As a global financial services group, Shinhan Financial Group (‘Group’) recognizes its ethical reputation as one of its core assets.
Therefore, all members of the Group recognize the importance of ethical values as a standard for desirable decision-making and
actions and thus practice them proactively. As an important set of principles for the Group’s ethical management philosophy and
policies, this code of ethics are observed by all members of the Group for contribution to the Group’s ethical reputation.
1. Scope of Application
- 1.1 The Code of Ethics applies to the Group’s holding company, subsidiaries and indirect subsidiaries and all of their executives and employees.
- 1.2 Subsidiaries and indirect subsidiaries are allowed to put in place a separate set of code of ethics to an extent that it does not violate the philosophy and policies incorporated in the Group Code of Ethics.
2. Reporting of Violation and Implications
- 2.1 If executives and employees become aware of a violation of the Code, they should report it without a delay to their managers or a relevant department such as Compliance or Internal Audit.
- 2.2 If an executive or an employee makes a decision or behaves in violation of the Code, he or she can be subject to investigation in accordance with relevant internal regulations and may face disadvantageous measures.
3. Monitoring of the Code’s Compliance and Request for an Opinion
- 3.1 Holding company’s Compliance Department conducts regular checks on the status of compliance with the Code and the Group’s CCO(Chief Compliance Officer) ascertains such.
- 3.2 If a judgment on the Code’s application or its interpretation is not clear, an executive or an employee can seek an opinion of the Group’s CCO.
- Chapter 1 Ethics for Executives and Employees
- Chapter 2 Ethics on Customers, Shareholders, Executives & Employees and Vendors
- Chapter 3 Social Responsibility and Contributions
Chapter 1. Ethics for Executives and Employees
1. Legal Compliance and Fair Execution of Work
Executives and employees of Shinhan should respect market order, comply with relevant laws and regulations in all areas of the Group’s operations and strive to conduct their work in a fair and ethical manner.
- 1.1 They should comply with relevant laws and regulations and respect tradition and culture of a local community.
- 1.2 They should not commit or get involved in illegal money laundering or insider trading.
- 1.3 They should not force or instruct a colleague or a subordinate to do unfair or unethical work and must not yield if given such a pressure or instruction.
2. Bribery ban and corruption prevention
Executives and employees should keep in mind that bribery and corruption could hurt the Group’s ethical reputation.
Bribery refers to a profit in any forms that is illegal or given with an intention to motivate an unethical conduct and includes money, services, gifts, donations, contributions and preferential treatment.
- 2.1 They should neither offer/take bribery nor promise anything in return.
- 2.2 They should neither take an illegitimate profit nor have a third party take such a profit by taking advantage of their company’s assets or their positions.
3. Prevention of a conflict of interests
Executives and employees should not create a situation of conflicting with the Company and customers and, if such a circumstance occurs, must put the interests of the Company and customers first.
- 3.1 If not in accordance with the due process, they should neither engage in other private profit-making activities nor take a second job or position for the purpose of profit-making.
3.2 If a conflict of interests does occur or is likely to occur among customers or between customers and the Company, they should notify such fact to their managers or a relevant department such as Compliance to have appropriate measures taken.
4. Information Confidentiality and Security
Executives and employees should strictly manage and protect information of the Company and customers that they become aware of in the course of conducting their duties.
4.1 They should protect the Company’s proprietary information and customer information that require confidentiality (‘Confidential Information’) in accordance with relevant laws/regulations, the Code of Ethics and internal regulations and should neither divulge nor use such information for personal motivation.
4.2 Confidential Information may exist in any forms of recording or may have no record. Executives and employees should not ask another member to provide or grant an access to confidential information not related to their own work.
4.3 If those who maintain/use confidential information are asked to provide or grant an access to information illegitimately by someone internal or outside the Group, they should refuse such a request and must keep confidential information separate from other general information for strict management.
5. Protection of the Company’s Assets and Business Opportunities
Executives and employees should protect the Company’s assets with the duty of care and not use them for personal gains.
They should neither take advantage of a business opportunity of the Company they came to know of in the course of conducting their duties by themselves nor have a third party do so.
6. Mutual Respect among Group Companies and Prohibition of Discrimination
Executives and employees should show respect for other Group companies and maintain organic collaboration to maximize Group synergy and not discriminate against those from other Group companies.
7. Prohibition of Involvement in Illegitimate Political Activities
Executives and employees should neither engage in illegitimate political activities nor offer illegal contributions or expenses to a political party or politicians directly or indirectly.
Chapter 2. Ethics on Customers, Shareholders, Executives & Employees and Vendors
1. Protection of Customers’ Profits and Assets
Noting that customers' success directly leads to the Group's growth, all members of Shinhan should think from the perspective of customers and strive to create new values for them at all times.
- 1.1 Respect genuine needs and expectations of customers and offer products and services that satisfy them.
- 1.2 Make constant improvements to the method and process of communication with customers so as to identify and reflect customers’ opinions.
- 1.3 Fulfill the duty of care faithfully in order to protect customers’ due profits and assets
2. Protection of Shareholder and Investor Profits
Under the recognition of protecting the interests of shareholders and investors as its duty, the Group should work towards producing outstanding performance and increaseing its value so as to maximize profits of shareholders and investors.
- 2.1 Maintain accuracy and reliability of accounting data in order to secure management transparency and thus increase the Group’s value.
2.2 Provide information necessary for shareholders and investors in a timely, fair manner in accordance with relevant laws/regulations and internal regulations.
- 2.3 Respect legitimate requests and suggestions of shareholders and investors to build the relationship of mutual trust.
3. Pursuit of Happiness of All Executives and Employees
The Group should respect the basic rights of its executives and employees and create a work environment in which every one of them can attain his/her full potential and apply creativity to a maximum extent.
- 3.1 Apply no discrimination whatsoever on the basis of educational, geographical backgrounds, age, gender, ethnicity, religion, marital status, physical disability or political affiliation.
- 3.2 All executives and employees should respect one another and not engage in any behaviors that undermine sound work environment such as sexual harassment, monetary transactions, organization of private groups or violence.
- 3.3 Compensate fairly based on performance and give equal opportunities for self-development based on one’s capacity and talent.
- 3.4 Make constant improvements to create a safe and pleasant working environment to promote health of all executives and employees.
4. Mutual Prosperity with Vendors
The Group should endeavor to build the relationship of mutual prosperity with its vendors such as suppliers and service providers and expect them to fully understand and comply with the spirit and contents of this Code.
4.1 Take into account alignment with the Group’s philosophy and policies such as ethics and environmental protection when selecting vendors and maintaining transactions with them.
- 4.2 Do not force purchase of the Group’s products or services when selecting vendors.
- 4.3 Pursue fair transactions on an equal footing and refrain from engaging in unfair practices using a superior bargaining position.
Chapter 3. Social Responsibility and Contributions
1. Environmental Protection
In recognition of the fact that environmental protection is an essential requirement for sustainable development for us and our future generation, the Group will comply with relevant laws/regulations and take part in activities for environmental preservation proactively.
- 1.1 Observe relevant environmental laws/regulations applicable in all areas of the Group’s operations.
- 1.2 Respect global standards and practices on environmental protection.
- 1.3 Note environmental protection as a main consideration in developing the Group’s policies, standards and procedures.
2. 2. Respect for Basic Rights
The Group shall respect basic rights of a human being in all areas of its operations and abide by international standards on basic rights.
3. Contribution to Local Communities
As a member of its community, the Group should actively participate in desirable activities for community services to make a contribution to enhancing value of the community and its constituents.