Global Anti-Corruption and Bribery Policy

Samsung Electronics operates as a responsible global corporate citizen by adhering to anti-corruption laws worldwide and upholding its core principles of legal and ethical compliance, while fostering a transparent and ethical organizational culture.

Samsung Electronics maintains a zero-tolerance policy against corruption and bribery, ensuring that it neither condones nor disregards any acts of corruption.

This Global Anti-Corruption and Bribery Policy establishes comprehensive guidelines and standards for directors, officers, and employees, applying to all business activities of Samsung Electronics.

This Policy applies to all directors, officers, and employees (including all permanent and temporary employees, contract workers, and corporate advisors) of Samsung Electronics Co., Ltd., its subsidiaries, and affiliated companies worldwide (collectively referred to as “Samsung Electronics”).

Anti-corruption laws vary among countries; therefore, certain subsidiaries or affiliated companies may have their own anti-corruption policies. In such cases, both this Policy and the local policy must be followed. In the event of any conflict between the policies, the stricter standard shall apply.

Samsung Electronics can be held liable for the corrupt acts of its third-party agents, who are also required to follow this Policy.

• 'Corruption' includes giving, receiving, or asking for anything of value to gain an inappropriate benefit or advantage (e.g., bribery) as well as improper solicitation.
• 'Government officials' is broadly defined to include individuals who work directly or indirectly for governments, political parties, government owned companies, institutions owned or controlled by governments (e.g., universities, hospitals, research facilities), or international organizations (e.g., World Bank, IMF). In Korea, this is extended to 'public officials' including government employees, employees of public institutions or organizations related to public service, school teachers and journalists. It also applies to Korean public officials who are overseas. For any inquiries regarding the definition and scope of 'government officials', please contact the Compliance Team.
• 'Gifts' means any item offered favorably and may include, but is not limited to, products, gift certificates, negotiable instruments and tickets.
• 'Hospitality' means the provision of meals, refreshments or entertainment as well as provision of admission tickets, transportation or lodging relating to cultural or sporting events, travels, conferences or seminars.
• 'Third-party agents' means individuals or companies that are engaged to provide services to or on behalf of Samsung Electronics.

Samsung Electronics' directors, officers, employees, and third-party agents are responsible for complying with all applicable anti-corruption and bribery laws, this Policy and the detailed Guidelines referenced in this Policy.

• Anti-corruption and bribery laws could include not only the applicable local laws but also the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA), and the Korea Improper Solicitation and Graft Act.

• Do NOT offer, promise, authorize, or provide anything of value in order to obtain or retain an improper advantage or as a reward for an improper advantage when doing business with individuals or organizations who have the ability to impact interests of Samsung Electronics.
  • - ‘Improper advantage' is interpreted broadly and may include winning a contract, avoiding taxes or fines, obtaining confidential information of a competitor, or securing other benefits.
  • - 'Anything of value' includes various forms ranging from cash, cash equivalents, gifts, or hospitality to charitable donations linked to a specific business advantage.
• Do NOT make payments to government officials to secure or expedite government services (known as 'facilitating payments').
• During government relations activities, do not make unlawful requests or solicit abuse of authority by public officials.
• Recruitment decisions should be based on an applicant's qualifications and not made to serve the interests of clients, business partners, or public officials.
• Do NOT receive anything of value from potential or current business partners with regards to Samsung Electronics' improper advantage.

Providing gifts or hospitality to serve a legitimate business purpose or to maintain a business relationship is permissible if all of the following principles are met.

• To ensure that the provision of gifts or hospitality by our company is not perceived as an attempt to obtain an improper advantage, we must confirm the following details with the recipient.
  • - As a general rule, the recipient should not be domestic or foreign public officials.
  • - There must be no specific matters of interest, either directly or indirectly, between the Company and the recipient.
  • - Appropriate measures should be taken to prevent the repeated provision of gifts or hospitality to the same recipient, and proper records must be maintained to ensure that neither individual nor cumulative amounts are excessive.
• The following matters should be taken into consideration when determining and providing the type and value of gifts or hospitality.
  • - As a matter of principle, the provision of cash or checks as gifts is strictly prohibited. Appropriate gifts may include promotional items displaying the company's logo or culturally representative souvenirs reflecting the traditions of the respective country.
  • - Gifts, meals, refreshments, alcoholic beverages, and other drinks should be provided in consideration of the cultural norms and customary practices of the respective country, while strictly complying with the applicable local laws and the recipient's internal policies, including any monetary limits.
  • - The Company should not provide transportation or accommodation for trips or travel that are unrelated to its business operations. However, by way of exception, such expense may be covered if the recipient is formally invited to an event organized by or sponsored by the Company, subject to prior approval in accordance with internal procedures.
  • - It is recommended that tourism and other entertainment activities be centered around locations that showcase and provide insight into the traditional culture of the host country.
  • - Hospitality should be provided in proximity to business-related locations, such as the workplace, and a company representative must be present during any meals or sightseeing activities.

• Lawful donations, contributions or sponsorships to credible institutions or organizations are permissible, provided that there is no intent to obtain any improper advantage or exert undue influence, and that all relevant internal procedures are strictly followed.
  • - Donations must be made for legitimate purposes that are aligned with the Company's public interest values and must be directed to institutions or organizations that support such purposes. The amount or items donated must be reasonable and appropriate. Recipients are required to provide a written statement affirming their compliance with applicable anticorruption laws and policies.
    Donations must be processed in accordance with the Company's approval and procedures, and payment must be made directly to a bank account held in the name of the recipient institution or organization.
  • - Contributions and Sponsorships provided to parties from whom the Company may derive business benefits must be proportionate to the value of the potential benefits received. A formal sponsorship or contribution agreement must be executed using the Company’s standard contract template.
    All payments must be processed in accordance with the Company’s approval authority and related procedures. Payments must be remitted directly to a bank account held in the name of the recipient institution or organization.
  • - Membership fees-general or special-payable to associations, academic institutions, or international organizations that are relevant to the Company’s business operations or research activities must be paid in accordance with the Company’s internal standards, subject to the applicable approval authority and established internal procedures.

Samsung Electronics does NOT retain third-party agents as a means to circumvent this Policy or any applicable anti-corruption and bribery laws.

Samsung Electronics manages third-party agents in accordance with its internal procedures, does not disregard any indications of corruption or bribery, and takes appropriate actions—including contract termination—if such agents engage in business activities in violation of this Policy or relevant laws.

Third-party agents are also required to comply with this Policy and applicable anti-corruption and bribery laws.

Samsung Electronics thoroughly records and maintains all expenditures in its accounting books and relevant documentation in accordance with internal procedures.

The establishment or use undisclosed or unrecorded corporate funds —such as secret accounts—for any purpose is strictly prohibited. Additionally, the inclusion of false, misleading, inaccurate, or forged information in the company's books or related records is not permitted under any circumstances.

Samsung Electronics operates its Anti-Corruption Compliance Program and continuously addresses any deficiencies identified in the course of its implementation.

Samsung Electronics designates the Head of the Corporate Compliance Team as the Chief Anti-Corruption Officer, with independent authority and responsibility over anti-corruption and anti-bribery matters.

The Head of the Corporate Compliance Team is responsible for implementing this Policy and the Anti-Corruption Compliance Program, and for continuously addressing any deficiencies identified in the course of its implementation. The Head of the Corporate Compliance Team also provides guidance and advice to support the resolution of related compliance issues.

Compliance officers at the Corporate Compliance Team, business divisions, regional offices, and subsidiaries support the Head of the Corporate Compliance Team by facilitating the implementation of the Anti-Corruption Compliance Program and serving as key contact points.

For any inquiries regarding this Policy or the Anti-Corruption Compliance Program, please contact the Compliance Team via the 'Ask Questions' function on the CPMS website or through other available channels.

Employees of Samsung Electronics and third-party agents must report any known or suspected violations of this Policy or applicable anti-corruption and bribery laws.

Reports may be submitted anonymously through the 'Whistle-blow' function on the CPMS website, via e-mail at cp.wb.sec@samsung.com, or on the 'Reporting Violation of Law' website (www.sec-compliance.net) hosted on Samsung.com. All reports, including the identity of whistleblowers and the contents thereof, will be maintained with the utmost confidentiality.

Retaliation against whistleblowers acting in good faith is strictly prohibited, and any such actions will result in disciplinary measures against those responsible.

Failure to comply with this Policy or applicable anti-corruption and bribery laws will result in appropriate measures.

A lack of awareness of this Policy or relevant laws shall not exempt any person from responsibility.

• Employees of Samsung Electronics: Subject to disciplinary action in accordance with internal policies, up to and including termination of employment
• Third-Party Agents: Subject to measures under internal procedures, including possible contract termination and civil or criminal liability