● Purpose

The "Guidelines for Reporting Unethical Conduct" (hereinafter referred to as the "Guidelines") is designed to prevent or minimize damages to stakeholders caused by unethical business practices of SK Shipping Co,. LTD (hereinafter referred to as the "Company") or all employees of the Company (the "Employees). Furthermore, the Guidelines shall play an essential role in building up sound and ethical corporate culture by encouraging the Employees' ethical conducts.

● Definition

1. Money and other equivalent items : Money and other equivalent items mean money, goods, or any securities equivalent to cash (e.g. cash, gift certificates, vouchers etc,).
2. Entertainment : Entertainment means free offer of treatment such as meals, concert tickets, and entertainment.
3. Convenience : Convenience means free offer of transportation, accommodation, and tour etc.
4. Stakeholders : Stakeholders include the Employees, customers, Business Partners (BPs) and other related organizations that affect or can be affected by the Company's actions.
5. General level : General level means the degree that the Employees or citizens can understand based on a common sense and that doesn't have an influence on beneficiaries' fair execution of work.

● Unethical Conduct to be reported

The Guidelines stipulate the following as Unethical Conducts to be reported.

1. Criminal acts
2. Unintentional or negligent acts causing damage to the Company
3. Acts taking advantage of the Company's asset or inside information for private benefit
4. Manipulation of document or false report
5. Neglect of duty or malfeasance
6. Acts receiving entertainment beyond the general level from stakeholders such as BPs.
7. Acts relating to business transactions or assigned duties that cause damage the Company
8. Acts that do not comply with Code of Ethics of the Company.
9. Other unethical or immoral acts beyond the general level

● Reporting process

Stakeholders who witness the acts violating the Ethical Principles have to follow the procedures below.

1. Submitting report

• ① Ethical Management Office has to establish reporting channels (homepage, telephone, fax, e-mail, and intranet) that stakeholders can use for reporting.
• ② Details reported through the above channels shall be notified to COO (Chief Operating Officer) and executives in charge without hesitation

2. Fact-finding. Ethical Management Office carries out an investigation for fact-finding and reports the results to COO and an executive in charge.
3. Deciding handling measures. COO and an executive in charge of Ethical Management Office shall decide necessary measures for a reported case immediately and notify related departments and executives.
4. Notification of results

• ① The department and the person in connection with a reported case shall take proper measures to prohibit and minimize further damage and notify Ethical Management Office of the results.
• ② Ethical Management Office shall inform the reporter of the final result through an appropriate channel. Ethical Management Office can inform the reporter of estimated time only if it is expected to take more than 10 days for solving a case.

● Protection of the reporter

The Company shall protect reports, related information or allegations and informants in the process of complying with the Guidelines.

1. Confidentiality

• ① The Company shall not release any information on the reporter's identity and reported information without reporter's consent.
• ② The Company shall protect information on the reporter's identity and reported details in the process of rewarding and punishing or fact-finding.
• ③ If the Company neglects its duty to protect the reporter, the Company shall recoup damages or take responsibility for the damage.

2. Securing identity

• ① The Company shall prevent a reporter from any damages and discrimination that may arise from reporting and related statements.
• ② If a reporter requests for protection, the Company shall take all available measures.

3. Reduction of punishment. If someone reports himself/herself for unethical conduct, the Company shall take relevant measures such as reduction of punishment or exemption from punishment in consideration of the circumstances.

● Reward and punishment

1. The Company shall reward employees who make significant contribution to achieving purposes of Ethical Management and to punish an employee involved in unethical activities that damage the reputation and interests of the Company.
2. The processes of rewarding and punishing follow the provisions in "the Code of Punishment" and "the Operations Manual for Human Resource Committee."

● Supplementary provisions

1. The Guidelines for Reporting will be effective November 1st, 2008.

● Reporting unethical acts

· SK Shipping is open to receiving reports of unethical conducts concerning the Company. The Company shall spare no effort to establish a transparent management environment by listening sincerely to the voices of our customers and business partners.

· The Company shall protect reporter and keep reported information confidential.

· The Company shall take appropriate measures for reported cases as soon as possible and notify reporters of the results in a manner the reporters request.

● Examples of unethical acts

· Acts that demand or receive money and other compensation items (money, vouchers, entertainment, etc.) beyond general level from stakeholders such as BPs.

· Acts that take advantage of the Company's asset or inside information for private benefit.

· Other unethical acts that involve stakeholders

* For more details, please refer to the "Unethical conduct" in "Guidelines for Reporting".

● Ways to report.

· You may click on the "Report" or contact the numbers or addresses below.

* Telephone : 02-3788-8600
* Fax : 02-3788-8324
* e-mail : sksh.ethics@sk.com
* Address: SK Shipping, Ethical Management Office 21st Fl., 416, Hangang-daero, Jung-gu, Seoul, Republic of Korea

● Purpose

The Operations Manual of Ethical Management Office is designed to stipulate needed provisions in connection with R&R (Roles and Responsibilities) of Ethical Management Office in order to have Ethical Management fully penetrate into SK Shipping (hereinafter referred to as the "Company").

● Contents

1. We establish and operate Ethical Management Office to manage Ethical Management activities to enhance the level of compliance of Code of Ethics.
2. The Compliance team serves as Ethical Management Office.

● Roles

The Ethical Management Office plays the following roles.

1. Establishment, revision, and supplementation of Ethical Management system and policies
2. Management of codes, principles, and guidelines of Ethical Management
3. Establishment of execution direction and implementation plan
4. Establishment and supplementation of needed systems for Ethical Management
5. Monitoring, educating and distributing Ethical Management
6. Receiving reports of unethical conduct and taking relevant measures for it
7. Advising and consulting

● Rights and responsibilities

1. The Ethical Management Office is mandated to request interviews and information for investigation of a reported case. The requests are mandatory and may not be refused.
2. When alleged unethical acts turn out to be true, the Ethical Management Office is mandated to request the alleged to take proper measures and shall report the results to CEO and an executive in charge of the related department.
3. A staff in charge of Ethical Management Office shall not disclose any information detained in the process of carrying out his/her duty without justifiable reason.

● Supplementary provisions

1. "The Operations Manual" will be effective November 1st, 2008.