We pursue a sound corporate culture based on ethical decision-making

Code of Ethics

Based on SK Group’s Management System, SKMS, SK hynix has established and disclosed the Code of Ethics—which defines the standards of value judgement and proper conduct expected of all employees—along with the Ethical Action Guide, which provides specific principles for ethical behavior. Key stakeholders, including the Board of Directors, employees and business partners, fully understand the Code of Ethics and the Ethical Action Guide, and use them as standards for their decisions and actions across management and business operations, thereby practicing ethical management in their daily work.

In 2025, we have overhauled our Code of Ethics to help employees better understand and reinforce their commitment to ethical conduct by specifying recent ethics violations and clear “Do’s & Don’ts”.

Scope of application for Ethical Norms

The above Ethical Norms apply to companies (including domestic and foreign investment companies with management rights) and employees (including part-time employees whose status corresponds to permanent employees and contract workers).
Employees have an obligation and responsibility to comply with Ethical Norms and stakeholders are also encouraged to practice this regulation.

Ethical Management
Framework

To ensure effective implementation of ethical management practices, SK hynix operates an ethical management system consisting of three stages: ①Prevent (prevention), ②Detect (monitoring and detection), and ③Respond (post-measures and prevention of recurrence).

SK hynix has a department dedicated to ethical management, organized under the Audit Committee, which operates the Ethical Management Framework.

Prevent (Prevention)

SK hynix operates various systems and training programs, such as ethical practice pledges and ethical practice surveys, to prevent violations of laws or unethical behavior by the company itself and its members while performing their duties, and to raise the level of ethical practice.

Pledge

Every year, all employees in Korea and abroad and our business partners (“BPs”) are encouraged to sign the Ethical Practice Pledge to deepen their understanding of the importance and necessity of ethical management and renew their commitment to ethical conduct. In 2026, over 40,000 employees and about 1,500 BPs signed the pledge.

Survey

The company conducts an annual "Ethical Practice Survey" targeting all members to assess the changes in their perception of the level of ethical practices and to effectively improve the ethical practice system.

Communication

We offer tailored communication programs to help employees and BPs easily understand what ethical management is and how to practice it. For employees, the Useful Ethical Management Dictionary explains challenging situations such as dual employment, concurrent position, or conflict of interest with related policies and examples. Also, employees can play an interactive game “Ethics Quest” and navigate through ethical dilemmas. For BPs, we provide “Ethics Insights”, a series of accessible and easy-to-understand short-form videos introducing SK hynix’s ethical management policies.

Training

Every year, we provide foundational ethics training online for all domestic and overseas employees (including regular, contract, temporary employees). Also, team leaders host case study-based discussions for in-depth learning, strengthening employees’ ability to make ethical decisions.
Additionally, we develop situation-specific ethics training content that helps employees understand the ethical conduct expected of them and delivering it through creative methods, maximizing training effectiveness.

Detect (Monitoring and Detection)

In addition to conducting regular or ad hoc inspections of domestic and overseas business units and operations through a department dedicated to ethical management, SK hynix also gradually reinforces monitoring activities on manageable risks to enable effective detection of misconduct through the operation of reporting and counseling channels.

Reporting and Counseling

Reports of unfair demands or irregularities by SK hynix employees or consultations on ethics related grievances relating to SK hynix employees can be made through various channels such as website, phone, email, mail and etc.

Talk or report to us about our ethical management

Investigation Targets (Examples)

Unfair practices and bullying towards BPs, such as accepting bribes/entertainment, personal demands, equity investments, unfair instructions, verbal abuse/physical violence
Lack of respect for individual dignity among members, including verbal abuse, physical violence, sexual harassment, and workplace harassment
Job-related conflicts of interest, such as neglect of duty, monetary lending between members, insider trading using internal information, transactions with related parties
Improper handling of work, including false reporting, manipulation of performance, unethical sales practices, improper use of company funds/assets, and unauthorized disclosure of information.
Non-compliance with environmental/safety/health/quality regulations, leakage of customer/technical information, etc.

Exceptions to Investigation

Cases related to simple customer complaints or personal privacy issues that the company cannot intervene in.
Simple dissatisfaction with personnel evaluations, welfare-related complaints, non-payment of wages by BPs, etc.

In accordance with the whistleblower protection regulations, the identity of the whistleblower and the content of the reporting will be kept confidential (anonymous reporting is possible), and thorough supervision will be conducted to ensure that no disadvantages arise from reporting, with post-monitoring implemented for at least a year. Since 2023, we have been operating the system by expanding the scope of reports and targets of follow-up monitoring.

Click here for Whistleblower Protection System

Self-Refinement System

For key functional areas including procurement, HR, finance and investment management, each team autonomously assess its compliance with ethical standards every year. The Ethics Management Team supports such activities by defining assessment items by functional areas and providing checklists. Then, it reviews and determines the validity of the results against data from relevant work systems.

Audit and Assessment

In accordance with the principle of auditing and assessing all operations every three years, SK hynix’s Ethical Management Team performs regular audits and assessments of business activities across all sites, including subsidiaries, to support risk mitigation efforts of the Audit Committee and the executive management. These audits and assessments examine compliance with applicable policies and procedures or the adequacy and efficiency of business processes and identify ethics violations.
The audit and assessment cover five areas: four functional areas and subsidiaries. To determine the scope of audit and assessment, a risk analysis is conducted on each area to identify high-risk sub-areas. At the beginning of every year, the annual plan is reported to the CEO and submitted to the Audit Committee for review and approval.
Audit and assessment results, including corrective action items and improvement plans, are reported to the CEO and the Audit Committee by the head of the internal audit. In 2025, a total of 12 such reports were submitted. In 2026, we continue to conduct audits and assessments in various areas, including investment in key products and production management, in accordance with our mid- to long-term audit and assessment plan.

[Annual Performance and Plan of Audit and Assessment]

2023년부터 2028년까지의 연도별 감사·진단 시행 현황을 R&D, 제조(양산/품질), 판매/마케팅, 경영지원, 자회사로 구분하여 제공한 표입니다.
Area	R&D	Manufacturing (HVM/Quality)	Sales/Marketing	Management Support	Subsidiaries
2023	-	New equipment under development Safety accident prevention system FAB parts	Account receivables	Collusive bidding	SK hystec
2024	-	Semi-finished goods, stored goods	Product-specific business assessment	Management of service fee payment	Happynarae
2025	Analytical equipment in all sites	Equipment utilities (SEC, Gas, Water treatment)	-	IT Infrastructure Self-correction system Vendor Mgmt.	SK hystec SK hyeng
2026	Technology entity’s Mgmt. Infra	Manufacturing entity’s Mgmt. Infra Product quality and yield control Equipment utilities (HVAC/Exhaust)	Sales entity’s Mgmt. Infra	Corporate security	-
2027	-	O	O	O	O
2028	O	O	O	O	O

Respond (Post-measures and Prevention of Recurrence)

Regarding any matters that need to be rectified such as the unethical and inefficient issues, which are identified during the ‘Detect’ stage, the company takes immediate corrective actions or collaborates with relevant departments to devise a means to improve them. The company also diligently monitors the progress of implementation on a regular basis to prevent the recurrence of risks.
For significant unethical behaviors such as false reporting, bribery, sexual misconduct, and harassment, we strictly respond without tolerance according to the Principle of Zero Tolerance, regardless of the individual's position. In particular, the company is strengthening the imposition of managerial responsibility for corrupt practices on leaders who should set an example.
Furthermore, if any BPs are involved in misconduct, they will undergo a review process conducted by the BP Sanctions Committee. Based on our criteria, they may be subject to sanctions such as restrictions on transaction volume, contract termination, or restrictions on access to our business premises.

Business Ethics