1

Operating an ethically committed organization

In order to build a more ethical organizational culture, change the ways in which it operates, and pratice its corporate social responsibilities, Orion created a CSR organization in all subsidiaries that will contribute to the well-being of both its internal and external skateholders.

2

Adopting ethical norms and pratical guidelines for the Group

Orion has established ethical norms and practical guidelines that reflect the goal of ethical management pursued by Orion and directions for each skateholder of the Group, and all the employees and management strive to engage in practical ethical management activities that are aligned with their duties.

3

Establishing a global ethical manangement system

All the subsidiaries of Orion are engaged in activities establishing an ethical organizational culture through global operating standards. By measuring the ethics management index, Orion checks the level of ethical manangement level of each subsidiary to reinforce its strengths and compensate for its weaknesses. In addtion, the company operates an ethical management evaluation system to enhance employees’ ability to implement ethical management and motivate the employees, and regularly conducts employee and partner statisfaction surveys to collect the information on satisfaction and opinions from skateholders.

4

Operating an ethical management system

Orion operates a CSR activity participation system that enables all employees and management to monitor thier own participation in ethical management, and we are also responding proactively to vulnerabilities through integrated incident and accident management of all subsidiaries by establishing a reporting system. In addition, the company has laid the foundation for ethical management by operating an internal reporting system that allows anyone to anonymously report unethical behavior within the organization, and a voluntary reporting system to establish transparent and fair relationships with skateholders.

5

Implementing activities spreading ethical management

Since the introduction of ethical management, Orion regularly provides position- and division- oriented training on ethical management/briefing sessions on ethical management and identifying/spreading best practices for promoting ethical management. In addition, Orion is strengthening ethical management practices in the field by selecting key talents in each division as ethical management leaders and making them communicate better in the field