Ethical Management

Through transparent management
will grow into a trusted company.

Overview of ISO 37001 Anti-bribery Management System

  • A requirements standard established by the International Organization for Standardization (ISO)
  • Demonstrate adequacy and effectiveness of an organization’s management by establishing and running an anti-bribery
    management system (ABMS) designed to control bribery and corruption risks → getting certified to
    ISO 370001 (based on compliance, ethics and transparency)
  • Conformity assessment interval : After initial certification, conformity assessment is conducted every year
    (certification to be renewed in the third year) → remain certified
    Get certified
    Post-certification
    evaluation
    Post-certification
    evaluation
    Assessment
    for renewal
  • Strategy for adoption, operation and certification

ABMS : Anti Bribery Management System

  • ISO 37001
    requirements
  • Updating the
    company policy
    and procedures
  • Evaluation of
    bribery and
    corruption risks
  • Operating system in accordance
    with policies (training,
    due diligence and risk management)
  • Performance
    evaluation
Improved
  • ISO37001 requirements : Identify internal and external bribery and corruption risks, conduct an analysis and update operational manual for improvement
  • Incorporating policies and procedures : Establish and incorporate into ABMS corporate policies and procedures to prevent bribery
  • Assessment of bribery risk : Establish processes and standards for evaluation of bribery risks and conduct evaluation
  • System operation in accordance with policies : Management activities including anti-bribery training & due diligence and risk control involving all the employees and stakeholders
  • Evaluation of performance and improvement : Evaluation of the performance and efficiency of anti-bribery measures through monitoring, internal assessment, and measures taken for continued improvement following managerial review

ABMS Organizational Chart

  1. CEO
    • Board of
      directors
    • HR
      Committee
    • Anti-bribery officer
    • ABMC
      (Anti-bribery
      manage-ment
      committee)
    • Anti-bribery team
      (CP team)
      • Administration
        3 members
      • Sales Support
        4 members
      • Sales
        3 members
      • Research
        1 members
      • Development
        1 members
      • Manufacturing
        1 members
    • Team/department managers across the company

Roles & Responsibilities

  • Board of directors
    • Approve anti-bribery policies
    • Receive and review managerial review regularly
    • Request support for resources
  • Anti-bribery officer
    • Oversee ABMS operations
      (see below for duties)
  • CEO
    • Approve policies and conduct managerial review
    • Evaluate effectiveness of ABMS operation
    • HR and budget support
  • Anti-bribery team
    (CP team)
    • Teams responsible for ABMS operation
      (Updating procedures/systems, risk assessment and support for internal assessment, internal and external due diligence, monitoring, anonymous reporting system, consultation body, advisory panel, training management, integrity culture, management of certification and conformity assessment, etc.)
  • Departmental Officer
    • Internal assessment
      (Internal assessment of the results of risk evaluation)
  • Team/department managers across the company
    • Evaluation of bribery risks(Identifying risks, analysis, evaluation and improvement)

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Date		 Related Data
1 CEO's Anti-bribery Commitments Declaratio 2019-05-07

Anti-bribery Commitments Declaration

HanAll Biopharma (hereafter “the Company”) has established and declared the “HanAll Biopharma Anti-bribery Policy”
to move toward its goal to become one of the world’s best bio pharmaceutical companies that can contribute to promoting health
of people across the world with its commitment to developing innovative medicines based on compliance, ethics and transparency.

Policies1
No colleague shall ever get involved in any form of
corruption including receiving bribery; and must not receive,
offer or accept money or anything of value, meals,
entertainment or gifts.
Policies2
All colleagues must comply with ISO 37001 requirements
and the Company’s ABMS policy as well as local and
global anti-corruption laws and regulations.
Policies3
If a colleague recognizes a suspected anti-bribery violation,
he or she must immediately report the case to Anti-bribery
Officer, who will guarantee confidentiality of the reporter’s
personal information and protect his or her rights.
Policies4
The Company must establish and operate and further
continue to improve an effective anti-bribery and anti-
corruption system to achieve its goal to prevent bribery
and corruption. Every colleague must actively engage in
the efforts to achieve the goal.
Policies5
The company must grant full authority of operations and
independence to Anti-bribery Officer to ensure that he or
she can provide anti-bribery guidance and advice to
employees and leadership of the Company and oversee
their business activities.
Policies6
In addition to colleagues who violate the anti-bribery policy,
the Company shall not be accountable for any failure to take
reasonable actions by its colleague who may be aware of
a violation. It will not tolerate and can take a disciplinary
action against a failure to report.

All colleagues are responsible for reading and complying with this policy.

Business Ethics Reporting System

Internal Whistleblower Center

Types of reporting
  • Reporting in good faith a case which is reasonably
    suspected as a violation of business ethics or
    anti-bribery policy by a colleague
  • Violation of the Anti-bribery Policy and ABMS requirements
  • Violation of CP guidelines and the company’s policies
  • Reporting based on reasonable doubt
  • Reporting a bribery or corruption case which has been
    turned down
  • Recommending CP best practices in and outside the company
Company’s assurance for
colleagues raising concern
  • Protecting colleagues who report a suspected case
    and guaranteeing anonymity
  • Keeping confidentiality of the evidence presented by
    the reporter or collected information about the reported case
  • Offer advice to colleagues involved in or facing a bribery case
  • Keeping the reporting colleague informed of the actions taken
    against the case

Business Ethics
Reporting System

email
Anonymous reporting via email
(Sent to Anti-bribery Officer
(chief/deputy))
chief hotline
Anti-bribery Officer
(chief/deputy)
hotline
익명제보
Anonymous reporting
via mail or phone