Ethics Management
Ethics Management Governance
Ethics Management Organization
To advance ethics management, Coway has established the Ethics Management Team and the Audit Team under the Ethics Management Office within the Compliance Division, which oversee system management, training, campaigns, monitoring, and audit activities. The Ethics Management Team controls risks in sales and service organizations, while the Audit Team manages risks across other organizations. The two teams work closely together to strengthen internal controls and to foster a culture of ethics management through training and campaigns.
Recognizing the importance of ethical practices, Coway operates the Ethics Management Committee directly under the CEO, ensuring that final responsibility and decision-making authority on ethical issues rest with C-level executives. The Ethics Management Committee is composed of top management, including business division heads and office-level executives. It promptly deliberates on and resolves key ethics and compliance issues across divisions, and drives improvements. This structure secures management's accountability and execution capability in ethical management. In 2025, the Committee deliberated on and executed structural improvements regarding the penalty discount policy for contract holder deceased cases and optimized internal/external notification messaging protocols (KakaoTalk notifications and text messages).
Organizational Chart for the Ethics Management Committee
Code of Ethics
Coway has established a Code of Ethics as the foundation for practicing ethics management, providing employees and stakeholders with a clear standard for ethical judgment and conduct. The Code of Ethics consists of the Charter of Ethics, Regulations of Ethics, and Code of Ethics, and applies to a wide range of stakeholders, including all employees and partners. Coway also strives to improve accessibility so that ethical values can be put into practice in the workplace. Following the publication of the English version of the Code of Ethics in 2021, Coway posted the Code of Ethics on the websites of major overseas subsidiaries, including those in Malaysia, the United States, and Thailand, in 2022, advancing the global expansion of its ethics management culture.
Ethics Management Strategy
3C Ethics Management System
Coway manages its ethics management framework based on the 3C Framework (Code of Conduct, Compliance Check Organization, and Consensus by Ethics Education). Through a dedicated organization that supervises ethical compliance, Coway preemptively addresses ethical risks and strengthens organization-wide ethical awareness by carrying out regular ethics training and campaigns for employees and partners.
3C Ethical Management System
Risk Management for Ethics Management
Field-Centered Ethical Risk Inspections
Coway conducts regular and ad-hoc business diagnoses to maintain its soundness and transparency. We carry out various risk management activities in parallel, including monitoring corporate credit card usage, preventing irregular sales practices, and auditing sales ethics across overseas subsidiaries. In 2025, we focused inspections on ethical risks that may arise in transactions with partners and are reinforcing business rules and procedures for preventive management.
In 2025, Coway strengthened the linkage between order filtering systems and ongoing monitoring indicators, reorganizing the framework into nine core risk metrics. We also conducted on-site inspections of large-scale irregular sales practices, recovering undue gains and taking measures to prevent recurrence. We regularly share company-wide soundness and risk status with field operations, and irregular sales and service risk metrics have been formally embedded as KPI items to further enhance sales transparency. Globally, in 2025 we intensively reviewed the management systems of our Malaysia and Thailand subsidiaries and established risk management systems tailored to local conditions. Going forward, we will continue ethical diagnoses and monitoring at home and abroad to strengthen our internal control functions.
Ethics Reporting Channel
Coway maintains procedures for reporting and handling Code of Ethics violations. Employees aware of a violation must report it to the responsible department, and reports can be submitted anytime through various channels, including online platforms, email, and postal mail. Coway operates domestic and overseas Ethics Management Centers and online reporting channels, keeping customer complaint channels for products, services, and sales separate from whistleblowing channels for employee and partner misconduct. Reports are processed promptly and fairly. When a violation of the Code of Ethics or employment rules is confirmed, disciplinary actions—including dismissal, suspension, salary reduction, or warning—are strictly enforced in accordance with the severity of the violation, following review by the Disciplinary HR Committee.
Reporting and Handling Procedures
Whistleblower Protection and Rewards
Coway places the highest priority on protecting whistleblowers' identity and the content of their reports. We have revised our protection process so that only the Head of the Compliance Division can access whistleblower information, and established the "Whistleblower Protection and Rewards Guidelines" to foster an active reporting culture. Coway operates both a "Whistleblower Reward System" and a "Self-Reporting Leniency System." Under the reward system, verified reports are eligible for up to KRW 50 million, paid within 60 days of verification. We will continue to strengthen these systems to protect whistleblowers and build a transparent reporting culture.
Principles of Whistleblower Protection
Status Protection
Where a whistleblowing report is made by an executive or employee, the whistleblower shall not be subject to any disciplinary action, loss of status, or discriminatory working conditions on the grounds of filing such report, providing statements, or submitting supporting evidence.
Identity Protection
The Ethics Management Office guarantees absolute confidentiality regarding the identity of the whistleblower and the contents of the report. Unless the whistleblower explicitly consents, their identity shall not be disclosed or implied in any manner throughout the investigation
Prohibition of Retaliation
In the event that a whistleblower experiences retaliatory action or adverse treatment from the reported party or related third parties, they may notify the Ethics Management Office immediately. The Office shall conduct an immediate investigation and enforce strict disciplinary measures against those responsible.
Supporter Protection
Protection measures equivalent to those for whistleblowers shall be extended to any individual who cooperates with audits, investigations, or fact-finding procedures by providing statements or submitting relevant materials.
Reduction of Responsibility
Where a disclosure made by a whistleblower leads to the discovery of wrongdoing in which the whistleblower or a cooperating supporter was involved, disciplinary actions against them may be reduced or waived.
Compliance Risk Identification and Assessment Process
To systematically manage compliance risks, Coway conducts annual regular diagnoses while also carrying out ad-hoc diagnoses based on reports submitted to the Ethics Management Center. In particular, we identify areas with a high likelihood of unfair trade and unfair competition as key compliance risks and conduct related risk assessments on a regular basis. We designate operations with a high likelihood of corruption and unfair practices, such as procurement involving large expenditures, as a core management focus and develop annual audit plans accordingly. Based on the results of regular audits, we establish and implement specific risk mitigation measures for unfair trade and unfair competition risks, and continuously conduct follow-up audits on improvement items. Through this approach, we run a prevention-focused ethics management system that goes beyond preventing recurrence to proactively block potential unfair trade and unfair competition before they occur.
Compliance Risk Assessment Activities
Annual Audit Plan
- Regular audits are conducted to assess and monitor the purchasing organization
Fraud and
Misconduct Reports
- Receipt and handling of reports related to fraud and misconduct
Pre-Risk Assessment
- Preliminary assessment of compliance with the Four Major Compliance Principles
- Prior approval from the Legal Team required for any policy revisions by the Purchasing Office
Subcontracting & Fair Trade Compliance
- Conducting monthly reviews to monitor compliance with the Four Major Fair Trade Guidelines
Identified Key Risks and Response Measures
Ethics Management Activities
Ethics Training
To establish a healthy organizational culture and sound sales practices, Coway consistently provides ethics management training content—covering workplace harassment prevention, internal whistleblowing procedures, and improper sales prevention—via our integrated learning platform, making it accessible at all times to all employees, including full-time, part-time, and contract staff. Monthly educational media are also displayed across key business sites, such as the Coway R&D Center, to continuously raise employee ethical awareness. In 2025, we delivered tailored training focused on field-level ethics internalization and unfair trade prevention. We conducted in-person training for 93 general sales managers and technical service branch managers to enforce managerial accountability, alongside online video training for 1,561 branch managers and team leaders to disseminate practical guidelines for preventing fraudulent orders. Monthly short-form video guides highlighting core compliance rules and procedures are also distributed company-wide. Going forward, we will continue regular training on unfair trade prevention to solidify a fair, transparent commercial culture.
Raising Employee Awareness
Coway operates the "Clean-Coway" initiative to foster a fair and transparent sales environment. Through our internal intranet, we disseminate ethical sales principles and focus on embedding compliant sales practices across field operations. We also analyze actual cases of irregular sales practices and distribute non-compliance case studies alongside prevention guidelines to ensure similar incidents are preemptively prevented.
CASE
2025 Ethics Management Forum
In April 2025, Coway convened its 3rd Ethics Management Forum to reinforce leadership commitment to practicing ethics management. Attended by headquarters leaders at the team manager level and above, including the CEO and C-level executives, the forum featured an Ethics Management Declaration Ceremony to solidify our organization-wide dedication. Division heads proactively identified internal ethical risks within their respective units, engaged in structured problem-solving, and immediately implemented field-level countermeasures, laying a solid foundation for autonomous ethical compliance across all operations.