expand the participation of outside directors in major IR events to listen to what shareholders expect from Naver and actively reflect them on the board of directors to review various measures to make innovative and shareholder-friendly operations. In order to increase the predictability and transparency of shareholder return, they established and announced shareholder return policy in 2019. Naver pays cash dividends and implements stock repurchases every year. They also set the shareholder return at 30% of the average of the consolidated free cash flows for the previous two years to stabilize returns by reducing fluctuations. The board of Naver consists of 6 male and 1 female. By having separated roles of the CEO and Board Chairman, they ensured the independence of the board and transparency. It has five board sub-committees (Audit Committee, Compensation Committee, Outside Director Nominating Committee, Risk Management Committee, and ESG Committee). The board is operated by directors who have extensive professional knowledge and experience in their fields. For ESG investors, data privacy risk has become a crucial metric in assessing the companies in which they invest. Naver has once had a personal information leakage incident in the process of providing receipts needed for year-end tax adjustment. After the incident, to make improvements they established a system preventing infringement during the data transmission process. And as the nation's largest search portal, it strictly applies privacy principles for its users. They created their own control services named Private Impact Assessment (PIA) and the Privacy Information Management System (nPIMS). Those systems manage risks, so that personal information protection can be fully established. Naver also operates a training system for their employees to enhance their awareness of personal information protection. They transparently discloses processing of user’s personal information at all times and collects minimum personal information in accordance with the purpose and responsibly manages personal information. Naver guarantees user’s freedom of expression and intellectual property rights by applying the policy regulations. For the company's ethical management, leaders in positions with considerable roles and responsibilities undergo separate ethical management training in the form of workshops every year. They also offered training to newly hired employees. In March, there was an online training designed to inform all employees of integrity related to corporate ethics, anti corruption,and human rights, and its significance. NAVER has established a system designed to prevent fraud risks in advance and detect them afterwards. As a part of these efforts, they are operating a “Self-Check System” that allows the employees themselves to build a culture of cautiousness to prevent serious fraud. The system, which is based on constant monitoring, frequently monitors unusual cases in the system across individuals, management support, business, and technology, and if any abnormal data is detected, a mail is sent to the relevant employee, who is then given an opportunity to provide an explanation. Further actions are taken as and when necessary. They are enhancing the effectiveness of monitoring by improving the monitoring scenarios, while expanding the scope of application, in a drive to boost our systematic countermeasures to corruption risks. NAVER continuously conducts surveys of all its partners to check that their transaction process with NAVER (selection of companies, terms
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