SK hynix has proactively established and is operating its Global Compliance Program (“GCP”) in line with the global antitrust laws that are increasingly more strictly enforced around the world.
GCP is designed to reflect antitrust laws of each country where SK hynix operates its business, international treaties, customers’ requirements, and the nature of the semiconductor industry. We are committed to carrying out sustainable business through the GCP.
- Understand the relevant regulations of each country, international treaties, and customers’ requirements
- Announce the Company’s commitment and compliance with the laws, in consideration of the nature of the semiconductor industry
- Global Compliance Team
- Educate the interested parties on compliance
- Manage the head office and overseas subsidiaries
- Establish appropriate policies for the Company’s business
- Audit and take proactive actions in advance
- Have the attitude to comply with laws and restrictions
- Recognize and apply the Company’s policy in performing tasks
- Attend compliance training
SK hynix’s Compliance Inspection System consists of steps such as the establishment of internal antitrust policies, periodic training and counseling, prior and follow-up inspections, monitoring, internal audit, and recurrence prevention. Our executives and employees are required to access the GCP system before engaging in activities that may raise antitrust concerns to familiarize themselves with the checklist, prevent antitrust violations, and monitor the fulfillment of the checklist through a follow-up inspection, allowing early discovery of any violations.
- Audit, recurrence prevention
- Investigation of violations and disciplinary actions against those responsible for violation
- Whistle-blowing system guaranteeing anonymity
- Whistle-blowing and monitoring
- Operation of whistle-blowing channel
- Detection of risks through electronic monitoring system
- Arrangement of internal policies
- Preparation and distribution of guidelines for members’ reference in performing their duties
- Periodic training
- Online and offline training
- Legal consulting service
- Establishment and operation of a dedicated team
- Establishment and operation of the Global Compliance Team
SK hynix has been expanding and strengthening the scope, contents, and subjects of the GCP activities each year. SK hynix actively engages in the following diverse GCP activities:
- CEO’s Commitment and Support for Compliance
- Our CEO officially declared his commitment and policy for compliance with the antitrust laws and instructed that the Key Performance Index fully reflect SK hynix’s commitment to implement the GCP. The CEO has been regularly reviewing the status and performance of the GCP operation and directly involved in activities to promote the GCP culture within the organization.
- Establishment of GCP Operation Standard and Procedure and Continuous Supplementation
- We prepared our policy setting forth the standard and procedure of the GCP operation and continue to modify and supplement the policy reflecting our work environment and development of antitrust laws. We distribute any amendment of laws and provide relevant training to our employees to keep them updated. Details of the GCP operation, including but not limited to its contents, methods, and subjects, are disclosed or announced on our website or internally through emails.
- Appointment of the Compliance Officer and Establishment and Operation of a Team Dedicated to Compliance
- The Compliance Officer is given the responsibilities and power to plan and supervise the GCP and report on the performance of the GCP, carries out his/her duties independently as provided by the policy, and is barred from working for departments whose interests conflict with his/her roles and duties. SK hynix also operates the Global Compliance Team dedicated to compliance with antitrust laws.
- Preparation and Utilization of Compliance Guideline (Compliance Handbook)
- We prepared guidelines for each business division and types of duty, based on periodic/non-scheduled inspections and reflective of the detailed guidelines of each competition authority, to provide measures of self-compliance for employees in different business areas and enable them to carry out their duties in accordance with specific standards. The guidelines are at all times accessible as online electronic files, offline documents, and any other forms that allow easy access and understanding of various users. The guidelines are continuously modified to reflect the recent changes to the antitrust laws and the relevant policies with which we are required to comply and changes in the market and technical circumstances.
- Continuous and Systematic Antitrust Law Training
- We have been continuously and systematically educating our officers and employees on antitrust laws. In planning such training, we prepare differentiated programs appropriate for the operations of each department and SK hynix.
- Periodic Self-Inspection and Risk Assessment
- Each year, the members of our Global Compliance Team conduct periodic/non-scheduled inspections of the head office and the overseas subsidiaries through online or in-person visits to identify business activities and improper practices that are violations of antitrust laws , and conduct personal in-depth interviews with selected key members and forensic inspection of their work materials. We have prepared a separate standard for assessing GCP-related risks (to identify areas vulnerable to the risks of violations, inspect the possibility of violations, and take actions to prevent violations). The risk assessment is divided into at least two levels, and if the inspection finds a risk that is assessed as at least a medium-level risk, we take actions to mitigate such risk. We review whether actions taken to mitigate the risk were appropriate and effective and reflect the result of the review in improving the risk assessment standard.
- Participation of External Experts
- In addition to the self-inspection, we receive objective evaluation and feedback on our inspection activities and the GCP through external counsels’ and consultants’ independent inspections.
- Operation of Reporting System for Contact with Competitors
- We built a separate system for our employees to file advance or follow-up reports of their contact with competitors so that we proactively prevent our employees from meeting, conversing, or exchanging information with competitors that may result in antitrust violations.
- Prior Consultation System
- We established the prior consultation system through which we consult with the Compliance Officer or the relevant department in advance, in reviewing potential violations of antitrust laws we are required to comply with. We have in place the standards such as roles and methods of operation for the council for prior consultation and keep records relating to the operation of the council (minutes, resolutions, and checklist, etc.). Using the prior consultation system, we have prevented employees from engaging in antitrust violations.
- Establishment of Internal Monitoring System
- We operate a whistle-blowing system through which our employees may report antitrust violations they become aware of. The whistle-blowing system is at all times accessible internally or from the outside by the employees. There are no limitations to requirements for filing such a report, and with transparency, the whistle-blowers are protected (through measures such as anonymity and prohibition on retaliation) and guaranteed that disadvantages would not be imposed.