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Ethical Management

KOLON Pharma actively implements the ethical
management to ensure shared prosperity with all members of society.

Anti-bribery Policy

Article 1 (Purpose)
The purpose of this policy is to establish the anti-bribery management system by setting the standards for the personnel of Kolon Pharma,
Inc (hereinafter referred to as "the Company").
Article 2 (Prohibits Bribery)
The Company shall prohibit bribery and conflict of interests such as gifts, hospitality, and benefits from interested party regardless of
any pretexts of the personnel.
Article 3 (Compliance with Applicable Anti-bribery Laws)
The personnel shall comply with applicable anti-bribery laws such as foreign anti-bribery acts and regulations as well as Korean.
(Korea: 「Criminal Act」, 「The law on aggravated punishment of specific crimes」, 「Convention on Combating Bribery of Foreign Public Officials
in International Business Transactions」, and 「The Improper Solicitation and Graft Prohibition Act」,
USA: 「Foreign Corrupt Practices Act」,
UK: 「Bribery Act」)
Also, do not engage in conduct that may be suspected of being violated.
Article 4 (Conformity of Organizational Purpose)
The personnel shall avoid the risk of bribery resulting from the violation of Article 3 in compliance with anti-bribery policy and anti-bribery
management system, thereby contribute to the achievement of the Company's purpose.
Article 5 (Commitment to Implementation and Improvement of the Anti-bribery)
The Company shall establish/operate an effective anti-bribery management system in order to prevent and reduce the risk of bribery resulting
from violation of Article 3, and continuously improve it. Also, all personnel shall sign and commit to the anti-bribery pledge at least once a year.
Article 6 (Authority and Duty of the Anti-bribery Compliance Function)
The Company shall appoint the anti-bribery compliance function for the anti-bribery. The anti-bribery compliance function is assign independent responsibility and authority related to the anti-bribery, and is obliged to provide/supervise the advice and guidance for resolving issues related to the Company's anti-bribery management system.
Article 7 (Protect the Identity of the Informant)
The Company shall keep confidential of informant’s personal data. Also, if the informant is a personnel, the company shall protect him/her from being evaluated and placed on the basis of the notification, and not to be treated unfavorably in the financial condition. The contribution of the Company from the notification of the informant shall be reflected in the performance evaluation.
Article 8 (Action of Not-complying with the Anti-bribery Policy)
The Company shall not be liable on behalf of the personnel for any imposed penalties pursuant to the relevant laws even if the personnel does not take reasonable measures in violating policy and related laws. The Company may take disciplinary action pursuant to the Company's regulations.
Addenda
1. This policy enter into force from December 01, 2017
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