related discrimination with regards to employment applies to all suppliers?

150. Progress on commitment to eliminate gender related discrimination with regards to employment?

The company reports it has conducted an anti-discrimination campaign and in March 2022, a total of 184 executives and organizational leaders received mandatory workplace harassment prevention training. However, this information is not externally verified.

151. Percentage or number of temporary employees?

45 - The company only reports the total number of non-regular workers for its domestic operations. The number of temporary employees in the company's overseas operations is not reported.

152. Percentage or number of women employees?

4% - The company reports 213 or 4% of women employees in its domestic operations. However, the number or percentage of women in the company's overseas operations is not reported.

153. Commitment to pay a living wage?

The company provides a commitment to pay a living wage.

154. Commitment to pay a living wage applies to all suppliers?

The company commits to paying a decent living wage. However, it is unclear if this commitment applies to all suppliers.

155. Progress on commitment to pay a living wage?

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

The company provides a commitment to address occupational health and safety.

158. Commitment to address occupational health and safety applies to all suppliers?

159. Provision of personal protective equipment and related training?

The company only provides evidence of hazardous chemical training in relation to natural rubber operations.

160. Time lost due to work-based injuries?

The company reports the accident severity rate (domestic and overseas) as 2.046 in 2021.

161. Number of fatalities as a result of work-based accidents?

0 - The company reports zero deaths in 2021.

162. Commitment to support smallholders?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also reports its own commitment to supporting smallholders.

163. Percentage of supply from smallholders?

164. Programme to support scheme smallholders/outgrowers?

165. Percentage of scheme smallholders/outgrowers involved in programme?

166. Programme to support independent smallholders?

167. Percentage of independent smallholders involved in programme?

168. Process used to engage smallholder suppliers on compliance with company's policy and/or legal requirements?

169. Number or percentage of smallholder suppliers engaged on compliance with company's policy and/or legal requirements?

170. Process used to prioritise, assess and/or engage non-smallholder suppliers on compliance with company's policy and/or legal requirements?

The company reports it has a process to assess non-smallholder suppliers on compliance with the company's legal requirements. However, limited details are reported.

171. Number or percentage of non-smallholder suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?

61% - The company reports that in 2021, the partner company's regular evaluation completion rate was 61% (32 companies) against the company's 'Partner Evaluation and Management Index'. However, this information does not cover all suppliers of the company.

172. Suspension or exclusion criteria for non-smallholder suppliers?

173. Time-bound action plans (including Key Performance Indicators) for suppliers to be in compliance with natural rubber sourcing commitments?

174. Proportion of direct and indirect supply from third-parties that comes from natural rubber plantations which are compliant with natural rubber sourcing policies?

175. Percentage of supply coming from agroforestry?

176. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and the prohibition of corruption.

177. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

The company reports commitment to working against corruption in all of its forms including extortion and bribery. However, it is unclear if this commitment applies to all suppliers.

178. Progress on commitment to ethical conduct and prohibition of corruption?

[Externally verified] The company conducts online education on the contents of the code of ethics and in 2021, 100% of employees completed the course on 'Ethical Education for Employees'. This information is externally verified by BSI Group Korea.

179. Disclosure of the company’s management approach to tax and payments to governments?

The company reports information on its tax strategy and states that tax-related organisations consist of the Head of the Strategy Planning & Administration Division, the Senior Vice President of Accounting & Management and the head of the accounting team. However, it is unclear which role is responsible for the tax strategy and its review.

180. Whistleblowing procedure?

The company has its whistleblowing procedure to report unethical conduct.

181. Own grievance or complaints system open to all stakeholders?

The company makes this commitment through the GPSNR Policy Framework. Partial points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that do not fully meet the SPOTT indicator criteria. The company also has its own grievance system in place, however, it is only accessible to internal stakeholders.