Business Ethics
1.Employee Ethics Rules (G6-1) — Five Areas
Area | Major Prohibitions and Compliance Items |
Prohibition of Corrupt Acts | Prohibit all corrupt acts that undermine fairness, including money, entertainment, hospitality, and improper solicitation. |
Prevention of Conflicts of Interest | Prohibit dual employment, investment in business partners, and coercion of employees to participate in multi-level sales. |
Protection of Company Assets | Use company assets within the approved budget, prohibit expenses unrelated to business, and prohibit leakage or unauthorized removal of company assets. |
Sound Corporate Culture | Prevent sexual harassment and workplace harassment, and prohibit slander against employees, distortion of information, and dissemination of false information. |
Protection of Confidential Information | Prevent leakage of trade secrets and personal information. |
Formalization of the Ethics Rules (G6-1): ① Designation of the Ethics Management Office + allocation of responsibility ② Signing of the Ethics and Compliance Pledge by all employees company-wide for the business ethics policy ③ Annual company-wide ethics and compliance training ④ Monthly compliance letter (intranet and e-mail) ⑤ Internal reporting, investigation, and disciplinary procedures in case of violations. Executives and persons holding positions are assigned responsibility for the management of their employees' compliance with the ethics rules.
i-SENS operates the Code of Ethical Conduct + the Employee Code of Conduct based on the ISO 37001 (Anti-Bribery Management System) and ISO 37301 (Compliance Management System) certifications. The Ethics Management Office oversees the entire process of policy, supervision, training, and reporting. The 2025 company-wide ethics, compliance, and ESG education (888 of a total of 919 persons completed · completion rate 97%) was directly conducted by Statutory Auditor Bo-Hyun Hwang and Jong-Sup Shim, member of Korea ESG Credit. The Company achieved 100% delivery of anti-corruption policy and education · 0 corruption cases, and the one case of disposition for violation of the Fair Trade Act on resale price maintenance (RPM) (KRW 256 million, May 7, 2025) is transparently disclosed in 1701 Statutory Auditor Section 7 along with post-corrective and recurrence prevention governance.
2. Fair Trade and Anti-Corruption Policy (G6-2)
2.1 Three Principles of Fair Trade (Code of Ethical Conduct)
Principle | Content |
① Fair Competition | Prohibition of unfair coercion of agencies · Prohibition of unfair subcontracting abuses · Prohibition of unfair labeling and advertising |
② Compliance with Trade Regulations | Compliance with domestic and foreign trade laws (export and import, trade, customs, sanctions) |
③ Counterfeit Prevention and Brand Protection | Prevention of product counterfeiting · Management of production, inventory, and procurement |
2.2 Seven Principles of Anti-Corruption
Principle | Content |
① Principled Prohibition | Complete prohibition of any illegal money, entertainment, hospitality, or convenience to domestic or foreign public officials or government agencies, including all bribery |
② Exceptional Permission | Within the limits of domestic and foreign anti-corruption laws and the Company's Anti-corruption Rules (strict application of statutory standards, reasonableness, non-repetition, supporting documentation, and accounting records) |
③ Management System | Establishment, implementation, monitoring, and continuous improvement of the Anti-Bribery Management System |
④ Reporting System | Activation of the 5-channel reporting system (online, e-mail, telephone, visit, mail) · Protection of good-faith reporters |
⑤ Education and Pledge | Recognition of responsibility through anti-corruption education + ethics pledge (including anti-corruption) |
[Five areas of Employee Ethics Rules]
Area | Major Prohibitions and Compliance Items |
① Prohibition of Corrupt Acts | Complete prohibition of all corrupt acts that harm fairness, including money, hospitality, entertainment, and improper solicitation |
② Prevention of Conflicts of Interest | Prohibition of dual employment · Prohibition of investment in business partners · Prohibition of forced multi-level sales on employees |
③ Protection of Company Assets | Use within budget · Prohibition of expenses unrelated to business · Prohibition of leakage of company assets |
④ Sound Corporate Culture | Prevention of sexual harassment and harassment · Prohibition of slander against employees, distortion of information, and dissemination of false facts |
⑤ Protection of Confidential Information | Prevention of leakage of trade secrets and personal information |
⑥ Liability for Violations | Strict handling of violators of the Anti-corruption Rules |
⑦ Independent Operation | Guarantee of independence of the anti-corruption organization → Efficient anti-corruption system |
3. Fair Trade and Anti-Corruption Management Activities (G6-3) — ISO 37001·37301
Activity | 2025 Implementation Content |
Certification Maintenance | Maintenance of ISO 37001 (Anti-Bribery) + ISO 37301 (Compliance Management System) certification — Item 7 of the 2025 ESG Action Plan |
Company-wide Education (May–June) | Fair trade and anti-corruption policy education for all employees |
Medical Device Fair Competition Convention (June) | Education on the Medical Device Fair Competition Convention for all sales and research employees |
Medical Devices Act Spending Report (July) | Training on preparation of the Medical Devices Act spending report for all sales and research employees + submission |
Compliance Letter | Monthly distribution (intranet and e-mail) — dissemination of the latest laws, cases, and changes in internal policies |
Third-Party Verification | Anti-corruption clauses + pledges + pre-verification + red flag analysis procedures at the time of contracting |
4. 2025 Ethics, Compliance, and ESG Education (G6-8 · 919 persons / 97%)
Of 919 employees company-wide, 888 completed the training — a completion rate of 97% was achieved.
Site | Schedule | Subjects |
Wonju Plant | 2025-05-26 | All employees |
Songdo Plant / Songdo No. 2 Plant | 2025-05-28 | All employees |
Seocho Headquarters | 2025-06-04 · 06-05 | All employees |
4.1 Five Major Modules of Education
1.Ethics and Compliance Management — Principles and practice of ISO 37001 and 37301
2.Six Items of the Code of Ethical Conduct — Prohibition of corrupt acts, conflicts of interest, asset protection, corporate culture, trade secrets, internal whistleblowing
3.ESG Management — E (energy, carbon neutrality, resource circulation) / S (human rights, occupational safety and health, community) / G (Board of Directors, ethics management, information disclosure) + Sharing of ESG materiality assessment results
4.Fair Trade + CP (Compliance Program) — Fair Trade Act, Subcontracting Act, Labeling and Advertising Act · CP Committee + Compliance Officer designation · Centered on cases of unfair collusion, unfair trade, and labeling and advertising regulations · Pre-consultation system for contracts
5.Information Protection and Trade Secret Management — Internal information leakage cases and response measures.
4.2 Delivery of Anti-Corruption Policy and Education 100% (G6-8)
Classification | Number Delivered | Delivery Rate | Number of Training Completions | Training Completion Rate |
Governance members | 5 | 100% | 5 | 100% |
Employees | 883 | 96% | 883 | 96% |
Total | 888 | 97% | 888 | 97% |
5. Reporting and Grievance Handling (G6-4, G6-5, G6-6) — 5 Channels + Quadruple Protection
Reporting through 5 channels (online, e-mail, telephone, visit, mail) and a choice between anonymous and signed reporting, with a quadruple protection mechanism of confidentiality, status protection, immunity from liability, and compensation. Grievances are received by the labor-management council or the HR Team, and depending on the matter, are responded to by the HR Team or improved through deliberation by the labor-management council. Mental health management is also supported through an external expert psychological counseling program.
Year | Cases Received | Cases Processed | Processing Rate |
2023 | 36 | 33 | 91.7% |
2024 | 41 | 38 | 92.7% |
2025 | 32 | 23 | 71.9% (remaining 9 cases in process) |
*Cases received and cases processed may not be processed in the same year and may be carried over.
6. Violation and Incident Statistics (G6-7, G6-9 to G6-15)
Metric | 2025 Performance |
G6-7 Corruption Risk Assessment Ratio | 100% (all sites) |
G6-9 Corruption Incidents | 0 cases · 0 dismissals/disciplinary actions · 0 terminations of business partner relationships |
G6-10 Antitrust Lawsuits | Violation of the Fair Trade Act on resale price maintenance (RPM) — 1 case of administrative sanction (surcharge of KRW 256 million) · 0 ongoing lawsuits |
G6-11 Fines for Violations of Laws and Norms | 1 case (RPM surcharge of KRW 256 million) · 1 case of non-monetary sanction (corrective order) |
G6-12 Violations of Product Health and Safety Regulations | 0 cases (fines, warnings, voluntary norm violations) |
G6-13 Violations of Labeling and Information Regulations | 0 cases |
G6-14 Personal Information Violations | 0 cases (consistent with the S6 Information Security metric) |
G6-15 Political Contributions | Not applicable |
Note) G6-7 Corruption risk assessment ratio of 100% (all sites) is 2026 performance.
7. 2025 RPM Case — Corrective and Recurrence Prevention Governance from the Ethics Management Perspective
KFTC resolution on May 7, 2025 — Violation of Article 46 of the Fair Trade Act (resale price maintenance) · Surcharge of KRW 256 million · Corrective order. The facts, timeline, and corrective actions of this case are disclosed in detail in 1701 Statutory Auditor Section 7, and this Ethics Management chapter summarizes the matters of governance strengthening from the perspective of recurrence prevention.
Area of Strengthening | 2025-2026 Implementation |
CP (Compliance Program) | Inclusion of Fair Trade Act + Subcontracting Act + Labeling and Advertising Act cases in Module 4 of the 2025 Ethics, Compliance, and ESG education, centered on case studies · CP Committee + Compliance Officer (designated by Board on March 7, 2025) |
Pre-consultation System for Contracts | Establishment of a pre-review procedure for price management clauses prior to contract conclusion · Mandatory prior approval by the Compliance Officer |
ISO 37001·37301 Certification | Item 7 of the 2025 ESG Action Plan, maintenance of certification → Review of shortening of the 2026 re-certification cycle |
Amendment of Distributor and Agency Terms | Deletion of price management clauses in general distributorship agreements such as that of Daehan Medical Equipment · Complete abolition of blacklist operations · Specification of pricing autonomy in agency transaction terms and conditions |
Reflection in Finance and Accounting | Recognized as KRW 256 million in non-operating expenses for FY2025 · Unqualified opinion of Samjong Accounting Firm maintained |
Regular Reporting to the Board of Directors | At the February 23, 2026 Board ESG and compliance control evaluation report, the implementation results of the RPM corrective order will be formally reported (see 1700 G7-1) |
8. 2025 Key Performance Summary · 2026 Plan
Company-wide education completion rate of 97% for 919 persons · 100% delivery of anti-corruption policy and education (governance 5/5 + employees 957/957) · 0 corruption incidents · Maintenance of ISO 37001 and 37301 certifications · 12 monthly compliance letters distributed
Significant Issue: Surcharge of KRW 256 million for violation of the Fair Trade Act on RPM (May 7, 2025) — 8 recurrence prevention actions in operation, including the designation of the Compliance Officer, implementation of the corrective order, and amendment of terms and conditions.
2026Plan
1.Application for CP rating evaluation (review of application for the KFTC CP rating).
2.Shortening of the ISO 37001 and 37301 re-certification cycle + addition of new module on Labeling and Advertising Act cases.
3.Standardization of general distributorship agreements — collective deletion of price management clauses + introduction of terms and conditions guaranteeing autonomous determination.
4.Prompt processing of the remaining 9 grievance cases + processing rate target of 95%.
5.Strengthening of internal whistleblower protection — external publication of guidelines on whistleblower status protection and compensation systems.
9. Global Mapping Matrix
This matrix aligns the 15 ethics management metrics of i-SENS (G6-1 to G6-15) with the GRI 2021 Universal Standards (2-27 Compliance with laws) + GRI 205 Anti-corruption + GRI 206 Anti-competitive behavior + GRI 417 Marketing & Labeling + GRI 418 Customer Privacy + GRI 415 Public Policy, ESRS G1 Business Conduct, KCGS governance evaluation indicators, OECD/G20 Principles of Corporate Governance (revised 2023), UN Global Compact Principle 10, and domestic laws (Fair Trade Act, Labeling and Advertising Act, Subcontracting Act, Improper Solicitation and Graft Act (Anti-Graft Act), and Personal Information Protection Act). The page is structured so that external stakeholders may simultaneously cross-verify against 5 global standards + 5 domestic laws.
Area | i-SENS Ethics Management Metric | GRI 2021 | ESRS G1 / ISO | UNGC · OECD · KCGS | Domestic Law |
Policy / Rules | G6-1 Employee Ethics Rules 5 Areas | 2-23 Policy commitment · 2-24 Policy implementation | G1.GOV-1 Policy · ISO 37301 | UNGC Principle 10 / P.IV.B | Anti-Graft Act · Commercial Act |
Policy / Rules | G6-2 Fair Trade and Anti-Corruption Policy | 205-2 Policy delivery · 206-1 | G1.GOV-2 Anti-corruption · ISO 37001 | UNGC Principle 10 / B-3 | Fair Trade Act · Labeling and Advertising Act · Subcontracting Act |
Management Activities | G6-3 Fair Trade and Anti-Corruption Management | 205-1 Assessment · 205-2 Delivery | G1.PER-1 Operation · ISO 37001·37301 | KCGS B-3 Transaction control | Article 51-2 of the Fair Trade Act, voluntary compliance |
Education / Capacity | G6-7 Corruption Risk Assessment (100%) | 205-1 Ratio of sites assessed | G1.PER-1 Operation | OECD P.II.A | Anti-Graft Act |
Education / Capacity | G6-8 Anti-Corruption Policy Delivery and Education (100%) | 205-2 Delivery and education | G1.GOV-3 Capacity building | B-6 Independent Director education | Anti-Graft Act · Medical Device Fair Competition Convention |
Reporting / Remedy | G6-4 Grievance Handling Process (5 channels) | 2-25 Remediation of negative impacts · 2-26 Mechanism | G1.GOV-2 Impact | B-13 / P.V.C | Labor Standards Act · Occupational Safety and Health Act |
Reporting / Remedy | G6-5 Number of Grievances Handled (32 cases / 2025) | 2-25 Remediation results | G1.PER-2 Evaluation | B-14 Internal control | Labor Standards Act |
Reporting / Remedy | G6-6 Advice and Issue-Raising Process | 2-26 Mechanism for reporting violations | G1.GOV-2 | P.V.D | Whistleblower Protection Act |
Area | i-SENS Ethics Management Metric | GRI 2021 | ESRS G1 / ISO | UNGC · OECD · KCGS | Domestic Law |
Incident Statistics | G6-9 Corruption Incidents (0 cases) | 205-3 Corruption incidents | G1-3 Anti-corruption | UNGC Principle 10 | Anti-Graft Act |
Incident Statistics | G6-10 Antitrust Lawsuits (1 administrative sanction) | 206-1 Anti-competitive lawsuits | G1-1 Policy | OECD P.IV.A | Article 46 of the Fair Trade Act (RPM) |
Incident Statistics | G6-11 Violations of Laws and Norms (0 fines) | 2-27 Compliance with laws | G1.PER-1 | P.II.A Responsibility | All relevant laws |
Incident Statistics | G6-12 Violations of Health and Safety Regulations (0 cases) | 416-2 Health and safety | S2 / E5 | P.II.A | Medical Devices Act · Pharmaceutical Affairs Act |
Incident Statistics | G6-13 Information and Labeling Violations (0 cases) | 417-2 Labeling · 417-3 Marketing | S4 Consumers | P.II.A | Labeling and Advertising Act · Medical Devices Act |
Incident Statistics | G6-14 Personal Information Violations (0 cases) | 418-1 Customer privacy | S4 Consumers | P.II.A | Personal Information Protection Act · Medical device cybersecurity |
Incident Statistics | G6-15 Political Contributions (KRW 0) | 415-1 Political contributions | G1.GOV-1 | P.II.A | Article 31 of the Political Funds Act |
Ethics Management Four-Pillar Integrated Framework (G6 · 15 metrics)
