Ethical and Compliance

Environmental
Social
Governance

ESG

Ethical and Compliance Management

In the global pharmaceutical and bio industry, where a high level of regulatory compliance is required, clean ethical and compliance management is a core standard for a company's sustainable growth and the securing of trust. If a compliance violation occurs, it can lead not only to legal sanctions but also to damage to corporate reputation, negatively affecting global partnerships and business opportunities. Accordingly, ST Pharm makes the Jeong-Do Management compliance pledge mandatory for all employees and operates an ISO 37001-based Anti-Bribery Management System (ABMS) to conduct regular risk assessments and internal audits. In addition, in response to the legislation of fund-fraud controls, we newly established controls in the finance area and completed the operating evaluation, and we identify the scope of fund controls to prevent and detect fund-related fraud and design and operate the related control activities. This ethical and compliance management framework serves as a foundation for enhancing corporate credibility and realizing responsible management.

Ethical and Compliance Management Governance

Category	Organization	Leadership	Composition	Roles & Responsibilities
Decision-Making Body	Audit Committee	Chairman	Internal Directors Outside Directors	Review and approve anti-bribery policy Review ABMS management review results
	Social Responsibility Management Committee	CEO	Management	Conduct ABMS management reviews and report the results Establish anti-bribery objectives
	Anti-Bribery Audit Committee	Director of Anti-Bribery Compliance Function	Corporate Audit Team Internal Auditors	Operate and oversee ABMS Manage bribery risk and internal audit
Implementing Organization	Corporate Audit Team (Risk Officer)	-	-	Conduct company-wide ABMS activities Conduct ABMS training
Implementing Organization	Internal Auditor	-	-	Identify, analyze, and assess bribery risks, and implement corrective and preventive actions Conduct monitoring and internal audits

Anti-Bribery Policy

All employees of ST Pharm shall not engage in any acts of bribery related to the work.
ST Pharm shall comply with applicable domestic anti-bribery laws and regulations, and if necessary, refers to international anti-bribery laws and regulations.
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.
If there are any Issues raised, it shall be possible to raise in good faith or in reasonable confidence, without fear of retaliation.
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.
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.
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.

ABMS anti-bribery objectives

Prohibition of corrupt practices	Prohibition of all giving or receiving of improper benefits related to employees’ work

Submission of pledges	100% submission of pledges to express commitment - Jeong-Do Management compliance pledge - Due diligence checklist for anti- bribery

Training	Implementation of and 100% completion of training to internalize awareness - Company-wide training (once a year) - Reinforcement training - New-hire training

Employee due diligence	Strengthening ABMS activities of teams with medium-or-higher corruption risk

Awareness enhancement	Sharing activity records and related materials on the bulletin board Company-wide promotion of standard contracts

Corruption Risk Assessment and Management

Based on the ISO 37001 PDCA (Plan-Do-Check-Act) cycle, ST Pharm operates an Anti-Bribery Management System (ABMS) to systematically assess and manage corruption risks. In accordance with the risk assessment process, each team identifies corruption risks by analyzing, from multiple angles, the occurrence and impact factors of country, industry, transaction, and business-partnership risks. We also implement preventive and mitigating measures for the identified residual risks

Corruption Risk Assessment Process

Environmental analysis	• SWOT analysis • Identification of internal and external issues
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Risk identification, analysis, and assessment	• Risk identification • Conducting a risk assessment by risk • Review of current control systems
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Establishment and implementation of management measures	• Establishment of a residual risk management plan • Implementation measures in accordance with the management plan
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Internal audit	• Conducting monitoring and internal audits • CAPA management

Ethics Risk Management

To enhance the transparency of corporate operations and proactively manage fund-related fraud risks, ST Pharm is advancing the operation of its internal accounting control system. In line with the 2025 legislation of fund-fraud controls, we newly established account opening/closing approval procedures and controls for preparing and reviewing monthly fund-balance plans, and completed the operating evaluation. In addition, to prevent and detect fund-related fraud, we have designed and operate nine key fund-control activities. We have established these control activities as a company-wide defense system to respond to potential ethics risks such as corruption and money laundering, and through the continuous review and advancement of our internal control system, we seek to practice transparent ethical management in line with global standards.

Fund Control Activities

Approval of account opening and closing

Verification of the balance of each CMS account and reconciliation with the balance of each account in the Douzone ERP

Physical control of the corporate seal

Control of approval for the use of the corporate seal

Review and approval of the payment list

Segregation of duties for fund execution

Control of the fund execution status through the daily fund report

Preparation and review of the monthly fund-balance plan

Approval of borrowing drafts and credit transaction agreements, or of proposals related to bond issuance and extension

Embedding Ethical and Compliance Management

Anti-Bribery Training

To establish a sound corporate culture and raise awareness, ST Pharm provides anti-bribery training for employees every year, and conducts regular anti-bribery training for each team's ABMS managers and internal auditors. In 2025, we conducted company-wide training by inviting an external instructor with high expertise and communication skills. A satisfaction survey conducted after the lecture confirmed high satisfaction with the external instructor's lecture and showed it to be effective in raising employees' awareness.

Social Responsibility Management Awareness Survey

ST Pharm conducts an annual online survey of employees to review the level of compliance management implementation and employees' awareness. The 2025 survey results showed improved awareness, with the proportion of positive responses rising by about 2-5%p year on year across all items, including a social responsibility management index of 81%, an external compliance management index of 74%, and an internal compliance management index of 70%. Based on the collected data, we will seek concrete measures to further raise the level of compliance management implementation and will actively strive to establish a transparent corporate culture.

Compliance Pledges

To establish a company-wide compliance management culture, ST Pharm conducts the Jeong-Do Management compliance pledge and the anti-bribery compliance pledge for all employees, achieving a 100% pledge submission rate as of 2025. Through the process of reviewing the details of the pledge and signing it, employees review their ethics and compliance awareness and internalize it as part of the corporate culture. In addition, as a result of requesting suppliers to submit the supply chain management Code of Conduct compliance consent form and the anti-bribery compliance pledge, we achieved a 100% supplier pledge submission rate.

Corruption Reporting Channel

ST Pharm operates a reporting system so that all stakeholders—including employees, partners, and customers—can report unethical conduct such as corruption, unfair trade, and legal violations freely and with peace of mind. We operate the Cyber Audit Office "CLEAN :D" and "K-Whistle," a reporting system entrusted to a third-party external organization, in parallel to secure accessibility and objectivity. Reports received are handled in accordance with the independent investigation procedures of the Corporate Audit Team and, depending on the severity of the matter, lead to appropriate measures and recurrence-prevention activities.

Report Now - K-Whistle / CLEAN :D

Scope of whistleblowers
• Employees • Customers	• Partners and supply chain members • Other stakeholders
Reportable conduct
• Corruption • Sexual harassment, sexual violence • Others (unethical conduct)	• Abuse of power and workplace harassment • Irregularities in HR recruitment and assignment
Whistleblower protection
Confidentiality (the whistleblower and the content are kept confidential; identity is not disclosed without the whistleblower's consent) • Status protection (protective measures so that the whistleblower does not suffer disadvantage from reporting) • Liability limitation (sufficient leniency where a whistleblower is involved in the reported violation such as corruption)

Environmental Social Governance