Creating Future Value through
Transparent Management

Ethics

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Ethics

SK Networks takes not only its economic and legal responsibilities seriously, but also ethical responsibility is vital in its management processes. By establishing a fair and transparent corporate culture, we aim to earn the trust of our stakeholders and contribute to the happiness of society as a whole through the continuous growth and development of the company. In this regard, SK Networks established and released the Code of Ethics in 2007, based on SKMS, SK's management philosophy. The Code provides employees with directions on proper behaviors and judgement and requests suppliers to understand and comply with the Code of Ethics.

Ethical Management System

To fulfill its ethical responsibilities and to enhance stakeholders' trust, SK Networks is striving to foster a fair, transparent corporate culture by establishing an ethical management system consisting of 3Cs (Code, Compliance, and Consensus). Our Internal Audit Division, an organization in charge of ethical management, operates the ethical management system and runs various systems and programs to establish and spread the ethics culture.
01 Code, 02 Compliance, 03 Consensus
  • Code of Ethics
    Code of Ethics Practice Guideline
    FAQs on the Code of Ethics
    Practice Guidelines

  • Exclusive organization for ethical management (Internal Audit Division)
    Self-monitoring & correction system
    Reporting channel and Whistleblower protection

  • Ethics training
    Ethics practice workshop
    Ethics practice surveys
    Ethics Management Practice Pledge

Ethical Management Targets and Roadmap

SK Networks vows to establish an ethical management system living up to global expectations and empowering the ethical management systems of its subsidiaries and suppliers as well. To that end, SK Networks defines and tries to accomplish the following targets regarding ethical management policy and training.

2024 ~ 2025

Upgrade the ethical
management system to
global standards

Policy

  • Disseminate and support ISO 37001 certification across subsidiaries
  • Establish ethical management control standards for subsidiaries

Training

  • Develop/Implement ethical education and anti-corruption training content reflecting organizational characteristics
  • Expand ethical education content for suppliers
2026 ~ 2027

Spread the ethical
management system to
global standards

Policy

  • Stabilize/Disseminate ISO 37001 certification across subsidiaries
  • Increase the coverage of ethical management control targets across subsidiaries

Training

  • Continue developing ethical education content to reflect changes in the business environment
  • Implement pilot training programs tailored to each target (leader/member)
  • Provide support for developing ethical education content to reflect the characteristics of subsidiaries
2028 ~

Ensure the ethical
management system at
the global top-level

Policy

  • Maintain ISO 37001 certification for the head office and subsidiaries and evaluate expanding the certification scope
  • Improve the quality of ethical management control for subsidiaries

Training

  • Update education content for ethical education and anti-corruption training
  • Establish an education system tailored to each target
  • Continue supplementing/improving ethical education content for suppliers
  • Provide support for improving ethical education content to reflect the characteristics of subsidiaries

Code

SK Networks developed in 2007 a code of ethics modeled from SKMS (SK Management System) epitomizing SK Group’s management philosophy and has continued to update it ever since. The code of ethics contains provisions governing good practices and decisions to be upheld by SK Networks people in terms of customer relations, basic employee ethics, accountability to shareholders, relations with business partners, and roles to play in favor of the society at large. In addition, SK network has rolled out a guideline for ethical practices to ensure that the code of ethics is correctly understood and complied with as intended. The guideline for ethical practices spells out practices to be upheld by SK Networks people in terms of anti-corruption, mutual respect, protection of corporate and customer data, avoidance of conflict of interest, arm’s-length transaction, safety/environment/health responsibilities, obligations to report irregularities and protect whistleblowers among others In particular, the guideline contains a series of provisions to monitor and eliminate non-compliance of anti-corruption laws including the Improper Solicitation and Graft Act (Anti-graft Act in short). The code of ethics and the guideline for ethical practices are shared with not only SK Networks people but also business partners, with ethical practice training programs provided and compliance agreements from them required. Furthermore, SK Networks had its anti-corruption management system certified (ISO 37001) in December, 2022 to promote ethical compliance, vowing to bolster up ethical practices ever more.

Compliance

Organization of the Ethical Management Council
This is an image of the organization of the ethical management council. Please refer to the bottom for more information. This is an image of the organization of the ethical management council. Please refer to the bottom for more information.
SK Networks Audit Committee
  • Chief of Ethical Management Council : SK Networks Audit Division Head
  • Walkerhill Management Supporting Division Leader, SK Networks service Management Strategy Division Leader, SK Magic Risk Management Division Leader
  • Ethical Management Council
    • SK Networks (Secretary) : Ethics & Audit Team Leader, The person in charge of Ethical Management
    • Walkerhill : The person in charge of Ethical Management
    • SK Networks service : Compliance Management Team Leader, The person in charge of Ethical Management
    • SK Magic : Corporate Audit Team Leader, The person in charge of Ethical Management
Operating the Ethical Management Council

SK Networks has been operating an Ethical Management Council since 2018 to establish a systematic framework and elevate the standard of ethical management practices between the head office and its subsidiaries. The council, primarily composed of working-level personnel from each company, holds quarterly meetings where they collaboratively plan and implement ethics training and workshops. Additionally, the council supports various activities such as establishing ethics regulations for each company, conducting audits, investigating reports, and enhancing the competencies of those responsible for corporate ethics. Through the activities of the Ethical Management Council, SK Networks aims to continuously strengthen the independent ethical management functions of its subsidiaries.

Operation of the Self-Compliance System

To strengthen its autonomous commitment to ethical management, SK Networks operates a self-compliance system that ensures adherence to legal and ethical standards while preventing and controlling misconduct and corruption. As part of this initiative, an annual checklist is developed to assess and monitor ethical risks across business area at the headquarters and its subsidiaries.
The checklist covers key functions such as HR management, expense control, procurement and business partner management, sales and receivables management, investment oversight, and inventory management. It is designed to identify and mitigate ethics and anti-corruption risks tailored to the specific characteristics of each business function. The checklist is continuously improved each year with the addition of new assessment items. In particular, high-risk areas are subject to direct inspections conducted by the Audit Office and the internal audit departments of subsidiaries. Through this process, SK Networks verifies the adequacy of the self-assessment results and supporting documentation submitted by each unit, thereby reinforcing the company’s ethical management system.

Ethical Management Reporting Channels

SK Networks operates a range of online and offline ethics reporting channels—including its website, in-person consultations, and postal mail to enable all stakeholders to freely report unethical conduct. Reports received are thoroughly investigated by the Audit Team and the ethics management units of each subsidiary and are handled fairly and transparently in accordance with established procedures. Customer complaints related to service are referred to the relevant business units for prompt and appropriate resolution.
We place the utmost importance on safeguarding whistleblowers’ identities and safety by enforcing clear protection policies and rigorously managing all reporting procedures to prevent any retaliation against legitimate disclosures. Furthermore, employees who cooperate with whistleblowing-related investigations are afforded the same level of protection as whistleblowers themselves, thereby fostering a secure environment for ethical management practices.

Address

SK Networks Internal Audit Team, 85, Cheonggyecheon-ro, Jongno-gu, Seoul, 03190, Republic of Korea

Consensus

  • Ethics Education Policy

    SK Networks provides ethics education annually to its people including contractors and part- timers, aiming to ensure that all of them attend and finish the ethics education programs. A separate ethics education program has been available for management leaders and board members since September 2021, with another ethics education program intended for business partners rolled out from 2022 to boost awareness of ethical management practices. The ethics education programs cover major ethical management issues in SK Networks, including anti-corruption, office bullying, and work ethics. We also survey the ethics education program takers on the effectiveness, difficulty and logistics of the education programs to inform our efforts to improve the programs and contents of feedback from SKN people. SK Networks also plan to upgrade the ethics education programs for management leaders, board members and business partners annually in quantitative/qualitative terms in line with the rapidly changing business landscape both at home and abroad.

    Ethics Training History
    The table provides results of ethics training and consists of categories (SK Networks and its subsidiaries and partners), 2019, 2020, 2021, 2022, and 2023.
    Category 2019 2020 2021 2022 2023 2024
    SK Networks, subsidiaries, and second-tier subsidiaries* No. of employees completed training
    (Unit : person)**
    4,635 4,922 4,866 4,913 4,862 3,361
    Percentage of employees completed training
    (Unit : %)
    98.4 97.8 98.5 99.2 99.4 99.5
    Partner companies*** Implementation
    (Unit : Y/N)
    N N N Y Y Y
    No. of partner companies completed training
    (Unit : number)
    32 10 13

    * From 2019 to 2021, the Ethics Practice Survey had been implemented in six companies (SK Networks (incl. Walkerhill), SK Networks service, SK Magic, SK Magic service, SK Rent-a-car, SK Rent-a-car service). From 2022 to 2023, Ethics Practice Survey was expanded to eight companies (the existing six companies + MINTIT and Cartini) From 2024, the Ethics Practice Survey has been implemented in five companies (SK Networks (incl. Walkerhill), SK Networks Service, SK Magic, MINTIT, SK Electlink).
    ** Independent directors and non-regular employees were included from 2022.
    *** Business partners in direct transactions with SK Networks headquarters have been subject to a pilot ethics training program since 2022.

  • Ethics Practice Survey

    SK Networks conducts an Ethics Practice Survey for employees at the headquarters and its subsidiaries to assess compliance with the Code of Ethics and the level of ethical practice culture. Ethical management for employees is supported by handling critical implications from survey results, including mutual ethics among employees, inspection of Social Value-degrading elements, and continuous improvement of the ethical management practice system.

    Ethics Practice Survey History
    The table provides the results of the Ethics Practice Survey and consists of categories (SK Networks and its subsidiaries/subsidiaries), 2019, 2020, 2021, 2022, and 2023.
    Category 2019 2020 2021 2022 2023 2024
    SK Networks, subsidiaries, and second-tier subsidiaries* No. of participating employees
    (Unit : person)
    3,705 3,537 4,125 3,985 3,963 2,883
    Percentage of participating employees
    (Unit : %)
    76.0 68.8 82.1 79.7 81.8 85.9

    * From 2019 to 2021, the Ethics Practice Survey had been implemented in six companies (SK Networks (incl. Walkerhill), SK Networks service, SK Magic, SK Magic service, SK Rent-a-car, SK Rent-a-car service). From 2022 to 2023, Ethics Practice Survey was expanded to eight companies (the existing six companies + MINTIT and Cartini) From 2024, the Ethics Practice Survey has been implemented in five companies (SK Networks (incl. Walkerhill), SK Networks Service, SK Magic, MINTIT, SK Electlink).

  • Ethics Management Practice Pledge

    On the first business day of each year, all employees are encouraged to participate in the Ethics Practice Pledge. Along with the employees’ voluntary actions, we aim to enhance awareness of ethical management and establish a transparent corporate culture.

  • Ethics Practice Workshop

    Each year, SK Networks holds an Ethics Practice Workshop for all employees to elevate the level of their ethical management. During the Ethics Practice Workshop, participants watch videos or have discussions after reviewing pre-distributed materials related to ethical issues such as workplace bullying and conflict of interest at work, followed by sharing areas of improvement for practicing ethical management. In addition, organizations are selected and awarded the Ethics Management Workshop Excellence to internalize the ethical practice culture in each company, including subsidiaries.

    Ethics Practice Workshop History
    The table provides the implementation results of the ethical management practice workshop and consists of categories (SK Networks and its subsidiaries/subsidiaries), 2019, 2020, 2021, 2022, and 2023.
    Category 2019 2020 2021 2022 2023 2024
    SK Networks, subsidiaries, and second-tier subsidiaries* No. of participating organizations
    (Unit : number)
    414 393 549 419 393 414
    Percentage of participating organizations
    (Unit : %)
    95 98 98 98 99.8 100

    * From 2019 to 2021, the Ethics Practice Survey had been implemented in six companies (SK Networks (incl. Walkerhill), SK Networks service, SK Magic, SK Magic service, SK Rent-a-car, SK Rent-a-car service).
    * From 2022 to 2023, Ethics Practice Survey was expanded to eight companies (the existing six companies + MINTIT and Cartini)
    * From 2024, the Ethics Practice Survey has been implemented in five companies (SK Networks (incl. Walkerhill), SK Networks Service, SK Magic, MINTIT, SK Electlink).

Implementation of Internal Audits (Ethics/Anti-Corruption Audits)

SK Networks conducts internal audits through its Audit Office, which operates under the Audit Committee of the Board of Directors. These audits consist of regular audits (including follow-up reviews), self-compliance system reviews, and investigations into whistleblowing cases.

At the end of each year, SK Networks conducts risk assessments across all domestic and overseas businesses and support functions, including its subsidiaries. Based on the results, an annual audit plan is established for high-risk businesses units and implemented upon approval by the Audit Committee. Audit findings and implementation status of recommendations are continuously monitored through a centralized system and reported to the Audit Committee on a regular basis to enhance strong execution and accountability. The Company aims to conduct audit all business units and support functions, including subsidiaries, at least once every three years.

  • Through self-compliance system reviews, operational teams conduct an annual evaluation of ethics and anti-corruption risks across all business units, support functions, and subsidiaries, covering key areas such as HR, expense control, procurement, and business partner management. SK Networks Audit Office, along with the internal audit departments of its subsidiaries, conducts direct reviews of high-risk items to verify the adequacy of both the self-assessment results and the supporting documentation provided by operational teams.
  • SK Networks and all its subsidiaries operate a variety of online and offline ethics reporting channels, including a website, in-person consultations, and postal mail. Reports and inquiries received are handled fairly and transparently in accordance with established procedures. Customer service complaints are referred to the relevant business units for resolution, while all reports, including those related to unethical issues, are independently investigated* by the Audit Office and the internal audit departments of the subsidiaries.

* Reports received from subsidiaries are investigated in coordination with the respective subsidiaries.

Based on the results of internal audits, if any violations are identified, immediate corrective actions are taken. Matters requiring improvement are reflected in business operations, and when necessary, comprehensive response measures are developed in collaboration with relevant departments.

Over the past three years, SK Networks has conducted at least one internal audit covering its headquarters, all domestic and overseas business units, and subsidiaries. During these audits, key risks were identified, including information security issues (e.g., document security), improper business practices and procedural violations, and the misuse of company assets for personal purpose. Appropriate corrective actions are taken, and all related matters has been reported to the Audit Committee on a quarterly basis. To prevent the recurrence of similar cases, the company has implemented company-wide announcements, ethics training sessions, and ethics practice workshops.

Fair Trade Compliance Program

SK Networks’ Fair Trade Compliance Program (CP) is an internal compliance system established and operated with the goal of fair trade-related compliance. SK Networks introduced the CP in 2002 and has been presenting CP operation as an agenda for the BOD every year. Through the CP operation, we propose clear and concrete fair trade-related codes to our employees and minimize the risk of legal violations that can occur during business through preventive activities.

Operating Compliance Council

SK Networks operates the SK Networks Compliance Council, which includes the head office (including Walkerhill) and eight subsidiaries and sub-subsidiaries. This council ensures that all participating companies are committed to fulfilling their social responsibilities in compliance management and fair trade, continuously striving to elevate their compliance levels. The council is structured around three areas: Legal Affairs, Fair Trade, and SHE (Safety, Health, Environment). Through its activities, the council facilitates the sharing of necessary regulatory information, educational resources, and lessons learned among the member companies. These interactions strengthen proactive prevention and enhance the ability to respond to issues effectively.

* SK Networks Service, SK Magic, SK Magic Service, MINTIT, SK Electlink, En-core, SK Speedmate, Glowide

SK Networks Compliance Council

  • Participants

    SK Networks(including Walkerhill) and eight first and second-tier subsidiaries

  • Modules

    Legal / CR / SHE

  • Members

    52
    (as of 2025)

  • Key Activities

    Improvement of compliance sensitivity and response capacity, education and information sharing

Fair Trade Compliance Committee

SK Networks appoints a compliance officer from the BOD and operates an organization dedicated to compliance management. Through the voluntary compliance committee, we are preparing a foundation for compliance by deriving key ethical issues and consequently inspecting the status of fair trade-related compliance for each business, promoting fair economy, enhancing trade transparency, and sharing the key Fair Trade policies with the relevant divisions.

This is an image of an anti-corruption policy. Please refer to the following for an explanation.
Anti-Corruption Policy

SK Networks has specified and developed the following Anti-Corruption Policy in a bid to ensure sustainable happiness of its people and stakeholders and foster a fair and transparent corporate culture.

  1. All SK Networks people do not engage in corrupt acts.
  2. All SK Networks people uphold domestic and international anti-corruption laws as well as corporate regulations/guidelines that are applicable to their business practies.
  3. SK Networks implements anti-corruption control systems in conformity of global standards and continues to improve anti-corruption controls by monitoring the operation of the control systems.
  4. SK Networks strictly disciplines its people in a transparent manner when they fail to comply with ethical standards and anti-corruption policies.
  5. SK Networks guarantees the authority and independence of organizations and individuals responsible for enforcing anti-corruption controls.
  6. All Members of SK Networks' management leadership spare no support in ensuring the efficient operation of anti-corruption control systems.

CEO & President
Lee, Ho-jeong