Article 1 (Purpose)

The purpose of the Code of Conduct is to define and implement ethical standards by which all employees shall perform their duties and work in a fair and transparent manner.

Article 2 (Scope)

The Code of Conduct shall be applied to all executives and employees of OCI Holdings Company Ltd and OCI Company Ltd. (hereinafter referred to as "the Company").

Article 3 (Terminology)

• ① Cash equivalents: cash, gift certificates, marketable securities, goods (gifts) or other economic benefits
• ② Receiving entertainment: receiving meals, wining and dining, golfing, public performance/ exhibits, etc.
• ③ Getting benefits: receiving various supports for events such as transportation, housing or tourism.
• ④ Related parties: all internal and external individuals or groups which will be affected by any actions or decisions made by the Company or its executives/employees (companies, other organizations)
• ⑤ Socially acceptable level: it refers to the level which would not influence any actions or behavior of its recipient in performing his/her duties in a fair manner based on common sense of other employees or general public (socially acceptable level)

Article 4 (Responsibilities and Obligations for Customers)

• ① Employees shall honor promises made to customers and carry out all transactions in accordance with sound and fair trade practices.
• ② Employees shall do their best to prevent customer complaints (regarding quality, delivery, technical support, etc.) and try to rapidly resolve issues if they take place.
• ③ Employees shall not provide or leak customer information to outsiders without customers' prior consent.
• ④ Employees shall not ask for any unfair trade or make undue requests using his/her superior position.

Article 5 (Responsibilities and Obligations for Shareholders)

• ① The Company shall maximize the interest of the shareholders through transparent decision-making and efficient management activities.
• ② The Company shall prevent any issues including class action lawsuits by disclosing accurate management information in a timely manner.
• ③ The Company shall do its best to reflect rightful opinions of minority shareholders in its management.
• ④ Prepare and disclose true & fair financial statements based on accounting standards

Article 6 (Fair Performance of Duties)

1. ① Employees shall perform their duties in a fair manner according to company rules and if the company rules are not available or not clear they should do their best to perform their duties in a transparent and reasonable manner.
2. ② Employees shall not be engaged in any undue activities, money transactions or asking/receiving favors, Acts related to Money Laundering-related Activities In Accordance With The Act on Reporting and Using Specified Financial Transaction Information (the "Act on Specified Financial Information") with related parties.
3. ③ Employees shall not receive entertainment, benefits, gifts or other cash equivalents beyond the socially acceptable level. If it is inevitable, employees shall treat the case transparently by contacting the department in charge of Code of Conduct (Audit Dept.) for advice.
4. ④ Employees shall avoid any situations which cause conflicts of interests between the Company and themselves.
   1. 1. Business transactions with competitors or business partners of the Company by running his/her own business, etc.
   2. 2. Business transactions with the Company or customers of the Company by himself/herself or using a third party
   3. 3. Dual/side job which may impair one's performance at work
5. ⑤ Employees shall immediately report any issues related to local community, the press, related government offices, civil organizations to prevent any collective complaints or issues.
6. ⑥ We respect the market economy under the principle of global free competition, and we do not engage in unreasonable collective actions with competitors(so-called collusion, etc.)

※ The reason for not specifying the exact amount (for socially acceptable level) in the Item 3 above is to show respect for ethical standard and common sense of the employees out of the belief that they can honestly follow their common sense and ethical awareness in performing their duties.

Article 7 (Protection of Company Assets and Information)

1. ① Employees shall not pursue undue interest or benefits either for themselves or for others using the Company's assets or information without official permission.
2. ② Employees shall not use company properties for person use or get reimbursement for personal expenses.
3. ③ Employees shall execute budgets in a transparent and reasonable manner as a trustworthy trustee. (clear distinction between public and private expenses, and prevention of budget diversion without permission)
4. ④ Employees shall not disclose any Company information obtained while performing one's duties without permission.
5. ⑤ Employees shall not use company IT network for personal purposes (not-business related Internet use, PC communications, etc.)

Article 8 (Sound Working Environment and Social Life)

1. ① Employees shall create an organizational culture founded on mutual trust and respect. (Privacy shall be respected while any defamation of character, including libel and slander, workplace harassment and sexual assault, including sexual harassment, are prohibited.)
2. ② As exemplary social members, Employees shall not be engaged in any activities or behavior which might impair dignity of the Company.
3. ③ As an employee of the Company, one shall refrain him/herself from expressing his/her political stance. One can participate in any political activities as an individual but should prevent any misunderstanding that the Company is involved due to his/her participation.
4. ④ A superior shall not make undue order to his/her subordinate in violation with the laws and Company rules, and if a subordinate receives such an order, he/she can reject it and shall not receive any undue treatment because of his/her rejection.
5. ⑤ Employees shall not ask their colleges in charge to provide special favors to a certain party or receive cash equivalents such as gifts, entertainments and benefits in return for giving favors.

Article 9 (Making Contributions to the Nation and Society)

1. ① Employees shall strive to prevent environmental pollutions and protect the nature to preserve the clean environment for future generations.
2. ② Employees shall take every necessary measures and stick to safety laws & regulations to make sure safety of themselves, customers and local community.
3. ③ Employees should actively participate in volunteer activities, rescue activities for disaster stricken areas, etc.

Article 10 (Comply with the Code of Conduct)

All executives/employees shall comply with the Code of Conduct of the Company, and managers and executives shall take the responsibility to make sure that their subordinates stick to the ethical standards stipulated in the Code of Conduct.

1. ① If an employee happens to know any violations of the Code of Conduct by other employees, he/she must ask the violator to correct the wrong or report the violation to the Audit Dept. (anonymity of a whistleblower will be guaranteed)
2. ② All employees shall sincerely follow the Code of Conduct and if an employee violates the Code of Conduct, he/she shall be subject to disciplinary measures including dismissal according to the Company rules and regulations.
3. ③ Matters which are not stipulated in this Code of Conduct shall be consulted with the Auditing Team.

Article 11 (Reporting)

Employees shall prevent any unethical behaviors/actions and implement transparent and ethical business practices by reporting any illicit or undue business activities or undue work orders of superiors which impair transparent and ethical business practices.

1. ① Reporting scope
   1. 1. Matters/actions which impair transparent business or violate the Code of Conduct
   2. 2. Illegal activities/ actions
   3. 3. Actions/behaviors causing intentional or unintentional damages to the Company
   4. 4. Any work related illegal or undue orders
   5. 5. Receiving undue benefits such as cash equivalents, entertainment, wining/dining or special favors (if it's not socially acceptable level)
   6. 6. Undue work delay or (approval) rejection
   7. 7. Acts violating company rules and regulations (such as Internal Accounting Management Regulations, etc.) or instructing employees to commit such violations
   8. 8. Acts related to Money Laundering-related Activities In Accordance With The Act on Specified Financial Information
   9. 9. Other violations of the Code of Conduct or unethical behaviors by an employee
2. ② Protection of Whistleblowers
   1. 1. Protect his/her position and anonymity
   2. 2. Prevent any human resource management related disadvantage due to his/her reporting and actively accommodate request of the whistleblower(s)
3. ③ How to report
   1. 1. FAX : 02)727-7808
   2. 2. Cyber reporting via the Company website
   3. 3. Mail: To Compliance Dept 1 of OCI Holdings Company Ltd. OCI Company Ltd. Bldg. 94, Sogong-ro, Jung-gu, Seoul or Audit Dept. of OCI Company Ltd. OCI Company Ltd. Bldg. 94, Sogong-ro, Jung-gu, Seoul
   4. 4. Reporting using the form: Code of Conduct violation reporting form including receiving cash equivalents/entertainment etc.
      

Introduction

Human Rights Policy of OCI Holdings and OCI

Principles on the Respect for Human Rights