ESG
Ethical and Compliance

Environmental
Social
Governance

ESG

Ethical and Compliance
Anti-Bribery
Security & Privacy
ST Pharm operates an Anti-Bribery Management System (ABMS) based on ISO 37001 to prevent corruption and establish an ethical corporate culture. The ABMS, which was introduced in 2021, applies to all employees and aims to promote an anti-bribery workplace culture and strengthen risk management through various activities. Major activities include company-wide anti-bribery training, awareness surveys, and risk identification and corrective measures. Through these efforts, we continue to improve our ethical management throughout the organization.

Policy

 
  1. All employees of ST Pharm shall not engage in any acts of bribery related to the work.
  2. ST Pharm shall comply with applicable domestic anti-bribery laws and regulations, and if necessary, refers to international anti-bribery laws and regulations. 
  3. The head of anti-bribery shall establish company-wide anti-bribery goal and execution plan accompanied with detailed objectives and schedule and ensure that this policy is achieved.
  4. If there are any Issues raised, it shall be possible to raise in good faith or in reasonable confidence, without fear of retaliation. 
  5. The authority and independence of the head of anti-bribery and the ST Pharm Anti-Bribery Audit Committee(STPAAC) shall be guaranteed according to the detailed operational standards of the STPAAC.
  6. All employees of ST Pharm shall comply with anti-bribery policies and procedures. All employees shall be aware that if we do not comply with the policy, we shall be subject to strict disciplinary action in accordance with in-house human resource procedures.
  7. This anti-bribery policy shall be communicated in an appropriate language to ST Pharm employees, related stakeholders, and business partners with medium or higher bribery risks. 
Anti-Bribery Audit Committee(STPAAC)
To ensure the effective operation of the anti-bribery management system, the Anti-Bribery Audit Committee holds regular meetings once every six months to share detailed plans and results of ABMS activities. 
 
Audit Committee
As the highest decision-making body, the Audit Committee reviews and approves anti-bribery policies and deliberates on the results of ABMS management reviews to propose directions for ongoing improvement. 
Anti-Bribery Risk Management

Pledge to Practice Jeong-Do Management
As part of our commitment to establishing and realizing a culture of Jeong-Do Management, all employees, including the CEO, submit a pledge every year to practice Jeong-Do management. We have confirmed that 100% of our employees submitted their pledges.

Assess and Manage Bribery Risk
ST Pharm evaluates and manages company-wide bribery risks based on anti-bribery goals established using the ISO 37001 Plan-Do-Check-Act (PDCA) cycle. Teams are divided into groups and follow a risk assessment process to identify bribery risks by considering factors such as the occurrence and impact of national risks, industry risks, transaction-related risks, and business partnership risks. We also identify residual risks and take corrective measures to prevent and mitigate such risks, and regularly report the final results of internal audits to the CEO and the Audit Committee.
 
Survey on the Implementation of Jeong-Do Management
ST Pharm conducts an annual Jeong-Do Management awareness survey to understand the level of Jeong-Do Management implementation and employee awareness. A total of 25 questions related to Jeong￾Do Management and social responsibility were asked in an anonymous online survey.
 
Anti-Bribery Training
Each year, ST Pharm holds anti-bribery training to promote an anti￾bribery culture and internalize awareness of the dangers of workplace bribery. We implement company-wide training for all employees and capacity-building training for internal auditors on a regular basis. In addition, we conduct a separate ABMS enhancement training for departments classified as “medium or higher” in the bribery risk assessment. Following the company-wide and ABMS training, we administer surveys to evaluate the effectiveness of the training in raising awareness. 
Corruption Reporting Channel
ST Pharm operates “K-Whistle” and a “cyber audit office (CLEAN :D)” to enable employees and stakeholders (partners, clients, etc.) to easily report corruption and unethical behavior (unfair trade, violation of laws, etc.).
 

Report Now - K-Whistle / CLEAN :D 



[Corruption Reporting and Handling Process_PNG]
Ethics and Compliance Management
Classification
Unit
 2022 2023 2024
Anti-corruption activity
 Jeong-Do Management pledge rate % 100 100 100
Corruption case
 Total monetary loss KRW 1 million 0 0 0
Corruption or bribery Case 3 0 1
Code of conduct
violation
 Discrimination and harassment Case 0 0 0
Customer information protection Case 0 0 0
Conflicts of interest Case 0 0 0
Money laundering or insider trading Case 0 0 0
Legal and regulatory 
violation
 Safety and health violation (fines) Case (KRW 1 million) 1 (1.5) 1 (5) 0
Environmental violation (fines) Case (KRW 1 million) 0 0 0
Anti-competitive and antitrust 
violation (fines)		 Case (KRW 1 million) 0 0 0
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