Sustainability Management

Sustainable Supply Chain Management

SeAH Besteel has established the following standards for its suppliers to establish a safe working environment, ensure workers' respect and dignity, and operate an eco-friendly and ethical business.

Third Party Code of Conduct

SeAH Besteel has established Code of Conduct, highlighting SeAH Group’s strong commitment to working together for sustainable growth.

SeAH Besteel, along with various third-party partners dealing with SeAH Besteel, intends to become a "business that makes the world more beautiful" by abiding by this Code. This code is based on the Responsible Business Alliance (RBA) Code of Conduct, a global standard for ethical business practices. In the event of any conflict between local regulations and the content of this code, we adhere to the stricter standards.

01 Labor Human Rights

Suppliers must protect and respect the human rights of all members. This applies to all types of employees, including temporary employees, migrant employees, interns and dispatched employees, etc. Further, all employees must be guaranteed lawful employment and rights as prescribed by local laws.

① Voluntary Employment

② No Child Labor

③ Compliance with Working Hours

④ Wages and Benefits

⑤ Humane Treatment

⑥ Non-Discrimination

⑦ Freedom of Association

02 Safety and Health

Suppliers shall recognize that the safety and health of employees are essential to all activities performed in connection with the company's business. In addition, suppliers shall exert efforts to provide employees with a safe and clean working environment in accordance with local laws and regulations.

① Industrial Safety

② Emergency Precautions

③ Industrial Accidents and Diseases

④ Industrial Hygiene

⑤ Physical Burden

⑥ Safety Management of Dangerous Machinery, Instruments and Equipment

⑦ Hygiene, Food and Housing

⑧ Safety and Health Education

03 Environment

Suppliers shall manage greenhouse gases, air pollutants, wastes, recycling, industrial water reuse and chemicals, etc. in compliance with laws and regulations on environmental protection. Also, suppliers shall identify the environmental impact of its manufacturing process, and protect public safety and health by minimizing negative impact on the community, environment, natural resources, etc.

① Obtaining Environmental Permits

② Prevention of Contamination and Reduction of Resource Use

③ Hazardous Substances

④ Waste Management

⑤ Control of Air Pollutants

⑥ Substance Regulatory Compliance

⑦ Water Resource Management

⑧ Energy Consumption and Greenhouse Gas Emissions

⑨ Animal Welfare

04 Ethics and Fair Trade

Suppliers shall comply with all local laws and regulations for social responsibility and sustainable co-existence, and strive to improve its ethics standards.

① Integrity

② Prohibition of Undue Profits

③ Disclosure of Information

④ IP Protection

⑤ Privacy

⑥ Fair Trade, Advertising and Competition

⑦ Identity Protection and Non-Retaliation

⑧ Responsible Material Management

⑨ Export Restrictions and Economic Sanctions Compliance

⑩ Anti-Money Laundering and Tax Evasion

⑪ Conflicts of Interest

05 Management System

Suppliers shall establish and continuously improve a management system to comply with the laws and regulations applicable to this Code, comply with customer demands, comply with this Code, and identify risks and opportunities associated with this Code.

① Compliance Pledge

② Management's Duties and Responsibilities

③ Legal and Customer Requirements

④ Risk Management

⑤ Improvement Objectives

⑥ Training

⑦ Communications

⑧ Member Feedback, Participation and Grievance Handling

⑨ Audit and Evaluation

⑩ Corrective Process

⑪ Documents and Records

Code of Conduct (SeAH)
Code of Conduct (Third-Party)

Purchasing Strategy

Based on the philosophy of shared growth, SeAH Besteel focuses on supply chain management for win-win situations and pursues fair trade and pro-social purchasing policies. In particular, in a rapidly changing environment, it has promoted a purchasing strategy that strengthens the supply chain's intrinsic purchasing competitiveness while also securing supply stability through supply chain internalisation and diversification. Furthermore, it has established standards for sustainable purchasing strategies and, as a result, a system that responds flexibly to the external environment, enhancing its purchasing response capabilities.

01

Supply Chain Management for Shared Growth

A sustainable purchasing strategy that coexists with the supply chain is critical. In addition to providing win-win support measures, selecting and rewarding excellent suppliers, and conducting regular face-to-face meetings, SeAH Besteel's supply chain management goes beyond support measures such as training and joint response to various risks to further grow as a business partner and includes a consulting concept.

02

Pro-social Purchasing Policy

SeAH Besteel pursues a pro-social purchasing policy. It manages the country of origin intensively for minerals with conflict risks in order to prevent risks from arising in advance. Furthermore, SeAH Besteel promotes pro-social purchasing policies, such as preferential trade benefits for ESG companies and various certified companies, such as ISO.

03

Ethical Management and Fair Trade

SeAH Besteel fulfils its responsibilities and efforts in fair trade on the basis of ethical management, so that all procedures, from bidding to delivery and settlement, can be managed transparently. All of its core partners have signed an ethics pledge to end unethical trading practices.

04

Increasing Intrinsic Purchasing Competitiveness

SeAH Besteel is increasing its purchasing competitiveness by improving strategic purchasing through price forecasting using data, discovering new sources of supply, and co-developing new items.

05

Securing Supply Chain Stability

SeAH Besteel promotes supply chain internalisation and diversification to ensure supply chain stability in a rapidly changing external environment. It is proactively managing risks in the supply chain for all items, not just raw materials, to support a smooth production process.

06

Organisation operated in an agile manner with flexible responses

SeAH Besteel is pursuing a purchasing strategy based on the existing purchasing organisation that allows it to respond intensively to changes in the external environment and major issues by operating a flexible organisation such as a project TFT or matrix organisation.

Responsible Minerals

SeAH Besteel adheres to the principle of not using industrial minerals derived from conflict areas in its products.
SeAH Besteel produces no conflict minerals (tin, tantalum, tungsten, or gold) in its special steel and large forgings.

Subject

Responsible minerals are minerals mined on the basis of social responsibility in order to prevent them from being used to fund wars and to protect human rights and the environment, a concept that extends beyond conflict minerals.

[Responsible minerals]

Conflict minerals (3TG): tin, tantalum, tungsten, and gold

Conflict areas (10 countries): DRC, Republic of the Congo, South Sudan, Rwanda, Brundi, Uganda, Zambia, Angola, Tanzania, and Central Africa

In addition to ① and ②, the concept includes minerals from areas where human rights violations occur

[Related regulations]

USA: Dodd-Frank Wall Street Reform and Consumer Protection Act (July 2010)

Europe: EU Conflict Minerals Regulation (May 2017)

[Countries covered by conflict minerals]

Policy

SeAH Besteel has included a clause prohibiting the use of illegally mined raw materials in its Purchasing Policy, Supplier Code of Conduct, and Purchasing Standard Contract, which were established in 2016.

It takes part in CFSI (conflict-free sourcing initiative) activities such as due diligence, reporting, and smelter consultation.

Ensuring that no responsible minerals are added to the products it produce, including obtaining conflict mineral-free certificates.

Process

SeAH Besteel recognises human rights violations and environmental destruction caused by the mining of minerals from conflict areas as serious problems. Therefore, SeAH Besteel is continuously improving its responsible mineral management process to comply with laws and regulations related to responsible minerals and fulfil its social responsibility.

Planned supply chain management activities upon receipt of responsible minerals such as tin and tungsten

- Apply the OECD "Supply Chain Due Diligence Framework"

- Conduct due diligence surveys on purchases

- Check smelter status through the EICC conflict minerals reporting template

Continuous monitoring and review of responses when new minerals become controversial

Process

SeAH Besteel recognises human rights violations and environmental destruction caused by the mining of minerals from conflict areas as serious problems. Therefore, SeAH Besteel is continuously improving its responsible mineral management process to comply with laws and regulations related to responsible minerals and fulfil its social responsibility.

Planned supply chain management activities upon receipt of responsible minerals such as tin and tungsten

- Apply the OECD "Supply Chain Due Diligence Framework"

- Conduct due diligence surveys on purchases

- Check smelter status through the EICC conflict minerals reporting template

Continuous monitoring and review of responses when new minerals become controversial

Direction for the future

Currently, SeAH Besteel does not use responsible minerals; however, it will continue to monitor the mineral purchases of its suppliers and expand to secondary suppliers in the future to ensure that the policy of not using responsible minerals is established. SeAH Besteel also plans to establish a communication channel between stakeholders in case controversies arise over minerals handled by it in the future.

Shared Growth

SeAH Besteel strengthens the competitiveness and partnership of its suppliers
by promoting policies and supporting programmes for shared growth in the future.

Organisational Structure

To promote shared growth and strengthen competitiveness with its suppliers, SeAH Besteel has gradually expanded its shared growth programmes. It will continue to strive to grow alongside its suppliers by faithfully implementing fair trade agreements for mutual growth and developing and implementing numerous programmes to assist them.

Subcontracting Practices

Title Attachment
Implement fair trade from the contract signing stage to the execution stage by introducing and operating desirable contract signing practices between large, medium, and small companies. PDF
Adopt and comply with practices for fair selection (registration) of suppliers to ensure fair and objective selection and operation (registration and change) of suppliers. PDF
Adopt and implement practices for establishing and operating an internal review committee for subcontracting transactions to establish a prevention-in-advance and audit system for unfair trade practices. PDF
Adopt and implement practices for desirable document issuance and preservation in order to establish document issuance and preservation practices in subcontracting transactions. PDF

Reports and Suggestions

We appreciate your feedback. We welcome suggestions for improvement during transactions as well as reports of unfair trade practices, unfair subcontracting practices, and so on, so that improvement activities can be carried out. Suggestions and reports will not be shared with third parties, and the confidentiality of those contacted will be strictly maintained

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"Seah Besteel's" (hereinafter referred to as the "Company") respects the privacy of its clients and abides by the "Act on Promotion of Information and Communications Network Utilization and Information Protection." The Company notifies the client of the purpose and means for which the personal information provided by the client in accordance with the personal information administration policy is used, as well as the security measures implemented to protect personal information. If the Company modifies its policy on the administration of personal information, it will post notices on its website and/or send out individual notifications. Personal information to be collected: name, e-mail address, phone number The purpose of collecting and using personal information: the client’s requests Period of retention and use of personal information: The Company will destroy the personal information of the client without delay when the purpose of its collection and use has been achieved.