Purpose
This Code of Conduct is intended to provide for standards and procedures guiding ethical behavior and value judgment of Lotte Shopping Co. Ltd. to promote ethical adherence in its management.
Scope of Application
This Code of Conduct is applicable to all executives and employees conducting the businesses of Lotte Shopping Co. Ltd. and its business partners.
Definition
This Code of Conduct is applicable to all executives and employees conducting the businesses of Lotte Shopping Co. Ltd. and its business partners.

¨ç Money
Refer to cash, securities, goods and other monetary gains.
¨è Entertainment
Refer to the offering of food, alcoholic beverage, sports, amusement or entertainment.
¨é Accommodations
Refer to the offering of lodging, transportation, tour guide or event other than money or entertainment whose recipient is to incur financial loss on the part of donor.
¨ê Generally Acceptable Courtesies
Refer to courtesy offered by its provider voluntarily and in good faith and recognized as a generally-accepted social practice without anything expected in return and for which there is no other alternative. However, anything whose value is greater than 50,000 Won per occurrence or 500,000 Won in annual aggregate shall not be regarded as a generally acceptable courtesy.
¨ë Stakeholders
Refer to individuals or groups in and out of company to be affected by the actions or decisions of the company or its executives/employees.
¨ì Business Partners
Refer to individuals or organization with whom the company conducts a transaction.
¨í Relators
Refer to executives, employees business partners or customers, etc. who are required to report the acceptance of money, gift or entertainment or the knowledge of such acceptance.
Respect Customers
We should always listen to our customers, accept their rightful requests proactively and regard customers as standards governing all our judgments and actions.
Satisfy Customers
We should put our respect for customers into practice to maximize their satisfactions.
¨ç We should respond to our customers with well-groomed look and polite posture
¨è We should be kind and sincere while talking with customers over the phone.
¨é We should conduct customer businesses first.
¨ê We should clarify details affecting customer interests and write every printed
material to be readily understandable by customers.
¨ë We should keep our customer facilities and working environment neat and clean all the time.
¨ì We should respond to rightful customer requests for replacement or refund positively.
¨í We should cater for customer complaints or suggestions with promptness and accuracy.
Earn Customer Trust
We should be honest to our customers to be loved and trusted by them.
¨ç We should treat our customers with sincerity and deliver on our commitments to them.
¨è We should use customer information for a purpose other than our valid business or
disclose it to a 3rd party unless customers agree in advance.
¨é We should try our utmost to facilitate communication with customers.
We should strive to ensure transparency and accountability in our management with creativity and innovation to enhance the market value of our shares.Lotte shall contribute to preservation of environment and conservation of natural resources by developing and marketing environment-friendly products, recycling wastes and promoting the value of saving our limited resources.

Sincerity
All executives and employees should dedicate themselves to enhancing the corporate value by conducting their businesses with sincerity and in compliance with the articles of incorporation and the internal regulations of Lotte Shopping and relevant legal and regulatory provisions.
Transparency
We should prepare and publish corporate management data in accordance with the corporate accounting standards and adherence to the generally-accepted corporate management principles.
Shareholder's Right to Know More
We should honor the shareholders'right to know more and respect their rightful requests or suggestions.
Lotte Shopping executives and employees shall endeavor to cherish customer values, earn their trust, and pursue fairness and transparency in our corporate culture to maintain corporate reputation and individual integrity with adherence to legal and regulatory framework, social norms and ethical standards. We shall contribute to the corporate development by exercising our rights and performing our duties as executives and employees based on mutual respect and with proactive and creative mindset.

Compliance
We should not act in violation of laws, corporate regulations, common social values and our consciousness.
¨ç We should not be subject to criminal charges for violation of law.
¨è We should conduct our business in a fair and rightful manner and abide by corporate
rules and applicable legal/regulatory provisions.
¨é We should not be engaged in unethical or illegal practices with regard to our daily life
and business.
¨ê We should not accept any form of financial gains such as money, gift, entertainment
or reception that may impact the fairness in our business. However, a sign of courtesy that is generally acceptable in view of the prevailing standards of our society may be an exception.
¨ë We should not inform our business partners of our own personal occasions or our
colleague's to have them feel obliged.
¨ì We should not use company assets for our personal purpose and disclose or reveal
corporate information acquired while conducting business to a 3rd party.
¨í Executives should be mindful of their social responsibilities, respond to crises and
opportunities actively and take initiatives in compliance with globally-accepted corporate management practices.
¨î Lotte Shopping should organize anti-sexual harassment training sessions more than once
a year by regulation. Executives and employees should attend such training sessions and agree to be subject to strict disciplinary measures if they are found to be responsible for unsavory activities.

1. We should not use any form of language or perform any activity that may cause sexual
displeasure or stress stereotyped role of a given gender.
2. We should abstain from making obscene and indecent jokes and forcing others to drink
or dance against their will.
3. We should not watch obscene materials on the Internet, the Intranet or other form of
media at work.
4. We should not make remarks with sexual and physical connotations relating to our
colleagues.
5. We should not subject our colleagues to physical contact intentionally or unnecessarily.

¨ï We should not use illegal copies of computer software.
¨ð We should not be engaged in any other form of conduct that is deemed to be unethical
objectively.

Compliance
We should exert our utmost to perform our assignments and conduct businesses with honesty and fairness.
¨ç We should play the roles assigned to us respectively in adherence to the corporate
management mission.
¨è We should prevent risks that may be caused by our decisions and conducts and assume
responsibilities for the consequences of such decisions and conducts.
¨é We should try to cooperate with our colleagues and relevant departments and facilitate
communication with them.
¨ê Employees should be banned from offering money or gift to each other in principle with
the following exceptions:

1. If a superior provides money or gift to his or her junior voluntarily;
2. If members of a team offer gifts at their own cost to a colleague in commemoration of
personal anniversary such as birthday;
3. If a gift is offered purely as a sign of gratitude with nothing expected in return.

¨ë Employees may be allowed to offer allowance in aid for colleagues in commemoration or
condolence of personal occasion at their will and in accordance with generally-accepted social practices.
¨ì Employees should not be allowed to extend loans to each other in principle. However, if it is
inevitable, such a loan extension should be approved by the superior of the employees involved in the proposed loan.
¨í Employees should not assume joint and several liabilities together with other colleagues or
stand security for each other. However, security for loans extended by the company as a part of employee welfare program can be provided subject to superior's approval.
¨î Employees should not exchange any form of financial gain such as money or entertainment
in return for acceptance of unlawful request.
¨ï If personal interest and corporate interest conflict with each other in regard to this Code of
Conduct, corporate interest should prevail.

Good Faith
We should try our best to make a wholesome and rewarding workplace, appreciating the value and dignity of each of us as human beings.
¨ç We should not be engaged in any conduct that violates generally-expected etiquettes.
¨è We should not make any disrespectful or belittling remark to superiors, juniors or peers.
¨é We should always maintain neat and fine look and not be engaged in any conduct that may
cause displeasure to others.
¨ê We should not discriminate others based on academic background, gender, religion or
hometown, etc.
¨ë Human resource management should be monitored periodically to collect feedback from
employees to prevent complaints relating to transference or promotion.
¨ì Company should strive to improve the quality of working conditions.

Self-Development
We should be proud of being a 'Lotte Man' based on our knowledge and skills required of any employee of premier corporation.
¨ç We should develop ourselves to be a leader in the era of globalization.
¨è Superiors should spare no advice or guidance for juniors in consideration of their aptitude
and talents and juniors should develop skills required for their assignments.
¨é Company should provide equal training opportunities to promote originality and
self-regulation.
¨ê Tangible and intangible knowledge obtained with regard to company business should be
shared with all other executives and employees to support corporate growth.
We should promote mutual trust and cooperation with our business partners to facilitate mutual development by ensuring fairness and transparency in our transactions with them in adherence to the principles underpinning the free market economy.

Fair Transaction
¨ç We should guarantee equal opportunities for engagement in adherence to the principle of free
competition and publicize information relating to transaction with fairness for mutual benefits.
¨è We should discuss transaction details sufficiently with our business partners to ensure that all
transactions are conducted fairly and in accordance with the principle of reciprocity.
¨é We should not amend transaction terms and procedures unilaterally against our business
partners without consulting them in advance.
¨ê We should not be engaged in conducts banned in laws and regulations relating to fairness in
transaction.

Mutual Development
¨ç We should maintain equal and fair contracting terms with our suppliers as partners and strive
actively to encourage mutual cooperation.
¨è We should help our business partners develop their competitive edge and pursue mutual
growth.
¨é We should publicize our Code of Ethics and Code of Conduct to our business partners and
encourage them actively to put them into practice.

Ban on Unethical Conduct toward Business Partners
¨ç We should not accept money, entertainment, reception or accommodations from business
partners with regard to business. However, courtesies generally accepted in view of social norms should be regarded as exceptions.
¨è Unethical Conducts Banned Herein

1. We should not force our business partners to settle or repay credit card obligations, accounts
payable or loans, have them guarantee our loans or seek financial gains in such forms as movable assets, real properties, securities, goodwill or membership.
2. We should not borrow money from our business partners.
3. We should not lease assets from our business partners or have them furnish collaterals for
personal benefit or profit with regard to business.
4. We should not seek profits by purchasing movable assets or real properties from business
partners at a price lower than market price with regard to business.
5. We should not be engaged in any other unethical conduct against business partners with
regard to business.
We should be aware that our company can exist only based on our nation and society and contribute toward the richness of the life the public and the development of the society by developing our company based on sound corporate activities and thus creating wealth for the society.

Sound Corporate Activity
We should conduct our corporate activities in a sound and reasonable manner and in adherence to the values shared by our society.
¨ç We should reject all irregularities that impact sound corporate activities.
¨è We should meet our social responsibilities as a corporate citizen through our outreach
programs relating to education, culture, and social welfare.
¨é Executives and employees should be encouraged to be engaged in our communities to
contribute to social development.
¨ê We should accept rightful requests from various social classes and community members
with humbleness.
¨ë We should continue to create more jobs to contribute to national development.

Non-Engagement in Politics
Lotte Shopping should not be engaged in politics.

Conservation
We should exert our efforts and interest continuously to keep our environment clean.
¨ç We should support environment preservation campaigns in compliance with environmental
laws and regulations.
¨è We should put environment conservation facilities in place to prevent and address
environmental pollution and maintain such facilities in good order.
¨é We should try our best to conserve environment in our business sites and to ensure pleasant
living conditions for local community.

Conservation
We should seek perfection in our safety management and strive to prevent any safety disaster.
¨ç We should respond immediately to accidents with top priority placed on the safety
of customers and local community members.
¨è Company should train executives and employees thoroughly to prevent safety accidents and
respond to contingencies immediately and abide by applicable safety management standards.
¨é We should maintain various facilities (elevator, escalator, etc.) thoroughly at scheduled
interval and try to prevent fire or gas accident.
Enforcement
This Code of Conduct shall be enforced on January, 1, 2001.

Non-Retroactive Application
This Code of Conduct shall not be applicable to unethical conducts committed prior to its enforcement date.

Organization & Operation of Ethics Committee
¨ç Ethics Committee shall be organized to maintain the Code of Ethics and the Code Conduct
and monitor compliance with them. Ethics Secretariat shall be put together to support operation of the said committee.
¨è Details relating to the operation of the Ethics Committee shall be provided for in a separate
document.

Reportable Items
Executives and employees should report any and all conducts that go beyond the boundary of generally accepted social practice described herein ex pre or post facto. Reportable items and reporting procedure should be provided for in the regulations of the Ethics Committee.

Whistleblowing Encouragement & Protection
The Ethics Committee should take all possible measures to encourage disclosures for public interests and protect whistle blowers, of which details should be provided for in the regulations of the Ethics Committee.

Rewards & Disciplinary Measures
¨ç Rewards
Anyone who deserves credit for the ethical management of the company may be rewarded, subject to the resolution of the Ethics Committee. Details relating to the rewarding level and procedure should be governed by relevant corporate regulations.
¨è Disciplinary Measures
Anyone who is involved in violation of the Code of Ethics and the Code of Conduct may be subject to a disciplinary measure based on the resolution of the Ethics Committee. Details relating to the level and the procedure of disciplinary measure should be governed by relevant corporate regulations.

Interpretation
¨ç This Code of Conduct shall prevail over any other internal regulations except for the articles
of incorporation and the Code of Ethics.
¨è Matters not specified or herein or exposed to debate in terms of their interpretation shall be
interpreted based on the deliberation of the Ethics Committee.

Amendment
This Code of Conduct may be amended or nullified by the resolution of the board.