Compliance and Ethical Management
Ethical Management
Ethical Management Policy and System
Policy
SK Gas bases its corporate management on SKMS, creating value for diverse stakeholders such as customers, employees, shareholders, and business partners, playing a crucial role in societal and economic development, and contributing to human happiness.
Ethical management and anti-corruption practices ensure that a company fulfills its economic, legal, and ethical responsibilities in all management activities, reflecting the company's role as a social member in its actions and decision-making to enable sustainability management. To achieve this, we have established ethical standards and anti-corruption management system regulations, using them as the basis for decisions and actions in all management activities. These ethical management and anti-corruption standards apply to all executives and employees at all business sites (including overseas subsidiaries), as well as domestic and international subsidiaries and Business Partners (BP).
Our ethical standards encompass the basic ethics of our employees and compliance with laws and management policies, supported by subsidiary regulations and guidelines such as counseling and reporting systems, budget and expense use standards, leader FAQs, and ethics pledges. The anti-corruption management system regulations define the authority and procedures for operating anti-bribery and anti-corruption policies. Our procurement management regulations and subsidiary procedures present ethical standards and evaluation criteria for procurement activities and relationships with Business Partners (BP).
ISO 37001 (Anti-Bribery Management Systems)
Download Code of Ethics
ISO 37001 (Anti-Bribery Management Systems)
In April 2020, SK Gas became the first among SK Group companies to obtain ISO 37001 (2016) (Anti-Bribery Management Systems) certification for 'LPG import, storage, and supply' across all domestic business sites. We passed maintenance audits in 2021 and 2022, and a recertification audit in 2023. Our efforts include updating and complying with relevant regulations, providing anti-corruption and ethical management training, conducting surveys, operating a counseling and reporting system, and systematically identifying, evaluating, inspecting, and improving company-wide corruption risks through our self-purification system. All plans, results, and follow-up actions related to ISO 37001 are periodically reported to and reviewed by the CEO and the Audit Committee.
System
To align with the company's internal control policies and ethical management system, the Audit Committee serves as the highest decision-making body, with the audit group as the anti-corruption operational team. This team establishes and maintains anti-corruption regulations and systems, provides anti-corruption training for employees, operates reporting systems, and conducts regular inspections and corrective actions.
At the beginning of each year, the CEO formulates an anti-corruption and ethical management execution plan, which is reviewed along with the previous year's key achievements by the Audit Committee under the Board of Directors. Furthermore, under an enterprise-wide risk management system based on the 'prevention-detection-response' process, all ethical and compliance management risks are managed and inspected, with biannual risk management reports submitted to the Board of Directors.
The audit group, the anti-corruption and ethical management department under the direct supervision of the CEO's Legal Office, conducts internal audits, anti-corruption compliance checks, ethical management training for all employees including subsidiaries, and ethical management surveys for internal staff and business partners. The group also ISO 37001 (Anti-Bribery Management Systems) and maintains it, engages in ESG evaluations, and measures ethical management systems through external evaluations to enhance the company's level of ethical management.
- Board of Directors
- Audit Committee
- CEO
- Legal Office
- Audit Group
Ethical Management Goals and Support Activities
Ethical Management Goals
SK Gas aims for a fair and transparent society without corruption, setting the goal of 'Zero' cases of corruption and bribery (based on criminal punishment). To continuously achieve this goal, we maintain ISO 37001 (Anti-Bribery Management Systems) certification and strive to meet the top level required by SK Group's ethical management measurement system by continuously improving related systems and activities.
Additionally, we aim for 'Zero' cases of corruption and bribery (based on criminal punishment), 'Zero' disciplinary actions for ethical management violations, and '3 hours' of ethics education per employee. We are making various efforts in three areas: enhancing external evaluation standards, spreading an ethical culture, and upgrading systems.
| Key Performance Indicators | 2021 | 2022 | 2023 | 2024 Goal | 2025 Goal | 2026 Goal | |
|---|---|---|---|---|---|---|---|
| Number of Corruption and Bribery Cases (Based on Criminal Punishment) | 0 | 0 | 0 | 0 | 0 | 0 | |
| ISO 37001 Certification | Maintained | Maintained | Renewed | Maintained | Maintained | Renewed | |
| Ethics/Anti-Corruption Training (Including Sexual Harassment Prevention, Workplace Bullying Prevention) |
Training Hours (Hrs/Employee) | 3.5 | 3.5 | 5 | 5 | 5.5 | 5.5 |
| Training Participation Rate (Including Non-Regular Employees) |
100% (531/531) |
100% (564/564) |
100% (99.5%) (638/641) |
100% | |||
Ethical Management Support Activities
In accordance with SK Group's ethical management guidelines and the requirements for ISO 37001 certification, SK Gas annually identifies and updates key risk factors related to ethical management and anti-corruption, and conducts inspections of the anti-corruption self-purification system. To measure the awareness and practice levels of ethical management among employees, surveys are conducted for all employees, including subsidiaries and business partners, to identify weaknesses and derive improvement measures to enhance the level of ethical management.
Anti-Corruption/Ethical Management Training
To spread a culture of ethical management, SK Gas conducts ethics training for all employees, including subsidiaries, contract, and dispatch workers. The training covers basic topics such as sexual harassment prevention and workplace bullying prevention, as well as areas like improper work practices and dual employment for locally hired staff. In 2023, 863 employees, including those from subsidiaries (100%), completed ethics training and all signed ethics pledges.
Contents of Employee Ethics Training
| Category | Main Contents |
|---|---|
| Basic Ethics for Employees | Cases of workplace bullying and related laws, unethical cases related to verbal abuse, improper work practices, unfair treatment, and practical standards for dual employment |
| Improper Use of Company Assets | Personal use of corporate cards, travel expenses, and company supplies |
| Counseling/Reporting System | Methods and precautions for reporting ethical management issues |
Anti-Corruption/Ethical Management Training Status
| Category | Unit | 2021 | 2022 | 2023 | |
|---|---|---|---|---|---|
| Training Hours per Employee | General Ethics/Anti-Corruption Training | Hours | 2 | 2 | 2.2 |
| Sexual Harassment Prevention, Workplace Bullying Prevention | 1.5 | 1.5 | 2.8 | ||
| Training Participation Rate | % | 100 | 99.5 | 99.7 | |
- * Includes sexual harassment prevention and workplace bullying prevention training
Ethics Practice Workshops
SK Gas conducts ethics practice workshops led by executives from each department or group. In 2023, a total of 796 employees, including those from domestic and overseas subsidiaries, participated in the workshops. The workshops focused on workplace bullying, including verbal abuse, as a common topic, and discussed cases from the 2023 ethics management survey in breakout sessions for leaders and employees.
Ethics Practice Surveys
To measure the awareness and practice levels of ethical management among employees, SK Gas conducts ethics management surveys for all employees, including subsidiaries. In 2023, 99% of employees (846 out of 868) participated in the survey. The survey results showed that SK Gas's ethical management practice level (overall average of 3.98) was generally favorable compared to the group average (overall average of 3.93). To address relatively weak areas identified in the survey, such as reporting and follow-up actions, we plan to listen to the voices of vulnerable organizations, encourage leaders to set an example, and expand company-wide promotion and education on ethical management activities.
Additionally, an anonymous survey is conducted at the end of each year for approximately 300 Business Partners (BPs) to assess the adherence to ethical management by our employees. The survey results are shared with relevant departments to raise awareness of ethical management. Subsidiaries also participate in the BP survey, using the results to check their self-purification systems and incorporate them into internal audits.
Support for Ethical Management of Business Partners (BP)
To support the practice of ethical management among Business Partners (BP), SK Gas requires the submission of an ethics pledge and a code of conduct (ESG/Ethics/Human Rights Management) during procurement contracts. The company also collects annual ethics pledges through a dedicated IT procurement system and provides detailed guidelines on fair trade and ethical management, as well as ethical management practice guidelines for holidays such as Lunar New Year and Chuseok. Furthermore, we actively utilize various opportunities to strengthen support for ethical management among business partners, such as providing guidance on holiday gifts, counseling and reporting channels, inappropriate bidding practices, and the code of conduct during BP surveys and annually updating these guidelines.
Inspection of Anti-Corruption Self-Purification System
In April 2020, SK Gas obtained ISO 37001 (Anti-Bribery Management Systems) certification for 'LPG import, storage, and supply' across all domestic business sites, and has maintained the certification through annual audits.
We also update and comply with regulatory systems, provide anti-corruption and ethical management training, operate a counseling and reporting system, and systematically identify, evaluate, inspect, and improve company-wide corruption risks through our self-purification system. The risk management status is regularly reported to and reviewed by the CEO and the Audit Committee.
We operate the anti-corruption self-purification system for all subsidiaries, identifying new risks and conducting risk evaluations and inspections annually to continuously improve. In 2023, inspections were conducted in seven areas, covering 35 key tasks and 120 inspection items. We are also implementing and monitoring improvements based on issues identified in inspections from 2019 to 2022. To ensure more effective and accurate inspections, we have developed and applied inspection manuals for each item and organization, and have completed the development of an IT system to enhance operational efficiency and effectiveness.
Internal Audits (Regular/Occasional)
SK Gas sets internal audit tasks by reflecting the risk evaluation results of the anti-corruption self-purification system, the results of the ethical management survey, and the diagnoses of the group and external agencies. Identified tasks are prioritized based on urgency and importance, and a three-year plan is established and executed. Additionally, compliance audits are conducted at least biennially for company-wide or high-risk areas such as expenses, procurement, and receivables.
Ethics Counseling and Reporting System
SK Gas operates a counseling and reporting system for ethical management violations such as corruption and unfair trade practices. Employees can report violations of ethical regulations, including unreasonable demands, receipt of money, entertainment, or convenience, through various channels (online, phone, mail, email), either anonymously or by name. The counseling and reporting center is operated by dedicated staff within the internal audit/ethical management department, and all regulations and procedures to thoroughly protect the identities of counselors and reporters are specified in the operating rules.
Receipt and Processing of Reports
(Unit: Cases)
| Category | 2021 | 2022 | 2023 | |
|---|---|---|---|---|
| Ethical Management Report Reception (by Informant) | Employees | 4 | 0 | 1 |
| Business Partners | 0 | 2 | 3 | |
| Customers | 0 | 4 | 4 | |
| Others | 1 | 1 | 1 | |
| Processing Results | Investigation (Audit) | 1 | 1 | 1 |
| Transferred to Relevant Department | 1 | 1 | 1 | |
| Others (Dismissal, etc.) | 3 | 5 | 7 | |
Ethical Counseling and Reporting
Protection of and channels for counseling/reporting
The counseling and reporting system refers to a series of processes for receiving, investigating, and handling reports related to ethical management, anti-corruption, and internal accounting control systems. Counselors and reporters can choose a convenient method among various channels and report anonymously if they wish.
Counseling and Reporting System
SK Gas operates an ethical counseling and reporting system for receiving, investigating, and handling reports related to ethical management, anti-corruption, and internal accounting control systems. Employees can report violations of ethical regulations, such as unreasonable demands, receipt of money, entertainment, or convenience, through various channels (online, phone, mail, email), either anonymously or by name. The counseling and reporting center is operated by dedicated staff within the internal audit/ethical management department, and all regulations and procedures to thoroughly protect the identities of counselors and reporters are specified in the operating rules. Additionally, this system is operated under SK Group's integrated reporting IT system, managed by the Group Autonomous Responsibility Management Support Team, ensuring that the process is free from arbitrariness.
Counseling and Reporting Contents
Reports can be made at any time for violations of ethical regulations, such as unfair work practices, unreasonable demands, receipt of money, entertainment, or convenience by employees, and violations of internal accounting control regulations, such as the creation, falsification, alteration, or destruction of accounting information or orders to do so. Your courageous statement will greatly contribute to SK Gas's practice of transparent management.
- Receiving money, entertainment, or convenience from stakeholders such as business partners
- Improper use of company assets and information for personal gain
- Failure to report, delay, minimize, distort, or falsely report and create false documents
- Seeking private benefits using one's job position and authority, among other corrupt practices
- Falsifying, altering, damaging, or unauthorized destruction of accounting information, or ordering such actions
* For customer complaints about filling station services, please submit through 'Company Introduction - Customer Support - 1:1 Customer Inquiry' on our website.
- * For customer complaints about filling station services, please submit through 'Company Introduction - Customer Support - 1:1 Customer Inquiry' on our website.
Counseling and Reporting Methods
When discovering violations of ethics or internal accounting control systems by employees, reports can be made by name or anonymously through convenient methods such as online, phone, mail, or email. SK Gas operates a counseling and reporting center with dedicated staff within the internal audit/ethical management department and has established and applies comprehensive regulations and procedures to thoroughly protect the identities of counselors and reporters.
Reporting Channels
- Mail: Audit Group, ECO Hub SK Gas, 332 Pangyo-ro, Bundang-gu, Seongnam-si, Gyeonggi-do
- Online Reporting: Group Ethics Counseling http://ethics.sk.co.kr
- Phone: 02) 6200-8229
- Email: Skgas.ethics@sk.com
- * Please provide as much detail as possible in your counseling/report, and attach relevant evidence if available.
Protection of Counselors and Reporters
SK Gas prioritizes the protection of the identities and personal safety of counselors and reporters, ensuring that they do not suffer any disadvantages due to their counseling or reporting. To this end, the heads and staff of the ethical management department must ensure that the identities of counselors and reporters, as well as the content of their reports, are not disclosed during the entire process of receipt, investigation, and follow-up handling. We adhere to the following:
- 1Do not use real names or minimize content that could infer identities during record-keeping in the entire process of receipt, investigation, and reporting.
- 2Do not leak related records outside the ethical management department. Exceptions are made for internal accounting-related counseling and reports requiring joint work with the internal accounting management department.
- 3Conduct investigations carefully to prevent the disclosure of the counselor's/reporter's identity. If the risk of exposure increases, suspend the investigation immediately and implement preventive measures before resuming.
Counselors and reporters can notify the head of the ethical management department if they believe their identity might be exposed or if their personal safety is threatened. The head of the ethical management department, in consultation with the head of human resources, will take necessary protective measures such as departmental transfers with internal approval.
The head of the ethical management department is responsible for educating and managing the department staff on security management guidelines during the receipt, investigation, and follow-up handling process.
Disciplinary Measures for Violating Counselor and Reporter Protection
Employees must not inquire about the identities of counselors/reporters or engage in any actions that could lead to the disclosure of their identities, and must not give any disadvantages or discriminatory treatment in working conditions to counselors/reporters for making legitimate reports.
Organizations or individuals violating these rules will be subject to disciplinary measures in accordance with the ethical standards. If the head or staff of the ethical management department violates 'identity and personal protection' by disclosing the identities of counselors/reporters or the contents of their reports, disciplinary actions will be taken according to relevant regulations.
However, the following exceptions can be considered for immunity:
- 1Serious safety accidents and business interruptions
- 2Significant fraudulent incidents, company secret leaks, data falsification, and media reports
Self-Reporting and Reward System
If a counselor/reporter confesses their involvement in wrongdoing but voluntarily reports it, the company may consider this when determining punishment or disciplinary actions. Additionally, the company may reward counselors/reporters who contribute to the company's benefit or value enhancement through their reports.
Fair Trade and Compliance Management
Compliance Management Policy and System
SK Gas has established four key guidelines to ensure fair contracts with trading parties: contract signing, supplier selection and operation, internal review committee installation and operation, and issuance and preservation of subcontract-related documents. These guidelines are incorporated into contracts in accordance with the Monopoly Regulation and Fair Trade Act, and the Act on Fair Transactions in Subcontracting. Additionally, through the Fair Trade Compliance Program, we provide cautionary notes for compliance with fair trade laws and guidelines for employee conduct.
In compliance with the Commercial Act (Article 542-13), SK Gas appoints a compliance officer to prevent and manage legal risks across corporate activities. The compliance officer, appointed by the Board of Directors, conducts compliance education and checks adherence to compliance control standards.
Role of the Compliance Officer
Compliance Support
- Provide continuous legal advice and support for contract signing
- Operate the Compliance Program
- Conduct compliance education (online training, surveys, counseling system, workshops, etc.)
Compliance Control
- Check adherence to laws and regulations and perform activities to establish policies and control to prevent legal violations and manage legal risks
Reporting Results
- Report compliance results to the Board of Directors once a year
Compliance Organization
| Department | Number of Employees | Composition | Key Activities |
|---|---|---|---|
| Legal Group | 11 | 2 team leaders and 9 managers | Provide legal support for each transaction |
Key Compliance Activities
- Legal review and advice, litigation response
- Conduct ethics management education and practice surveys for employees
- Establish and operate an internal reporting system
- Provide and manage sexual harassment prevention education and reporting procedures
Compliance Management Activities and Goals
Based on the CP rating evaluation indicators announced by the Fair Trade Commission, SK Gas derives and pursues short-term and long-term tasks. Our goal is 'Zero violations of fair trade-related laws,' which we achieved in 2023. In 2024, we plan to conduct risk assessments in certain areas to enhance risk management levels.
Fair Trade Compliance Activities
To prevent unfair trade, SK Gas implements pre-review procedures by the internal review committee, evaluating compliance with fair trade-related laws. In 2023, we conducted on-site compliance inspections for local sales offices.
Anti-Corruption and Anti-Competitive Actions and Violations
| Category | Unit | 2021 | 2022 | 2023 |
|---|---|---|---|---|
| Unfair Trade Practices, Monopolies, etc. | Cases | 0 | 0 | 0 |
| Monetary Penalties for Violations of Laws and Regulations | Cases | 0 | 0 | 0 |
| Litigation Cases for Violations of Laws and Regulations | Cases | 0 | 0 | 0 |
| Fines and Settlements for Anti-Trust/Anti-Competitive Practices | KRW billion | 0 | 0 | 0 |
| Litigation Costs and Fines for Price Collusion | KRW billion | 0 | 0 | 0 |
| Violations of Product/Service Information and Labeling Regulations | Cases | 0 | 0 | 0 |
| Violations of Internal Transaction Regulations | Cases | 0 | 0 | 0 |
| Violations of Subcontracting Transaction Regulations | Cases | 0 | 0 | 0 |
Fair Trade Education
SK Gas conducts fair trade education to foster a leading compliance culture. We provide specialized fair trade education for roles and tasks exposed to fair trade risks, such as agencies and branch offices. Additionally, we publish a compliance newsletter every two months to raise employee awareness and caution regarding compliance with fair trade-related laws.