Code Of Conduct - Samsung Compliance

Transcription

Code of ConductDriving Us Forward to Success

2 Samsung Code of Conduct / Driving Us Forward to SuccessContents12Message from Leadership3Samsung Values4Introduction:Our Code Is Our Framework5Our Code Is Our FrameworkWe Look to Our Leaders and Other Managers to Set the ExampleMaking Ethical ChoicesWe Drive Forward and Succeed TogetherWe Understand How Concerns Are HandledWe Do Our Part to Prevent Retaliation667899Our People Drive Us Forward10We Work in a Safe and Healthy EnvironmentWe Support Diversity and InclusionWe Treat Others with Dignity and Respect111112Our Brand and ReputationDrive Us Forward13We Protect Company Information and AssetsWe Avoid Conflicts of InterestWe Help Prevent Fraud14151634We Do Not Tolerate Bribery and CorruptionWe Exchange Gifts and Hospitality AppropriatelyWe Compete Vigorously but FairlyWe Are Responsible with Our Sales and Marketing Practices17171818Our Business PartnersDrive Us Forward19We Sell and Deliver Safe and High-Quality ProductsWe Respect the Privacy of Personal InformationWe Look for Ways to Advance Accessibility202121Our Global CommunitiesDrive Us Forward22We Act As Good Corporate CitizensWe Follow Global Trade RegulationsWe Help Make the Environment Better232324Conclusion:We Drive Forward and Succeed Together 25Our Code helps us achieve our success and drives usforward the right way with integrity26

Samsung Code of Conduct / Driving Us Forward to Success 3A Message fromLeadershipColleagues,At Samsung, our success has always been centered around our ability to evolve andinnovate in order to deliver best-in-class products and services that make a meaningfulimpact on society. However, success means more than just meeting our business goals – itis also about our commitment to acting ethically and with integrity in everything we do.Samsung is a company that is built on a foundation of strong core values – People,Integrity, Change, Excellence and Co-Prosperity. Our Code of Conduct is an extensionof these values and serves as a framework for how we make decisions, take actions andultimately, drive our business forward. It provides guidance on how to act with integrityand make ethical choices.Our people are talented, dedicated and passionate individuals who take pride in ourcollective success. Each and every one of us is responsible for understanding andfollowing our core values and our Code of Conduct – and Samsung’s reputation dependson how we live these values. By working together, we can continue to preserve ourstrong reputation and build a better Samsung.Sincerely,KS ChoiPresident & CEO,Samsung Electronics North America

4 Samsung Code of Conduct / Driving Us Forward to SuccessSamsung Quite simply, a companyis its people. At Samsung,we’re dedicated to givingour people a wealth ofopportunities to reach theirfull potential.Everything we do at Samsungis driven by an unyieldingpassion for excellence and anunfaltering commitment todevelop the best products andservices on the market.As we have done since ourfoundation, we set our sightson the future, anticipatingmarket needs and demandsso we can steer our companytoward long-term success.Operating in an ethical wayis the foundation of ourbusiness. Everything we dois guided by a moral compassthat ensures fairness, respectfor all stakeholders andcomplete transparency.Samsung is committed tobecoming a socially andenvironmentally responsiblecorporate citizen in all of itscommunities worldwide.

Samsung Code of Conduct / Driving Us Forward to Success 5IntroductionOur Code Is Our Framework

6 Samsung Code of Conduct / Driving Us Forward to SuccessOur Code Is Our FrameworkSamsung’s success of yesterday, today and tomorrow is built on our ability to innovate, changeand deliver safe and high-quality products and services to the market. Our people drivethis success by acting with the highest levels of integrity. This Code of Conduct provides theframework for how to act with integrity and make ethical decisions. While conducting businessfor Samsung, we are all committed to: Acting ethically and honestly.Accepting responsibility for our actions and decisions.Following our Code, policies and the law.Speaking Up when we have questions or concerns.Everyone at Samsung Electronics Americaand its subsidiaries and affiliated companiesin North America, including our board ofdirectors, executive officers and employees,are responsible for understanding andfollowing this Code. We also hold our businesspartners to the same high ethical standards.We Look to Our Leaders and Other Managersto Set the ExampleWe all play an important role in creating our culture, but leaders and managers have additionalresponsibilities, including: Leading by example and setting a positive tone for employees to emulate.Creating an environment that emphasizes our values in our words and actions.Promoting a workplace where compliance is expected.Identifying any compliance risks within our roles and responsibilities.Raising issues identified to a Speak Up Resource when needed.As a global company selling a wide variety of products and services, Samsung’s policy is tocomply with laws that may vary across our businesses and in different countries and cultures.We must all abide by the laws, regulations and policies that apply to our business and role atSamsung. If you have questions about what law applies, it is important that you reach out to oneof the Samsung Speak Up Resources described in this Code.Remember that ethicalleadership starts with you –leading by example is the bestway to inspire others.

Samsung Code of Conduct / Driving Us Forward to Success 7Making Ethical ChoicesEveryone at Samsung should always use good judgment in making decisions to drive Samsung’s success forward, but if you are ever unsure, you should ask yourself:12345Does my decisionreflect our company’svalues? Does it feelright?What impact wouldthis decision haveon Samsung or itsreputation?How would othersfeel about thisdecision?Will my choiceviolate the Code, lawor our policies?Is there someone Ican ask for advice?If the answers to the above questions present any doubt, consult with a Speak Up Resource.

8 Samsung Code of Conduct / Driving Us Forward to SuccessWe Drive Forward and Succeed TogetherEveryone at Samsung plays an important part in our growth and success. Following this Codeand asking questions when you aren’t sure about something are fundamental to Samsung’sability to drive forward.You are encouraged to seek guidance and to report concerns when you see or hear of activitiesyou think may not be right. The most important thing is that you Speak Up, not how you speakup. To report a concern or ask questions, contact one of the below:Samsung Speak Up ResourcesThe Samsung Webline: https://samsung.webline.saiglobal.comThe North America (NA) Compliance Team (by phone or email) U.S. and Canada: 1-855-50-COMPLiance (1-855-502-6675) International: 1-201-334-FONE ( 1-201-334-3663) Email: NACompliance@sea.samsung.comOur Code is supported by policies that may be found on our local company intranet sites.Each Samsung subsidiary or affiliate has specific people who may be contacted as anadditional resource.The Samsung Webline is anonline resource for reportingconcerns anonymously.

Samsung Code of Conduct / Driving Us Forward to Success 9We Understand How Concerns Are HandledWhen you raise concerns, you can count on Samsung to take them seriously and to investigatethem. At times, you may be asked to participate in an investigation, and if this happens, you areexpected to cooperate fully and communicate honestly.Violations of laws and regulations can have severe consequences for both the Company and theindividuals involved. The Company will take appropriate action, up to and including terminationof employment, if a violation of our Code, policy or law has occurred.We Do Our Part to Prevent RetaliationSamsung is committed to creating a “speak up” culture where anyone can ask questions, seekguidance or report concerns of potential wrongdoing without fear of retaliation. No one will beretaliated against for making a good-faith report, for asking questions or for cooperating in aninvestigation — even if the concern turns out to be unfounded. Anyone who retaliates againstanother individual may be subject to discipline, up to and including termination of employment.

10 Samsung Code of Conduct / Driving Us Forward to Success1Our PeopleDrive UsForward

Samsung Code of Conduct / Driving Us Forward to Success 11We Work in a Safe and Healthy EnvironmentWe succeed with integrity byAt Samsung, we are dedicated to providing a work environment that is healthy, safe and securefor all. We comply with all health and safety laws and regulations that apply to our work. Thisincludes maintaining a workplace that is free from violence, threats of violence and anyoneworking under the influence of drugs or alcohol. Performing our work safely and not under theinfluence. Conducting work safely and responsibly. safety risks and concerns.We Support Diversity and Inclusion Not engaging in threats or violent or intimidatingbehavior.At Samsung, our people are one of our greatest assets and as a result, we are committed tocreating an inclusive work environment of diverse backgrounds, ethnicities, cultures, beliefs andexperiences. We each play an important role in our workplace, which respects the diversity ofpeople, ideas and viewpoints.We succeed with integrity by Respecting each other regardless of individualcharacteristics or backgrounds.We each play an important role in ourworkplace, which respects the diversityof people, ideas and viewpoints. Promoting a diverse and inclusive workplaceand not engaging in favoritism. Listening to other opinions and ideas andcommunicating responsibly. Following our policies and our Employee Handbook.

12 Samsung Code Of Conduct / Driving Us Forward to SuccessWe Treat Others with Dignity and RespectWe strive to create a team where each of us feels welcomed and valued, and we share theresponsibility of treating each other with respect. We foster a dynamic team environment that isfree from any form of harassment, discrimination, favoritism or disrespectful treatment.We succeed with integrity by Making all employment-related decisions basedon an individual’s strengths and experiences. Not participating in, and always acting toprevent or stop, any harassing or discriminatorybehavior.Harassment and discrimination are defined as any action takenagainst another based on certain characteristics, including but notlimited to: Race Religion Transgender status Color Pregnancy Military status Sex Medical condition Veteran status Gender Genetic information Ethnicity Disability Marital or civilunion status National origin Sexual orientation Ancestry Gender identity orexpression Age Any other traitor characteristicprotected by law.Harassment includes any unwelcome conduct that has thepurpose or effect of creating an intimidating, offensive or hostilework environment, and can take many forms, including physicalactions, spoken and written remarks, and videos or pictures.Harassment negatively affects individual work performance andour workplace as a whole, and will not be tolerated.

2Our Brandand ReputationDrive Us Forward

14 Samsung Code of Conduct / Driving Us Forward to SuccessWe Protect Company Information and AssetsOur work for Samsung provides us with access to information and other assets that we havea responsibility to use sensibly and to safeguard from loss, theft and misuse. We should allprotect confidential and proprietary information and assets and treat these assets and propertycarefully and responsibly.We succeed with integrity by Respecting the confidentiality of all sensitiveand proprietary information regardless of who itbelongs to. Only sharing information on a need-to-know basis.Samsung assets include physical, financial, intellectual and humanassets, physical premises, communication systems, equipment,corporate charge cards, supplies and other information or itemspurchased, owned or maintained by the Company.We have a responsibility to use information and otherassets sensibly and to safeguard them from loss, theftand misuse. Using our technology assets primarily forbusiness purposes. Exercising good judgment when using Samsungassets. Safeguarding the integrity and security of ourbusiness systems from unauthorized access.

Samsung Code of Conduct / Driving Us Forward to Success 15We Avoid Conflicts of InterestAs Samsung employees, we should all make sound business decisions that are in theCompany’s best interest. This includes avoiding any situations that might create or evenappear to create a conflict of interest.A conflict of interest can occur when our personal, financial orfamily interests interfere with our ability to do our jobs objectivelyor effectively. Even the appearance of a conflict can damage ourpersonal credibility and the Company’s reputation.At Samsung, “family” includes: spouse or domestic partner parents, children, grandparents and grandchildren brothers and sisters aunts, uncles, nieces and nephews cousins in-laws anyone with whom we share a homeWe succeed with integrity by Not having any financial or ownership interest ina company that competes or does business withSamsung, such as a customer, vendor or businesspartner. Removing ourselves from employment-relateddecisions or supervision that involves a personal,romantic or family relationship. Avoiding second jobs that may conflict with ourroles and responsibilities at Samsung. Disclosing outside board of director positions to aSpeak Up Resource. Following our internal policies on conflicts ofinterest and seeking guidance and approval beforetaking any action that may be a conflict of interest.

16 Samsung Code of Conduct / Driving Us Forward to SuccessWe Help Prevent FraudOur business and financial records help us make important business decisions and arefundamental to Samsung’s continued success. The accuracy and integrity of our businessrecords are also legally required, which is why it is essential that we maintain all recordswith honesty and transparency. We all have a responsibility to follow our internalprocesses and to help prevent fraud.Fraud occurs when information is intentionally concealed, altered, falsified or omitted forindividual benefit or the benefit of others. Fraud may be motivated by the opportunity togain something of value (such as meeting a performance goal or obtaining a payment) orto avoid negative consequences (such as discipline).We succeed with integrity by Submitting only accurate and honest financialrecords, such as correct time sheets, invoices orexpense reports. Using company-issued credit cards for businesspurposes only. Providing timely, realistic forecasts andassessments to management. Watching for signs of fraud and reporting anyconcerns immediately.Examples of fraud include: Falsifying expense reports Altering numbers to meet productivity or bonus goals Presenting false information to regulatory authorities Falsifying time cards Misrepresenting sales or donations of products to obtain unauthorizedpricing for a customer Misstating financial information in our company’s books and records

Samsung Code of Conduct / Driving Us Forward to Success 17We Do Not Tolerate Bribery and CorruptionSamsung’s success and reputation depend on each of us following the law and acting ethicallyat all times. This includes abiding by strict local and international laws prohibiting offering andaccepting bribes.Samsung does not tolerate bribery and expects that anyone acting on our behalf followsthis same standard. No one should ever give or offer anything of value directly or indirectly,through a third party, to anyone, including government officials, in order to obtain business orto influence an act or decision.A bribe is any act of offering oraccepting anything of value,including for personal orfinancial gain, in order to secure acompetitive advantage.Violations of anti-bribery and corruption laws can have severe consequences. If you have anyquestions, seek guidance from our internal policies or a Speak Up Resource.We Exchange Gifts and Hospitality AppropriatelyWhen we exchange gifts and hospitality, we must do so in a manner that demonstratesgood judgment and moderation. Although gifts and hospitality can help foster businessrelationships, if they are extravagant, or if they lack transparency or a legitimate businesspurpose, they may be inappropriate. We must be careful to ensure that any gifts or hospitalitydo not harm our reputation, damage trust, or violate the recipient’s polices.If you are involved in selling to a governmentbody, be sure to find out if more specificpolicies apply to you by contacting a SpeakUp Resource.We succeed with integrity by Exchanging gifts and hospitality only when theyare appropriate, reasonable and infrequent. Never giving or receiving cash or cashequivalents. Avoiding putting ourselves or others insituations where the gift or hospitality couldinfluence or appear to influence a businessdecision. Seeking guidance from NA Compliance whenexchanging gifts or hospitality.

18 Samsung Code of Conduct / Driving Us Forward to SuccessWe Compete Vigorously but FairlySamsung thrives in the market by staying ahead of our competition and finding ways todrive innovation for our customers and consumers. While competing aggressively helps usmeet our business goals, we should do so through fair business practices.We abide by antitrust laws, which promote fair competition and prohibit competitors fromcreating “agreements” that prevent, restrict or distort the exercise of free competition.We Are Responsible with Our Sales and Marketing PracticesWhen marketing or selling our products, we do so with honesty, fairness and integrity, andwe make only truthful and accurate statements.Regardless of the value of a transaction or the length of a business relationship, we shouldnever take unfair advantage of our business partners or competitors through unethicalmeans, including manipulation, abuse of confidential information, misrepresentation ofmaterial facts or any other unfair or deceptive practice. We expect our business partnersto meet these same high standards.If you have questions aboutantitrust laws, consult ourinternal policies or a Speak UpResource.

Samsung Code of Conduct / Driving Us Forward to Success 193Our BusinessPartnersDrive Us Forward

20 Samsung Code of Conduct / Driving Us Forward to SuccessWe Sell and Deliver Safe and High-Quality ProductsOver many years, our business partners, customers and consumers have come to trustthe products and services we create, sell and deliver. Each and every one of us playsan important role in preserving this trust and confidence in the marketplace. We caredeeply about product safety and quality, and we make sure our products meet orexceed our own internal standards, as well as the standards set by laws, regulationsand our industry.We succeed with integrity by Keeping safety, quality and customersatisfaction at the foundation of our business. Understanding the needs, lifestyle andbehaviors of our customers and consumers so wecan innovate and change. Meeting the promises we make to our customersand holding our business partners accountable.Each and every one of us plays an importantrole in preserving our customers’ andconsumers’ trust and confidence. Following all laws and regulations related to thedesign, manufacturing, packaging, storage andshipment of our products. Complying with all applicable laws, regulationsand company procedures in the event of aproduct safety issue, and contacting a Speak UpResource with any concerns.

Samsung Code of Conduct / Driving Us Forward to Success 21We Respect the Privacy of Personal InformationThe collection and storage of information is increasingly important to Samsung’s success,and our customers and consumers count on us to do so in appropriate ways. Collectinginformation must also be done in compliance with strict laws governing data protectionand privacy, as well as our internal policies. We must always protect personal informationrelated to other Samsung employees and our customers, consumers and businesspartners, and exercise caution (such as obtaining consent) prior to disclosing personalinformation to others.We succeed with integrity by Following our policies when collecting,processing, using, transferring or disclosingpersonal information. Only accessing, collecting, using, or sharingpersonal information for authorized businessreasons and with proper consent. Taking privacy concerns into account whendeveloping new products.Personal Information may include, but is not limited to, items such as: Name Biometrics Address Facial recognition attributes Email Medical history Government-issuedidentification numbersWe Look for Ways to Advance AccessibilityOur products and services are in the hands of millions of people. These people depend on ourability to create and deliver technology solutions that are inclusive and accessible for thosewith disabilities. We strive to continuously look for ways to increase the accessibility of ourproducts and services so that all can experience the excitement of our technologies. Immediately reporting a data breach, includinga loss or theft of personal information, to aSpeak Up Resource.We succeed with integrity by Looking for ways to advance accessibility tothose with visual, hearing, mobility, speech andother disabilities. Finding ways to improve our technologies to helppeople with disabilities. Being honest about the accessibility of ourproducts and services. Respecting and following legal requirementsrelated to accessibility.

22 Samsung Code of Conduct / Driving Us Forward to Success4Our GlobalCommunitiesDrive UsForward

Samsung Code of Conduct / Driving Us Forward to Success 23We Act as Good Corporate CitizensWe are committed to being a good corporate citizen and to remaining involved in ourcommunities, creating a meaningful and positive impact on the places where we live and work.One of the ways in which we support our surrounding communities is through volunteer projectsand charitable giving.We are committed to complying with laws and regulations that help protect human rightsand the safety of children. We do not tolerate or permit human trafficking or the use of childlabor or any form of forced, indentured or involuntary labor in any of our operations or at anyof our properties.We Follow Global Trade RegulationsThe products we sell are produced all over the globe, crossing borders on a daily basis. Our abilityto deliver products and services to our customers requires that we follow very complex customsand other international trade laws and regulations. These laws, which are constantly changing,govern areas such as imports, exports, economic sanctions and immigration. We must all take careto understand how they apply to our work and follow them in our business activities.Violations of global trade laws and regulations can result in severecivil and criminal penalties for the Company and our employees, andmay impact our ability to import our products and deliver them toour customers.When questions arise, seek helpfrom our internal policies or aSamsung Speak Up Resource.

24 Samsung Code of Conduct / Driving Us Forward to SuccessWe Help Make the Environment BetterWe are committed to incorporating sustainable thinking into our business and working todeliver products and solutions that reduce the environmental footprint of Samsung and ourconsumers. We follow applicable environmental laws and strive to exceed industry standards ofenvironmental excellence. We work to deliver products and solutions that are eco-friendly, useenergy more efficiently, are made from more preferable materials and can be safely recycled ordisposed of at the end of their lifecycle.We succeed with integrity by Supporting environmental stewardship andcontinually evaluating and minimizing theimpact we have on the planet. Striving to increase the energy efficiency andrecyclability of our products. Reducing the amount of sensitive and hazardoussubstances we use.We follow applicable environmental lawsand strive to exceed industry standards ofenvironmental excellence. Supporting environmental sustainabilitythrough pollution prevention, wastemanagement, recycling, energy conservationand energy-saving innovations.

Samsung Code of Conduct / Driving Us Forward to Success 25ConclusionWe Drive Forward and Succeed Together

26 Samsung Code of Conduct / Driving Us Forward to SuccessOur Code helps us achieve oursuccess and drives us forwardthe right way — with integrity.As the people of Samsung.We Create a Positive WorkEnvironment We respect others and listen to their opinions. We promote diversity and inclusion. We do not tolerate harassment or discrimination. We work in a healthy, safe and drug-free work environment. We communicate responsibly.

Samsung Code of Conduct / Driving Us Forward to Success 27We Protect Our Brand and Reputation We use Samsung assetsresponsibly. We protect confidentialinformation and intellectualproperty. We safeguard our informationtechnology systems. We avoid conflicts of interest. We prevent fraud. We do not tolerate bribery andcorruption. We exchange gifts and hospitalityappropriately. We compete vigorously but fairly. We are responsible with our salesand marketing practices.We Promote OurGlobal Communities We strive to make a positive impact onour communities. We respect international trade laws. We take the initiative to reduce ourenvironmental footprint.We Support OurBusiness Partners We sell and deliver safe and highquality products. We respect the privacy of personalinformation. We help advance accessibility.

Samsung Code of Conduct / Driving Us Forward to Success 28

forward the right way with integrity 26. Samsung Code of Conduct / Driving Us Forward to Success 3 Colleagues, At Samsung, our success has always been centered around our ability to evolve and