This code is intended to foster a sense of responsibility and obligation among participants in the capital market, ensuring diligent performance, protecting investors and ultimately contributing to the sound development of the capital market and the national economy.​

• 1. Basic Principles

  All Employees of the company (hereinafter referred to as “employees”) must adhere to legal compliance and transparent business conduct, avoiding any illegal activities and following fair procedures in all aspects of their work. They should act in good faith, maintain professionalism, and diligently fulfill their duties.

• 2. Investors’ Benefits and Asset Protection

  Employees should prioritize protecting investors’ assets and act as responsible custodians of investors’ property, ensuring that the investors interests are not harmed under any circumstances.

• ​3. Prevention of Bribery and Conflict of Interest

  Employees are prohibited from giving or receiving any form of payment, gift, or hospitality related to their duties and must make efforts to avoid conflict of interest with investors.

• 4. Respect for Marker Order

  Employees must respect the principles of fair and transparent free market economic order and work to uphold it.​

• 5. Ethics Toward Nation and Society

  Employees should conduct business ethically and legally, aiming to contribute to the nation and society’s well-being through the company’s sound growth.

​Based on the above principles and spirit of ethical management, all employees of the company shall actively participate and endeavor to contribute to the long-term prosperity of investors and members of society.​

Stewardship Code

Harborbricks Partners (hereinafter referred to as "Harborbricks") is a PEF GP registered under Articles 249-10 of the Financial Investment Services and Capital Markets Act. Based on the "Principles on the Stewardship Responsibilities of Institutional Investors" established and published by the Korea Stewardship Code Establishment Committee(KSC), the following seven principles on the Stewardship Responsibilities of Harborbricks are specified and implemented as follows.

• Principle 1

  Institutional investors, as a steward of assets entrusted by their clients, beneficiaries, etc, to take care of and manage, should formulate and publicly disclose a clear policy to faithfully implement their responsibilities.

• Principle 2

  Institutional investors should formulate and publicly disclose an effective and clear policy as to how to resolve actual or potential problems arising from conflicts of interest in the course of their stewardship activities.

• Principle 3

  Institutional investors should regularly monitor investee companies in order to enhance investee companies’ mid- to long-term value and thereby protect and raise their investment value.

• Principle 4

  While institutional investors should aim to form a consensus with investee companies, where necessary, they should formulate internal guidelines on the timeline, procedures, and methods for stewardship activities.

• Principle 5

  Institutional investors should formulate and publicly disclose a voting policy that includes guidelines, procedures, and detailed standards for exercising votes in a faithful manner, and publicly disclose voting records and the reasons for each vote so as to allow the verification of the appropriateness of their voting activities.

• Principle 6

  Institutional investors should regularly report their voting and stewardship activities to their clients or beneficiaries.

• Principle 7

  Institutional investors should have the capabilities and expertise required to implement stewardship responsibilities in an active and effective manner.