CONSTITUTION AND APPLICATION SCOPE

Shinhan Vietnam Finance Company Limited (hereinafter called “SVFC” or “Company”) operates with policies and procedures which are consistent with the Shinhan Financial Group (hereinafter called “SFG” or “Group”), Shinhan Card and Company’s core values standard conducts and ethics.

Based on Group’s Code of Ethics as well as Group’s Code of Conduct for Employees, the Code of Conducts and Ethics (hereinafter called “Code”) has been designed for SVFC in order to provide all employees with the standards of ethical decision-making or conducts in the specific situations related to their daily work, lives and duties. In addition, vendors of Company, such as suppliers and services providers are recommended to operate in accordance with this Code or have and operate its own equivalent code of ethics.

GENERAL PRINCIPLES

- This Code is applied through out of the SVFC including all of employees of the Company.

- If an employee becomes aware of a violation of this Code, he or she should report it without a delay to his or her line-managers or relevant departments, such as Legal & Compliance, Human Resources department.

- Should an employee makes a decision or behaves in violation of this Code, he or she can be subject to Company’s internal disciplinary actions and/or additionally may be subject to investigation and penalty in accordance with laws and regulations.  

CHAPTER I. CONDUCTS AND ETHICS FOR EMPLOYEES

Compliance with laws and regulations and ensure the fair business

All employees of SVFC must respect market order, comply with relevant laws and regulations in areas of SVFC’s operations and strive to conduct their work in a fair and ethical manner.

- Must comply with relevant laws and regulations and must respect tradition and culture of a local community.

- Must not commit or get involved in illegal money laundering or insider trading.

- Must not force or instruct a colleague or a subordinate to do unfair or unethical work and must not yield if given such a pressure or instruction.

Integrity and Honesty

- All employees shall refrain from excessive investment activities deviating from their own economic ability and shall maintain an appropriate level of liabilities by considering the ability to repay.

- All employees must have basic knowledge of ethics and law-abiding spirits required as members of the Company, and they should not try to engage in the activities in contravention of laws and regulations. Activities in contravention of laws and regulations are listed but not limited to the list below:

+ Making extravagant consumption behavior deviating from their own economic ability or beyond their means.

+ Engaging in speculative gambling or visiting gambling houses beyond the extent of the temporary entertainment.

+ Habitually visiting harmful places likely to cause excessive drinking or social controversies, which give an inconvenience or a feeling of disgust to third parties.

+ Driving under the influence of alcohol.

+ Unreasonably using the Company’s budgets or expenses, including business trip expenses and business promotion expense, for any purposes other than the original purpose.

+ Engaging in any other activities equivalent of the above activities.

- All employees must clearly recognize their own rights and duties, must not provide goods and services to customers without qualification or authorities and must communicate honestly in performing their duties.

Anti-Money Laundering (AML) and Countering Terrorist Financing (CTF)

Money laundering acts and terrorism financing are global criminal offences by both local laws and regulations and international and practices. Breaches of AML/CTF Law and regulations can incur severe criminal and or civil sanctions for corporations and individuals; seizure of money and other assets; substantial fines and imprisonment or permanent shutdown applied for the organization.

All employees of SVFC:

- Must comply with the internal policy on Anti – Money Laundering (AML) & Countering Terrorist Financing (CTF).

- Must enhance AML & CTF’s awareness by attending all compulsory training programs on AML & CTF.

Detailed information can be found in the internal policy on Anti – Money Laundering & Counter Terrorism Financing. Should you have enquiries, please contact Legal & Compliance Department for further instructions.

Anti-Bribery and Corruption (ABC)

Accepting or giving gifts, meals, entertainment and travel may create an apparent or potential conflict of interest or a circumstance where these acts could be viewed as bribery under the local anti – bribery, corruptions law and regulations and the SVFC’s policies.

All employees acting on behalf of SVFC must comply with the anti – bribery, corruptions law & regulations and Company’s policies.

Gifts, meals, entertainment and travel:

- Must be made for a legitimate purpose and must not place the recipient under any obligation with the intent to impair the objectivity of any act or business decisions with the Company.

- Must be made openly, apparently, reasonably and in appropriate with current business practices and local customs.

Disclosure of accepting or giving gifts, meals, entertainment and travel is compulsory. Detailed information can be found in the internal policy on Gift & Hospitality and the internal policy on Anti – Bribery & Corruption; all employees are required to read, understand and comply with these policies. Should you have enquiries on these policies, please contact Legal & Compliance department for further instructions.

Prevention of Conflicts of Interests (COI)

All employees should not create a situation of conflicting with of SVFC and customers and, if such a circumstance occurs, must put the interests of the Company and customers first. In general, all employees must:

- Avoid any activity that is apparently or potentially a conflict of interest with the Company and customers.

- Avoid circumstances where personal, outside businesses and or related family interests apparently or potentially impair the sound decisions making process of the Company.

- Not engage in activities that compete with SVFC or impair the performance of your responsibilities to the Company.

- Not use SVFC’s confidential information, assets & property (unless being permitted by SVFC) and your authority, role or position to take personal gains.

All employees of SVFC must have duties and responsibilities to disclose any apparent and or potential conflicts of interest amongst parties to their line managers and relevant departments, such as Human Resources, Legal & Compliance department.

Disclosure of conflicts of interest is compulsory. Failing to disclose a conflict or a perceived conflict is a violation of this Code as well as Company’s internal policies.

Detailed information can be found in the internal Policy of Conflicts of Interest. All employees are required to understand and comply with this Policy; if there are any enquiries on the Policy, please contact with Legal & Compliance Department for further instructions.

Information Confidentiality and Security

All employees should strictly manage and protect information of the Company and customers that they become aware of in the course of conducting their duties:

- Must protect the Company’s proprietary information and customer information that require confidentiality (‘Confidential Information’) in accordance with laws and regulations, internal regulations and must not divulge nor use such information for personal purposes.

- Confidential information may exist in any forms of recording or may have no record. All employees should not ask another member to provide or grant an access to confidential information not related to their own work.

- Should employees who maintain or use confidential information are asked to provide or grant an access to information illegitimately by someone internal or outside the Company, they should refuse such a request and must keep confidential information separate from other general information for strict management.

Detailed information can be found in the Information Security Code of Practice, the internal Policy of Information Risk Management.

Fraud awareness and prevention

All employees of SVFC must:

- Understand and comply with the internal anti – Fraud and the reporting procedures of the Company.

- Not engage in any fraudulent activities that apparently or potentially impair the Company’s financial health, brand name and prestige.

- Prevent, support to detect frauds and report any suspicious cases to authorized person(s) or departments, such as

- Your line manager;

- Fraud Prevention Unit (FPU);

- Legal & Compliance department.

Protect the Company’s branding, domain names and websites guidelines

All employees of SVFC must:

- Understand and comply with all requirements set in the Company’s internal policies related to domain names, agent websites and branding.

- Ensure that all communications with the use of logo and company name of SVFC, such as leaflets, advertising, emails, etc. must be adhered to the template of and approved by Customer Experiences, Brand and Communication department prior to their official release.

- Not use, demonstrate and quote any of the following materials on their personal websites, or on social websites, such as Facebook, blogs and other equivalents forms.

Detailed information can be found in internal documents released by Customer Experience, Brand and Communication Department (CX, B&C). Should you have any inquiry, please contact CX, B&C for further instructions.

Protect Company’s assets and business opportunities

All employees must protect the Company’s assets with the duty of care and not use them for personal gains. They must neither take advantage of a business opportunity of the Company they came to know of in the course of conducting their duties by themselves nor have a third party to do so.

Mutual respect among Group’s companies and prohibition of discrimination

All employees must show respect for other Group’s companies and maintain organic collaboration to maximize Group synergy and not discriminate against those from other Group’s companies.

Prohibition of involvement in political activities

All employees must neither engage in any political activities nor offer contribution or expenses directly or indirectly related to political activities.  

CHAPTER 2. ETHICS ON CUSTOMERS, INVESTORS, EMPLOYEES AND VENDORS

Customers

- Customers must be treated fairly, openly and honestly;

- A range of products and services provided and promoted to customers must meet their needs, be easy to understand and be able to deliver real value;

- Our customer information must be kept confidential (except where the Law requires disclosure);

- High standards of customer service must be provided and promoted; and these standards must be monitored rigorously;

- Our complaints processes must be effective and fair means of balancing the interests of the Company’s business and customers.

Investors and Economies

- Communicate our business strategy, achievements and prospects honestly.

- Keep accounting records which accurately disclose the financial position of the business and issue financial statements to ensure transparency of information on the Company's financial performance.

- Respect legitimate requests and suggestions of investors to build the relationship of mutual trust.

Employees

- Provide equal opportunities to all employees.

- Not tolerate any form of discrimination whatsoever on the basic of educational, geographical backgrounds, age, gender, ethnicity, religion, marital status, physical disability or political affiliation.

- All employees must respect one another and not engage in any behaviors that undermine sound work environment such as sexual harassment, illegitimate monetary transactions, organization of private interest groups or violence.

- Provide appropriate remuneration to employees and maintain performance objectives that reinforce the Company’s core values and delivery of its long-term ambitions.

- Promote training and opportunities for personal development.

- Create a favorable employee relations environment with soundness in which the involvement of all employees is encouraged.

- Maintain effective processes to enable whistle-blowers to report instances where they believe malpractice has occurred within the business.

- Provide a healthy and safe work environment, stressing the obligation on all employees to take every reasonable precaution to avoid injury to colleagues and members of the public.

Vendors

The Company endeavors to build and retain the relationship of mutual prosperity with the vendors such as suppliers and services providers and expect them to fully understand and comply with the spirit and contents of the Code.

- Take into account alignment with the Company and/ or Group’s philosophy and policies such as ethics and environmental protection when selecting vendors and maintaining transactions with them.

- Pursue fair transactions on an equal footing and refrain from engaging in unfair practices using a superior bargaining position.  

CHAPTER 3. SOCIAL RESPONSIBILITY AND CONTRIBUTIONS

Environmental Protection

Environmental protection is an essential requirement for sustainable development for Company and the future generation, the Company shall comply with relevant laws and/ or regulations and take part in activities for environmental preservation proactively.

- Observe relevant environmental laws and/ or regulations applicable in the Company’s operating areas.

- Respect global standards and practices on environmental protection.

- Environmental protection as one a main consideration in developing Company’s internal policies, standards and procedures.

Respect for Basic Rights

The Company shall respect basic rights of a human being in all areas of its operations and abide by international standards on basic rights.

Contribution to Communities

- Contribute to the social and economic wellbeing of those communities where we are an employer.

- Encourage employees to participate in projects and initiatives that bring benefits to those communities.

- Minimize the adverse environmental impact of our business operations.

- Conduct our activities, so far as possible, in a manner sensitive to the cultural and social traditions of local communities.