Pledge of Lotte International to Practice Voluntary Compliance

All executives and employees of Lotte International Co., Ltd. (hereinafter referred to as the “Company”) shall comply with the following code of conduct in performing their duties.

• 1. I will prevent any and all unfairness in advance through fair and transparent business practices.
• 2. I will never engage in any unethical acts such as provision or receipt of money, gifts, or entertainment to/from stakeholders such as business partners.
• 3. I will fully understand and implement the rules of conduct regarding insider trading, unfair common action, and subcontracting and the guidelines described in the Fair Trade Compliance Program.
• 4. I will select business partners in a reasonable way based on objective and fair evaluation standards, and I will not use my superior position to engage in or influence any form of unfair action.
• 5. In order to ensure fair trade, I will not engage in any unfair acts and will endeavor to establish a culture and climate that observes norms such as the regulations of the Fair Trade Act.
• 6. I will abide by the Code of Conduct and Fair Trade Voluntary Compliance Program regarding insider trading, unfair joint action, and subcontracting, and if I have any concerns or doubts with regards to a violation, I will raise the matter to the Compliance Manager or Fair Trade Compliance Officer.
• 7. I will do my best in my duties with a sense of duty to comply with the law.