A four-question ethics check for finance, HR and legal staff in Korea

This guide is for people in accounting, HR, legal and business support roles in Korea, and for foreign managers who work with them. These jobs often meet requests that look lawful on paper but are questionable in intent. It offers four self-check questions, shows where Korean law draws hard lines, and explains how to act when a request feels wrong.

The moment of doubt

Picture a quarter-end close. A senior manager asks you to "adjust this quarter's numbers a little", presented as a reasonable change of accounting method. The real purpose is to make results look better. Refusing feels risky for your position; agreeing does not sit well with your conscience.

Similar moments come up in daily work: unclear spending in a budget, fairness in performance reviews, conflicts of interest with suppliers, improper instructions from a boss. "It is not illegal" or "my boss told me to" is not a sufficient test. Ethical decisions ask for a higher standard than legal compliance alone.

What the rules actually require

Expectations on companies have risen, but some claims about new rules are overstated. As of 2026:

• Work rules (취업규칙): employers with 10 or more regular employees must file work rules covering the items in Article 93 of the Labor Standards Act (근로기준법), including rewards and sanctions and the prevention of workplace harassment. Ethics management is not one of the required items.
• Compliance officers: listed companies with total assets of ₩500 billion or more must adopt compliance control standards (준법통제기준) and appoint at least one compliance officer (준법지원인), unless another law already requires similar internal controls (Commercial Act, Article 542-13).
• External audit: all listed companies, and other stock companies above set thresholds, must have their financial statements audited by an outside auditor. Based on the previous year, the thresholds are total assets or sales of ₩50 billion or more, or at least two of: assets of ₩12 billion, liabilities of ₩7 billion, sales of ₩10 billion and 100 employees, each or more.
• EU supply chain rules: the EU Corporate Sustainability Due Diligence Directive was amended on February 24, 2026 (Directive (EU) 2026/470). It now covers companies with more than 5,000 employees and more than EUR 1.5 billion of worldwide turnover, and non-EU companies with more than EUR 1.5 billion of turnover in the EU. It applies from July 26, 2029. Companies in scope may ask business partners for information, but for partners with fewer than 5,000 employees only when it cannot reasonably be obtained otherwise.

Beyond formal rules, staff in accounting, HR and legal roles take part in key decisions, so they are expected to judge carefully.

Four self-check questions

1. Would it pass an audit? Most companies have internal audits, and listed companies are audited externally. If an auditor examined your work in detail, could you explain it with confidence? Checking the procedure, approvals and supporting documents also tests the ethics.
2. Could you show it to your colleagues? Think about people doing similar work in your team or other teams. If they would see the handling as unfair or embarrassing, something is wrong.
3. Could you teach it to your successor? If you moved on tomorrow, would you hand this method over and say "this is how we do it here"? If not, it is not the right way.
4. Does it fit the company's core values or code of ethics? Most companies have them. Even if you rarely read them, check important decisions against them.

Common dilemmas by function

• Accounting: the timing of expense or revenue recognition at quarter-end or year-end, when you are asked to "adjust within the rules" for an unclear purpose. Know the hard line: under Article 39 of the External Audit Act (주식회사 등의 외부감사에 관한 법률), people in charge of accounting who falsely prepare or disclose financial statements in breach of accounting standards face up to 10 years in prison or a fine of 2~5 times the gain made or loss avoided.
• HR: fairness in hiring, promotion and evaluation, such as a senior manager's interest in one candidate or pressure to change review results. Keep to objective criteria and procedures.
• Legal and compliance: deals or practices that are lawful but ethically doubtful. Look beyond the text of the law to the company's reputation and social responsibility.
• Business support and purchasing: transparency in budgets and purchasing, especially where a supplier relationship or a personal interest is involved. Make sure both the procedure and the substance hold up.

Putting it into practice

1. Take time. Under pressure, say "I will review it and come back to you." Snap decisions in a dilemma are more often wrong.
2. Talk to trusted colleagues or seniors. Another view widens your perspective, and people who have done similar work for years are especially helpful.
3. Check the rules. Codes of ethics, internal control rules and manuals often already cover similar cases, as do industry practice and the law.
4. Keep a record of why you decided, which standard you applied and whom you consulted. It helps you explain later and makes you more careful now.

What the organization should do

Individual judgement has limits without support from the organization:

• Set clear ethics standards and procedures, with practical guidance and case-based manuals for common dilemmas.
• Provide channels for advice and internal reporting, with real anonymity and protection from retaliation.
• Lead from the top. Ethics must start with senior management and be visible in how decisions are made and explained.

Korean law protects reporters of certain violations. Under the Public Interest Whistleblower Protection Act (공익신고자 보호법), no one may retaliate against a person who reports a violation of the laws listed in its annex, which include the External Audit Act. A reporter who suffers retaliation can apply to the Anti-Corruption and Civil Rights Commission (국민권익위원회) for protection within 1 year. Dismissing a whistleblower for reporting can be punished by up to 3 years in prison or a fine of up to ₩30 million.

Why it pays off

An ethical choice can look like a loss in the short term. Over time, people who decide ethically earn trust and are given more important roles, and being able to stand behind your choices is worth a lot. Companies that practice ethics earn the trust of customers and society, which supports sustainable growth, and environmental, social and governance (ESG) expectations make this harder to ignore.

Before acting on a doubtful request, run the four checks on audit, colleagues, successor and values. Small decisions add up to your career and your company's culture.