GLOBAL COMPLIANCE GUIDELINE - Hyundai Mobis · DO NOT exchange any pricing information with a...

GLOBAL COMPLIANCE GUIDELINE

Dear Hyundai MOBIS associates,

Hyundai MOBIS is to strengthen the advanced management system·compliance

management system global company must have and expedite the essential

technological competitiveness in order to lead the future vehicle technology.

Hyundai MOBIS associates must have the compliance consciousness suitable for global

company. It is obvious transactions of multinational company with subsidiaries, joint

ventures, related companies and supplier is being a new business opportunity, however,

it gives us a business risk at the same time.

Therefore, Hyundai MOBIS is moving to an established compliance management

system through strengthening the supervision and monitoring infrastructure for the risk

management system and ensuring the continued awareness of compliance and ethical

obligations.

The most important success factor in the compliance is the continuous and absolute

commitment of Hyundai MOBIS associates to compliance management. If Hyundai

MOBIS associates are aware of the compliance with voluntary conduct, compliance

management will be internalized naturally and settled in the corporate culture.

This Global compliance guideline offers a direction can respond effectively as to

representative and bumping into basic eight areas (Anti-corruption·Fair trade·Customs·

Personal data protection·Employment·Environment·Intellectual property·Product

safety) while performing the tasks.

Please cooperate in the efforts for Hyundai MOBIS to grow as a trusted global company

through successfully establishment of the advanced compliance management by

ensuring and complying with this Global compliance guideline.

2015. 7.

Hyundai MOBIS CEO

Myung-Chul Chung

CEO Message

CONTENTS of GUIDELINE

ANTI-CORRUPTION1

FAIR TRADE2

CUSTOMS3

PERSONAL DATA PROTECTION4

P.04

P.22

P.10

P.30

HYUNDAI MOBIS GLOBAL COMPLIANCE GUIDELINE02

EMPLOYMENT

ENVIRONMENT

5

INTELLECTUAL PROPERTY7

6

PRODUCT SAFETY8

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P.44

P.38

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CONTENTS of GUIDELINE 03

ANTI-CORRUPTIONGUIDELINE

1


Hyundai MOBIS prohibits all bribery and corruption.

In general, corruption is the misuse of entrusted power for private

gain. Corruption is offering anything value in order to obtain or

retain business, or to gain preferential treatment and 'anything

value' includes any type of money·property·service·special

terms or offers, etc. An offer or a promise can violate the law even

if nothing is ever actually given and it may result in disciplinary

action.

Please note that if a Hyundai MOBIS associate commits the acts of

corruption, the associate and Hyundai MOBIS as well may receive

criminal penalties by the anti-corruption law of the associate's

country but also by the laws of other countries.

In general, corruption may take forms as following:

● A bribe in return for providing an illegal or irregular service or

treatment

● Anything value, is given to an individual in return for an unfair

business advantage, even when that individual may not have

requested a payment or be expecting one

ANTI-CORRUPTION GUIDELINE1 05

GIFTS ANDENTERTAINMENT

Business gifts and entertainment of nominal value are customary courtesies

designed to build goodwill among business partners, however, it should be

modest and intended only to facilitate business goals. If a level of entertainment

is excessive, and it may arise when such courtesies compromise, or appear

to compromise on the ability to make objective and fair business decisions,

Hyundai MOBIS associates must refuse request or demand for a bribe because

it could be interpreted as a bribe.

Legitimate business promotional activity can include moderate meals and

beverages, souvenir or promotional goods and reasonable travel and

accommodation for business purpose.

If you have difficulty determining whether a particular gift or entertainment item

is within the bounds of acceptable business practice, ask yourself these guiding

questions:

● Is it legal?

● Is it moderate, reasonable, and in good taste?

● Is it fine to disclosure to the public?

● Is there any pressure to reciprocate or grant special favors?


Strict rules apply when Hyundai MOBIS does business with government

officials, and associates must take particular care when dealing with.

The term 'government official' includes:

● Officials and employees of government-owned or government-

controlled departments or agencies

● Employees of government departments or agencies

● Officials and employees of any government-owned or government-

controlled commercial entities, banks or joint ventures

● Political parties and party officials

● Political candidates

GOVERNMENT OFFICIALS

Formal agreement must be signed by Hyundai MOBIS and the business partners

before service begins and the scope of service, service fee, and service period

must be clearly documented. There must be standard terms and conditions

covering not to offer, authorize or give bribery and to take affirmative steps to

prevent from engaging in bribery and to promptly report to Hyundai MOBIS any

corruption or suspected violations.

Engaging business partners is to be conducted through a fair process and

concluding an executed written agreement under the nature and results of the

due diligence, an explanation of the business reasons for requiring a business

partner for the proposed business, and the justifications for selecting the

specific business partner proposed.

BUSINESSPARTNER


To prevent anti-corruption fines for the cause of inaccurate record or hid

the payments on the accounts under other expense descriptions such as

promotional or marketing expenses or cost of goods sold, Hyundai MOBIS

associates must always maintain accurate and complete financial books and

records.

Hyundai MOBIS associates shall avoid actual or perceived conflicts of interest

in performing business and shall avoid engaging in transactions on behalf of

Hyundai MOBIS with close relatives or other companies in which you or a close

relative directly owns or indirectly financial involved.

ACCURACY OF FINANCIAL RECORDS

CONFLICTS OF INTEREST


Hyundai MOBIS associates should report immediately any suspected corrupt

activity or potential violations to management. Reports may also be made

anonymously and Hyundai MOBIS will protect associates who report suspected

corruption violations. All concerns raised are taken seriously and will be

handled thoroughly.

REPORTING CORRUPTION BEHAVIOR


FAIR TRADE GUIDELINE

2

10 HYUNDAI MOBIS GLOBAL COMPLIANCE GUIDELINE

Hyundai MOBIS is committed to do its utmost efforts for

complying with the Monopoly Regulation and Fair Trade Act (also

known as 'Fair Trade Act', hereinafter referred to as 'Fair Trade

Act') of all countries that are applicable to its business through

operating fair trade compliance program in order to lead the

international automotive parts business by delivering the most

competitive products of the highest quality.

This Fair Trade compliance guideline has a common underlying

theme, which is that fair competition benefits consumers by

providing the best products at the competitive prices and also

ensures that productive resources are allocated in the most

efficient matter.

A violation of the Fair Trade Act can be a serious crime and

individuals convicted of Fair Trade Act violations can face

jail terms and civil claims and Hyundai MOBIS can also be

imposed on penalty or surcharge for the wrongful conduct of

individual associates, even when such associates act contrary to

instructions.

FAIR TRADE GUIDELINE2 11

DO

● DO know your major competitors for Hyundai MOBIS product

● DO exercise the utmost caution to avoid competitively sensitive

topics whenever there is need to interact with personnel from

competing companies

● DO always include the source of price information (ex. market

reports, customer or other proper source) when making a record of

competitor's prices

● DO encourage associate to report if you learn the associate have

contacted competitors for an inappropriate purpose

● DO consider whether there are justifiable reasons for any disparity

between profit margins on sales to different types of customers

DO NOT

● DO NOT communicate with a competitor or exchange information

unless it has been determined by your management

● DO NOT attempt to injure a competitor by making false statements

about its products or using unfair or deceptive tactics

● DO NOT use any improper means to gather information from a

competitor

Do!

Don't!

There is no activity that raises fair trade risks than communications and

dealings with competitors. Given the potential legal risks, it is best to avoid

communications with competitors if at all possible. On the other hand, there

are some aspects of our business that require us to interact with personnel

from competing companies. Whenever this becomes necessary, it is very

important to exercise the utmost caution.

When communicating with competitors, drawing distinctions between lawful

and unlawful conduct can often be challenging and may require a careful legal

analysis. Please contact Compliance officer if you have even the slightest

question about the legality of a given course of action.

CONTACT WITH COMPETITORS


● DO NOT stay at any meeting that includes competitors (such as

a trade association meeting or conference) if pricing or any other

competitively sensitive topics become a topic of conversation. If this

happens, leave quickly and make an effort to ensure that those who

remain are aware of your departure

● DO NOT exchange any pricing information with a competitor,

regardless of whether it is about

- Price - An increase or decrease in prices

- Pricing procedures - Standardizing or stabilizing prices

- The level and reasons for a competitor's bid price

- What profit level is fair

● DO NOT have any discussion of non-price terms of sale with

competitors

- Volume of business - Delivery commitments - Production capacity

● DO NOT have any contacts with competitors during a competitive bid

for a supply contract

● DO NOT agree to submit a non-competitive bid or no bid (sham

bidding)

● DO NOT seek or reach any understandings with competitors such as

- On pricing - On terms of sale to customers

- On geographical regions where products will be offered for sale

- Industry segments

● If a competitor makes a statement about a price change or ending

discounts, DO NOT DO ANYTHING to suggest agreement, either by

responding orally or by nodding of the head or some other tacit sign

of agreement

● DO NOT give a competitor any indication that you may be interested

in their or any other competitor's pricing information


● DO NOT refer to competitively sensitive topics or speak freely about

the company's operations even in casual conversations with friends,

relatives or acquaintances who work for competing firms

● DO NOT ask a competitor to indicate what its price or position would

be with a customer regardless of whether you or the competitor

see a good reason for providing the information, and regardless

of whether you could confirm the competitor's information

independently

● DO NOT enter any industry-wide agreements to:

- Prohibition of competitive transaction - Divide markets

- Divide customers - Non-competition

- Divide territories - Rid bids

- Fix price - Reduce output

- Restrictions on a certain transacting partner

● If you have occasion to refer to a competitor in any communication

DO NOT say anything that could be construed as suggesting

cooperation, support, alignment, sharing or allocating markets, or

following or coordinating action with the competitor

● DO NOT make or mention predictions about competitors' actions

without explaining proper, independent basis for the prediction

● DO NOT use any pricing information from a competitor in any way

to determine the price to a customer

● DO NOT attend meetings with competitors on the sidelines of

industry events

● DO NOT impose any price discrimination, or offer promotional

allowances, between different customers in the same market where

not clearly justified by differing purchase volumes or differences in

cost, expedited delivery schedule


DO

● DO have a clear decision-making process for determining prices

● DO ensure that there is transparency about who makes pricing

decisions, how they are reached and the reasons for them

● DO document the reasons whenever exceptions are made to the

standard pricing methodology

● DO document the reasons whenever different prices are set for the

same products in the same market

● DO have a clear process for bids of supply contracts

● DO always follow the tender rules when bidding

● DO have and follow a clear procedure for reviewing customers'

response to Hyundai MOBIS' bids and deciding whether and how to

submit a revised bid

Do!

Hyundai MOBIS' prices must be determined independently based on its own

analysis of costs and prevailing market conditions. In setting prices, it is legal

to consider information relating to competitors' price that has been obtained

lawfully or to analyze independently a price charged by competitors.

Competitor price information must, however only be obtained from proper

sources such as customers, newspapers, industry reports, and other public

sources. The source of this price information should always be documented so

that Hyundai MOBIS can show it was properly obtained.

PRICING


DO

● DO understand the Hyundai MOBIS' pricing to customer and the

process and decision-making authority for determining prices

● DO contact Compliance officer before imposing any form of

competitive restriction on business partners

● DO consider some business partners have relationships with

competitors

Do!

Fair trade issue can also arise when dealing with business partners. Hyundai

MOBIS' business partners are entitled to make their own independent business

decisions and any attempt to deprive business partners of their freedom to

determine what products they will purchase or sell, the prices they will pay or

charge, what territories they will compete in, or what companies they will do

business with, could result in an antitrust violation.

BUSINESSPARTNER

DO NOT

● DO NOT appoint or terminate a specific business partner resulting

from the relation of other business partners

● DO NOT require business partners to deliver all or most of their

output

Don't!


DO

● DO seek the guidance of the Compliance officer whenever another

type of restriction, or a new or different type of distribution

arrangement or practice is to be imposed on a customer, dealer or

distributor

Do!

Restrictive in agreements with customers, dealers and distributors are normal

and necessary, while others (e.g. restrictions on markets, or terms of resale)

may not be appropriate without a justifiable grounds permitted under the Fair

Trade Act.

DISTRIBUTION PRACTICE

DO NOT

● DO NOT make agreements with customers to set specific prices or

minimum resale price (known as 'resale price maintenance')

● DO NOT fix a maximum profit margin that a customer can achieve,

or maximum level of discount that it can provide, on resale of the

product

● DO NOT make any type of threat or warning or use any type of

penalty, delay or suspension of deliveries as a means of influencing a

customer's resale price

● DO NOT grant a rebate or pay a promotional cost to a customer if it

agrees to a certain resale price

● DO NOT ask a customer to link its resale price to a competitor's price

Don't!


● DO NOT impose non-price restrictions on resellers imposing limits

on:

- What products they can sell

- What customers that they can do business with, or

- What territories they can compete in

● DO NOT impose discriminatory prices or added costs on competing

customers of the same class for the same product, unless there is a

fair or objective justification such as a cost saving, differing volume

of purchase, differing level of promotional services

● DO NOT make sales of one product conditional upon acceptance of

other products or services without providing appropriate justification

● DO NOT propose sales at unprofitable or marginally profitable prices,

or at prices that are lower in some geographic areas than they are in

others

● DO NOT agree to buy or sell goods or services on the condition that

the other party will buy from or sell


Please keep in mind that violations of Fair Trade Act are grounds for internal

disciplinary action and it may lead to criminal punishment can be regarded as

a serious crime, and in the event a Fair Trade Act investigation of competent

authorities, obstruction of justice is also a serious breach of applicable legal

regulations.

In order to prevent this, associates are familiar with Fair Trade Act, and fully

corporate in internal monitoring and audit on a regular basis to verify Fair Trade

compliance. In particular, the associates who are involved in setting prices or

making sales to customers should take a Fair Trade training mandatory and get

a confirmation on completion.

KNOWLEDGEOF FAIR TRADE ACT


All communications should be accurate and communicated in a written form.

Please avoid careless language or misleading statements that might cause

someone to think that Hyundai MOBIS has done something wrong when it has

not.

ACCURATE WRITING

DO NOT

● Avoid oral, written statements in careless language or exaggerations,

and misleading statements or hastily composed business documents

● DO avoid jokes or careless phrases that create an air of impropriety

or wrongdoing

● Do avoid exaggerations of a predicted market share or a predicted

impact of marketing efforts on competitors

● DO NOT use the word 'we' when referring to pricing or other market

action if there is any possibility that it could be misunderstood as

referring to some type of joint activity involving competitors

Don't!


In order to verify compliance with the Fair Trace Act, competition authority can

obtain evidence by way of an unannounced visit to conduct examination for

the respective premises of the Hyundai MOBIS, and they can order to submit

materials necessary and interview staffs.

On-site examination by itself does not mean that Hyundai MOBIS has violated

Fair Trade Act, however, a refusal to comply can create the impression that

Hyundai MOBIS had something to hide, and non-compliance may lead to fines

on Hyundai MOBIS or the person concerned.

Therefore, please cooperate in request of competition authority to submit

materials and questions within the scope of legitimate examination, and

associates are expected to contact Compliance officer for advice and assistance

whenever there is any doubt about the legality of matter in the responding

examination such as corresponding is beyond the authority or unreasonable

demand.

COORPERATION ON INVESTIGA-TIONS OFCOMPETITON AUTORITY


CUSTOMS GUIDELINE

3


Hyundai MOBIS is to comply with the customs compliance and ensure all the Hyundai

MOBIS' data pertinent to customs compliance are accurate and up to date.

The associates responsible for managing Hyundai MOBIS' supply chain are expected to

be aware of and familiar with the applicable rules of customs classification, valuation,

and country of origin, as well as FTA requirements and applicable anti-dumping and

countervailing duties.

There has been an increasing number of Free Trade Agreement (FTA) around the

world in recent years, and Hyundai MOBIS has taken advantage of benefits under

Korea's FTAs with United States, EU, ASEAN, India, Chile and Peru. These FTAs impose

significant and complex conditions on the qualification of manufactured goods for the

FTA benefits.

FTA rules of origin was determined whether a product assembled or manufactured

in Korea has undergone the right type of manufacturing or has the required level of

Korean or other originating content in order to qualify for the FTA benefits.

Because these rules of origin vary significantly from one FTA to another, a product that

qualifies as Korean origin under one FTA may not qualify as Korean origin under other

FTA. Therefore, country of origin analyses must be performed separately under each

FTA.

Hyundai MOBIS' associates responsible for customs are expected to understand and

comply with conditions and limitations concerning FTA, duty drawback, imports, and

must confirm FTA qualification before claiming FTA benefits because the rules of origin

vary significantly from one FTA to another. In addition, associates are expected to

maintain complete and accurate records of all import and export transactions, including

purchase orders, contracts, invoices and payment records to support its position.

When a customs issue is not clear, it is expected to consult with Compliance officer by

receiving the customs regulations.

23 CUSTOMS GUIDELINE3

Hyundai MOBIS associates should take steps to ensure that the sources of

HS classifications are regularly updated and keep classification data current

and valid. If you are unsure of the correct HS classification, it is encouraged to

contact management for guidance, including the possibility of obtaining a legal

advice or requesting a customs ruling.

When authorities investigate customs classifications, seek to verify country

of origin, question to valuation or raise other compliance issues, it is vitally

important to have complete and accurate records to support its position.

Fines can be imposed if required records have not been kept, and associates

who receive a subpoena or other formal notice of an investigation or alleged

violation should report the matter promptly to management.

Associates entering data to be used for customs valuation are expected to be

familiar with the valuation hierarchy of WTO and the elements of price and cost

that apply to the valuation method.

The transaction values by customs authority are used as the preferred method

of valuation whenever they are available, and when reviewing or relying upon

valuation data received from other employees or other companies, associates

are expected to be alert to anything suspicious that could suggest that an

incorrect valuation or methodology has been proposed. Please enter and use

valuation only when you consider them appropriate and reasonable based

upon all the information available and it can be modified in accordance with

the authoritative interpretation from an upper customs authority after customs

clearance.

In transactions between Hyundai MOBIS affiliates, please adhere to the Hyundai

MOBIS' transfer pricing policy. If associates believe that the existing transfer

pricing policy does not cover their transaction, please report to management

and encouraged to receive legal advice regarding the necessity of updating

transfer pricing policy.

CUSTOMSCLASSIFICATIONS

CUSTOMSVALUATION


● Materials, components, parts or other items incorporated in the

imported goods

● Tools, dies, molds or other items used in the production of the

imported goods

● Engineering, development, artwork, design work, and plans and

sketches that are undertaken outside the country of import and are

necessary for the production of the imported merchandise

Customs assists can affect customs valuation because Hyundai MOBIS has

international operations and customs assists generally occurs when there

are transfer pricing issues between affiliated groups or the followings may

be required to be added to the valuation of products manufactured with the

benefit of such an assist.

When determining the correct customs valuation of the imported products,

Hyundai MOBIS' associates are expected to include the price of the product

or service when it comes to products were provided at no cost, and include

discount difference in case of products were provided at reduced price when

import declaration.

Hyundai MOBIS' associates are to ensure that all dutiable assists are identified

and properly reflected in the customs valuation and report either customs

authorities or to the person concerned. Furthermore, it is expected to take an

appropriate step to confirm that no adjustment in the valuation is required due

to an assist.

ASSISTS


● The product is manufactured entirely from raw materials (e.g. raw

metal or plastic resin) in that country,

● The product is destined for a non-FTA destination and substantial

transformation has occurred through undergoing a complicated

assembly process in the proposed country of origin

● The product is destined for an FTA destination and has been found to

have that country of origin under the rules of origin that apply under

the applicable FTA

Rules of country of origin is to qualify for the FTA benefits, and country of origin

analyses must be performed separately under the respective rules of country of

origin because it varies significantly from one FTA to another.

Whenever entering the country of origin information for a product that is

imported or exported for the first time, please take appropriate steps to be

assured that the information has been correctly determined before you base

the information merely on a third party addressed.

Please do not enter a specific country as the country of origin for a product

unless you know or have been reliably informed the followings.

If you are not certain the country of origin, please enter the country of origin in

the documents·database·system based on the accurate grounds by advance

determination requests regarding country of origin to customs authorities.

In no circumstances should you ever base a country or origin determination

merely on a third party address from which a product was shipped.

COUNTRY OF ORIGIN


Templates for certificates of origin have to maintain appropriately the applicable

FTA, related parts, the criteria for country of origin that are being relied upon,

other pertinent data, and the relevant FTA records are preserved and retained

in accordance with procedures because customs authority can request to

submit the certificates or origin and other relevant materials for verification of

the status of the country of origin.

The backdating, fabrication or altering of any documentation pertinent to

customs matters will be subject to criminal violation or discipline excepting for

the case permitted by applicable laws.

In Free Trade Zone (hereinafter referred to as 'FTZ'), it is allowed to import

goods free of customs duties for the purpose of re-export following storage,

assembly or other processing. Hyundai MOBIS is to maintain strict security and

accounting for FTZ operations so that goods entering FTZ are used only for

authorized purposes and are re-exported in compliance with applicable law.

In the operations at FTZ, do not prepare or maintain different versions of

inventory or other accounting records, and in no circumstances will release

goods from FTZ into the domestic market except as may be permitted by law.

Violation of the rules governing FTZ security, re-export and handling of goods

in FTZ or proper accounting for such goods will be considered a serious

infraction and will be subject to discipline.

FTA ANDCUSTOMSDOCUMENTATION

FREE TRADE ZONES (FTZ)


Many countries use trade remedy proceedings to redress what are found to

be unfair practice such as dumping of goods at less than fair value or the

promotion of exports by means of improper government subsidies.

The trade remedies used to respond to such dumping or subsidies are anti-

dumping duties and countervailing duties and the duties also can be extremely

high, sometimes as much as 200% of the value of the goods.

Hyundai MOBIS is to comply fully with anti-dumping and countervailing duty

orders, and to cooperate with government anti-dumping and countervailing

duty investigations when asked to provide information. It could happen,

however, that a supplier may be tempted not to follow the rules and, instead,

try to pass goods off as having been produced in a another country or by a

different producer not subject to the same level of duties and this is a serious

violation of law referred to as 'circumvention'.

Anti-dumping and countervailing duties are based upon the country of origin

and these duties are often quite high, therefore, custom compliance requires

ongoing vigilance including the misreport a product's origin to try to avoid

these duties.

Hyundai MOBIS' associates are expected to be vigilant and take steps to ensure

that no goods have become subject to anti-dumping or countervailing duties

are incorrectly reported.

If a request of meeting or sharing information from other companies in a

reference to a potential anti-dumping or countervailing duty case is not

handled carefully, it could draw the unnecessary legal disputes or compromise

competitive information confidential and it can also raise Fair Trade issues

depending upon the circumstances. Therefore, any associates who receive

such requests are required to contact Compliance officer how to respond to the

request before proceeding with any meeting or providing any information.

ANTI-DUMPING ANDCOUNTERVAILINGDUTIES


Customs authorities are paying increasing attention to supply chain security

issue aiming for combatting terrorism and drug trafficking.

Hyundai MOBIS is to meet, and where appropriate, exceed the standards of

security for its supply chain and qualify and maintain qualification for customs

security programs, including the U.S. Customs Trade Partnership Against

Terrorism (C-TPAT).

Associates responsible for managing shipments and movement of goods in the

Hyundai MOBIS' supply chain are expected to be familiar with and take steps to

maintain the qualification for C-TPAT, AEO and similar programs.

Hyundai MOBIS is to conduct regular audits to comply with customs

compliance. Such audits will include testing and verification whether the

customs data is appropriate, including classification, valuation (including

assists), country of origin, FTA compliance, anti-dumping and countervailing

duty compliance and supply chain security.

Customs authority can audit or examine Hyundai MOBIS' customs compliance

and Hyundai MOBIS is to cooperate to the full extent required by law with all

such customs audit.

When customs authorities conduct audit, please respond objectively within the

range of tasks and misleading customs authorities can be a crime or be subject

to discipline.

Customs authorities will give advance notice of routine auditing activity, and

any unannounced customs visit or raid, as well as any customs audit that is not

a matter of routine, will be notified to Compliance officer. Please seek guidance

from Compliance officer before responding to subpoenas, interrogations or

other inquiries from customs authorities.

If there are programs that provide benefits including reduced customs audit

activity, assistance and resources in exchange for the fulfillment of customs

obligations by customs authority, it is encouraged to evaluate custom incentive

programs that may be available in their jurisdiction and consider participating

if benefits are considered worthwhile in comparison with the cost of the

additional obligations.

SUPPLY CHAIN SECURITY

CUSTOMSAUDITS


PERSONAL DATA PROTECTION GUIDELINE

4


Hyundai MOBIS strictly protects the personal data of associates

and customers, and personal data that is in the records of

the various business places at the head quarter and overseas

corporations around the world will be protected by Hyundai

MOBIS from unauthorized disclosure.

'Personal data' is generally a term that any information associated

with a person, not known to be publicly available and this includes

the following:

● Name

● Address

● Telephone or cell phone

● E-mail

● Nationality, residence status and country of origin

● Date of birth

● Marital status and family members

● An individual's financial information

● Identifying numbers of individual (e.g. national identification

number, passport number, credit card number, bank account

number, etc.)

● Any health related information

● Any information concerning religion, personal interests or

personal activities

31 PERSONAL DATA PROTECTION GUIDELINE4

● Hyundai MOBIS must inform data owners about the purposes for

which their personal data are collected and used

● Hyundai MOBIS must give data owners a choice whether their data

will be used for a different purpose or disclosed to a third party

● Hyundai MOBIS must use reasonable measures to protect personal

data from loss, misuse, unauthorized access, disclosure, alteration or

destruction

● Hyundai MOBIS must ensure that personal data collected are relevant

for the purposes for which the data are used

● The data owner must have access to the personal data that

Hyundai MOBIS holds and the ability to correct, amend or delete the

information

● Hyundai MOBIS must provide a process for review and resolution of

data owners' complaints and disputes concerning the handling of

their personal data

● Notifying data owners of their ability to examine and correct, amend

or delete information about them

● Managing and upgrading system security to ensure the aspects of

security do not become out of date

● Using strong encryption to protect system from the unauthorized

access

● Continually upgrading system security to ensure that levels of

encryption and other aspects of security

● Having reporting procedures in place in the event of a breach of

personal data

Hyundai MOBIS will carry out the examinations on a regular basis to ensure

the technical protection measures for personal data are implementing properly

based on the following principles.

Associates responsible for personal data protection are expected to constantly

monitor the personal data protection regulatory changes, and have clear

procedures to comply with regulations.

Complying with personal data protection means the following:

PERSONALDATAPROTECTION PRINCIPLES


● Restricting access to personal data to Hyundai MOBIS' associates,

and other professional consultants who have a need to know the

information in order to perform their work

● Maintain a system in order to protect personal data and prevent its

loss or destruction

● Ensure that documents containing any personal data are kept in

locked place

● Any loss of a computer, electronic device, paper file or other material

that may contain personal data

● There was an attack on a system that contains personal data or any

evidence suggesting that there was an attack

● The personal data has been transferred or any circumstance

suggesting that personal data has been transferred without

authorization

● Hyundai MOBIS' personal data protection compliance policy

● The basic personal data protection principles applicable in the

respective country

● Prohibition the transmission of personal data collected

● The report and appropriate protection measure

One of the most important aspects of personal data protection compliance is

the immediate reporting of personal data protection breaches. When personal

data have been compromised, it requires early notification to the data owners

so that data owners can take steps to protect themselves against losses such

as the fraudulent misuse of their identifying information.

Please report immediately the following events to the security officer.

Protection of personal data and prevention a breach of data security requires

proper training of the associates who may have access to personal information

on a regular basis, and personal data protection training covers the following.

REPORTINGANDPROTECTION MEASURE

PERSONALDATAPROTECTION TRAINING

33 PERSONAL DATA PROTECTION GUIDELINE4

EMPLOYMENT GUIDELINE

5


The purpose of this employment compliance guideline is to

summarize basic principles that will govern Hyundai MOBIS'

relationships with its associates and associates are expected to

follow. Please consider the violation of this policy can lead to

discipline.

Hyundai MOBIS is committed to having a respectful and inclusive work

environment and no Hyundai MOBIS' associates shall be subject to physical·

sexual·psychological·verbal harassment or abuse.

In this guideline harassment includes language or conduct that may be

derogatory, intimidating, or offensive to others, and take all harassment

complaints seriously. Managers should immediately address behavior or

conduct that may be offensive, and should encourage an atmosphere in which

every associate feels free to report potential violations.

Treat coworkers with trust and respect at all times, and always think about

how something could be perceived by others as a precaution. Do not harass or

intimidate others through bullying or making jokes using abusive language or

participate in activities that may be offensive to others and discourage others

from engaging in such behavior.

Hyundai MOBIS prohibits retaliation against anyone making a good-faith

complaint of harassment, or who cooperates in an investigation or a complaint

that alleges harassment, and retaliation will result in discipline.

HARASSMENT OR ABUSE

35 EMPLOYMENT GUIDELINE5

● Honor the Hyundai MOBIS' non-discrimination policy

● Remember that every associates share responsibility for implementing

Hyundai MOBIS' policy of equal opportunity in employment, and its

commitment to diversity

● Participate Hyundai MOBIS' effort as it strives to have minorities and

women well represented throughout its work force

● Treat coworkers with trust and respect at all times

Hyundai MOBIS is committed to equal opportunity in employment and to

fostering diversity in its work force. Hyundai MOBIS' hiring policies and practices

require that there be no discrimination, mainly, because of race·color·

religion·age·gender·gender-identity·nationality·disability or other factors

and shall not subject any associates to discrimination in employment including

salary·benefits·advancement·discipline or other factors.

Hyundai MOBIS recognizes that diversity in its work force is a valuable asset,

and it strives to provide an inclusive work environment in which different ideas,

perspectives, and beliefs are respected. Violations of Hyundai MOBIS' non-

discrimination policy may result in discipline.

Hyundai MOBIS expects all associates to comply with the followings:

Hyundai MOBIS will not use forced labor against his will by oppression of

associates' thoughts or body, will not engage in any production or labor

manufacture by persons younger than legal ages and is committed to

complying with the regulations of wages·benefits·hours of work·overtime

compensation.

NONDISCRIMI-NATION

EMPLOYMENT AND WORKING ENVIRONMENT


● Searches on personal or facility for alcohol or illegal drugs

● Alcohol and drug testing

1. If judgment or performance appears impaired

2. If judgment appears behavior is erratic

3. Under special circumstances such as following an incident.

Hyundai MOBIS is committed to providing associates with the workplace

be free from substance abuse for associates' health, benefits and Hyundai

MOBIS' profit, and it is prohibited to use·possess·manufacture·distribute·

dispense·transport·promote·sell illegal or illicit drugs or other intoxicating

substances, and drug paraphernalia while on business or on Hyundai MOBIS'

premises.

Hyundai MOBIS will take steps to investigate possible violations of its substance

abuse when it is determined that judgment or performance appears impaired or

under special circumstances such as following an incident, and violation of the

substance abuse policy or refusal to cooperate without justifiable grounds may

result in discipline.

In order to protect associates' health and safety, Hyundai MOBIS will take steps

to investigate possible violations of its substance abuse in accordance with the

local laws and associates are expected to cooperate in the followings.

SUBSTANCE ABUSE

37 EMPLOYMENT GUIDELINE5

ENVIRONMENT GUIDELINE

6


Hyundai MOBIS is committed to meeting environmental regulatory

requirements that apply to its business as a leading automotive

parts manufacturer and is taking positive steps to preserve and

protect the environment through manufacturing and business

operations in compliance with applicable environmental laws and

regulations.

Hyundai MOBIS' environmental policy also includes supporting

improvements in fuel economy for the vehicles using Hyundai

MOBIS' parts and systems as well as supporting reductions in

emissions. Environmental improvements of Hyundai MOBIS

facilities likewise extend beyond reductions in pollutants to

encompass reduced water consumption, conservation of energy,

recycling and reuse of materials and use of renewable sources of

materials.

ENVIRONMENT GUIDELINE6 39

● Have properly trained and experienced environmental personnel who

know the applicable legal requirements and policies

● Ensure that their facilities have effective controls for the safe handling

and disposal of IMDS controlled chemicals

● Have water·air·waste disposal facilities appropriate to local

regulations and management system

● Maintain procedures and programs in place to ensure environmental

compliance

● Support effectively to comply with the local environmental

compliance by using IMDS and other corporate resources

Hyundai MOBIS' place of business should comply with a program in accordance

with the nature of its local operations and the laws and business practices

applicable in its jurisdiction to manage environmental compliance.

The responsibilities of Hyundai MOBIS are as the following.

ENVIRONMENT COMPLIANCE PROCEDURES


● Identifying new production inputs

● Identifying the substances that will be present in the final product

● Identifying new airborne, liquid or solid waste that will be generated

● Including in this analysis intermediates to which workers may be

exposed

Because IMDS is maintained by the Automotive Industry Action Group,

companies that use it cannot reply upon it as a legal guarantee of compliance,

however, IMDS is the primary tool upon which Hyundai MOBIS relies for

ongoing environmental compliance.

It covers global regulations for countries, including EU rules (RoHS, WEEE and

REACH), U.S. rules, and special local rules like those of California Prop 65.

For ongoing environmental compliance, please regularly review IMDS regulatory

changes and ensure that regulatory changes have been noted and acted upon

by Hyundai MOBIS in a timely manner.

The design of any product or production process requires the identification and

clearance through the IMDS program of all substances being introduced into

the product, the manufacturing facility or the environment.

This means:

Hyundai MOBIS' manufacturing requires the use of solvents of various kinds.

These solvent give rise to volatile organic compounds that become airborne.

Please monitor continuously the use and dispersion of these volatile organic

compounds to minimize their dispersion through the air, or in waste water or

other waste, and also monitor on an ongoing basis to ensure that solvents

and volatile organic compounds are not present in the Hyundai MOBIS' final

products.

THEINTERNATIONALMATERIAL DATA SYSTEM (IMDS)

VOLATILEORGANICCOMPOUNDS


● DO NOT permit or disposal of any chemical substance subject to

restriction in any drain or sewer

● DO NOT dispose or permit the disposal of any chemical substance

subject to restriction into the circulating air of the facility or into the

open air without authorization in excess of limitations.

● DO NOT dispose or permit the disposal of any waste water containing

chemical substance in open bins or unauthorized disposal containers

● In case of leakage or accidents, notify the environmental·safety

compliance manager and follow their direction

● Access restrictions and control of initial response general public

(staff·visitor, etc.) not wearing personal protection equipment

● Report fire·explosion·leakage incident due to chemicals to

authorities involved

● In case of toxic chemical substance accidents, evacuate staff in

workplace and nearby residents

● As for issue of management and disposal, request for environmental

compliance managers to take measures for complying with

regulations

● Cooperate as required in the completion and filing of any report of

the incident

Associates responsible for handling chemical substance, please note the

followings.

If any chemical substance is released, not maintained by due course or

disposed without authorization in the premises of Hyundai MOBIS, Hyundai

MOBIS' associates who first notice this should immediately take the following

actions.

RESPONSIBILITIESOFPERSONNEL HANDLING CHEMICALS


Hyundai MOBIS' responsibility includes knowing the environmental

characteristics of parts it sources from other companies and uses in production

through contractual provisions and regular quality assurance checks. Parts

suppliers will be required to enter a proper chemical composition information,

and provide Material Safety Data Sheet (MSDS) regarding chemical substance

or mixtures containing them.

Hyundai MOBIS maintains the ISO 14001 standard and works to source as

parts and materials for its operations from suppliers who meet the ISO 14001

standard.

When Hyundai MOBIS establishes new facilities, Hyundai MOBIS operates

facilities to meet the ISO 14001 standard and regulations through

environmental analyses to the facilities, and when ISO authority issues

recommendations or detects a violation, Hyundai MOBIS will work diligently to

implement such recommendations and correct it promptly.

Hyundai MOBIS will dedicate the resources necessary for engineering

consultants with environmental regulatory expertise and wide experience to be

available to assist whenever necessary to ensure that environmental analyses

of new substances and production operations are complete and correct.

Please fully cooperate with government inspections of environmental

compliance by manufactures in the vehicle sector.

If you receive a notice from any government agency initiating compliance

investigation or a potential environmental violation, forward it immediately

to the management and do not handle compliance investigations or alleged

violations on your own.

PARTSSUPPLIERS

ISO 14001 STANDARD

CONSULTANTS

GOVERNMENT INSPECTIONS


INTELLECTUAL PROPERTY GUIDELINE

7


Hyundai MOBIS publishes and uses intellectual property (IP) in

its global operations, including patent, design, trademark, and

copyright, and the protection of IP rights extends to import

remedies that can be invoked to prevent the import of allegedly

infringing goods into other countries.

Customs authorities in the respective countries have the authority

to seize goods if they use trademark or other IP that are registered

without permission and importer and manufacturer are not on

the list of authorized licenses that the IP rights has notified to

customs.

When associates deliberately take or infringe another company's

IP, there can also be an investigation and prosecution of Hyundai

MOBIS and the associates responsible.

Hyundai MOBIS' associates responsible for managing design·process·

trademark·copyright materials or other IP are to follow the legal procedures

with respect to the evaluation of the new IP, and if you are uncertain whether

your work product constitutes IP or the subject of legal protection, please

report to the management.

OBTAININGLEGALPROTECTION FOR IP

45 INTELLECTUAL PROPERTY GUIDELINE7

● Before sourcing electronics or other parts from suppliers, please

investigate the nature of supplier's IP compliance organization and

supplier has its own engineering and design department with the

expertise to create its own designs and process.

● Ask supplier to document its IP rights applicable to the their product

that it is using to supply

● When procuring parts from suppliers, make sure if there is a

possibility of IP related disputes

● When entering into procurement contracts, include the representation

and warranty clauses including indemnification of Hyundai MOBIS in

the event the supplier's product infringes a third party's IP rights in

the supply contract

When associates procure parts from suppliers, please take appropriate steps

to satisfy whether the supplier has the legal right to use the IP that it is using to

supply. This requires compliance with the following steps:

CONTRACTS WITHSUPPLIERS

● Keep IP secure on the protected premises

● DO NOT send IP by unsecure means

● Maintain fire wall, encryption and other cyber security systems

● DO NOT carry copies off the premises except in accordance with

management instructions

● Report promptly to management if you learn of any loss or

compromise of IP or IP licensed belonging to Hyundai MOBIS, and

the potential violations of infringement or infringement of such IP by

a third party

Please comply with the below requirements on the use·duplication·distribution·

storage and handling of IP.SECURING IP


● Please consider whether Hyundai MOBIS would be able to enforce its

indemnity rights against the supplier in the event of an infringement

of IP

- Where are the supplier's assets

- When Hyundai MOBIS enforces the indemnity, a realistic prospect of

recovering damages from the supplier

● DO NOT ever plagiarize or use another company’s or author’s

creation without attribution, and seek permission whenever required

by law or contract

● DO NOT take design specifications, drawings or data from the

Internet except when you can be certain that they have been released

into the public domain without restriction. Examples of unrestricted

materials are specifications published by governments or public

agencies for public use (e.g. ISO standards, public domain). If you are

considering the use of materials that you cannot be certain fit the

public domain, then consider whether Hyundai MOBIS has a license

or other legal authorization to use it.

● DO NOT bring materials from your prior company to Hyundai MOBIS

and do not apply the concepts to Hyundai MOBIS projects

Hyundai MOBIS' associates should not use the unauthorized other companies' IP

in the performance of work, and it also requires care when using any information

known or believed to have originated from another company.

It is the strong policy of Hyundai MOBIS not to use other parties' IP without license

or other legal authorization. Personnel found to be infringing other parties' IP either

deliberately or as a result or recklessness or lack of due care will be subject to

discipline.

PROTECTING OTHERCOMPANIES' IP


● Verify the proposed new employee comes from a competitor or a

company with IP of using or potential interest to Hyundai MOBIS

● Verify the proposed new employee have access to any of IP belonging

to the former company

● Evaluate the proposed new employee signed an agreement with

the former company restricting its IP, and review those terms to the

extent necessary to identify any issues and access any risks of hiring

● Require the proposed new employee to certify that he has not taken

trade secrets from the prior company when leaving that position

● Require the proposed new employee to sign a certification of the

facts concerning the IP issue, and include notice that if the facts turn

out not to be as represented, this will be grounds for discipline

● Require the proposed new employee to sign an agreement to

hold Hyundai MOBIS harmless against an claim resulting from an

infringement claim brought by the prior company

● If there is a risk that Hyundai MOBIS or the associate could be

accused of infringing IP by prior company about the position that the

proposed new employee would be responsible, please consult with IP

department or Compliance officer on how to mitigate that risk

● Avoid the use any trade secret belonging to the prior company at

Hyundai MOBIS

IP can be infringed by personnel when moving from one company to another.

It is important, therefore, to include appropriate steps for IP compliance in local

human resources procedures for hiring and termination. Local hiring procedures

should include examination of the following points whenever personnel are hired

into positions involving design·engineering·trademark·materials subject to

copyright or use of confidential information such as customer lists.

HUMANRESOURCES


● In the case of retirement, similar human resources procedure is

applied. When leaving Hyundai MOBIS, it is prohibited to take the

Hyundai MOBIS' IP to new positions, and ensure that Hyundai MOBIS

can bring legal claims against the employee and his new company in

the event such misuse of Hyundai MOBIS' IP occurs

● Any lawsuit against Hyundai MOBIS asserting infringement of IP

● Any seizure of goods of Hyundai MOBIS by customs or other

government authorities that is based upon a claim of IP infringement

● Any document from a party which intends to file any lawsuit asserting

infringement of IP

● Any letter from a government agency alleging IP infringement by

Hyundai MOBIS

● Any investigations by a government agency concerning IP infringement

by Hyundai MOBIS

Hyundai MOBIS' associate should engage in occasion pursuant to business to

publish or speak on matters relating to the marketing programs, or the vehicle

industry only with management's approval and are ensured to protect Hyundai

MOBIS' intellectual property whenever engaging in such activities.

Whenever damage claims related to intellectual property litigation caused, please

notice immediately to Compliance officer of the followings, and it should not be

handled solely by personal because a product or part is the subject of legal actions

in one jurisdiction, it may easily become the subject of parallel action in another

jurisdiction.

In the event of damages claims concerning IP, Hyundai MOBIS will investigate the

circumstances, assert its contractual and legal rights to protect against possible

exposure.

AUTHORIZED PUBLIC EVENTS ANDDISCLOSURES

RESPONDINGTO CLAIMS


PRODUCT SAFETY GUIDELINE

8


Hyundai MOBIS meets and exceeds applicable safety standards

in many product safety areas and will study other manufacturers'

products in an effort to improve safety as a whole to gain new

insight.

51 PRODUCT SAFETY GUIDELINE8

● Ongoing monitoring and updating of product designs and production

to reflect the latest safety standards

● A rigorous program of product testing for design changes

● Extensive quality assurance testing of parts in production

● Careful assessment of the safety and quality standards of prospective

suppliers

● Monitoring of service experience

● Responding appropriately in the event of a product recall or claim

Hyundai MOBIS puts product safety first and this policy is implemented to

reflect the highest safety standards adopted by countries where Hyundai

MOBIS' products are sold.

Hyundai MOBIS' associates are expected to understand the vehicle safety,

product liability, and design and production decisions must be made with this

in mind. Please ensure the compliance with with regulations in order to comply

with safety regulations of its products, and keep monitoring on developments

involving other automotive parts and vehicle manufacturers to ensure

compliance with safety regulations of Hyundai MOBIS' products.

Safety issues have arisen because of the sourcing of parts or materials from

non-qualified suppliers. When sourcing parts or materials, Hyundai MOBIS'

design and quality assurance standards will be maintained and exceptions will

never be made. It is the responsibility of associates sourcing components,

parts or materials to satisfy themselves of the safety and quality standards

of Hyundai MOBIS, and to be alert to any signs that may raise a question

concerning the supplier's safety or quality capabilities.

When initiating a new design or design change, associates will follow the

applicable new design qualification procedure in force at the time. Please

ensure that new design efforts are undertaken from the outset with a view to

possible product safety issues, and design changes could be implemented to

improve safety.

FULFILLING REGULATORY REQUIREMENTS


Associates responsible for design and production engineering should write or

computerized the safety reasons behind design and production decisions and

improvements in the position of a vehicle purchaser from the proposal stage to

final approval and implementation of the change in a clear language to clarify

the evidence concerning the rationale for product safety.

Even the design or production engineering changes is based on highly technical

data or analysis, please include a brief summary explanation that puts the

safety rationale or improvements so that it can be presented if this is required.

The same priority given to safety in Hyundai MOBIS' own design and production

process must be applied whenever Hyundai MOBIS sources components or

materials from other companies. Hyundai MOBIS associates responsible should

take steps to be sure that sources or industry research reports concerning the

supplier's safety records are reviewed before a final decision is made to source.

In the case of negotiating terms of contracts with suppliers, please give

consideration to use Hyundai MOBIS' standard terms governing safety·quality

assurance requirements, recalls or legal liabilities.

Safety is never compromised under any circumstances, and it is never

appropriate to make that safety issue subsidiary to a question of cost. Never

make a design or production engineering choice if it would reduce safety,

and the design and production engineering decisions with potential safety

implications could be scrutinized in detail.

DOCUMENTA-TION

SOURCING

53 PRODUCT SAFETY GUIDELINE8

Hyundai MOBIS is committed to having systems and procedures available to

ensure that fully informed and correct decisions can be made with respect to

the safety of the products. Hyundai MOBIS associates are strongly encouraged

to bring to its attention any safety issues or concerns that they may notice or

become aware of.

If you suspect that a product of Hyundai MOBIS may be subject to a recall

or may need to be considered for recall, please report this case to the

management in the course of work or any other sources.

If you receive an inquiry from the unidentified party, lawyer or unidentified party

questioning the safety of Hyundai MOBIS' products, please do not provide any

information and say 'Make the correct person aware of the inquiry' and ask the

person for their name and contact information so that the right person can

contact with.

Please handle inquiries from suppliers or customers with caution based on the

sound judgment. Any inquiries seem unusual or accusatory should be reported

because the supplier or customer could be seeking information for reasons that

have not been disclosed unless there is clear direction from management.

If you receive a written inquiry from the government·subpoena·notice of

deposition or other legal documents that raise a question concerning safety

of Hyundai MOBIS' products, inform your management and if you receive an

oral inquiry from the government official concerning safety of Hyundai MOBIS'

product, simply say 'Let me make the correct people aware of the inquiry' and

report the matter promptly to management.

REPORTING SAFETY ISSUE

RESPONDINGTO OUTSIDEINQUIRIES


Hyundai MOBIS Global Compliance Guideline

Publisher Hyundai MOBIS

Date of Publication 29 July 2015

Publication Department Hyundai MOBIS Legal team

Design Mecayours

Copyright© Hyundai MOBIS.All rights reserved.

Please contact Compliance officer if you have any

questions on this Global compliance guideline.

-

Compliance officer contact information

[email protected]

www.mobis.co.kr

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