ACCURACY AND RETENTION OF BUSINESS RECORDS
Employees involved in the preparation of the Company's financial statements must prepare those statements in accordance with Generally Accepted Accounting Principles, consistently applied, and any other applicable accounting standards and rules so that the financial statements materially, fairly and completely reflect the business transactions and financial condition of the Company. Further, it is important that financial statements and related disclosures be free of material errors. In particular, Company policy prohibits any employee from knowingly making or causing others to make a misleading, incomplete or false statement to an accountant or an attorney in connection with an audit or any filing with any governmental or regulatory entity (such as the Nasdaq Stock Market and the Securities and Exchange Commission).
Company policy also prohibits any employee from directly or indirectly falsifying or causing others to falsify any company or client documentation. In addition, an employee must not omit or cause others to omit any material fact that is necessary to prevent a statement made in connection with any audit, filing or examination of the Company's financial statements from being misleading. Employees are prohibited from opening or maintaining any undisclosed or unrecorded corporate account, fund or asset or any account with a misleading purpose.
Destruction or falsification of any document that is potentially relevant to a violation of law or a government investigation may lead to prosecution for obstruction of justice. Therefore, if an employee has reason to believe that a violation of the law has been committed or that a government criminal or regulatory investigation is about to be commenced, he or she must retain all records (including computer records) that are or could be relevant to an investigation of the matter, whether conducted by the Company or by a governmental authority. Questions with regard to destruction or retention of documents in this context should be directed to the Corporate Audit Department.
All Company books, invoices, records, accounts, funds and assets must be created and maintained to reflect fairly and accurately and in reasonable detail the underlying transactions and disposition of Company business. No entries may be made that intentionally conceal or disguise the true nature of any Company transaction.
In addition, if an employee believes that the Company's books and records are not being maintained in accordance with these requirements, the employee should report the matter directly to their supervisor or to a Corporate Audit
All directors, officers and other employees should protect the Company's assets and ensure their efficient use. The Company's assets, whether tangible or intangible, are to be used only by authorized employees or their designees and only for the legitimate business purposes of the Company.
Employees are not permitted to take or make use of, steal, or knowingly misappropriate the assets of the Company, including any confidential information of the Company, for the employee's own use, the use of another or for an improper or illegal purpose. Employees are not permitted to remove or dispose of anything of value belonging to the Company without the Company's consent. No employee may destroy Company assets without permission. Participation in unlawful activities or possession of illegal items or substances by an employee, whether on Company property or business or not, jeopardizes the employee's employment with the Company.
FRAUDS AND THEFTS
Company policy prohibits fraudulent activity and establishes procedures to be followed to ensure that incidents of fraud and theft relating to the Company are promptly investigated, reported and, where appropriate, prosecuted. Fraudulent activity can include actions committed by an employee that injure suppliers and customers/clients, as well as those that injure the Company and its employees.
Employees and agents who suspect that any fraudulent activity may have occurred must immediately report such concern to the Corporate Audit Department. The Legal Department should be contacted before any action is taken with respect to the individual accused of perpetrating the alleged business impropriety. Such allegations, if proven to be factual, will lead to the dismissal of the employee, the involvement of local law enforcement and actions to recover Company funds or property. No employee or agent may sign a criminal complaint on behalf of the Company without prior written approval of the Legal Department.
PAYMENTS AND GIFTS TO THIRD PARTIES
Any payment made by the Company to a third party must be made only for identifiable services that were performed by the third party for the Company. In addition, the payment must be reasonable in relation to the services performed.
Employees are not permitted to give, offer or promise payments or gifts with the intent to influence (or which may appear to influence) a third party or to place such party under an obligation to the donor. There are also other public, as well as private, institutions that have established their own internal rules regarding the acceptance of gifts or entertainment. Employees should become familiar with any such restrictions affecting those with whom they deal.
It is Company policy to protect individual consumer, medical, financial and other sensitive personal information that the Company collects from or maintain about personnel or individual consumers or customers by complying with all applicable privacy and data protection laws, regulations and treaties.
Employees must take care to protect individually identifiable personnel, consumer or customer information and other sensitive personal information from inappropriate or unauthorized use or disclosure. Furthermore, employees must provide individual customers with, as required by law and by the Company's privacy policies:
- notice of relevant privacy policies
- descriptions of the types of information being collected and the uses to be made of the information
- choices regarding certain uses of the information by your business
- access to the information for verification and correction
- security for the information
Employees may not acquire, use, or disclose individual personnel, consumer or customer information in ways that are inconsistent with the Company's privacy policies or with applicable laws or regulations. Finally, employees should consult with the Corporate Audit Department before establishing or updating any system, process, or procedure to collect, use, disclose, or transmit individual personnel, consumer or customer information, medical or financial records, or other sensitive personal information.
The Company has a highly valuable asset in the non-public, confidential and proprietary information that relates to the present or planned business of the Company, including its suppliers, vendors, competitors, customers and/or clients (“Confidential Information”). ”Trade secrets” and ”know-how” are types of Confidential Information, but the general category is broader. Confidential Information includes, but is not limited to:
Computer software, systems, databases, documentation and all data therein;
Financial data (including investments, profits, pricing, costs, and accounting);
Inventions, new product design, research and development;
- Game development processes, techniques and formulae;
- Marketing, advertising and sales programs and strategies;
- Merger, acquisition or divestiture activity;
- Personnel information (including compensation, recruiting and training);
- Regulatory approval strategies;
- Strategic business plans.
Company employees are expected to protect the confidentiality of all Confidential Information, whether obtained from or relating to the Company and/or its suppliers, vendors, customers, clients or other third parties having a confidentiality agreement with the Company. Employees should not disclose (even to family) or use any Confidential Information for any purpose other than on a "need to know" basis within the Company. Similarly, employees should not attempt to obtain or learn Confidential Information that they do not need to know to perform their own employment duties. This obligation lasts during the entire term of one's employment with the Company and at all times thereafter.
Employees should not discuss confidential matters in the presence or within hearing range of unauthorized persons, such as in elevators (even on Company property), restaurants, taxis, airplanes or other publicly accessible areas. Cellular telephones or other non-secure means of communication should be used with care.
If an employee believes it is appropriate for business reasons, or required by law or regulation, to disclose or use Confidential Information outside the company, the Legal Department must be contacted before the disclosure or use to discuss the proper protective measures. Employees should also contact the Legal Department if any uncertainty exists as to whether certain information is, in fact, Confidential Information. Any unauthorized use or disclosure of Confidential Information may subject an employee to civil or criminal liability, and may be prosecuted fully by the Company.
All companies regard their confidential information as extremely valuable. Employees should not attempt to obtain confidential information from any third parties - suppliers, vendors, customers, clients or competitors - without contacting the Legal Department in advance. If the Company executes a confidentiality agreement with a third party regarding confidential information to be disclosed to the Company, all employees must honor the terms of such agreement.
The Company respects the confidential information of its competitors. Under no circumstances should an employee conceal or misrepresent his/her true identity or purpose to obtain confidential information from others. No person may be hired to obtain his/her specific knowledge of a former employer's confidential information, nor placed in a position that would inevitably require the disclosure of such information. Offering a job to an executive of a direct competitor requires the approval of the Legal Department and the Company's Chief Executive Officer before any active negotiations are undertaken
COMPUTER RESOURCES AND SECURITY
The Company's computers, hardware, software, systems, networks and documentation, and all information contained therein or transmitted thereby ("Systems") are all Company property, including laptops, PDAs, or Company systems accessed and used remotely. The Company expects all employees using its Systems to observe the highest standard of professionalism and Company security at all times. To this end, the following policies and principles apply:
- Employees must ensure the integrity and confidentiality of their unique user identification codes and passwords. Any suspected breach must be reported to appropriate management immediately.
- Employees must not access the Company’s Systems without authorization, including by use of someone else’s password, or exceed their authorized access on such Systems.
- Employees must log out before leaving the presence of any Systems that do now support an automated log out process.
- Employees must not alter, delete or destroy any information contained on any System without prior authorization.
- Employees must not obstruct the authorized operation of the Company’s System, including through use of a virus, worm or other corruption.
- Employees must protect the integrity and security of all Systems.
- Employees may not install their own software on Company Systems without prior permission from the Legal Department and must abide by all terms of any license agreement governing such software.
- Employees must use all Systems(including any use of the Internet accessed via any Company Systems) only to further Company business and not for personal gain or non-business related communications.
- The use of company computers must conform to its legal and human resources policies. For example, e-mail messages should never be used for communications that (i) are insulting, disruptive, offensive, inappropriate;(ii) nation, or (iv) could be viewed as disparaging of any race or color, gender, sexual orientation, national origin, religion, political belief of disability.
- The Company’s computers may not be used to solicit for any charity, political cause, or organization or for the distribution of literature relating to any such cause or organization.
- Employees may not initiate or forward chain e-mail. Chain e-mail is a nonbusiness message sent to others asking each recipient to send copies with the same request to a specified number of others.
The sender of any e-mail or chat message on any Company System is wholly responsible for the content of the message and must ensure that the message would not be inappropriate, embarrassing or offensive to the recipient(s), any other person or the firm. ALL EMPLOYEES ARE SUBJECT TO ANY OTHER COMPANY POLICIES AND PROCEDURES REGARDING THE USE OF COMPANY SYSTEMS. THE COMPANY RESERVES THE RIGHT TO MONITOR ITS SYSTEMS AND TO ACCESS, VIEW AND MONITOR THE COMPUTERS AND ELECTRONIC MAIL OF ITS INDIVIDUAL EMPLOYEES TO ENSURE COMPLIANCE WITH THE ABOVE POLICIES AND OTHERWISE AS NECESSARY TO FURTHER THE VALID BUSINESS INTERESTS OF THE COMPANY. BY USING THE COMPANY'S SYSTEMS, ALL EMPLOYEES CONSENT TO SUCH ACCESS VIEWING AND MONITORING.
All employees have access to the Internet through the Company's computers. Employees using the Internet also should be aware that it is a "non-secured" communication vehicle. Any information sent via the Internet is susceptible of wrongful interception by third parties. Accordingly, Internet communications, including external e-mail messages to customers, suppliers and other Company business partners, should not include any Confidential Information and should be structured so that no Confidential Information can be deduced from the content of the message.
Employees should also be aware that, when they visit a website from a Company computer, Internet technology may permit the web site owner to identify both them and the Company. Employees should not visit web sites or construct searches using names or terms that, in conjunction with the Company's name, would allow a third party to deduce Confidential Information. When using the Internet, the following specific points should be noted:
- The internet should be accessed from Company computers only for the company’s business purposes. The internet may be accessed occasionally for limited personal use if the use does not (a) interfere with any employee’s work performance; (b) harm the operation of the systems (e.g., by creating excessive amounts of traffic or overloading); or(c) violate any other provision of this policy or any other policy, guideline or standard of the Company.
- Personal use of any firm computer or of the network is a privilege that may be revoked at any time.
- The Company has the right, but not the obligation, to monitor internet access from all Company computers, including tome spent at particular sites. Employees have no expectation of privacy when using the internet through the company’s network.
- Internet documents of any type can be printed on network printers. However, downloading software or other condensed files is prohibited because of concerns relating to security and virus protection.
- Users should draft, send and forward e-mail with the same standards of care and quality as they use for a formal business letter. The quality of writing in an e-mail message origination from the Company directly reflects on the Company.
- It is the duty of each user of the firm’s network and computers to adhere to this e-mail policy. Any use of the firm’s network and computers in violation of this e-mail policy may result in disciplinary action, up to and including termination
The Company has a highly valuable asset in its patents, inventions, technology, know-how, copyrighted works, software, databases, website, written materials, trademarks, logos, product designs, domain names and Confidential Information. Employees must protect and preserve the Company's intellectual property.
Additionally, pursuant to an agreement signed on an employee's first day of employment, all employees agree to assign to the Company all patent rights in any patentable subject matter invented or discovered within the scope of their employment, on Company time and/or through the use of Company resources.
Ownership. The Company is the sole owner of the copyright in all works of authorship (including software, databases, website and written materials) created by employees within the scope of their employment, whether such works are created at the office, an employee's home or elsewhere. Such works are considered "works made for hire" under the law. Pursuant to an agreement signed on an employee's first day of employment, the Company has the right to claim copyright ownership in other works of authorship that are created on Company time and/or through the use of Company resources. The employee manual should be consulted on this issue.
The Company is the sole owner of all intellectual property rights in its Confidential Information (p. 6) and Systems (p. 7) and all trademarks, logos, product designs and domain names that the Company uses.
Notices and Legends. All Company products and materials should be published, distributed and/or sold only with the proper notices and legends required or recommended by law (e.g.,ⓒ, ®, TM or patent symbol). Use of these notices and legends helps to protect the Company's intellectual property rights against infringement by others. Employees should consult the Legal Department with any questions about the use of proper notices and legends, and must obtain permission from the Domestic Marketing Department prior to using the Company's name in marketing materials, press releases or interviews or other publicly-distributed materials.
Rights of Others. The Company respects the intellectual property of others, including its competitors. Employees are not to copy, modify or distribute (including via the Internet or electronically) any computer software, databases, website or written materials (including magazine or other articles) that are not owned by the Company without consulting the Legal Department in advance. This prohibition applies even to purely internal distributions of such materials. The Company has many agreements with third parties regarding the use of their intellectual property, and all employees are expected to abide by their terms. Employees must not remove copyright, trademark or patent notices from any materials that they use.
International Rights. Intellectual property laws differ in each country; employees should consult with local representatives of the Legal Department before engaging in any activity discussed in this policy outside the Republic of Korea.