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We pursue ESG for sustainable management.

ESG

ESG Data

ESG Data

A. General Disclosures
B. Environmental
C. Social
D. Governance

A. General Disclosures

A01. Organization
Company Name Huvis
CEO Kim, Suk Hyun
Date of Establishment November 1, 2000
Listing February 23, 2012 (KOSPI)
Head Office 343, Hakdong-ro, Gangnam-gu, Seoul, Republic of Korea
Business Areas Polyester Fibers, Super Fibers
Subsidiary Company Sichuan Huvis, Huvis Global
No. of Employees 709 (As of 2025)
Sales KRW 889 bln (As of 2025)
A02. ESG Evaluation Rating
KCGS(Korea Corporate Governance Service)
Evaluation Year Integrated Rating Category
Environmental Social Governance
2025 B+ B+ A B+
2024 B+ B+ A B+
2023 A B+ A+ B+
2022 B+ B+ A B+
2021 A B+ A+ A
2020 B+ B+ B+ B+
2019 B B B B
2018 B+ B+ B+ B+
2017 B+ B+ A B
2016 B+ B+ B+ B
2015 B B B C
2014 C B C C
A03. ISO Implementation Plan

ISO(14001)
Operational Plan (2026)

Month Scope of Work
January Establish 2026 environmental objectives and identify internal and external issues and risk
February Prepare the 2025 environmental management review report
March Report the results of te 2025 environmental management review
April Obtain approval and prepare for the first-half 2026 ISO surveillance audit
May Conduct the first-half 2026 ISO surveillance audit
June Implement corrective actions arising from the first-half surveillance audit
July Train ISO coordinators and review the operation of the environmental management system
August Obtain approval and prepare for the internal audit
September Conducting the internal audit
October Obtain approval and prepare for the second-half 2026 ISO surveillance audit, and evaluate compliance obligations
November Conduct the second-half 2026 ISO surveillance audit
December Implement corrective actions arising from the second-half surveillance audit

B. Environmental

 

※ In the absence of specific workplace categorizations, the following applies to the Jeonju plant regarding objectives and performance

B. Energy Management

B01_01. Consumption Targets and Performance

Category Energy Usage(*TJ)
2022 2023 2024 2025
Target(①) 6,000 5,950 5,950 5,950
Performance(②) 5,891 5,860 5,846 5,816
Target(*Converted to TOE) 140,677 139,937 139,602 138,886
Difference(②-①) -109 -90 -104 -134
Reduction Rate Compared to the Previous Year -17% -0.5% -0.2%

-0.5%
  • *TJ(Tera Joule)
  • *TOE(Ton Of Oil Equivalent) : Represents the net calorific value of 1 ton of crude oil. 1 TJ = 23.88 TOE

B01_02. Energy Intensity

Category 2023 2024 2025
Energy usage(TJ) 5,860 5,846 5,816
Sales(KRW 100 million) 7,212 7,251 6,914
Energy consumption intensity(TJ/KRW 100 million) 0.813 0.806 0.841
  • ※ Revenue source : Huvis Business Report

B01_03. Use of Renewable Energy

Category 2023 2024 2025
Renewable Energy
Consumption(MWh)		 623.90 1,165.38 1,475.57
TJ Conversion
(MWh = 0.0036TJ)		 2.246 4.195 5.312
Annual Total Energy
Consumption(TJ)		 5,860 5,846 5,816
Percentage of Renewable
Energy Use(%)		 0.038 0.072 0.091
Improvement Rate Compared
to the Previous Year(%)		 0.027 0.034 0.019
  • *Renewable energy consumption is based on the solar power generation produced and consumed at the Jeonju plant
  • *The percentage of renewable energy use is calculated against Huvis' total energy consumption (TJ)
B02. Greenhouse Gas Emission

B02_01. Emissions Targets and Performance (2025)

Category Greenhouse Gas Emissions(*tCO2 eq)
Head Office Jeonju Plant R&D Center Daegu Ofifce Total
Target 255 410,000 600 10 410,910
Performance 253 403,506 559 8 404,326
  • *tCO2 eq : Ton CO2 equivalent

B02_02. Greenhouse Gas Emissions

Category Greenhouse Gas Emissions(tCO2 eq)
2022 2023 2024 2025
Direct greenhouse gas emissions(Scope1*) 245,342 262,834 274,598 289,352
Indirect greenhouse gas emissions(Scope2*) 139,435 130,304 123,704 114,976
Indirect greenhouse gas emissions(Scope3*) - - - -
Total 384,776 393,137 398,301 404,326
Reduction Rate Compared to the Previous Year(%) -17.4% 2.2% 1.3% -1.5%
  • * Scope1 : Direct emissions from sources owned or controlled by the company
  • * Scope2 : Indirect emissions from the consumption of purchased electricity, steam, etc
  • * Scope3 : Indirect emissions occurring in the company’s value chain (Huvis currently does not estimate separate Scope 3 emissions)

B02_03. Emissions Intensity

Category 2023 2024 2025
Greenhouse Gas Emissions(tCO2eq) 393,137 398,301 404,326
Product Output(tons) 603,500 618,832 539,830
Greenhouse Gas Emissions intensity(tCO2eq/tons) 0.65 0.64 0.75
B03. Waste Management

B03_01. Generation Targets and Performance

Category 2022 2023 2024 2025 2030
Target Performance Target Performance Target Performance Target Performance Target
Waste Generation(tons) 31,477 25,765 23,147 29,609 31,700 28,817 29,187 30,217 28,070

Year-over-year unit reduction rate

 -14% 15% -3% 5% -7%

Result

 Compliance Non-compliance Compliance Non-compliance Compliance
  • ※ Target for 2030 : Set a goal to reduce generation by 10% compared to 2025 by decreasing it by 2% annually
  • ※ Reduction Measures : Reduction and reuse of raw and auxiliary materials loss, reduction in the use of disposable products

B03_02. Treatment Performance by Type

Category 2024 2025
Incineration Landfill Others* Recycling Total Incineration Landfill Others* Recycling Total
Hazardous Waste(tons) 2,083 - 14 637 2,733 1,778 1 - 511 2,290
General Business Waste (tons) 436 2,052 278 23,180 25,946 411 2,330 - 24,964 27,705
Construction Waste(tons) - - 138 - 138 - - 223 - 223
Total(tons) 2,519 2,052 429 23,817 28,817 2,188 2,331 223 24,475 30,217
Recycle Rate 83% 84%
  • *Others : Intermediate disposal methods such as neutralization, shredding, etc.

B03_03. Record of Use of Recycled Raw Materials (2025년)

B03_03_01. Process for Using Purchased Recycled Raw Materials

(2025 HP-Chip (GRS certified))

  • Raw Material Procurement and Receipt
    • Receive purchased bottle flakes
    • Feed into silo after receipt
  • Melting and Impurity Removal
    • Weigh and melt
    • Filter to remove impurities
    • Control physical properties such as viscosity
  • Melting and Impurity Removal
    • Cut chips
    • Pack in bags after weighing
    • Feed chips into silo
  • Undrawn Yarn Production
    • Weigh and melt
    • Perform composite spinning of undrawn yarn (S/C)
    • Wind into cans after applying oil/lubricant
  • Drawing, Cutting, and Packaging
    • Draw and impart physical properties
    • Pack after cutting by product specification
    • Store after moving to warehouse
B03_03_02. Use of Purchased Recycled Raw Materials

(2025 HP-Chip (GRS certified))

Category Staple Fiber (SF) Filament Yarn (FY)

Total
Recycled raw material consumption (tons) HP-Chip (GRS certified) 369 384 753
Product production using recycled raw materials (tons) HP-Chip
(GRS certified)		 436 333 769
  • *HP : Hybrid Polymerization, GRS: Global Recycled Standard, LM: Low Melting
B03_03_03. Process for Using Purchased Recycled Raw Materials

(2025 Ecoever LM (GRS certified))

  • Raw Material Procurement and Receipt
    • Receive purchased bottle flakes
    • Feed into silo after receipt
  • Melting and Impurity Removal
    • Weigh and melt
    • Filter to remove impurities
    • Control physical properties such as viscosity
  • Melting and Impurity Removal
    • Cut chips
    • Pack in bags after weighing
    • Feed chips into silo
  • Undrawn Yarn Production
    • Weigh and melt
    • Perform composite spinning of undrawn yarn (S/C)
    • Wind into cans after applying oil/lubricant
  • Drawing, Cutting, and Packaging
    • Draw and impart physical properties
    • Pack after cutting by product specification
    • Store after moving to warehouse
B03_03_04. Use of Purchased Recycled Raw Materials

(2025 Ecoever LM (GRS certified))

Category Staple fiber (SF)
Recycled raw material consumption (tons) Ecoever-LM (GRS certified) 1,449
Product production using recycled raw materials (tons) Ecoever-LM (GRS certified) 2,868
  • *HP : Hybrid Polymerization, GRS: Global Recycled Standard, LM: Low Melting
B03_03_05. Process for Using Recycled Raw Materials

(Fed into process after toll manufacturing of 2025 waste)

  • Classification and Recording
    • Classify generated waste (by polymer, color, etc.)
    • Record daily generation volume by classification
  • Collection and Weighing
    • Collect classified waste
    • Weigh collected waste
    • Move to designated location
  • Toll Manufacturing
    • Move to designated location
    • Move to toll manufacturing partner
  • Receipt and Production Input
    • Receive toll-manufactured products at factory
    • Input into process
B03_03_06. Use of Recycled Raw Materials

(Fed into process after toll manufacturing of 2025 waste)

Category Waste sent for toll manufacturing Toll-manufactured products purchased Toll-manufactured products fed into production Production volume

Remarks
Recycled raw material consumed (tons) 365 359 344 425 Production increased due to additional input required for raw material correction following the input of toll-manufactured products
B04. Recycling

B04_01. Process Recycling Process

  • Classification and Recording
    • Sorting waste by type(e.g., by polymer, color)
    • Daily recording of amounts by classification
  • Collection and Weighing
    • Collecting sorted waste
    • Weighing collected waste
    • Moving to a designated location
  • Recycling
    • Transport to a designated location
    • Disposal by recycling companies

B04_02. Recycling Performance

Category 2022 2023 2024 2025
Waste(Plastic Waste) Recycling Performance(tons) 6,519 6,912 6,449 5,540
B05. Water Resources Management

B05_01. Water Usage Plan and Performance by Facility (2025)

Business Site Industrial Water(tons) Domestic Water(tons) Groundwater(tons) Reuse Amount(tons) Total Usage(tons)
Plant 1 Target 2,200,000 100,000 150,000 550,000 3,000,000
Performance 2,122,500 92,980 137,560 547,910 2.900,950
Plant 2 Target 720,000 48,000 0 125,000 893,000
Performance 698,530 46,590 0 125,190 870,310
Total Target 2,920,000 148,000 150,000 675,000 3,893,000
Performance 2,821,030 139,570 137,560 673,100 3,771,260

B05_02. Water Usage by Source

Year Industrial Water(tons) Domestic Water(tons) Groundwater(tons) Reused Water(tons) Total Water Usage(tons) Reuse Rate Water Usage Increase/Decrease Rate
2025 2,821,030 139,570 137,560 673,100 3,771,260 18% 4%
2024 2,641,029 155,360 108,150 708,090 3,612,629 20% -5%
2023 2,649,140 136,390 56,580 959,190 3,801,300 25% -12%
2022 3,134,970 129,620 90,430 969,430 4,324,450 22% -1%
B06. Pollutants Management

B06_01. Air Pollutant Management Standards

Pollutant Types Emission Allowance Standards(ppm) Self-Management Standards Remarks
Nitrogen Compounds(NOx) Varies by location Within 80% of the emission
allowance standards		 Under total quantity control
Sulfur Compounds(SOx) Varies by location Under total quantity control
Dust(mg/m3) Varies by location Under total quantity control
Brominated Compounds 3
Carbon Monoxide -
Ammonia 30
Zinc 4
Copper 4
Total Hydrocarbons 200

B06_02. Air Pollutant Emissions

Category 2023 2024 2025 2030
Target
(kg)		 Performance
(kg)		 Target
(kg)		 Performance
(kg)		 Target
(kg)		 Performance
(kg)		 Target
(kg)
NOx 159,786 93,978 147,439 114,110 103,447 111,956 78,462
SOx 134,803 145,423 70,601 175,807 199,507 176,433 147,804
Dust(mg/m3) 4,324 4,993 2,856 5,356 3,599 7,054 3,240
Total 298,913 244,394 220,896 295,273 306,553 295,444 229,506
Result Compliance Compliance Compliance
  • ※ 2030 Plan: Application of the total emission allowance allocation plan for the second planning period (2025-2030) (average 30% reduction compared to 2025 performance)
  • ※ Reduction Measures : Investment in new air pollution control facilities and optimization of existing facilities

B06_03. Water Pollutant Management Standards

Pollutant Types Emission Allowance Standards(mg/L) Self-Management Standards(mg/L) Remarks
BOD 200 100 50%
TOC 115 60 52%
SS 200 100 50%
T-N 60 45 75%
T-P 8 5 63%

B06_04. Total amount of water pollutant discharge

Category 2024 Performance(tons) 2025 Performance(tons) 2030 Target(tons)
BOD 8.63 3.74 3.55
TOC 8.96 33.88 32.19
SS 15.1 9.11 8.65
T-N 1.23 1.93 1.82
T-P 18.18 4.14 3.93
Total 52.1 52.8 50.16
  • ※ Target for 2030 : Set a goal to reduce generation by 5% compared to 2025 by decreasing it by 1% annually
  • ※ Reduction Measures : Reduction of pollutants from wastewater discharge facilities and increased efficiency of wastewater treatment plants
B07. Chemical management

B07_01. Chemical Emissions

Category 2023 Performance(kg) 2024 Performance(kg) 2025 Performance(kg) 2030 Target(kg)
Dichloromethane 15,486 10,838 13,443 12,771
Hydrogen Chloride 92.7 91.7 96.4 91.5
m-Phenylenediamine 20 25 1.9 1.8
Antimony and its Compounds 0.3 0.2 0.2 0.2
Total 15,599.0 10,955 13,541 12,864
  • ※ Target for 2030 : Set a goal to reduce generation by 5% compared to 2025 by decreasing it by 1% annually
  • ※ Reduction Measures : Optimization of the mA process and reduction of Dichloromethane emissions through reuse

B07_02. Hazardous Chemical Usage

Product Name Content(%) Substance Name 2023 Performance (tons) 2024 Performance (tons) 2025 Performance (tons) 2030 Target (tons)
DMAc 100 N, N-Dimethylacetamide 240 128 117 111
Hydrogen Chloride 35 Hydrogen Chloride; Hydrochloric Acid 244 126 169 161
Sodium Hydroxide 50 Sodium Hydroxide; Caustic Soda; Lye 288 157 158 150
Sodium Hydroxide 50 Sodium Hydroxide; Caustic Soda; Lye 124 95 98 93
m-Phenylenediamine 100 m-Phenylenediamine 347 301 281 267
Dichloromethane 100 Dichloromethane 32 21 21 20
Total 1,275 828 844 802
  • ※ Target for 2030 : Set a goal to reduce generation by 5% compared to 2025 by decreasing it by 1% annually
  • ※ Reduction Measures : Optimization of the R/O equipment operation in the water treatment room and application of non-hazardous chemical substitutes
B08. Environmental Regulations
Category 2023 2024 2025
Status of Legal Violations None None 2 Cases of fine
Measures for Recurrence Prevention - -

Strengthen facility inspection and improvement of old facilities

Conducting an analysis of all air pollutants (step-by-step)
B09. Eco-friendly Biz/Products

B09_01. Status of Eco-friendly Purchases

Category 2023 2024 2025
Purchase Volume
(tons)		 Purchase Amount
(billion KRW)		 Purchase Volume
(tons)		 Purchase Amount
(billion KRW)		 Purchase Volume
(tons)		 Purchase Amount
(billion KRW)
Eco-friendly Purchases 807 19 1,123 18 2,000 26
Total Purchases 403,663 4,479 375,211 4,138 370,328 3,849
Eco-friendly Proportion 0.20% 0.43% 0.30% 0.43% 0.54% 0.67%

※ Criteria for Eco-friendly Purchases

  • 1. Products not using harmful chemicals in the manufacturing process (Biomass)
  • 2. Products mechanically or chemically recycled through resource circulation (Bottle Flake, GRS Chip)

B09_02. Status of Eco-friendly Product Sales

Classification 2023 2024 2024
Sales Volume (tons) Sales Amount (billion KRW) Sales Volume (tons)) Sales Amount (billion KRW) Sales Volume (tons)) Sales Amount (billion KRW)
Eco-friendly Sales 22,494 574 22,906 578 22,119 572
Total Sales 337,754 7,139 324,427 7,230 315,523 6,897
Eco-friendly Proportion 6.7% 8.0% 7.1% 8.0% 7.0% 8.3%

※ Criteria for Eco-friendly Products

  • 1. Products that do not use or use reduced amounts of harmful chemicals in the manufacturing process compared to existing products (Biomass, antibacterial fibers, recycled fibers, etc.)
  • 2. Products that do not contain or contain reduced amounts of harmful chemicals in the final product compared to existing products (H/Bico for filtration, yarn, mask fibers & nonwovens, biodegradable fibers, etc.)
  • 3. Products with eco-friendly certifications (ECOPET, Animal Protection, etc.)

B09_03. Eco-friendly Certifications

No Certification Name Certifying Agency View Certification
1 ISO 14001 LRQA
Download
2 Environmental Label Certification(EL243) Korea Environmental Industry & Technology Institute
Download
3 OEKO-TEX STANDARD 100 OEKO-TEX
Download
4 EcoVadis EcoVadis
Download
5 GRS SCOPE CERTIFICATE Control Union
Download
6 Certificate of Vegan Korea Agency of Vegan Certification and Services
Download

C. Social

C01. Human Resource

C01_01. Workforce Status

Category Gender 2024 2025
Total Workforce Male 620 621
Female 84 88
Total 704 709
Executives Male 10 8
Female 0 0
Total 10 8
General Management Directors/Deputy Directors Male 95 110
Managers/Deputy Managers Male 81 71
Subtotal 176 181
Directors/Deputy Directors Female 7 9
Managers/Deputy Managers Female 9 12
Subtotal 16 21
Total 192 202
Production Staff Male 375 354
Female 38 37
Total 413 391
Office/Research & Technical Staff Male 4 3
Female 28 25
Total 32 28
Contract Employees Male 55 75
Female 3 5
Total 58 80
  • ※ Excluding CEO, as of December 31

C01_02. Diversity in Workforce Composition

Category 2024 2025
Employment Status of Individuals with Disabilities General Management 1 1
Office Staff 3 8
Production Staff 8 6
Subtotal 12 15
Employment Status of Foreign Nationals 0 0
Total 12 15

C01_03. Ratio and Long-term Goals for Women/Disabled Employees

Category 2025 Ratio 2030 Target
Ratio of Female Managers 3.0% 3.0%
Ratio of Female Employees 12.4% 15.0%
Ratio of Employees with Disabilities 2.1% 3.0%
  • ※ Manager Criteria : Individuals in general management positions

C01_04. Voluntary turnover rate

Category 2024 2025
Number of voluntary turnover 38 18
Voluntary Turnover Rate(as a percentage of year-end staff) 5.4% 2.6%
  • ※ Voluntary turnover persons : Individuals who left the organization based on personal decision, irrespective of organizational intent

C01_05.Labor-Management Council Meetings (2025)

Classification 1Q 2Q 3Q 4Q
Meeting date March 31 June 30 September 30 December 29
Number of agendas 3 3 2 2

C01_06.Employees Participating in Remote Work

Year 2025
Number of Employees 8
  • ※ Based on employees eligible to choose between remote work and office-based work
C02. Human Resource Development

C02_01. Talent Development Strategy
and Education System

Category Group Training Individual Training
Position Level Common Job Functions Degree Programs Self-directed Learning Beyond General Management
Executives Executive Programs New Executive Programs Common Job Function Issue Workshops Marketing Common Job Function Programs Production Common Job Function Programs R&D Common Job Function Programs E
M
B
A		 E-IDP Breakfast & Forums SERI
CEO		 In-house/External Language Courses Reading Management, Legal Education, ESG Evaluation Training
Team Leaders Team Leader Programs New Executive Programs Inter-level/Inter-organization
Workshop		 Promotion Programs IDP & Educational Platform (Videos) SERI
PRO
Directors/Deputy Directors Section Leader Programs M
B
A		 Master’s/Doctorate
Managers
Assistant Managers
Junior Managers New Employee Introduction & Practical Training
Office Staff Office Staff Capability Enhancement
Production Staff Production Staff Capability Enhancement Production Job Functions

C02_02. Talent Development Roadmap

Category Programs Key Content
Self-directed Learning IDP Actively support opportunities for external education to enhance competencies required for job performance.
Book Learning Strengthen individual and organizational capabilities through knowledge and experience gained from reading / Actively support book clubs.
Leadership Training New Executive/Team Leader Programs Foster leadership skills necessary for roles as executives/team leaders, recognizing the role change.
Promotion Training Implement to enhance expertise linked to role awareness due to rank changes.
Level-specific Training Aim to improve common competencies required for respective levels.
Job-specific Training Job Competency Enhancement Establish courses to actively respond to the needs of different job groups/functions.
Language Education Support Provide education tailored to expatriates & overseas business project pool/general staff to enhance global communication skills and support for self-development expenses.
Core Talent Development Degree Sponsorship Program Offer educational opportunities for employees selected through internal competitions to develop job competencies/management leadership at domestic and international schools.
Onboarding New Employee Training Aim to develop an understanding of Huvis’s core values, processes, products, and essential business competencies.
Experienced Employee Training Support early integration by assisting in understanding Huvis and ensuring a soft landing.
Ethical Management Ethics Training Aim to enhance ethical awareness across all employees, including anti-corruption and fair-trade practices.

C02_03.Training Performance Status (2024)

Category Programs Content
Conduct Schedule Time No. of persons Location

Position/

Rank

 Promotee Training ● 4/15~16 12hr 34 Off-site lecture hall
New Employee Mentoring ● 9/9~11 8hr 4 Off-site lecture hall
Sales and Procurement Competency Development Training ●

9/11~12

9/17~18

 12hr 46 Off-site lecture hall
Obligatory Statutory Training
(sexual harassment prevention, disability awareness, safety training)		 ● 6/30~7/11 3hr 253 Online

Company-Mandated Training

(workplace harassment prevention, fair practices and human rights, information security, AEO training)		 ● 12/1~12 4hr 250 Online
C03. Safety and Health Management

C03_01. Industrial Accident Rate and Number of Industrial Accidents

Category Classification 2023 2024 2025
Huvis Number of injuries(persons) 4 2 1
Industrial accident rate(%) 0.65 0.36 0.18
Lost Time Injury Frequency Rate(LTIFR) 2.23 1.22 0.60
Partner Companies Number of injuries(persons) 3 4 3
Industrial accident rate(%) 0.33 0.45 0.32
Lost Time Injury Frequency Rate(LTIFR) 1.15 1.53 1.11
  • ※ From 2019, businesses with over 500 employees are subject to integrated management of industrial accidents for primary contractors and subcontractors.

C03_02. Safety and Health Education System

Category Executives Team Leaders Section Leaders/Managers/Deputy Managers Junior Managers/Assistant Managers S/J Staff
Regular Safety and Health Education Conduct and verify worker education - - - Industrial Safety and Health Education (Minimum 6 hours per quarter)
Supervisor Education Supervisor Education
(Team Leaders to Crew Leaders) (Minimum 16 hours annually)
Training at Recruitment Safety and Health Education at New Hire (Minimum 8 hours)
Training When Job Content Changes Safety and Health Education at Department Transfer or Job Content Change (Minimum 2 hours)
Special Safety Education Special Safety Education for Designated Tasks
(Minimum 16 hours per designated task)

C03_03. Management of Safety and Health Risk Factors

C03_03_01. Response to the Serious Accidents Punishment Act
Items Goals Implementation Methods Performance Indicators
Establishment of Safety and Health Goals and Management Policies Expression of the top management’s commitment to safety and health Setting next year’s goals based on the previous year’s safety and health performance Once per year
Inspection of Safety and Health Implementation Status Check and monitor safety and health obligation fulfillment Comply with and check the implementation of measures required by safety and health laws, and establish improvement plans for deficiencies

Check obligation fulfillment and report results to the CEO

1 time/half-year

Level diagnosis score of 73 or higher
Respond proactively to changes in the Serious Accidents Punishment Act, Occupational Safety and Health Act, etc. Respond proactively to the 2026 Ministry of Employment and Labor's safety and health policy direction and revisions to related laws Developing and executing response plans according to detailed guidelines and amendments to relevant laws for the reduction of serious accidents 0 cases of judicial actions such as fines
Improvement of Regulations, Procedures, and Detailed Work Standards Revise manuals and guidelines to reflect legal realities, and apply them to the field

Reflect legal requirements in manuals and guidelines

Continuously monitor whether regulations and procedures are implemented		 Ten or more cases per year
Environmental Safety Master Plan L/H/C Strengthening the management of risk factors and responding to regulatory changes Planning and tracking the budget for safety and health-related investments Implementation rate of 90% or higher
Continuous Implementation of Detailed Initiatives from the Major Accident Reduction Roadmap Responding to Regulatory Changes and Strengthening Hazard Management Conducting Major Accident Drills, SHE (Safety, Health, and Environment) Level Diagnostics, and SHE Staff Workshops to prevent major accidents Number of implementations of serious accident reduction initiatives
C03_03_02. Transition to Field-centered Safety Management System L/H/C
Item Goal Implementation Method Performance Indicators

Process Hazard Analysis (HAZOP)

Job Safety Analysis (JSA)

Level-up

 Identifying and improving potential risk factors Regular: Conduct risk assessments once a year, implement and track improvements for high-risk factors (1Q)
Ad Hoc Events: Risk assessments conducted more than three times a month, addressing high-risk factors, and tracking management
Identification and incorporation of potential hazards and blind spot risk factors missed in JSA risk assessments
On-site risk assessment guidance: Safety team + supervisors + contractors

Achieving target number of regular and occasional risk assessments

High-risk operations of 13 cases/month or more
Apply corrective actions from unannounced Ministry of Employment and Labor inspections and the SK DY SHE assessment across comparable operations Prevent repeat findings by extending corrective actions to similar equipment, facilities, and working environments Review similar equipment and working environments for the same issues and implement broader corrective measures 100% improvement rate for identified issues
C03_03_03. Improvement of Potential Risk Factors and Work Environment
Item Goal Implementation Method Performance Indicators
Improvement of Potential Risk Factors Improvement of potential risk factors Environmental Safety Master Plan: Investment Performance Tracking, Government Inspections, SHE Level Diagnostics, and Improvements to Safety Devices Implementation performance: 95% or higher
C03_03_04. Safety Management for Partner Companies
Item Goal Implementation Method Performance Indicators
Operation of Partner Company Council Sharing of safety and health regulations, accident cases Hold meetings with in-house and construction partner companies Partner Companies 12 Sessions
Construction Partners 12 Sessions
Enhancement of contractor safety management work standards Strengthened regulations for occupational health and safety compliance, enhanced penalties for non-compliance Establishment and revision of work standards reflecting legal and stakeholder requirements 1 case/year or more
Semi-annual evaluation of subcontractors Select qualified subcontractors for safety and health management Apply the revised evaluation criteria and implement semi-annual evaluations from 2022 1 time/half-year
Implementation of independent, mutually beneficial cooperation Safety observation of thorough construction supervision compliance according to the Huvis hot work safety regulation manual Safety observation of thorough construction supervision compliance according to the Huvis hot work safety regulation manual Semi-annual evaluation; score of 80 or higher
Safety training at the main gate for visitors Train employees of newly entering construction companies on safety regulations, and emphasize compliance matters Require personnel to view safety regulation manual videos at the Plant 1 main gate safety training room, and emphasize compliance with regulations for the day's construction work Daily
Safety innovation school facilities, and safety training instructors Improve the safety and health management awareness level of subcontractors Provide training rooms for internal and construction subcontractors' independent safety training, and support safety team training instructors upon request from internal or construction subcontractors Upon request by subcontractors
C03_03_05. Safety and Health Education
Item Goal Implementation Method Performance Indicators
Legal Safety and Health Education (Regular Safety and Health Education, Supervisor Education, New Hire Training, Training upon Job Content Change, Special Safety Education, Legal Appointee Education, etc.) Cultivating safety awareness Conduct independently based on team/part-specific plans Conducted according to legal education cycles and hours
C03_03_06. Safety Observation and Inspection
Item Goal Implementation Method Performance Indicators
Daily Inspections, Pre-work Safety Inspections Identifying risk factors and improving the work environment Conduct inspections based on the daily check sheet Daily
Joint Labor-Management Safety and Health Inspections Identifying risk factors and improving the work environment Form a joint labor-management inspection team and conduct field inspections, and improve deficiencies found during field inspections 1 time/half-year or more, 100% improvement rate for identified issues
Joint Safety and Health Inspections with Partner Companies Identifying risk factors and improving the work environment Form a joint inspection team consisting of the safety team and subcontractor representatives and conduct inspections, and improve deficiencies found during inspections 1 time/quarter or more, 100% improvement rate for identified issues
Monitoring safety compliance with the hot work safety regulation manual Improve the safety and health management level of construction subcontractors Observe safety compliance based on the Huvis hot work safety regulation manual, and ensure thorough construction management and supervision 4 or fewer identified issues/month
C03_03_07. Safety and Health Activities
Item Goal Implementation Method Performance Indicators
Safety and Health Emphasis Period Operations/Events Promoting voluntary safety and health management Awards for Departments Achieving No Accidents, Outstanding Employees/Partner Companies in Environmental Safety Once per year
Environmental Safety Day Operations at the Factory Implementing and improving factory environmental safety measures and identifying potential risk factors Operate Environmental Safety Day within each team, conducting factory environmental safety observations, etc. Once per month
Joint safety campaigns with employees, management, and subcontractors Promote safety and health, and improve safety awareness Execute joint safety campaigns involving employees, management, and subcontractors 1 time/quarter
C03_03_08. Risk Factor Improvement Activities
Item Goal Implementation Method Performance Indicators
Identifying Near-miss Incidents Identifying and improving potential risk factors Post and share near-miss incidents on the internal bulletin board At least one incident per month per department
C03_03_09. Safety and Health Management
Item Goal Implementation Method Performance Indicators
PSM internal audits Perform internal checks to maintain PSM Form a PSM internal audit team and conduct inspections on relevant departments 30 or fewer identified issues
Extension Audit and Follow-up Audits for KOSHA-MS Adherence to KOSHA-MS certification standards and maintenance of certification Internal Review: Form an audit team and inspect each team
Extension Asudit: Respond to inspections by the Korea Occupational Safety and Health Agency 		Internal audit: 10 or fewer observations; Surveillance audit: certification standard 'compliant', 3 or fewer observations
Integrated industrial accident surveys for prime contractors and subcontractors Manage industrial accidents integratedly for Huvis and subcontractors Verify entry history of external subcontractors, verify the number of industrial accidents, and prepare and submit the prime-subcontractor integrated industrial accident survey sheet Submit within the deadline (by April 30, 2026)
Managing work standards Focus on safety and health tasks to identify and improve hazardous risk factors Conduct safety and health-related tasks from arrival until 13:00 ~14:00 More than ten times per month
Filling out TBM activity logs Share safety and health activity details by posting TBM activity results from Huvis and subcontractors Post and share TBM activity results from Huvis and subcontractors in the Notes safety intensive work category 200 or more cases/month
Regular SLC Meetings Sharing safety and health improvement performance across teams Report safety observation performance and critical safety environment improvement performance by each team Once per month
Emergency Response Training Improving response capabilities in case of an emergency Conduct emergency response drills based on scenarios for fire, explosion, leakage, natural disasters, and asphyxiation Twice per year
Industrial Safety and Health Committee Preventing worker injuries Form a committee with equal representation from labor and management, holding quarterly meetings, making improvements, recording, and announcing minutes Once per quarter
Accident Investigation Committee Establishing cause analysis and preventive measures for accidents Form an accident investigation committee in case of occurrence to analyze causes and establish preventive measures Upon Occurrence Less than 4 issues per year
Process Accident and Equipment Management Zero occurrence of process accidents
Reduction in equipment failures 		Identify causes and eliminate causes in case of process accidents/equipment failures Upon Occurrence Less than 4 issues per year
C03_03_10. Health Management
Category Objective Approach KPI
GHS/MSDS Management (Chemical Substances) Improve MSDS management Secure and maintain MSDS; ensure familiarity with handling procedures; wear protective equipment; and check whether warning signs are properly posted 1 or fewer identified issues per quarter during field inspections
Health Examinations (Follow-up Care for Abnormal Findings) Promote employee health Conduct general and special health examinations 100% examination completion rate
Work Environment Measurement Improve working environment Conduct work environment measurements for night work, noise, and chemical exposure, and improve areas exceeding permissible exposure limits 1 or fewer cases exceeding permissible exposure limits per year
Identifying Musculoskeletal Risk Factors Reduce physically demanding tasks associated with musculoskeletal risks Identify physically demanding tasks and implement musculoskeletal disorder prevention measures 100% implementation rate of corrective measures for high-burden tasks
Chemical Risk Assessment Improve working conditions related to chemical exposure Conduct risk assessments based on work environment measurement results and perform additional assessments of substances not subject to work environment measurement Improve working environments for processes with a risk level exceeding 9
Hearing Conservation Program Improve working conditions related to noise exposure Provide training to employees working in noise-exposed processes and improve the working environment based on work environment measurement and special health examination results 100% implementation rate of improvement plans for areas exceeding 85 dB
Emergency Rescue Training for Confined Space Operations Comply with safe work procedures in confined spaces Implement confined space operation programs At least once every half-year
Managing Protective Equipment Provide and inspect protective equipment Thoroughly manage personal protective equipment issuance ledgers and common protective equipment management ledgers, and check management status during quarterly safety evaluations 2 or fewer identified issues per quarter
Vaccinations Prevent influenza, hepatitis, and other infectious diseases Arrange vaccinations through healthcare institutions Once a year
Conducting AED Operational Checks Ensure that AEDs remain operational and available for use in emergencies Check AED operation and the proper placement of AED signs monthly, and submit inspection results to the Deokjin Health Center Once a month
C03_03_11. Fire, Hazardous Materials, and High-Pressure Gas Safety Management
Item Goal Implementation Method Performance Indicators
Preparation of Fire Safety Plan Establishing and enhancing fire safety management standards and capabilities Prepare and submit the fire safety plan for the Jeonju plant to the fire station Once per year
Self-defense and Joint Fire Drills Improving emergency response capabilities Train fire brigade on roles and procedures, conduct joint drills with the fire station Twice per year
Maintenance and Inspection of Firefighting Equipment (e.g., extinguishers, hydrants) Preserving firefighting facilities Maintenance of firefighting facilities through internal and external inspections 5 or fewer identified issues/quarter
Preparation of Hazardous Materials Prevention Regulations Establishing and enhancing hazardous materials safety management standards and capabilities Prepare hazardous materials prevention regulations for the Jeonju plant (submit to the fire station in case of significant changes requiring permits) In the Event of Changes to Hazardous Material Permits
Safety Inspection of Hazardous Materials and High-Pressure Gas Facilities Ensuring safe operation of hazardous materials and high-pressure gas facilities Conduct internal inspections for the safe operation of hazardous materials and high-pressure gas facilities 4 or fewer identified issues/quarter
C03_03_12. Legal Safety Inspections
Item Goal Implementation Method Performance Indicators
Inspection of Harmful and Dangerous Machinery and Equipment Ensuring safe operation of harmful and dangerous machinery and equipment Conduct inspections before the expiration date (outsourced) Once every two years (legal compliance)
Regular Inspection of Hazardous Materials Facilities Ensuring safe operation of hazardous materials facilities Conduct joint inspections with hazardous materials safety managers Once per year (legal compliance)
Regular Inspection of High-Pressure Gas Facilities Ensuring the safe operation of high-pressure gas facilities Request regular safety inspections from the Korea Gas Safety Corporation Twice per year (legal compliance)
C03_03_13. Training of Safety Management Professionals
Item Goal Implementation Method Performance Indicators
Training of Legally Appointed Specialists in Safety/Fire/Hazardous Materials/High-Pressure Gas Managing legally appointed personnel and securing backup staff Encourage departments requiring legally appointed personnel to obtain certifications or hire new employees with relevant qualifications Obtain certifications for two personnel per year
Training of Internal Auditors for PSM
Training of Internal Auditors for KOSHA		 Developing internal inspection personnel for thorough internal audits Complete professional education at external training institutions Complete training for four personnel per year

C03_04. Proportion of Feedback from Partner Company Workers Processed through Feedback Channels

Year Issue Improvement Completed Improvement Under Review Feedback Processing Rate Performance Indicators
2025 5 4 1 80% 1. Support instructors and safety training facilities upon request for construction subcontractor safety and health training
2. Prioritize improvements to high-risk items based on risk assessment results, regardless of whether they concern Huvis or its subcontractors
3. Provide guidance on inspection methods and standards to ensure that each hoist is inspected individually
2024 15 15 0 100% 1. Improving after establishing a long-term investment plan for Huvis' self-installation of guardrails for work at height
2. Sharing contractor improvement cases when sharing near-miss improvement cases
3. Sharing plant-wide emergency response system for fire and explosion risk processes
4. Training guidance for gas concentration measurers in confined space work
2023 12 11 1 91.7% 1. Establishment and Implementation of Pedestrian Safety Guidelines
2. Distribution of Leaflets on Major Accident Sirens, Case Studies, and Preventive Measures
3. Briefings and Educational Sessions on the Serious Accident Punishment Act for Workplaces with Fewer than 50 Employees
4. Compilation and Sharing of Materials on the Standards and Comparisons Between General and Special Medical Examinations
C04. Environmental Management Training

C04_01. Environmental Management Training Records
(2025)

Course Name Institution Method Frequency Hours Completion Trainees (Persons)
Huvis

Partner

Companies
Training for Hazardous Chemical Technical Personnel and Managers National Institute of Chemical Safety In-person Every two years 16 2025 5 -
Training for Hazardous Chemical Handlers and Responsible Personnel National Institute of Chemical Safety In-person/Online Every two years 16 2025 67 22
Training for Employees Handling Hazardous Chemicals National Institute of Chemical Safety In-person/Online Annually 2 2025 490 489
Specialized Training for Water Quality Environmental Engineers National Institute of Chemical Safety In-person/Online Every three years 28 2025 1 -
Air Quality Management Specialist Course Korea Environmental Engineers Association In-person - 14 2025 1 -
Jeonbuk Province Industrial Complex Emission Facility Outreach Training Jeonbuk State Provincial Government In-person - 4 2025 1 -
Environmental Regulations Training for All Huvis Departments Huvis In-person - 2 2025 33 -
C05. Human Rights Management

C05_01. Human Rights Risk Activities
(2025)

No Major Human
Rights Issues		 Verification and Improvement Measures Effectiveness Assessment*
1 Child Labor and Forced Labor
  • Establishing human rights policies to eradicate modern slavery, including child labor and forced labor, and creating a healthy working environment
 100 points
(0 incidents)
2 Workplace Harassment
  • Notifying and educating on the prohibition and prevention of workplace harassment and operating reporting channels (internal portal/website (Ethical Management - Report))
 100 points
(0 incidents, 2025 100 points)
3 Sexual Harassment Prevention
  • Conducting annually sexual harassment prevention and disability awareness education for all employees
  • Operating reporting channels (internal portal/website (Ethical Management - Report))
 100 points
(0 incidents)
4 Severe Accidents and Industrial Safety and Health
  • Establishing and operating a dedicated safety and health organization
  • Developing and implementing the Environmental Safety Master Plan (2022-2026)
  • Conducting monthly inspections of safety and health performance by the CEO
  • Establishing and managing annual safety and health plans for each team focused on nine core tasks, including risk assessment, to ensure field-centered safety and health management
  • Utilizing the Safety Contact system for TBM (Tool Box Meeting) activities to strengthen the execution of risk assessments
 100 points
(0 incidents)
  • * Effectiveness Assessment - 0 incidents : 100 points, 1-2 incidents : 50 points, 3 or more incidents : 0 points

C05_02. Status of Human Rights Issue Reports Handling
(2025)

Number of Received Reports Number of Handled Reports Handling Rate(%)
0 0 -
C06. Fair Trade

C06_01. Unfair Trade Risk Management Activities
(2025)

No Major Issues Verification and Improvement Measures Effectiveness Assessment*
1 Raising awareness among members in relation to unfair-trade policies
  • Conducting fair trade education (ethics education)
 100 points
(0 incidents)
2 Activities to prevent unfair trade practices Activities to prevent
  • Establishing a monitoring mechanism for unfair trade
    - Operating an anonymous reporting channel (internal portal/website (Ethical Management | Report))
  • Conducting preventive activities by obtaining consent to the code of conduct and collecting opinions from partners
  • * Effectiveness Assessment - 0 incidents : 100 points, 1-2 incidents : 50 points, 3 or more incidents : 0 points
C07. Community

C07_01. Community Risk Management Activities
(2025)

No Major Issues Content Verification and Improvement Measures Effectiveness Assessment*
1 Environmental pollution issues around the factory Minimizing the negative impact of waste, pollutants, and air emissions generated during the production process on the local environment
  • Establishing and operating an environmental management system
  • Conducting monthly environmental safety day events at the Jeonju plant
  • Implementing activities related to waste disposal, air and water quality management, and energy efficiency
 100 points
(0 incidents)
2 Safety issues around the factory Minimizing the negative impact on residents caused by negligence, accidents, or disasters related to safety issues
  • Conducting safety and health cooperation with partner companies (council meetings, education support, performance evaluations, etc.)
  • Conducting regular safety interviews with individual employees by managers
  • Preventing safety accidents through the identification and improvement of near-miss cases
 100 points
(0 incidents)
3 Potential disruptions from factory operations affecting residents Preventing negative impacts on the quality of life of residents due to noise, odors, and traffic from factory operations through continuous feedback from the community
  • Promoting active communication and cooperation with the local community by attending the Residents’ Autonomy Committee (Palbok-dong)
 100 points
(0 incidents)
  • * Effectiveness Assessment - 0 incidents : 100 points, 1-2 incidents : 50 points, 3 or more incidents : 0 points
C08. Corporate Social Responsibility

C08_01. Corporate Social Responsibility Activities
(2025)

Category Support Activities Beneficiaries Support Details Implementation Periods
Scholarship Support Book/Material Support
  • Four elementary schools in the North Jeolla region
  • Support for books/materials and environmental improvements
    (40 million won)
 May
Scholarship Funding
  • Underprivileged/model/probation targets in Jeonju City
  • Jeonju District Prosecutors' Office Legal Love Association
    (10 million won)
 November
Living Support Meal Support for Children without Access to Food
  • Low-income families at three elementary schools near the Jeonju plant
  • Meal support during summer and winter breaks
    (40 million won)
 July, December
Book and Meal Support for Low-Income Families
  • Selected low-income and marginalized groups in Jeonju City
  • Wisdom's Side Dishes (books), Mother's Table (meals) (donations from Jeonju City Hall)
    (20 million won)
 April, November
Coal Donation/Delivery
  • Impoverished, low-income, and elderly living alone (Seoul, Jeonju, Daejeon)
  • Coal purchase and delivery volunteer activities
    (10 million won)
 November
Fire Safety Fund
  • Vulnerable groups affected by residential fires in the North Jeolla region
  • Fire damage home repair/living expenses support (organized by Jeolla North Province Fire Headquarters)
    (5 million won)
 July
Housing Environment Improvement
  • Vulnerable residents in Paldok-dong near the Jeonju plant
  • Support for the replacement of old wallpaper and flooring (donations from Paldok-dong Community Center)
    (5 million won)
 April
Product Donation Uniform Support
  • One elementary or middle school soccer team in the North Jeolla region
  • Uniform donations linked with company products (summer and winter)
    (8 million won)
 Jun
Bedding Support

  • 10 households each from 8 elementary schools in the Jeollabuk-do region

  • 20 low-income households in the Jeollabuk-do

  • Corporate volunteer group (Suseomyeonghwa Social Welfare Center)
  • Bedding sets utilizing our products
    (14 million won)
 January, February, September
Eco-friendly Social Contribution Activities Love for Nature Blue Heart Art Festival
  • Nationwide kindergarteners and elementary students
  • Environmental Art Festival co-hosted by Huvis, Samyang Corporation, Samyang Kasei, and Sudang Foundation
  • Held annually since 1996 at the Huvis Jeonju plant
  • Events to educate children about environmental protection, including eco-friendly drawing competitions and experiential activities
 May

D. Governance

D01. Board of Directors

D01_01. Composition of the Board of Directors

Category Kim Sukhyun Lee Donghyun Kim Sungjin
Position Inside Director, Representative Director Other Non-Executive Director Other Non-Executive Director
Length of Service 2024.03.26. ~ present 2026.03.24. ~ present 2026.03.24. ~ present
Term of office 3years 3years 3years
Expertise Corporate management Strategy, Planning Accounting, Finance
Career
  • BA in Economics, Chonnam National University / MBA, Korea University
  • CEO, Huvis (present)
  • Head of Human Resources Development(VP) / Strategy Team Leader, Marketing Planning Team Leader at Huvis
  • (Current) Head of Future Strategy Office at Samyang Holdings
  • Former Head of New Business Promotion Division at Hanwha
  • (Current) Head of Financial Planning at SK Discovery
  • Former Team Leader of Financial Team 1 at SK
Category Kim Taehong Oak Dongsuk Park Sungchul
Position Independent Director, Chairman of the Board Independent Director, Chairman of The Audit Committee, Chairman of Committee on Nomination of Outside Directors Independent Director
Length of Service 2025.03.25. ~ present 2023.03.29. ~ present 2026.03.24. ~ present
Term of office 3years 6years(re-elected) 3years
Expertise Finance and Banking Finance, Trade (University Professor) Textile industry and Business
Career
  • Former CFO & Head of Management Strategy Division (MD) at Hana Card
    Former Head of Card Financial Support Division and Card Operations Center at KEB
  • (Current) Chairperson of Open Society Forum, Professor Emeritus, Dept. of Trade at Incheon National University
  • Professor, Dept. of Trade, Incheon National University, Former President of KIPF and NHI
  • Former CEO and Advisor at Samyang Innochem, Former Head of Industrial Materials BU (VP) at Samyang Corp

D01_02. Expertise of Outside Directors

Classification Kim Sukhyun Lee Donghyun Kim Sungjin Kim Taehong Oak Dongsuk Park Sungchul
Business operation and risk management ● ● ● ●   ●
Finance / banking / accounting ●   ● ● ●  
Core industry and business ● ●   ●
Law/Policy   ●  
Strategy / planning ●  
Category Responsible Person Appointment Background The Audit Committee Committee on Internal Trade Committee on Nomination of Outside Directors
Inside Directo Kim Sukhyun
(Representative Director)
  • Joined Sunkyung Fiber Co., Ltd. in 1994, possessing a deep understanding of the company and its chemical fiber industry through over 30 years of service
  • Expected to contribute to enhancing corporate competitiveness with extensive insight, experience, and perspective on the company and its core industry
  • Regarded as an ideal leader capable of creating synergy through the unity of internal members
 - - -

Non-executive

director		 Lee Dong-hyun
  • Expected to play a substantive role in the company’s growth and development by bringing strategic and systematic
- - -
Kim Sung-jin
  • Expected to contribute to rational management, transparent operations, and enhanced financial soundness by leveraging extensive experience and knowledge in finance and accounting
 - - -
Outside Director

Kim Tae-hong

(Chairperson of the board)
  • Expected to provide direction and advice for competitive corporate management based on experience across various management functions, including finance, audit, and marketing
  • Meets the requirements for an accounting and finance expert under the Commercial Act (financial institution career type)
  • Expected to contribute to enhanced corporate transparency from an objective standpoint as an independent party with no conflicts of interest involving major shareholders or the company
 ● ● Chairman
Ok Dong-suk
  • Appointed based on a comprehensive assessment of independence, responsibility (including Board participation rate), ethical awareness, and contribution, as demonstrated through prior service as an outside director and Audit Committee member
  • Expected to contribute significantly to decision-making based on extensive knowledge of finance, accounting, trade, and economics
  • Capable of independently performing checks, monitoring, and supervisory functions in relation to major shareholders and other directors, based on professionalism and independence and without any material conflicts of interest arising from transactions with the company or concurrent positions
 Chairman Chairman ●
Park Sung-chul
  • Capable of providing valuable insights into the company’s business management based on a strong understanding of the materials industry and management experience
  • Capable of providing professional opinions in the company’s decision-making process based on practical experience and professional knowledge gained throughout the candidate’s career
  • Capable of independently performing checks, monitoring, and supervisory functions in relation to major shareholders and other directors, based on professionalism and independence and without any material conflicts of interest arising from transactions with the company or concurrent positions
 ● ● ●
D02. Comparison with best practices
Category Adoption Status Remarks
Adoption of Corporate Governance Charter ○
Download
Establishment of Code of Ethics for Employees ○ -
Cumulative Voting System × -
Electronic Voting System ○ -
Written Voting System × -
Solicitation of Proxy Voting ○ -
Separation of CEO and Board Chair ○ Outside director as board chairman
Directors’ Liability Insurance ○ -
Audit Committee Composition Requirements (Ratio of Outside Directors) ○ -
Establishment of Regulations for the Operation of the Board of Directors and Board Committees ○ -
Disclosure of Activities of the Board of Directors and Board Committees ○ -
Explanation of Differences from Best Practices ○ -