Reward for Reporting

- With the goal to build a sound corporate culture by preventing ethical misconduct, we reward those who report unethical behaviors.

Ethical Misconduct

• - Act of accepting bribes or lavish treatments offered by external stakeholders to influence business decision
• - Use of one¡¯s position of power to gain unjustified personal benefit; using unjust means and/or harboring wrongful intent to cause harm to the company
• - Other ethical misconduct involving external stakeholder(s)

¡Ø Please note that your report may be excluded from the investigation if.

• - you report about an employee's personal life and/or private disputes that the company cannot get involved in;
• - you request preferential treatment in connection with the report or make the report for unjustifiable purposes;
• - or you slander others with unfounded, malicious reports or falsehoods or one-sided allegations.

Eligibility & Value of Reward

• 1. Eligibility
  • General public (exception: POSCO Group employees)
• 2. Reward
  • Maximum: ₩10 million
  • When liability compensation or recovered loss results in direct growth in corporate revenue and/or reduced cost, a percentage of the money recovered will be added, based on the following rules, to the total value of the reward.

  ¨ç When the filed complaint results in loss ruling and when the money is recovered

  When the filed complaint results in loss ruling and when the money is recovered

  Recovered Value	Reward
  Below ₩10 million	None
  In excess of ₩10 million	3% of the recovered amount (₩10 million max.)

  • If the report leads to a one-off recovery of revenue or loss, reward shall be based on the total recovered amount. However, if the recovery is expected over time, the reward is to be based on the annualized recovery amount.
  • Any additional recovery identified during ESG team¡¯s investigation shall be excluded from the reward.

  ¨è When value of the recovery cannot be estimated or when no recovery of loss results from the report, no reward shall be provided.

• 3. Exceptions to Reward Payment
  • When the report is proven to be false, or when claim cannot be substantiated due to insufficient evidence
  • When the reported misconduct is unassociated with the business activities involving external stakeholder(s)
  • All whistleblowers are rewarded for reporting conduct that causes direct damage, i.e., embezzlement, theft
  • When the reported misconduct has been reported or is under investigation by the ESG team or other organizations and/or external agencies, and for which disciplinary action has been taken or is underway
  • For misconduct already exposed in media
  • When the whistleblower requests anonymity or uses a pseudonym, making it impossible to identify the complainant
  • When the report simply suggests a business process improvement
  • When deliberation rules ineligibility for the reward

Whistleblower Protection

• 1. Payment of Reward
  • To protect the whistleblower¡¯s identity during the payment process, the ESG team leader shall collect the reward and deliver it to the whistleblower through means desired by the recipient and in a manner that ensures confidentiality
• 2. Whistleblower Identity Protection
  • Should an employee become aware of the whistleblower¡¯s identity in line of work or by chance, the identity shall be kept concealed
  • Any act or attempt, such as inquiry or investigation, made to expose the whistleblower¡¯s identity is strictly prohibited
  • Any act that exposes, disclosed or implied, the identity of the whistleblower and/or those interviewed during the investigation without their consent is strictly prohibited
  • An employee who has violated the duty to protect the identity can be penalized
• 3. Protection against Retaliation
  • Any adverse action taken against a whistleblower is strictly prohibited; those in violation shall be subject to punishment as provisioned in the Company bylaws.

How to File a Complaint

• 1. Select a Method
  • At Cyber Center (to report online) or by post mail, phone, fax or in person
• 2. Reporting Instruction
  • Identify self and the violator and document the event based on the 5W 1H guiding framework to report the ethical misconduct
• 3. Report Filing
  • Online: Visit POSCO Holdings website (www.posco-inc.com) and go to Ethics & Reporting ¡æ click Report
  • Tel: 080-390-3366
  • Mail: (Postal code) 06194 /440, Teheran-ro, Gangnam-gu, Seoul (892, Daechi 4-dong, Gangnam-gu, Seoul) Corporate Audit, POSCO Holdings