Compliance

To foster a transparent, mature trade culture, SK ecoplant has been operating the “Compliance Program (CP)” since 2008, and we receive a pledge every year from all employees including the CEO to practice compliance and commit ourselves to establishing a culture of compliance. SK ecoplant has enacted regulations and rules for operating CP to operate the program systematically, complying with its standards and procedures. In 2022, we made it mandatory for all employees to participate in CP training by revising part of the regulations, and newly added the clause for guaranteeing the independence and anonymity and mandatory obligation of maintaining neutrality and protecting the confidentiality of a whistleblower regarding the works of internal report monitoring team, such as Ethical Management Team and Compliance Division.
For SK ecoplant to operate CP independently, the Chief Compliance Officer appointed by the resolution of the Board of Directors supervises the CP operation. The Chief Compliance Officer directly reports the CP operation plan and performance to the management (BOD or CEO) every quarter, meets the feedback, and continuously improves the level of operation. Moreover, We have incorporated the personnel in charge of CP-related departments such as the Compliance Division, Win-win Design Team, Ethical Management Team, Corporate Legal Team and Business Legal Team into the Compliance Office and established a system wherein in-company CP duties can be operated. The Compliance Office assists the Chief Compliance Officer and performs actual work, such as conducting legal training related to fair trade, publishing periodic newsletters about CP operation (CP Letter), operating an internal reporting channel, evaluating the effectiveness of the CP operation status, etc.

[Chief Compliance Officer]

Duties of Chief Compliance Officer

1. Establishment of plan for the Compliance Program and management of its operation
2. Identification of risks for violating the Competition Act and execution of risk assessment for management
3. Pre-business consultation for complying with the Competition Act
4. Management of training related to the Competition Act
5. Monitoring on the actual conditions of voluntary compliance
6. Analysis and improvement of violation of the Competition Act, consideration of corrective & preventive measures
7. Determination of level of sanctions on the Competition Act violator and request for review by the Reward and Punishment Review Committee
8. Reporting the CP activities and agendas to the BOD
9. Collection of CP pledge from all employees
10. Other matters deemed necessary by the BOD
(CP Operational Regulations Article 7)

Authority of Chief Compliance Officer

1. Rights to inspect and investigate the actual condition of CP
2. Rights to request the submission of materials and information needed for performing duties
3. Rights to investigate and report Competition Act violators and their acts of violation
4. Rights to correct and improve the violation of the Competition Act
5. Other rights deemed necessary by the BOD
(CP Operating Regulation Article 8)

Appointment of SK ecoplant’s Chief Compliance Officer

2023.02: Sung-jong Bang (Head of ESG Center)
2022.03: Jang-suk Yoon (Head of ESG Center)
2021.03: Joo-ho Park (Head of CPR Group)
2018.02: In-gi Lee (Head of Compliance Center)
2015.02: Jeong-il Yang (Head of Ethical Management Division)
2013.01: Chul Park (Head of Ethical Management Division)
2008.01: Jeong-il Yang (Director of Legal Affairs Office)

Organizational Chart of Compliance

자율준수사무국 조직도에 관한 이미지 입니다. 자세한 설명은 하단 내용을 참고하세요.

Global Compliance

SK ecoplant established a CP operating system conforming to global standards due to an increase in overseas M&As. The company has specified the behavioral standards and procedures that employees must follow through the “Global Anti-corruption and Compliance Policy” and provided the compliance standard needed for engaging in business with Biz. Partners by preparing the “Rules for Joint Ventures” and “Rules for Biz. Partners.” Furthermore, SK ecoplant’s compliance system was integrated to M&A target companies, and potential risks were minimized through the procedure for collecting the Declaration of Anti-corruption Compliance as proof of having undergone actual inspection and for compliance with the regulations before transacting with overseas Biz. Partners. SK ecoplant has the global compliance task force under the ESG Center to supervise the actual inspections of overseas Biz. Partners and monitor compliance issues constantly. In addition, we conduct training on international laws and regulations for internal employees to pay attention to when engaging in overseas business activities. SK ecoplant employees can discuss with the global compliance task force about behaviors that may violate global anti-corruption laws and regulations. When a violation of overseas anti-corruption laws is detected, it can be reported to the task force anonymously.

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Overseas Anti-corruption regulations (KR) Overseas Anti-corruption regulations (EN)

CP Guidebook

SK ecoplant established the “CP Guidebook” as a working guideline for practicing compliance management for the first time in 2008. We have selectively included regulations with high relevance to our company by considering the company’s business structure and characteristics, contract relations, and stakeholders, periodically revising the CP Guidebook by reviewing the changes in policy environment, legal amendments, latest violations, etc. While the fifth revision of CP Guidebook in 2022 reflected the amendment of the Subcontracting Act, cases of violations of fair trade-related laws was also seperately updated in order to enhance employees' understanding and prevent violations of the law. In addition, we prepared the “CP Handbook” including a work checklist related to subcontracting in 2022 and ensured that people in charge of the relevant work can refer to unfair special contracts frequently occurring in the same industry and matters related to the Subcontracting Act.

자율준수 편람 테이블 (초파, 1차 개정, 2차 개정, 3차 개정, 4차 개정)
2008	2011	2015	2017	2021	2022
First edition	First revision	Second revision	Third revision	Fourth revision	Fifth revision¹⁾

1) Reflected amendments to the Subcontracting Act and updated cases of violations related to fair trade.

Preliminary Inspection System

SK ecoplant’s departments related to compliance and fair trade regularly inspect the potential legal violations related to fair trade by reviewing the in-company work procedures

1) Prevention of bid rigging

SK ecoplant is implementing a preliminary reporting policy for industry meetings to prevent bid rigging by industry meeting attendees. When reported, pledges including the code of conduct on participating in industry meetings are collected. Industry meeting participants can attend the meeting after declaring the purpose of attendance and number of attendees on the report form and then obtaining prior approval from the Compliance Team Leader. Any abnormal behavior must be immediately reported to the Chief Compliance Officer.

Prepare participation report
(By representative of participant)
- Prepare at least one day
  before a meeting
Final approval after reviewing appropriateness of the meeting
- Notify behavioral instructions
  when attending meeting
- Spread types of improper
  concerted acts
Immediately report in case of abnormal behavior
Submit result report after attending meeting
- Within 2 weeks from
  attending a meeting
- Required for all attendants

Principles for participating in industry meetings

If an industry meeting violates or is likely to violate fair trade laws, it should be immediately reported to the chief compliance officer through the compliance champion.
Participants do not discuss collusion-related issues that are prohibited by the Fair Trade Act such as prices (bid price, determination of successful bidders, and bridesmaids) and transaction conditions at industry meetings.
As collusion is punishable only by the fact that there was an agreement even without implementing it, participants should clearly express their intention of not participating in the case when agreements or resolutions are expected to violate the Fair Trade Act.
Even if attendees express no active consent and stay silence, their action is considered as participation. Therefore, it is necessary to clearly indicate their objection (in case of writing the minutes, they need to require to stipulate their objection), and immediately notify the intention of refusal by leaving the place.
Regarding agendas that have not actually been discussed at the industry meeting or that some participants have simply expressed their opinions, writing it in related documents as if the consensus was made in the form of meeting minutes, information reports, and activity reports, this may be mistaken for collusion or used as evidence of collusion. Therefore, it is necessary to record based on the fact and avoid making false reports. (Thoroughly check the meeting documents)

2) Prior review for compliance with Subcontracting Act

In terms of subcontract agreements, we use a standard subcontracting contract form, and then the Policy CR Team and Contract Management Team check for any violations of the Subcontracting Act in on-site manuals concerning special agreement conditions.

Prepare draft of site report
Review site report
(Compliance Division, legal team)
Approval request of
final reviewed copy
Conduct on-site briefing session

3) Prevention of theft and misuse of Biz. Partner technical data

Our Policy CR Team and Business Legal Team pre-screen advertising materials before they are distributed to prevent legal violations related to unjust labeling and false advertising.

Occurrence of material request
Prepare technical
material request form
Reviewing written details
(Compliance department)
Issuing technical material
request form (PJT)

4) Prevention of labeling and advertising violations

Our Policy CR Team and Business Legal Team pre-screen advertising materials before they are distributed to prevent legal violations related to unjust labeling and false advertising.

5) Prevention of violations concerning the Improper Solicitation and Graft Act

SK ecoplant is operating a process it has established wherein the Compliance Team reviews the possibility of violating the Improper Solicitation and Graft Act before processing congratulatory and condolatory expenditures, presenting gifts, and producing souvenirs. Also, We are continuously encouraging all employees to comply with the Improper Solicitation and Graft Act by distributing guidebooks containing the overview of the Act, checklists, and violation cases. In addition, we share various potential cases and the latest issues through the company bulletin board to raise our employees’ awareness of the Act.

Implementation Review Process

SK ecoplant is monitoring if there are any legal violations during the contract implementation process by operating an “internal monitoring system.” We fully review whether all subcontracting payments are legitimately made by conducting document inspections and take improvement measures immediately upon discovery of a violation. In addition, our monthly on-site inspection checks the violation status of 10 items within the Subcontracting Act (subcontractor payment, ban on wrongful reduction of payment, etc.) and 4 items within the Framework Act on the Construction Industry (notification of subcontractor issues to the owner, issuance of guarantee for construction machinery payment, etc.) for all our domestic projects. Then, we take improvement measures and carry out disciplinary procedures according to the result of the inspection. Furthermore, SK ecoplant is carrying out awareness evaluation and implementation evaluation to raise the project site employees’ level of awareness on subcontracting.

Awareness evaluation

Awareness evaluation on project site employees regarding the Subcontracting Act

Conducted Test on Subcontracting Act (conducted training for those who did not pass the test and conducted test again)

Implementation evaluation

Implementation evaluation on the legitimacy of the Subcontracting contract

Prepared a self-diagnosis chart at the project site such as written issuance status, payment status, etc., and then performed self-diagnosis
Inspection visits were made for projects wherein repetitive and numerous violations occurred
Conducted a survey on major Biz. Partner’s project managers regarding difficulties·requests and project violations

Oath of participation in the CP

I agree to actively participate in the “Compliance Program (CP)” for the purpose of establishing and maintaining a fair and sound trade order and declare in writing as follows:

I acknowledge that my voluntary compliance with fair trade-related laws and regulations is associated with SK ecoplant’s competitiveness in the market and agree to actively comply with such laws and regulations.
I will not engage in any unfair business conduct (such as bid rigging or collusion) which undermines fair competition with respect to bidding, market distribution and market price. I will comply with the pre and post-reporting procedures for industry meetings when attending such meetings with other business persons.
I will not engage in any unfair trade or business activities - including but not limited to any unfair supporting activities – which undermine the order of free market economy, in any transactions with SK ecoplant’s affiliates or its business partners.
I will not set or require any unfair contract terms, cancel consignment, reduce payment, request or misappropriate technical data in any dealings or transactions with subcontractors. Further, I will not engage in any business conduct that undermines the order of free market economy – including but not limited to demanding economic benefits from other suppliers or subcontractors - by abusing the company’s position in any transactions.
I will not make any signs or advertisements that may deceive or mislead consumers or other stakeholders.
I will not instruct, approve, or assist in any violations of laws and regulations related to fair trade, and in the event of a risk of potential violation of any such laws or regulations, I will immediately report it to the Compliance Office or the anonymous reporting channel (CP Hot Line).

2023 Oath of participation in the CP _ CEO 2022 Oath of participation in the CP _ CEO 2021 Oath of participation in the CP _ CEO

Compliance Program Current status of the CP operation

Since introduction of the CP in 2008, SK ecoplant has been operating a variety of programs focusing on the eight key elements such as fair-trade education and fair-trade activity inspection, to voluntarily comply with fair trade-related laws.


Year	Month	Activities
2022	September	Distributing relevant cases of Subcontracting Act
		CEO MBWA : visit site of LSPC PJT and emphasize ‘Compliance’
		Revise company regulations (Ethical Management & whistleblower protection)
		Conducting ‘compliance seminar’
		Develope new menu for “CP HOT LINE(Online reporting platform to Compliance Officer’s) on intranet
		Education ‘Global compliance’
	August	Issuing regular newsletter (CP Letter), No.5 of 2022
		Company-wide announcement of the video “Compliance Officer’s Message : encourage compliance”
		Education of CCP qualification course
	July	Publish an special article about SKEP’s CP performance
		Conducting employee survey on CP operation
		Producing new CP Handbook : prohibition unfair Special Agreements
		CEO’s participation in the ‘Resolving inequality Agreement Ceremony’ and emphasize ‘Compliance’
		Reorganize and expand Compliance Office (9 new members)
	June	Counducting education on cases of compliance with Subcontracting Act (total 1,817 people completed)
		Conducting education on cases of Internal Trading (total 92 people completed)
		Issuing regular newsletter (CP Letter), No.4 of 2022
	May	Conducting education for member of the Compliance Office for each BU
	April	Completion of ‘Statement of Oath for Fair Trade Compliance’ (96% consent rate)
		Conducting special training according to the results of inspection of subcontracting status in 2021
		Completing the subcontract document inspection (12,895 cases)
		Issuing regular newsletter (CP Letter), No.3 of 2022
		CEO MBWA : visit site of M15 PJT and emphasize ‘Compliance’
		Signing a fair-trade agreement with Biz-Partners
		Education on the revised ‘Monopoly regulation and fair trade act’
	March	Appointing the Chief Compliance Officer through the board of directors’ resolution
	March	Issuing regular newsletter (CP Letter), No.2 of 2022
	February	Education on the revised ‘Fair transactions in subcontracting act (total 2,801 people completed)
		Operating KPI deduction system for violation of compliance
		Issuing regular newsletter (CP Letter), No.1 of 2022
	January	New employee Compliance Program training (total 63 people completed)
	January	Feedback completed according to the results of inspection of subcontracting in 2021


Year	Month	Activities
2021	July	Issuing regular newsletter (CP Letter) on CP operation.
	June	CEO’s participation in the 'Charity Corporate Agreement Ceremony'
	May	Completing the subcontract document survey (12,901 cases)
	April	Reorganizing the Compliance Office under the direct control of the CEO: Education on cases of compliance with Subcontracting Act (total of 311 people completed)
		Education on cases of compliance with Subcontracting Act (total of 311 people completed)
		Signing a pledge to practice Fair Trade Compliance Program
		Signing a fair-trade agreement with Biz-Partners
		CEO’s message _ Demand to comply with global Compliance
	March	Conducting online education for unfair special agreements & written issuance (total of 3,581 people completed)
		Appointing the Chief Compliance Officer through the board of directors’ resolution
		Launching 'Kakao Talk Open Chat’ for an ethical management reporting channel


2007 ~ 2020	Year	Activities
~2020 Major Activities	2020	Producing the Guide for on-site manual and introducing a review process
	2020	TDMS (Technical Data Management System) efficiency
	2019	Establishing and operating TDMS (Technical Data Management System)
	2019	CEO’s message_ emphasis on CP
	2018	CEO’s message_ Calling for CP
	2017	CEO’s message_ Calling for CP
	2017	3rd Revision of CP handbooks
	2016	CEO’s Message_ Calling for CP
		1st Request for CP Pledge
		CEO’s Message _Calling for CP
	2015	2015: 2nd Revision of CP handbooks
		CEO’s Message_ Calling for CP
		Revision of CP operational regulations and rules
	2011	1st revision of CP handbooks
	2011	CEO’s Message_ Calling for CP
	2008	1st edition of the CP handbook enacted
		CEO’s Message_ Calling for CP
		Introducing Compliance Program
	2007	Establishing regulations and rules for CP operation

For more information, go to Sustainability Report

ESG Reporting SK ecoplant 2022 Sustainability Report