Hana Financial Group Code of Ethics Preamble By pursuing ethical, creative, and sustainable corporate management, Hana Financial Group (hereon “the Company”) will continue to grow into a leading financial group by upholding our proud traditions of ethical behavior, respect for humankind, and strong work ethic. To that end, we hereby enact the Code of Ethics, setting forth the values and ethical standards held by the Company and the basic principles our employees should comply with when carrying out their everyday task. Considering the importance of social responsibility and trust expected of a financial business, all decisions determined and implemented by the Company and its employees in their relations with customers, the community, and subsidiaries require more stringent ethical standards and a greater sense of responsibility than usual. Members of Hana Financial Group, as financial professionals trusted and respected by customers and the society, pledge to faithfully abide by this Code of Ethics by establishing a culture of mutual respect and behaving in a careful and dignified manner. Chapter 1 General Provisions [Basic principle] Employees shall carry out their assignments with a strict sense of mission and responsibility and pursue the following objectives with integrity and mutual trust: A. (Precedence of customer satisfaction) Employees shall always think and act from the customers’ viewpoint and do their best to provide the best possible products and services to the customers. B. (Upholding Ethical Principles) Employees shall always strive to maintain a fully developed sense of ethics by being fully aware of and complying to this Code of Ethics. C. (Employee satisfaction) Employees shall value each employee’s dignity and strive to foster an environment in which all employees may pleasantly work together through guarantee of equal opportunities in every aspect of work, fair evaluation, and proper compensation. D. (Fulfillment of social responsibilities) Employees shall carry out their social responsibilities and roles as members of the community, and contribute to the country’s economic and social development by being an exemplary figure through compliance of rules and regulations and establishment of a stable financial market. E. (Maximization of shareholders’ wealth) Employees will provide stable benefits to shareholders in the long term by maximizing the Company’s value through reasonable investments and healthy management. [Scope of application and interpretation] This Code of Ethics shall be applied and interpreted consistently and fairly for all subsidiaries of the Company and their employees. Chapter 2 Duties to customers [Integrity and fairness] Employees’ business activities shall always be carried out honestly and fairly under the relevant laws and regulations. [Management of customer assets] Employees shall carry out their fiduciary duties in protecting the customers’ assets from the risks of fraud or loss and in taking care of their personal information or information concerning transactions involving their assets. [Caveats for business operations] Employees shall provide customers with truthful and accurate information so that they may select the products or services most suitable for them, and shall not engage in acts of excessive solicitation that may incur a customer’s misunderstanding or blur their sense of judgment. Chapter 3 Duties of Employees [Concentration on work] Employees shall not engage in any private activity that has no relevance to their duties as employees of the Company during work hours. [Healthy leisure activities and modest lifestyle] Employees shall make efforts to enhance the quality of their lives by engaging in healthy leisure activities outside their work hours and maintaining a modest lifestyle. [Prohibition of inappropriate instructions] Supervisors shall not give inappropriate instructions to employees under their control and shall not follow inappropriate instructions from their supervisors. [Reporting misconduct and whistleblower Protection] When employees detect a case that violates laws and regulations, this Code of Ethics, or recognize the possibility of such a case, they shall immediately report it to their supervisor or to the relevant department. In such cases, the Company shall strictly keep the anonymity of the whistleblower and shall not give any sort of negative consequences to the whistleblower due to the report. [Protection of inside information and Prohibition of insider trading] Except when followed by lawful procedure, inside information related to the Company or the customers shall not be shared or disclosed, and can be utilized only in relevance to assigned tasks. Also, insider trading using inside information of the Company or customers is prohibited. [Prohibition of Actions of Conflict of interest] Employees shall not engage in any act of investment, transaction or outside activity that may cause a conflict of interest between themselves, the Company and the customers, unless such is otherwise permitted under the relevant laws and regulations. Employees also shall not simultaneously engage in any business outside their duties as employees of the Company without obtaining the Company’s prior approval. [Outside activities] Employees shall not express their opinions concerning the Company or their tasks as employees of the Company through publication, lecture or external media without obtaining the Company’s prior approval. [Limitations of Political activities and on donations] Employees shall not engage in political activity such as expressing support for a particular political party or candidate, using his or her assignments or status as an employee of the Company. All contributions, donations, and expenses under the Company’s name such as political contributions and charitable contributions must obtain the Company’s prior approval. [Limitations on Gifts from outside sources] Employees shall not ask for, or accept, gifts from others in connection with their assignments, regardless of the value. [Management of expenses] Employees shall spend expenses only for the execution of the Company’s business at a reasonable and necessary level. The misappropriation of the Company’ money is strictly forbidden. [Money laundering] Employees shall recognize the importance of the system for the prevention of money laundering and comply with the procedure under the relevant laws and regulations concerning the prevention of money laundering. Employees shall not become directly or indirectly involved in money laundering under any circumstances. [Personal Loans] Employees shall not lend money to or borrow money from a customer on a private basis or engage in gambling that entails transfer of money with a customer. For the lending or borrowing of an exceptionally large sum of money, employees shall obtain the prior approval of the Company. [Mutual respect] Employees must respect each other and keep good manners; employees shall be wary of each other’s diversity and refrain from acts of discrimination. [Transparency in transactions] Decisions on the purchase of all products and services required by the Company shall be made based on quality, convenience of use, price and degree of contribution to the Company, as well as on the supplier’s trustworthiness and faithfulness, on both short- and long-term considerations of the value of the required articles or services, and on the purpose of the purchase. [Prohibition of sexual harassment] Employees shall not use their status within the Company or their tasks to use sexually offensive language or engage in sexually improper behavior or use them as condition to incur to incur disadvantages during employment or sexual humiliation to other employees. [Fair competition] Employees shall not engage, or cause an affiliate company to engage, in any unfair transaction. [Mutual cooperation] All employees shall faithfully cooperate with each other in the Company’s interest. Chapter 4 The Company’s duties to employees [Respect for Employees’ creativity] The Company shall strive to foster a work environment and corporate culture in which each individual employee’s creativity is respected and in which each employee’s abilities can be exerted fully. [Protection of personal information] The Company shall handle in a careful manner each individual employee’s personal information, including information on personnel affairs. [Prohibition of discrimination and Compensation based on performance and competence] The Company shall recognize the diversity of individual employees, not discriminate against them for any reason whatsoever on the basis of their race, gender, nationality, religion, regional origin, educational background, ancestry, or disability. The Company shall fairly evaluate and compensate employees based on their competence and job performance. [Education and training] The Company shall strive to provide employees with fair and proper opportunities for education and training for the enhancement of professional skills. Chapter 5 Social Responsibility [Exemplary business practice] The Company and its employees shall carry out lawful and honest business activities, setting an example for other companies and contributing to the development of the country through fulfilling all tax obligations. [Role as a corporate citizen] The Company and its employees shall always behave with respect to public interest instead of only focusing on profit in all of its activities. The Company and its employees will provide the society and its members with useful and affordable services. [Duty as a corporate citizen] The Company and its employees shall fulfill their duties as a corporate citizen by actively participating in the cultural and social activities of the community including efforts to preserve the environment. Chapter 6 Duties to the Company and shareholders [Preservation of the Company’s assets] All assets of the Company, including its trade name, shall only be used for the benefit of the Company, and shall not be used for a private purpose without the Company’s approval. All rights concerning assets and information acquired by the employees during their employment with the Company shall revert to the Company even after the termination of their employment. [Management of records] Employees shall draw up all records, materials and information concerning the Company’s business accurately and keep them in good order.