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Code of Ethics
 Chapter 1 General Provisions
 Purpose
 Application
 Chapter 2 Ethics toward Customers
  1.
    
    To respect customers
 (1)
    
    Directors, officers and employees shall treat customers with a kind attitude and give
customer satisfaction top priority.(2)
    
    Directors, officers and employees shall proactively collect customer opinions such as
suggestions and complaints.(3)
    
    Directors, officers and employees shall deal with customers with integrity and shall always
keep promises made to a customer.(4)
    
    Directors, officers and employees shall protect information related to customers and
customers rights.
 2.
    
    Employees shall provide value to customers




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(1)
    
    Employees shall strive to provide the value required by customers.(2)
    
    Employees shall provide at reasonable prices the goods and services to meet customer
needs.
 Chapter 3 Ethics toward Shareholders
  1.
    
    Provision of information in good faith
 (1)
    
    Directors, officers and employees shall respect the rights of shareholders and reasonable
requests and maintain transparent management and an accurate accounting record system to
establish a mutually reliable relationship.(2)
    
    Directors, officers and employees shall spontaneously provide information on the present
conditions and prospects of the Company to assist the shareholders in making investment
decisions.
 2.
    
    Protection of shareholders interests
 (1)
    
    Directors, officers and employees shall always strive to provide profits for shareholders
through reasonable investment and efficient management.(2)
    
    Directors, officers and employees shall use their best efforts to reduce expenses and
improve on productivity.
 Chapter 4 Ethics toward Nation and Society
  1.
    
    Compliance with lawsDirectors, officers and employees shall observe all laws, rules, regulations and orders of the
territory and country in which the Company conducts its business.2.
    
    Contribution to technical development and economic growth
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(1)
    
    Directors, officers and employees shall strive to develop and disseminate high-tech
technologies for the development of the nation.(2)
    
    Directors, officers and employees shall contribute to economic stabilization and growth
through the creation of jobs and faithful payment of relevant taxes.
 3.
    
    Service and return of profits to society
 (1)
    
    Directors, officers and employees shall contribute to the development of the nation and the
local community through the returning of corporate profits.(2)
    
    Directors, officers and employees shall contribute to social development by encouraging and
participating in healthy social welfare service activities.
 4.
    
    Avoidance of political involvement
 (1)
    
    Directors, officers and employees shall not provide or use any aspect of the Companys
organization, funds, manpower or facilities for political purposes.(2)
    
    Directors, officers and employees shall not engage in speeches or activities supporting or
objecting to a particular political party, organization or candidate, and will not coerce
other directors, officers and employees of the Company into engaging in such speeches or
activities.
 5.
    
    Protection of the environmentDirectors, officers and employees shall strive to prevent environmental pollution and protect
nature through environment-friendly management for environmental conservation.
 Chapter 5 Ethics toward Business Partners
  1.
    
    Provision of equal opportunities
 (1)
    
    Directors, officers and employees shall provide qualified companies the opportunity to
participate as partners.(2)
    
    Directors, officers and employees shall select partners by use of reasonable methods based
on fair and objective examination criteria.
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2.
    
    Fair dealing
 (1)
    
    All transactions shall be fairly conducted on equal footing, and neither unlawful money nor
other articles, entertainment, or conveniences shall be offered or received.(2)
    
    Directors, officers or employees are prohibited from using corporate property or position
for personal gain or otherwise unethical activities.(3)
    
    In the event that any of the partners offers illegal money or articles, entertainment or
conveniences to any of the directors, officers or employees of the Company, the Company may
impose disadvantages including the termination of the transaction with the partner involved.
 3.
    
    Other unfair practices
 (1)
    
    Directors, officers and employees shall not engage in any financial transaction with
partners (borrowing, guarantying, etc) independently of the Company business.(2)
    
    Directors, officers and employees shall not acquire any unlisted stocks of partners free of
charge or on substantially advantageous conditions without the approval of the Company.(3)
    
    Directors, officers and employees shall not serve as an employee or in any other capacity
in any partner.(4)
    
    Directors, officers and employees shall not disclose any information acquired in connection
with the Company business to unauthorized persons either in or outside of the Company.
 Chapter 6 Matters to be adhered to by Directors,
  1.
    
    Protection of the secrets and properties of the Company
 (1)
    
    Directors, officers and employees shall observe all Company policies as a constituent
member of the Company, and shall protect all information acquired in the course of performing
their duties.(2)
    
    Directors, officers and employees shall utilize the Company properties efficiently
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and shall not exploit them for any purpose other than official Company business.
 2.
    
    Fair performance of the Company business
 (1)
    
    Directors, officers and employees shall impartially execute personnel policies on the basis
of capability and quality, and shall treat other directors, officers and employees fairly
based on the level of their efforts and contribution to the Company.(2)
    
    Directors, officers and employees shall not discriminate against other directors, officers
and employees on the basis of relationship with a particular region or alumni, sex, religion
or physical handicap.(3)
    
    Directors, officers and employees shall not use their authority and position in the Company
for personal gain.(4)
    
    Directors, officers and employees shall maintain their integrity as directors, officers and
employees and shall not damage the professional atmosphere for personal gain.
 3.
    
    Relationship among Directors, officers and employees
 (1)
    
    Directors and Officers shall be responsible for implementing the Code and shall set an
example, train and supervise other employees.(2)
    
    Superiors shall not render to their subordinates any unfair instructions or orders and
shall not place their subordinates under any disadvantage.(3)
    
    Subordinates shall comply with the reasonable instructions of their superiors and shall
exert their utmost efforts to perform the business.(4)
    
    Directors, officers and employees shall not engage in any pecuniary transactions nor make
inappropriate requests.(5)
    
    With respect to congratulatory events or condolences, directors, officers and employees
shall show their courtesies but shall avoid paying an excessive amount of money.(6)
    
    Directors, officers and employees shall not engage in any verbal or physical acts of
annoyance to their superiors, colleagues or subordinates, nor shall any group of directors,
officers and employees single out an individual to annoy.(7)
    
    Directors, officers and employees shall not engage in sexual harassment, sexual acts or
sexual abuse in the Company.(8)
    
    Directors, officers and employees shall restrain themselves from engaging in gambling,
excessive drinking or conspicuous consumption which may jeopardize the smooth business
execution of other directors, officers and employees.
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4.
    
    Reporting of violations and furnishing information
 (1)
    
    When any director, officer or employee unintentionally violates the Code, such director,
officer or employee shall report the same to the Ethics Committee without fail.(2)
    
    When a director, officer or employee violates the Code, other employees who are aware of
this violation shall report the same to the Audit department.(3)
    
    The identity of the reporter or informer shall be thoroughly protected.
 5.
    
    Obligation to complete the training courseAll directors, officers and employees shall complete the Ethics Management Course at least once a
year without fail.6.
    
    Reward and PunishmentDirectors, officers and employees and relevant departments that abide by the Code and contribute
to the ethics management activities of the Company shall be rewarded, and those directors,
officers and employees who violate the Code shall be punished after deliberation of the case.
 Addenda
 Article 1 (Effective Date )
 Article 2 (Implementation of the Code)
 Article 3 (Interpretation)
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Article 4 (Relationship with Company Regulations)
 Article 5 (Obtaining Written Pledges)
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Pledge of Compliance with Code of Ethics
       Pledger
    
    (signature)
 To the Representative Director
of hanarotelecom incorporated
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