Ethical Management

LOTTE Personnel Code of Conduct

Trust with Our Partners

Principle of Lotte

We are taking the lead in complying with the Fair Trade Acts applicable to the subject regions around the world. The principles of equality, fairness and openness are the most important principles which have grown our society. We shall consider these principles as the very basic principles in our relationship with all partners around the world. We shall aggressively correct the existing practices of unfair trade, if any, to set the culture of fair trade, and shall pursue the beautiful culture of co-existence.


Action Plan

  • Do not ask our partners to conduct unfair trade or practices by abusing your position. Fully understand the Fair Trade Act, and strictly reject any unfair actions that violate this Act.
  • Select a partner publicly in accordance with the objective criteria and specified procedures such as quality, prices and financial soundness.
  • Provide an opportunity for a company, which shares Lotte’s dedication to and effort in integrity, ethics and social responsibility, to be selected as our partner.
  • Consult with and gain approval from the director since there could occur information leakage, improper solicitation or situations violating the Fair Trade Act when conducting business with our partners where the executives and employees’ relatives or friends are working, or any stakeholders.
  • Frequently check and be well aware of the details to avoid the violation of the Fair Trade Act since the laws and policies regarding fair trade may vary depending on country and the details of the Fair Trade Act are changing as times and the world change.

Principle of Lotte

We shall value our cooperation and relationships with all partners and treat them in an equal and fair way. All the principles of the code of conduct that we observe shall be applied to the relationships with our partners.


Action Plan

  • Respect and treat the executives and employees of our partners equally and fairly like those of Lotte.
  • Respect the management policy and the executives and employees’ working hours of our partners.
  • Explain the provisions regarding Lotte’s code of conduct and other policies to the partners, and request them to agree and comply to them.
  • Treat the partners in a fair way, regardless of their size.
  • Always pay particular attention to the protection of partners’ confidential information and intellectual property rights.
  • Actively provide partners with various growth opportunities, including HR development, quality improvement and technology development. The improvement of their competitiveness will be a driving force of our growth.

Principle of Lotte

We shall compete in a fair way based on the creativity of the company for the proper development of the national economy. We shall discourage the acts of undermining fair competition and shall take the lead in creating a fair and transparent world.


Action Plan

  • It is prohibited to conduct any acts of disturbing the reasonable choice of customers through mutual agreement or connivance among companies and limiting the actual competition among companies. Do not conduct any prohibited act for immediate gains or results.
  • Never even discuss with the competitors on anything against the Fair Trade Acts, including prices, the details of bidding, costs, profits, market share, sales region, the distribution of product family, business conditions, distribution method, the allocation of regions or markets, the boycott of a specific supplier and customer, provided products or services, and the class of customers or suppliers.
  • Do not participate in meetings with the competitors where the agenda is not clear. Even if participating in the meeting with a clear agenda, clearly show your intention to refuse the discussion when a dangerous subject begins to be discussed.
  • While an act, which is allowed in a certain country, may be illegal in another country, our competitors in a certain country may become our partners in another country. In order to prevent the violation of laws in such a case, be fully aware of competition-related laws of each country in advance.
  • Consider the possibility of violating the laws in advance, if the company runs the joint venture or cooperates with the competitor after finding it difficult to achieve its business goal alone.
  • An illegal act could significantly affect not only individuals, but also the company’s reputation. In addition to doing an illegal act itself, do not abet, condone and assist an illegal act.

Principle of Lotte

We shall collect and secure information about our competitors in a legitimate and fair way. We shall not take away or misuse technologies belonging to our partners by using our status in the business process, and shall strive to enhance the win-win cooperation relationship with our partners.


Action Plan

  • Do not collect the information of our competitors by using your personal relationships or through our customers and partners. Include and follow the provision of ‘Confidentiality’ in the agreements with the partners.
  • Consult with the Compliance Officer in advance, especially since the direct collection/exchange of information with the competitors could be considered a violation of the Fair Trade Act.
  • Since it could be a problem to require the confidential information of the competitors when hiring an employee who has worked for our competitor, do not acquire the information of the competitors through such an employee.
  • In the event of acquiring the information of our competitors from anonymous sources, consult with the Compliance Officer in advance when viewing and processing such information.
  • You may be subject to punitive damages if caught taking away or misusing the technical materials of partners such as our subcontractors. Do not require our partners to provide their technologies and related materials without any fair reasons.

Principle of Lotte

We shall conduct our business in a fair and transparent way. We shall not make any unfair personal profit, receive or provide improper money and valuables and entertainment treatment in our business relations. This principle is applied to all countries where we are conducting the business, and we shall respect and comply with any applicable domestic and foreign anti-corruption laws, including OECD Anti-Bribery Convention, Foreign Corrupt Practices Act (FCPA) and UK Bribery Act, in relation to our business activities in those regions.


Action Plan

  • The executives and employees of the company shall not make improper solicitation for any public officials.
  • The executives and employees of the company shall not provide money and valuables in relation to their duty for any stakeholders. Specifically, they shall not provide money and valuables above a certain amount for public officials, regardless of job relevance.
  • Money and valuables, prohibited to be provided, include all tangible/intangible financial gains such as gifts, meals, courteous and entertainment treatment, convenience, donations and sponsorship as well as cash.
  • Politely decline any money and valuables provided by stakeholders and then clearly explain the related company regulations and spirit of Lotte.
  • Comply with the company regulations regarding gifts, meals and courteous treatment and return any gifts that go against the regulations. If it is difficult to return the gifts, deal with it in accordance with the related regulations through consultation with the Compliance Officer or Ethical Management Officer.
  • Even if our partners such as stakeholders who are working with us receive any impermissible money and valuables, it may be seen as our fault. Explain our regulations to the stakeholders by, for example, specifying that the violation of the Anti-corruption Laws is the reason of contract cancellation, and then require them to follow the regulations.
  • Regulations or customs regarding gifts, meals and courteous treatment may vary depending on the country. Identify in advance and follow the related regulations or customs when taking a business trip or working at local offices overseas.
  • Receive advice and approval from the Compliance Officer of the company in advance for conducting business if it is unclear whether the domestic laws and code of conduct are being violated or whether the local laws and customs are different from this code of conduct or the company regulations while working in the foreign countries.

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