The Company’s CP aims to enhance employees’ awareness of compliance and to proactively prevent potential risks in business operations.
Based on the eight core requirements for CP implementation stipulated in the Regulations on the Operation and Evaluation of the Fair
Trade Compliance Program, Hyundai AutoEver continues to manage and operate its CP in a systematic and structured manner.
The CEO annually announces a Compliance Commitment Statement, publicly declaring the Company’s dedication to compliance both
internally and externally. Through CEO messages and other communications, the CEO emphasizes that compliance management is a
fundamental management principle that all employees must uphold. In addition, all employees, including the CEO, participate each year in
the Fair Trade Compliance Pledge, reaffirming their responsibility and commitment to practicing compliance.
Since 2023, Hyundai AutoEver has strengthened its compliance framework by expanding department- and job-specific training programs,
increasing the size of the dedicated CP organization, and designating compliance officers within each division and center to establish a
business-driven compliance management system. The scope of the Fair Trade KPI deduction system has also been gradually expanded.
Furthermore, the Company supports employees in understanding and practicing compliance more easily in their daily work through
initiatives tailored to its work environment, such as a generative AI-based compliance chatbot and CP webtoons.
In its relationships with business partners, Hyundai AutoEver strictly complies with the four key fair trade practices, including the
Subcontracting Act, and continues to make efforts to establish a fair and transparent transaction culture based on mutual trust.
As a result of these efforts, Hyundai AutoEver achieved an AA rating in the 2025 Compliance Program (CP) Evaluation.
2025 Fair Trade Compliance Commitment (CEO)
2025 Fair Trade Compliance Commitment (CP Manager)
implementation of its Fair Trade Compliance Program (CP).
The standards and procedures governing CP operation are based on the Compliance Program Management Policy for Fair
Trade (hereinafter referred to as the “CP Management Policy”), which serves as the highest-level principle. Supporting this
policy are detailed operational regulations designed to implement the policy in practice, including the Fair Trade Compliance
Program Operating Regulations, CP Monitoring Guidelines, Regulations on the Operation of the Subcontract Payment Dispute Mediation
Committee, and the Escrow Management Guidelines.
The CP Management Policy is the highest-level regulation established to embed the Compliance Program as a key standard
and core policy applicable across the Company’s overall management activities. Based on this policy, detailed standards and
procedures for CP operation are reflected in the CP Regulations, which clearly define employees’ obligations to
comply with fair trade regulations and the corresponding implementation framework.
In addition, Hyundai AutoEver regularly reviews and updates the CP operating regulations and related guidelines at least
once a year, reflecting changes in relevant laws and regulations, regulatory policies, and internal operational conditions.
Through this process, the Company continuously enhances the effectiveness and sophistication of its fair trade compliance
framework.
CP Management Policy
Fair Trade Compliance Program Operating Regulations
Hyundai AutoEver has established and operates a structured compliance governance system led by top management
to ensure the independence and effectiveness of its Compliance Program (CP).
The final decision-making authority for CP operation rests with the CEO, who delegates the responsibility for the
program’s independent operation to the Compliance Manager appointed by the Board of Directors. The CP Manager
oversees and manages the CP under independent authority and responsibility. In January 2024, Sim Min-jung, Vice
President of the Legal Group, was appointed as the CP Manager pursuant to a resolution of the Board of Directors.
The CP Manager reports the CP operation plans and key performance outcomes directly to the CEO and senior
management on a quarterly basis, and continuously improves and advances the compliance framework by reflecting
management feedback in CP operations.
To support the independent performance of the CP Manager ’s duties, a dedicated CP team operates under the
direct supervision of the CP Manager . This team assists the CP Manager by carrying out overall operational tasks
related to the CP, including planning and administration of the program, education and training, monitoring and
compliance inspections.
In addition, a Compliance Committee is convened on a quarterly basis to review and deliberate on major fair trade
issues and improvement initiatives. To ensure systematic company-wide compliance management, Compliance
Officers are designated within each division, responsible for disseminating CP policies and operational guidelines
across the organization and conducting regular self-assessments and monitoring activities.
Hyundai AutoEver has established and operates a Compliance Manual to enhance employees’ awareness of fair trade and
compliance and to strengthen their ability to adhere to applicable laws and regulations in day-to-day business operations.
The Compliance Manual is a practice-oriented compliance guide that compiles and organizes key laws and regulations relevant
to the Company’s business activities, taking into account its business structure, transaction practices, and contractual
arrangements. The General Manual systematically presents the core principles of fair trade-related laws and regulations. In
addition, four specialized Manuals—covering Fair Trade, Subcontracting, Intellectual Property, and Disclosure—have been
developed to reflect specific business characteristics and risk types. These Manuals include recent violation cases, major legal
precedents, practical guidance such as Dos and Don’ts, and compliance checklists to support employees in applying compliance
principles effectively in their daily work.
In particular, Hyundai AutoEver continuously monitors amendments to fair trade-related laws and regulations as well as the
latest enforcement cases through monthly legal and regulatory screenings. Relevant updates are promptly reflected in the
Compliance Manual to ensure that its content remains current and practical.
The results of regulatory screenings and updates to the Compliance Manual are communicated to all employees through
internal notices and other communication channels. Through these efforts, the Company aims to enhance awareness of the
evolving regulatory environment and further embed a company-wide culture of compliance.
Hyundai AutoEver establishes and operates continuous and systematic education and training programs to help employees acquire
knowledge of fair trade regulations and learn from relevant cases.
These programs are designed to enhance employees’ understanding of compliance requirements and strengthen their ability to apply
them in practice. The training framework consists of regular general training sessions conducted for all employees and specialized
training programs provided on an ad hoc basis for specific target groups or business units, depending on their roles and areas of
responsibility.
-
Category Target Content Method Date Position-based Training CEO and Executives Fair Trade Trends and Compliance Management Collective 9/4 Ethical and Compliance Management Collective 9/18 CP Manager (Self-Compliance Manager) Leader compliance management training Real-time Workshop 9/11 HR Manager(HR Department) Compliance risk prevention training Collective, Real-time Workshop 11/18, 11/25 New Employees Compliance training Collective 1/18, 8/21, 10/29 Department-based Training Sales/Procurement
(new employee)Fair Trade and Subcontracting–Focused Program Collective 6/24, 7/15 Sales Cartel Prevention Training Collective 2/25 Fair Trade general Collective, Real-time Workshop 12/8 Procurement Guidelines for Improper Price Determination Collective 9/24 Product Development Specialized Fair Trade Training Collective 6/23, 12/1 Function-Specific Training Operations/Logistics Specialized Fair Trade Training Collective 9/9, 9/10 PM(Project Manager) General Understanding of the Subcontracting Act and Its Practical Application in Business Operations Collective 6/9 Compliance Training on Preventing Technical Data Misappropriation Collective 12/12 Regular Training All Employees Specialized Fair Trade Training Online 5/14 ~ 6/19 New Employees Specialized Fair Trade Training Online 11/4 ~ 12/9
Hyundai AutoEver operates a Fair Trade Compliance Committee under the supervision of the Chief
Compliance Officer on a quarterly basis to proactively prevent potential risks related to violations of
fair trade laws and regulations.
The committee functions as a prior business consultation mechanism, reviewing matters related to fair
trade compliance and supporting the prevention of legal risks before business activities are carried out.
Pre-review for Compliance with Fair Trade Regulations (Ongoing)
Employees may request a prior compliance review from the CP dedicated department at any time
when they identify issues that may involve potential legal risks during the course of their work. The CP
dedicated department reviews the matter to determine whether it may constitute a violation of
applicable laws or regulations.
The review results are further examined through additional compliance checks (CP monitoring) to
ensure alignment with the CP operational standards and are subsequently reported to the Chief
Compliance Officer. Through this final confirmation process, potential risks are systematically managed
beforebusiness activities are implemented.
individuals and organizations that contribute to the promotion of a fair trade compliance culture and the continuous advancement of
the Compliance Program (CP).
In the event of violations of fair trade laws and regulations, the Company implements reasonable and stringent measures in
accordance with the CP Operating Guidelines and disciplinary regulations, following a pre-established sanctions process.
In addition, to prevent the recurrence of identical or similar violations, Hyundai AutoEver conducts root cause analyses and establishes
and implements preventive measures based on the findings. Through these efforts, the Company continuously enhances the
effectiveness of CP operations and strengthens its internal control system.
To ensure the program’s operational effectiveness, the Company performs CP operational effectiveness evaluations and CP training
effectiveness evaluations at least twice a year. In addition, regular CP audits are conducted to comprehensively reflect developments in
fair trade regulations as well as the results of internal risk assessments. Through these audits, Hyundai AutoEver systematically identifies
compliance risks in business operations and derives practical improvement measures.
To further enhance the CP framework from an objective perspective, the Company has participated in the CP Rating Evaluation since
2024. In the 2025 evaluation, Hyundai AutoEver achieved an AA rating. The Company actively incorporates the improvement
recommendations and advisory comments identified during the evaluation process into its overall CP operations, thereby continuously
strengthening and advancing its compliance framework.