SM Entertainment

PREAMBLE

SM Entertainment Co., Ltd. (the “Company”) utilizes Culture Technology to continuously create the best cultural contents, thereby spreading Korean culture to the world and enriching people's lives.

As Korea’s leading entertainment company, the Company respects all laws and market regulations and strives to become a trusted company by faithfully fulfilling its obligations and responsibilities as a listed company.

Accordingly, the Company enacts and commits to conform to this code of ethics (the “Code’) as a standard of behavior and judgment of value that all employees must follow to create a sound and fair corporate culture.

Chapter 1 General Provisions

Article 1 (Purpose)

The purpose of this Code is to enhance the ethical awareness of employees by defining all matters related to ethical practice, thereby promoting the growth and development of the Company.

Article 2 (Application)

① This Code applies to all company activities and all related activities of employees.
② The Company's various rules related to this Code must conform to this Code, and this Code takes precedence unless otherwise specified under law, articles of incorporation, or compliance control standards.

Article 3 (Enactment and Revision)

In order to enact and revise this Code, the resolution of the Board of Directors is required.

Chapter 2 Attitude towards Shareholders and Investors

Article 4 (Equal Treatment)

The Company shall treat all shareholders, including minority shareholders, fairly and equally, and make management decisions in consideration of the interests of all shareholders so that the interests or rights of minority shareholders are not unfairly infringed.

Article 5 (Provision of Information)

The Company shall timely provide management information such as financial status and business performance in accordance with relevant laws and regulations, so that information users, such as investors, can make reasonable investment decisions.

Chapter 3 Attitude towards Customers

Article 6 (Respect for Customers)

The Company shall actively refer to the customer's perspective and strive to realize customer satisfaction by providing reliable content and services, and shall not over-advertise.

Article 7 (Customer Protection)

The Company shall protect the legitimate interests of customers and information about customers, and shall not act unfairly to customers.

Chapter 4 Attitude towards Business Partners, Etc.

Article 8 (Fair Competition)

The Company respects the fair and free market economy and shall compete fairly with other businesses.

Article 9 (Fair Trade)

① The Company shall pursue joint development by establishing mutual trust and partnerships through fair trade with business partners.
② The Company shall not impose unfair acts or exert influence over its business partners.

Chapter 5 Social Responsibility

Article 10 (Compliance with Laws and Regulations)

The Company shall comply with various laws and regulations in the domestic and foreign regions where it conducts its business and respect the traditions and culture of the community.

Article 11 (Contribution to Social Development)

The Company shall contribute to the national economy and social development through job creation, sincere payment of taxes and social contribution activities.

Article 12 (Environmental Protection)

The Company shall strive to save energy and materials, and preserve nature and a clean environment.

Chapter 6 Responsibility for Employees

Article 13 (Fair Treatment)

① The Company shall not discriminate against employees unfairly and shall give fair opportunities according to their abilities and qualities.
② The Company shall prepare evaluation standards for employees' abilities and achievements, and evaluate and compensate them fairly.

Article 14 (Working Environment)

① The Company shall strive to create a healthy and safe working environment for employees.
② The Company shall respect the employees' independent personality, basic rights and privacy as individuals, and create an environment where employees can freely make proposals and suggestions to the Company.

Chapter 7 Basic Ethics of Employees

Article 15 (Performance)

Employees understand the goals and values pursued by the Company and shall perform their duties to the best of their ability in a legitimate manner, and comply with all laws and company regulations related to their work.

Article 16 (Protection of Company Property)

Employees shall protect the Company's tangible and intangible assets, intellectual property rights, and trade secrets, and employees shall not use them for personal purposes such as for former work or personal business.

Article 17 (Prohibition of Conflict of Interest)

Employees shall strive to avoid conflicts or conflicts of interest with the Company, and if there is any conflict of interest between the Company and the department or individual, the Company's interests shall be given priority and acted upon.

Article 18 (Prohibition of Use of Internal Information)

Employees shall not directly or indirectly trade stocks, etc., by using internal information of the Company or its affiliates acquired during work, and shall not arbitrarily provide information that may affect the profit or share price of the Company or its affiliates to third parties.

Article 19 (Restrictions on Political Engagement)

① The political rights and views of employees are respected, but each political view or political involvement should not be misunderstood as the Company’s.
② The employees shall not engage in political activities during working hours, and shall not use the Company's organization, manpower, and property for political purposes.

Article 20 (Prohibition of Sexual Harassment, Etc.)

Employees shall not engages in sexual harassment or harassment in the workplace, or use any other words that may harm other sound corporate culture and peer relationships.

Article 21 (Prohibition of Receiving Cash, Etc.)

① Employees shall not provide nor receive, financial gains, securities, real estate, or other tangible or intangible economic benefits to or from interested parties such as customers.
② Employees shall not provide nor receive gifts, entertainment, and so forth that are outside the range as recognized by related laws and social ideologies to or from interested parties such as customers.

Article 22 (Handling Violation)

① Employees shall report violations of this Code to the Compliance Support Division or Human Resources Division, and any person who receives or processes such reports must maintain the confidentiality of the reporter.
② The reporter referred to in paragraph 1 shall not receive any disadvantage in personnel due to the fact of the report, and the reporter may take into account extenuation if he/she reports a violation related to himself/herself.
③ The Company shall take appropriate sanctions corresponding to the effectiveness and importance of the department or employees who have violated this Code.

Addendum

This Code shall become effective as of May 25, 2020.