
Shinhan Financial Grouphereinafter referred to as “Group”) values its ethical reputation as the core asset of the group as a global financial group, and to this end, all executives and employees shall recognize and actively practice the importance of ethical values as a basis for desirable decision-making and behavior. This Code is a major principle of the group’s ethical management ideology and policies, and all executives and employees shall contribute to the group’s ethical reputation by complying with it.

General Provisions
1. Application of the Code
1.1. This Code shall apply to the holding company, subsidiaries, grandchildren companies and all executives and employees of the Group.
1.2. Subsidiaries and grandchildren companies may operate separate ethical standards within the scope of this Code and the Group’s ethical management ideology and policies.
2. Reporting and effects of violations of the Code
2.1. When the executives and employees recognize the violation of this Code, they shall report it to the relevant department, such as the senior manager, compliance support department, or internal audit department without delay.
2.2. When the executives and employees make decisions or act against this Code, they may be investigated in accordance with relevant internal regulations, and unfavorable measures may be taken against them.
3. Inspection of the Code and Request for Comments
3.1. The holding company’s Compliance Support Department may conduct periodic inspections of the Code and the Group Compliance Officer shall verify such inspections.
3.2. The executives and employees may request the opinion of the Group Compliance Officer if the judgment or interpretation of the application of this Code is not clear.
Chapter 1 Ethics of Executives and Employees
1. Compliance with laws and fair conduct
The executives and employeesshall respect market order, comply with all laws and regulations in all areas of the group, and pursue fair and ethical work performance.
1.1. They shall comply with and respect laws and regulations, international norms and local community traditions and cultures.
1.2. They shall not commit or engage in illegal money laundering or insider trading.
1.3. They shall not impose or direct unfair or unethical work on their colleagues or subordinates, or they shall not respond to such coercion or instruction.
2. Prohibition of Bribery and Prevention of Corruption
The executives and employees shall keep in mind that bribery and corruption can undermine the group’s ethical reputation. Bribery refers to all forms of gain handed over with the intention of promoting illegal or unethical conduct, including money, services, gifts, donations, grants and preferential treatments.
2.1. No bribery or promises shall be made in connection with business.
2.2. They shall not take unfair profits or let third parties take unfair profits by using the company’s assets or their position.
3. Prevention of Conflicts of Interest
The executives and employees shall not cause conflicts of interest with the company or customers, and in the event of conflicts of interest, the interests of the company and customers shall have priority.
3.1. They shall not engage in private profit-making activities or dual-job activities for profit purposes unless it has been allowed by due procedure.
3.2. When there is a conflict of interest between the customers or between the customer and the company or when there is a possibility of a conflict of interest, it shall be notified to the senior manager, related departments, and compliance support departments so that proper actions can be taken.
4. Protection of confidential information and Information Security
The executives and employees shall strictly manage and protect the information of customers and companies known in the course of their work performance.
4.1. Information that requires confidentiality in relation to the company’s own information and customers (hereinafter referred to as “confidential information”) shall be protected in accordance with the relevant laws, this code and internal regulations, and shall not be disclosed or used privately.
4.2. Confidential information is irrespective of the type of records and the presence or absence of records, and the executives and employees shall not ask other executives and employees to provide or peruse confidential information not related to their work
4.3. An executive or employee who manages and uses confidential information shall refuse the unjust request to provide or peruse the confidential information from inside and outside the company in performing his/her duties, and shall strictly manage confidential information in a manner separated from general information.
5. Protection of Company Assets and Business Opportunities
The executives and employees shall not use the company’s assets for private purposes but shall protect their assets with the duty of good manager’s care, and shall not use the company’s business opportunities known in the course of their work performance or let third parties use them.
6. Mutual respect and non-discrimination among group companies
The executives and employees shall not use the company’s assets for private purposes and protect their assets with the duty of good manager’s care, and shall not use the company’s business opportunities known in the course of their work performance or let third parties use them.
7. Prohibition of Engaging in Unfair Political Activities
The executives and employees shall not engage in unfair political activities and shall not provide illegal donations or expenses to political parties or politiciansdirectly or indirectly.
Chapter 2 Ethics for Customers, Shareholders, Executives & employees and Partner Companies
1. Protection of Interests and Property of Customers
The group shall keep in mind that the development of customers is our development, and shall do best to create new value for customers at all times.
1.1. The group shall provide the best products and services that meet the customer’s true needs and expectations.
1.2. The group shall continuously improve the methods and procedures of communication to respect and reflect customer opinions.
1.3. In order to protect the legitimate interests and property of customers, the group shall perform the duty of good manager’s care.
2. Protection of Interests of Shareholders and Investors
The Group shall recognize that protecting the interests of its shareholders and investors is our primary responsibility, and shall maximize the interests of its shareholders and investors by raising the value of the group by creating excellent performance.
2.1. In order to secure management transparency for enhancement of the group’s value, the group shall maintain the accuracy and reliability of accounting data.
2.2. The group shall provide Information necessary for shareholders and investors in a timely and fair manner in accordance with relevant laws and internal regulations.
2.3. The group shall establish mutual trust by respecting the legitimate requests and suggestions of shareholders and investors.
3. Pursuit of Happiness of Executives and Employees
The group shall respect the basic human rights of the executives & employees and create the working environment in which individual abilities and creativity are maximized.
3.1. No unfair discrimination shall be made based on academic background, regionalism, age, gender, race, religion, marital status, disability, political orientation, etc.
3.2. The executives & employees shall respect each other and shall not act to harm the sound working environment such as sexual harassment, money transactions, formation of private organizations, or violence, etc.
3.3. Fair compensation shall be given according to performance, and fair opportunities for self-development shall be given according to abilities and qualities.
3.4. The group shall continue to improve the safe and pleasant working environment so as to improve the health of the executives & employees.
4. Win-win with Partner Companies
The Group aims for win-win relationship through fair transactions with partner companies such as suppliers and service providers, and expects partner companies to fully understand and follow the spirit and content of this Code.
4.1. In selecting partner companies and maintaining transactions, considerations shall be given as to whether they comply with the group’s ideology and policies regarding ethics and environmental protection, etc.
4.2. In selecting partner companies, the group shall not force them to purchase goods or services of the group.
4.3. The group shall deal fairly in mutually equal positions and shall not engage in unfair acts taking advantage of superior positions.
Chapter 3 Social Responsibility and Contribution
1. Environmental Protection
The group shall recognize that the protection of the natural environment is the essential requirement for sustainable development for us and future generations, comply with applicable laws and regulations, and actively participate in environmental protection activities.
1.1. The group shall comply with environmental laws and regulations that apply in all areas of group activities.
1.2. The group shall respect international standards and practices for environmental protection.
1.3. Environmental protection shall be considered as a major factor in establishing the policies, standards and procedures of the group, and efforts shall be made to achieve eco-friendly work performance.
2. Respect for Basic Rights
The group shall respect the basic rights of human beings in all areas of group activity, and comply with the international standards for basic rights.
3. Community Contribution
As a member of the community, the group shall actively participate in desirable social contribution activities enhancing the value of the community and its members.