Principle of Lotte

By establishing effective internal control systems, we shall work to monitor and constantly improve the performance of the company on behalf of the stockholders and to enhance stakeholder value in the long term. We shall build the relationship of mutual trust with stockholders and guarantee the equal rights of all stockholders.

---

Action Plan

• Be committed to enhancing the profit of our stockholders through efficient and reasonable decision-making and transparent and sound management activities.
• Modify the Internal Accounting Control regulations and systems, and actively cooperate for audits or investigations to ensure independent supervision.
• Respect the due right of the stockholders as much as possible, and build a relationship of mutual trust with them.
• Guarantee equal treatment for all stockholders, and actively guarantee the rights of minority stockholders.
• It is Lotte’s stockholders who have affection to and interest in Lotte more than anyone. Carefully listen to the reasonable opinions of stockholders.

Principle of Lotte

If there is a conflict of interest between individuals and the company, we shall work to meet the interest of the stakeholders such as the company and stockholders. If there is, or is feared to be, a conflict of interest, we shall report the situation to and get approval from the company to ensure that our personal interests do not confuse the reasonable decision-making.

---

Action Plan

• Do not act against the interests of the stakeholders such as the company and stockholders, including making personal gains through the position of Lotte executives and employees. It is also prohibited to acquire personal gains indirectly through family members, friends and agents of Lotte executives and employees.
• Get approval from the company in advance in the event that there may be a conflict of interest with the company, including self-dealing transactions or utilizing the business opportunity of the company.
• Do not become the executive or employee of another company conducting the business in the same field or do not acquire the share of such company without the approval of the company.
• Consult with the Compliance Officer in advance in the event that there could be a conflict of interest between the executives and employees and the company or that it is unclear whether there is a conflict of interest.

Principle of Lotte

We shall accurately record any matters regarding the performance and financial position of the company in accordance with related laws, accounting standards and internal regulations. All accounting records shall be proven by appropriate accounting information. We shall record any matters regarding any performance and costs at the time of their occurrence in order to identify the accurate management situation. We shall not distort any data. Accurate accounting records are not an obligation simply limited to those who are responsible for accounting and finance, but the common obligation of all executives and employees.

---

Action Plan

• Prepare and manage the accounting records in accordance with the authorized accounting standards.
• Not only do international and national accounting standards differ, but they are also being frequently amended. Always check the latest standards.
• Record the related data within the proper accounting period. Do not record any revenues or costs in advance or later in order to exaggerate the short-term performance or temporarily avoid a reprimand.
• All costs incurred shall be proven by the uniform accounting data. Record time and expenses regarding the costs and submit it as a report.
• In the event that a person in charge manipulates the accounting documents according to the instruction of his/her supervisor, both he/she and his/her supervisor shall have civil/criminal responsibilities. In the event that the supervisor instructs the manipulation of documents, the person in charge shall immediately consult with the compliance officer.
• Consult on the problem with the director when your counterparty in the transaction is suspicious of manipulating the accounting documents or suspected as an individual, company or country having untransparent business practice, and reconsider such a transaction.
• The director shall thoroughly check everything in accordance with principles in order to provide accurate and transparent information, and shall monitor the data on a regular basis in order to prevent the manipulation of accounting documents.

Principle of Lotte

We shall not make any unfair profit for ourselves, our family members or friends by utilizing undisclosed and insider information. We shall be committed to protecting the profit of our stockholders through efficient and reasonable decision-making and transparent and sound management activities.

---

Action Plan

• Always pay particular attention when providing any information regarding our business. Specifically, if it is insider information, providing such information to others and using it for personal use are all illegal. In addition, it may harm the due rights of the stockholders who have affection to and interest in Lotte the most.
• Insider information includes data regarding management performance, the transfers of executives, restructuring, mergers, acquisition, new product development, new patents, information regarding large-scale investments and the investment plans for a certain region. Manage the information in accordance with the same standards as insider information, if it is unclear whether the information that you are handling is insider information.
• All trades such as transactions using the undisclosed important information and stock exchanges, the establishment/acquisition of the security right and securities lending transactions are strictly prohibited.
• Do not provide the undisclosed important information in expectance of transactions by others or do not recommend anyone to be involved in the other transactions by using such information.
• It is prohibited to conduct stock trading by using the insider information that you came to know at work even after leaving the company or moving to another company.
• Protect the information in accordance with the same standards applied to our insider information, in the event of coming to know the insider information of your partners and competitors.
• In principle, it is prohibited to own the stocks of our partners which have business relations with our company. The same applies to the case of acquiring the stocks of our partners in the name of your family members and relatives.
• Consult with the Compliance Officer even if you have owned the stocks of our partners before entering our company, since there may be a conflict of interest, including providing unfair convenience in the business process.
• It is prohibited to be involved in the trading of derivatives such as hedge trading and short stock selling for the stocks of our company and its affiliates and the related options and swaps.