코오롱제약

SUSTAINABLE BUSINESS PRACTICES

Sustainable Management

KOLON Pharma is committed to pursuing sustainable growth.

To be a respected entity, fostered by an authentic corporate culture.

KOLON Pharma firmly believes that corporate responsibility transcends mere adherence to laws and regulations
We champion ethical management for mutual prosperity across society

Proclamation of Autonomous ComplianceTrue competitiveness comes only from sustainable and fair competition

Our pharmaceutical company’s mission is to elevate the quality of life for individuals and the broader human community. We achieve this by developing safe, top-tier drugs, rooted deeply in respect for human life.

Embracing the idea that ‘sustainable competitiveness arises solely from fair competition’, we introduced a structured compliance program in 2010. In 2014, we further consolidated our efforts by launching a dedicated department to amplify education, monitoring, and oversight in this area. In May of the same year, we hosted the ‘Compliance Management Proclamation Event’ to affirm the unwavering commitment of every team member to autonomous compliance.

KOLON, while consistently exemplifying principled management, pledges to maintain its dedication to both compliance and ethical management. Our aim? To stand out as a trusted, compact, and powerful entity in the industry.
Thank you.

01

Enhance audit capabilities by ensuring that vendors meet essential criteria and reinforcing our collaborative frameworks.
02

Cultivate a sound corporate ethos through consistent adherence to ethical management.
03

Design a practical legal risk management system, further sharpening our competitive edge.

01

Enhance audit capabilities by ensuring that vendors meet essential criteria and reinforcing our collaborative frameworks.
02

Cultivate a sound corporate ethos through consistent adherence to ethical management.
03

Design a practical legal risk management system, further sharpening our competitive edge.

Leading Ethical Management

Engage in dialogue with affiliate audit areas.

Organize theme-specific audits.

Regularly share audit/whistle-blowing incidents among affiliate entities.

Guarantee the autonomy and independence of the auditing division.
Routine Audits & Oversight

Intensify audits of affiliates by instituting a regular audit protocol.

Initiate preventive audits for private firms.

Conduct consistent reviews of incident reports and risk management statuses.
Elevating Ethics Awareness

Facilitate ethical management training both online and offline.

Strengthen the whistle-blowing initiative and ensure comprehensive oversight.
Enhance protective measures for whistle-blowers.
Expand channels for both internal and external group audits.

Operate a dedicated website for ethical management.

Compile and share group-specific case studies.
Action-Based Legal Risk Management

Foster proactive legal risk management through continuous dialogue.

Distribute legal checklists and guidelines for pivotal contracts and operations.

Deliver comprehensive legal support, utilizing both domestic and international expertise.

Respond adeptly and proactively to emerging legal challenges.

Direct Link to KOLON Ethical Management Site

Principles that emphasize early risk identification to mitigate potential impacts.

We actively identify and evaluate a broad range of risks to minimize both their likelihood and impact.

KOLON Pharma Co., Ltd. (referred to as the ‘Company’) is dedicated to enhancing the quality of life for people everywhere by developing safe, high-quality medications anchored in a deep respect for human life.
Under our core values—which focus on being a beloved company to our customers and fostering unique, differentiated capabilities among our employees—we are committed to righteous management. We believe that “true sustainable competitiveness is achieved solely through fair competition.” With this principle in mind, our aim is to stand as a strong and trusted entity.
To this end, we have both established and proclaimed a compliance policy to ensure all employees adhere to the relevant rules and conduct their roles ethically.

Adherence to Compliance ObligationsBoth the Company and its employees are committed to fulfilling all applicable compliance obligations, domestically and internationally.

Actions Regarding Non-adherence to Compliance ObligationsIf an employee fails to adhere to compliance obligations or knowingly neglects preventive measures, the Company will not assume responsibility on their behalf. Instead, disciplinary actions may be taken based on company guidelines.

Duty to Report Compliance IssuesAll employees have the responsibility to address compliance matters and report them to the assigned compliance officer.

Protection of Compliance WhistleblowersThe Company provides a mechanism for employees to report compliance breaches. We guarantee the confidentiality of both the report and the whistleblower’s identity, ensuring protection against potential repercussions.

Alignment with Organizational GoalsThe Company continuously seeks to enhance its compliance management system, aligning it with our broader organizational objectives.

Our stance against corruption risks:
“Anti-Corruption Management Policy.”

KOLON Pharma stands firm in championing a transparent and equitable society. To this end, we have instituted our Anti-Corruption Management Policy and are perpetually refining our initiatives to support this mission.

Purpose This policy aims to establish an anti-bribery management system that sets the standards for the personnel of KOLON Pharma Co., Ltd. (referred to as the ‘Company’).

Bribery Prohibition The Company strictly forbids bribery and conflicts of interest. This includes, but is not limited to, the acceptance of gifts, hospitality, or other benefits from parties with vested interests, irrespective of the pretext by any personnel.

Adherence to Anti-bribery Laws All personnel must adhere to both local and international anti-bribery regulations. This covers laws such as Korea’s “Criminal Act”, “The law on aggravated punishment of specific crimes”, “Convention on Combating Bribery of Foreign Public Officials in International Business Transactions”, and “The Improper Solicitation and Graft Prohibition Act”. International mandates include the “Foreign Corrupt Practices Act” from the USA and the UK’s “Bribery Act”. Any activity that might be construed as a breach is prohibited.

Upholding Organizational Integrity Personnel are obliged to evade bribery risks arising from potential contraventions of Article 3. By strictly adhering to the anti-bribery guidelines and the management system, they further the Company’s overarching objectives.

Sustaining the Anti-bribery Initiative The Company commits to instituting and maintaining an efficient anti-bribery management system, aimed at preempting and mitigating risks tied to Article 3 violations. Furthermore, it’s mandatory for all personnel to annually reaffirm their commitment by signing the anti-bribery pledge.

Anti-bribery Compliance Role The Company will designate a specific function for overseeing anti-bribery compliance. This role, endowed with independent authority concerning anti-bribery directives, will provide and supervise initiatives addressing challenges intrinsic to the Company’s anti-bribery framework.

Whistleblower Protections The Company assures the confidentiality of all informants’ identities. If a whistleblower happens to be an employee, they will be shielded from any evaluations or positions stemming from their disclosure. They will also be insulated from any adverse financial implications. Any significant contributions made by the whistleblower will be acknowledged in performance evaluations.

Repercussions for Non-compliance The Company will not shoulder the legal consequences for any personnel in violation of this policy and associated regulations. Should any member fail in their preventive duties, they might face disciplinary repercussions as per Company guidelines.

AddendumThis policy becomes effective on December 01, 2017.

Internal Compliance System for Fair Trade Regulation Adherence

Kolon Pharma places the utmost emphasis on the safety and well-being of all employees as well as those engaged with partner entities across every business division.

Promotion of Competitive Order

Operated In-House

What is the Fair Trade Voluntary Compliance Program?

The Fair Trade Voluntary Compliance Program, also known as the Compliance Program, represents an ‘internal compliance system’. Companies, as economic actors, set up and manage this system themselves. It incorporates education and oversight to ensure businesses promote competitive standards and willingly adhere to fair trade-related laws and regulations (Law and Regulation).

The Compliance Program (CP) furnishes employees with clear guidelines on adhering to competition laws. By instilling a culture of compliance within the company, CP not only facilitates the early detection and voluntary rectification of legal infractions but also provides the groundwork for strategies to prevent recurrent violations.

The Compliance Program (CP) aligns with the Global Standard. Advanced economies like the US, Europe, and Japan have long adopted and operated under CP. It is also incorporated into the criteria used to judge corporate legal transgressions in these regions. Likewise, in our country, CP is considered a pivotal element of corporate economic operations.

Laws Pertaining to Fair Trade Fair trade-related laws include the Monopoly Regulation and Fair Trade Act, Fair Transactions in Subcontracting Act, Fair Transactions in Agency Act, Fair Transactions in Franchise Business Act, Act on Fair Labeling and Advertising, Framework Act on Consumers, Installment Transactions Act, Act on Door-to-Door Sales, Etc., and the
Act on the Consumer Protection in Electronic Commerce, Etc. All these regulations aim to enhance competition and sustain fair trading standards.

Implementation of the 7 Factors

Under the ‘Regulation on Fair Trade Compliance Program Operation, Incentive, Etc.’, companies must meet 7 criteria to achieve CP certification. KOLON Pharma has structured its internal compliance system according to these 7 factors, ensuring both a robust culture of compliance and the promotion of fair trade standards.

01

CEO’s Proclamation of Compliance The CEO conveys a steadfast commitment to upholding fair trade regulations to all employees. This commitment is reinforced through a dedicated proclamation event and supporting documents. In tandem, employees submit their Pledge of Compliance.
02

Appointment of a CP Compliance Officer An executive, excluding those from areas like sales and marketing that might be prone to legal breaches, is appointed as the compliance officer. This officer is vested with the authority and responsibility to steer the operations of the CP.
03

Creation and Dissemination of a Compliance Manual Employees are provided with guidelines on fair trade practices, operational regulations, and related directives to ensure clarity and consistency in adherence.
04

Ongoing and Structured Compliance Education To prevent potential infringements of fair trade laws, regular training sessions are held, especially for departments like sales and marketing, which are traditionally more vulnerable to legal complications.
05

Establishment of an Internal Control System A precise code of conduct is formulated, delineating the expected behaviors and practices for all employees. Furthermore, standards and procedures for the smooth operation of the CP are recurrently relayed to staff, ensuring continuous alignment.
06

Enforcement Against Fair Trade Regulation Breaches A system has been instituted that outlines equitable disciplinary measures for employees who contravene fair trade regulations. This framework is both established and actively maintained.
07

Creation of a Document Management System All compliance-related documents are systematically cataloged and stored, ensuring they are readily accessible when required.

Operating Organization

Operational Progress

2010~Present

2021

Board of Directors Meeting - Formation of Compliance Policy & Appointment of Compliance Officer

Designated Compliance Officers

JaeKwang Chun, CEO and DongMin Oh, Ethics Management Team Leader

03 ~ 06

Conducted ethics management training for the sales department in March and June (twice)

Online ethics management training catered to all employees

Achievement of ISO37301 external auditor certification (1 member from the Ethics Management Team)

Execution of ethics management training specifically for the sales department

On ‘Fair Trade Day’, promoted the fair trade self-compliance culture and received the ‘Fair Trade Commission Chairman’s Commendation’ (WoonYoung Lee, Vice-Chairman of the Ethics Management Team)

04 ~ 06

Ethics management training for the sales department held in April and June (two sessions)

Board of Directors Meeting - Appointments:

Self-Compliance Manager/Anti-Corruption Officer.

Collaborative appointments included JaeKwang Chun, CEO and JungHoon Lee, Chief of Business Support.

Anti-Corruption Officer roles filled by JaeKwang Chun, CEO and DongMin Oh, Vice-Chairman of Ethics Management Team

Recognition and incentives awarded to top CP-compliant employees (5 from the clinic business department and 2 from the hospital business department)

Creation and dissemination of the 2nd edition Fair Trade Self-Compliance booklet for staff members

2020

2019

All-staff online ethics management training

Three professionals achieved Level-1 Compliance Management Expert qualification

Two members from the Ethics Management Team secured ISO37001 international auditor certification

Inauguration of the ethical management enhancement ceremony

Comprehensive ethics management training spanning all business sectors

Best CP-compliant employees recognized with incentives (5 from the clinic business department and 2 from the hospital business department)

Ethics management training provided to all business units

Acquired ‘ISO37001 Post-Assessment Certification’

Outstanding CP-compliant employees rewarded with incentives (5 from the clinic business department and 2 from the hospital business department)

Online ethics management course designed for the entire workforce

Two professionals achieved Level-1 Compliance Management Expert status

Ethics management training rolled out to every business unit

Exceptional CP-compliant employees honored with incentives (5 from the clinic business department and 2 from the hospital business department)

05 ~ 06

All-inclusive ethics management training

Special CP lecture presented by WanBin Park, Attorney of Kim & Chang Law Firm, targeting CEO and departmental heads

Attainment of ‘ISO37001 Certification’ for the anti-corruption management system’s international standard

For contributions on ‘Fair Trade Day’, the team received the ‘Fair Trade Commission Chairman’s Commendation’ - JaeKoo Kang, Ethics Management Team Section Chief was highlighted

Underwent the 1st and 2nd rounds of ISO37001 certification audits

Conducted internal ISO37001 audit

02 ~ 03

Comprehensive ethics management training for all business divisions

Board of Directors Meeting to discuss a change in the ‘Self-Compliance Manager’ role for the Fair Trade Self-Compliance Program

Transitioned from ‘WonKwon Kim, Senior Manager’ to ‘ChanSung Park, Department Head’

A total of 17 individuals completed ISO37001 internal auditor training

Commended exemplary CP-compliant staff with incentives (5 from the clinic business department and 2 from the hospital business department)

2018

2017

Board of Directors Meeting

Establishment of Anti-Corruption Policy and Selection of Anti-Corruption Officer

Anti-Corruption Officers: WooSeok Lee, CEO; ChanSung Park, Department Head (jointly appointed)

Referral to Personnel Committee for employees violating CP guidelines; disciplinary actions taken (1 warning, 3 advisories)

Launching ceremony for the ISO37001 (Anti-Corruption Management System) certification task force

‘A’ grade achieved in the ‘Fair Trade Commission’ Fair Trade Self-Compliance Program evaluation;

CP training provided for all business units

Acquired Compliance Management Expert qualifications (1 Level-1, 1 Level-2)

Recognition on ‘Medicine Day’ for spreading CP culture; awarded the ‘Food and Drug Safety Award’ (given to Ethics Management Team Leader)

Special lecture on the Anti-Graft Law by Attorney JiHye Seol of Hwa Woo Law Firm – aimed at CP representatives of the Sales and Marketing Departments

Incentive awards given to exemplary CP-compliant employees (5 from the clinic business department, 2 from the hospital business department)

CP training for all business units

Special CP lecture by Attorney HanChul Kang from Kim & Chang Law Firm (for CEO and department heads)

Board of Directors’ resolution: WooSeok Lee, CEO, jointly appointed as ‘Self-Compliance Manager’

Incentive awards given to exemplary CP-compliant employees (5 from the clinic business department, 2 from the hospital business department)

11~12

CP training for all business units

09~10

Company-wide ‘Anti-Graft Law’ training

Company system overhaul following the implementation of the ‘Anti-Graft Law’

Special lecture on the ‘Anti-Graft Law’ by Attorney KyungBok Boo of TY&Partners (for CEO and department heads)

Incentive awards for exemplary CP-compliant employees (5 from the clinic business department, 2 from the hospital business department)

Revision of 3rd term Compliance operation (CP enhancement)

Acquired Compliance Management Expert qualifications (1 Level-1, 1 Level-2)

CP training for all business units

CP training for the management team

CP training for the marketing team and all business units

Achieved ‘A’ grade in ‘Pharmaceutical Industry Ethical Management Self-Assessment Index’ under the Korean Pharmaceutical Association

Incentive awards for exemplary CP-compliant employees (5 from the clinic business department, 2 from the hospital business department)

2016

2015

Referral to Personnel Committee for employees violating CP guidelines; disciplinary actions taken

CP training for all business units

Acquired Compliance Management Expert qualification (1 Level-2)

CP special lecture by an external speaker (for executives and related departments)

Acquired Compliance Management Expert qualifications (2 Level-1)

CP training for all business units

CP training for the marketing team

CP training for all business units

Production and distribution of ‘Kolon Pharmaceuticals CP Guidelines v2’

CP training for all business units

Board of Directors’ resolution: WooSeok Lee, CEO, jointly appointed as ‘Self-Compliance Manager’

CP training for all business units

Centralized CP training for all main office employees

Referral to Personnel Committee for employees violating CP guidelines; disciplinary actions taken

CP guidelines training for all main office employees

Establishment of the ‘Compliance Management Committee’

Production and distribution of ‘KOLON Pharma CP Guidelines’ for the entire company

Appointment of ‘Self-Compliance Manager’ and ‘Legal Observer’

“Strengthening Legal Management Proclamation Ceremony” held; CEO’s commitment and pledge from all employees to uphold the law

Formation of a dedicated CP department (Legal Management Team)

2014

2012

Joined the ‘Fair Trade Practical Research Association’

CP Officer Appointment

Education and related tasks for the Korea Pharmaceutical and Bio-Pharma Manufacturers Association (KPMA) Fair Competition Agreement

2010

Ministry of Health and Welfare Regulations

Link

Fair Trade Commission’s Fair Trade Law

Link

Korea Pharmaceutical and Bio-Pharma Manufacturers Association

Link

Anti-corruption & Civil Rights Commission’s Prohibition of Solicitation Act

Link

Kolon Pharmaceutical’s Ethical Management Reporting System

A system for Kolon Pharmaceutical’s employees, partner companies, customers, and other stakeholders to report unfair behaviors, undue requests, provision or receipt of gifts/bribes, misconduct, corruption, and other inappropriate activities by Kolon Pharmaceutical employees.

Kolon Pharmaceuticals commits to identifying employees’ legal violations or unethical behaviors early, ensuring ongoing ethical management, and paying attention to valuable employee feedback.

Reported matters will be kept confidential, and the whistleblower’s identity will be strictly protected.
We promise fair processing of reports and aim to actively engage with even the least heard voices, providing an open channel for communication.

Subjects for Reporting

Actions involving demands or receipts of gifts, favors, entertainment, or convenience.

Gaining unfair advantages or inflicting harm using one’s position or role.

Improper financial transactions among stakeholders.

Misusing company assets or profiteering from them.

Violating workplace laws, rules, or regulations.

Any actions against Kolon Group’s ethical management principles.

Procedures

STEP 01
Report
STEP 02
Receipt
STEP 03
Fact verification and investigation
STEP 04
Addressing the issue
STEP 05
Responding to the whistleblower

Report

Personal Information Collection and Use Agreement

We intend to collect and utilize personal information for the confirmation of reports and related investigations.
Please review the content in detail before providing your consent.

1. Purpose of Personal Information Collection and Use
· Additional confirmation of report details, guidance on receipt acknowledgment, and task processing, if necessary.

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