LIG Nex1 Co., Ltd

Based on public information, there is no readily available evidence that the CEO or Chair of the Board have published a statement that promotes the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the CEO or Chair of the Board demonstrates a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. TI notes that the CEO emphasised ethical management in his New Year’s Address/Management Principles, but no further details are provided.

Based on public information, the Vision Statement on the company website refers to trust and integrity, and the Ethical Management section of the website refers to fairness, honesty and reliability. The Code of Ethics slightly expands on these statements; however, this explanation is assessed to be rather limited. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company belongs to any national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption. TI notes that the Company is a member of KDIA, but its anti-corruption focus remains unclear.

Based on public information, there is no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence of a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and no evidence of improvement plans being implemented when issues are identified.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

Based on public information, there is no readily available evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance. The company website states that ethical management agreements are signed with partners and suppliers. However, TI notes that no further details are provided.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

Based on public information, the Code of Ethics prohibits the ‘use of prominence to execute an unjust transaction’, ‘acquiring economic benefits from customers’, or ‘requesting special favours or exerting pressure in business transactions’. Employees are also prohibited from accepting ‘any form of benefits from interested parties that may obstruct fair judgement’. However, TI has found no clear statement prohibiting corruption or information on the different forms that corruption might take. The company therefore scores 1.

Based on public information, the Code of Ethics uses strict language. However, there is no explicit statement against corruption or bribery specifically, and no information relating to violations of the Code.

Based on public information, the Code of Ethics is available on the company website. However, evidence suggests the Code is only available in English, while evidence suggests it operates in multiple countries worldwide. The company therefore scores 1.

Based on public information, the Code of Ethics is written in clear, understandable terms for all audiences.

Based on public information, there is some evidence that the Code applies to all employees, but is not clear whether it covers the members of the Board as well. The company therefore scores 1.

Based on public information, there is evidence that the Code of Ethics states that employees must avoid behaviour or relationships that conflict with company interests. Employees must not use company property to pursue personal interest without prior permission. However, the Code does not clearly define conflict of interest or illustrate where such a policy might apply. The company therefore scores 1.

Based on public information, there is evidence that the Code of Ethics prohibits the offering of gifts among employees but allows exceptions for ‘small gifts’, which are accepted in the scope of social convention. Limits for what can be accepted as a ‘small gift’ are not specified and the Code does not outline restrictions for the offering of gifts to non-employees. TI has found no readily available evidence that the receipt of gifts is prohibited.

Based on public information, there is no readily available evidence that the giving and receipt of hospitality is controlled so as to ensure that such transactions are not corrupt.

Based on public information, there is no readily available evidence of a policy that prohibits facilitation payments.

Based on public information, there is evidence that the company recognises the corruption risk posed by political contributions. The company prohibits involvement in politics, the use of company resources for political purposes, and the expression of political views on behalf of the company.

Based on public information, there is no readily available evidence of a clear policy on engagement in lobbying activities. The Code of Ethics indicates that the company may express its views relating to policy planning or law enactment.

Based on public information, there is evidence that the company engages in a number of charitable activities. TI has found no readily available evidence that the company regulates these programs, or other charitable contributions, so as to prevent undue influence or other corrupt intent. Details of contributions do not appear to be publicly declared.

Based on public information, there is no readily available evidence that the ethics and anti-corruption agenda is fully explained to employees through the use of written guidance. The Code of Ethics refers to an Action Guide for Code of Ethics. However, this document does not appear to be publicly available.

Based on public information, the company website states that ethical management training is provided for new employees, executives and staff members, and relevant employees and representatives of partners and suppliers. TI has found no readily available evidence that there is a specific anti-corruption training module. The company therefore scores 1.

Based on public information, ethical management training is provided for all executives and staff members. However, TI has found no further evidence that training is provided across all geographies. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board. The website states that ethical management training is provided for executives/staff members but it does not explicitly state whether training for executives is different to that provided for staff members.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence of a clear and formal process by which employees declare conflicts of interest. Employees are only instructed to avoid behaviour or relationships that are in conflict with company interests.

Based on public information, there is no readily available evidence of an explicit commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that employees are able to report concerns or instances of suspected corrupt using one internal whistleblowing channel, via e-mail, telephone, fax, or post. Evidence does not suggest that employees are able to report anonymously or using an independent channel. The company therefore scores 1.

Based on public information, there is evidence that across geographies, all employees have access to internal whistleblowing channel available via internet, telephone or post. The company therefore scores 1.

Based on public information, the company website states that individuals who provide information will be protected from disadvantages under the company’s informant protection principles. However, TI has found no evidence of formal mechanisms, such as detailed analysis of whistleblowing data or independent employee surveys that ensure whistleblowers are supported and not deterred.

Based on public information, there is no readily available evidence that employees have access to resources where help and advice can be sought on corruption-related issues. Available resources appear to be for reporting concerns only.

Based on public information, there is evidence that the company website states that informants will be protected from any disadvantages. However, TI has not found further evidence that the company will apply disciplinary measures if someone is found to breach this protection. The company therefore scores 1.