Building fences to create sustainable joy: Bong-kyu Suh, Chief Legal Officer

Last April, NC newly established the position of Chief Legal Officer (CLO) and appointed Bong-kyu Suh as the CLO. Based on importance of sustainable management, the society’s demand for enhanced corporate responsibility is constantly increasing. NC also understands such importance and is preparing itself to take steps forward. In this interview we meet NC’s CLO Bong-kyu Suh who talks about how NC prepares itself to become an ‘ethical company’ and what the future of NC would be like.Bong-kyu Suh Chief Legal Officer (CLO) of NCSOFT Having a bird’s eye view You served more than 20 years as a prosecutor, and NC was the first destination after you entered the private sector. What prompted you to enter the world of corporate legal affairs?When I worked as a prosecutor, I had many opportunities to carry out roles involving communications with companies. I used to carry out projects in commercial areas when working in the Ministry of Justice including revision of the Company Law and came across many related cases when working as the Chief Prosecutor responsible for fair trades in the Seoul Central District Prosecutor's Office. Also, I believe that my experiences in establishment of the Electronic Bill System and consultation with economy-related Ministries including the Fair Trade Commission helped me understand the importance of corporate law and contributed in making this decision. What made you decide to join NC among many other companies?I found NC’s corporate mission to create a world connected with joy very impressive. I had a dream to work in the forward-looking businesses, and I thought that NC’s business areas and visions were in line with the values that I pursued. How different is the role of a prosecutor and a corporate legal department?Prosecutors would look into each case in much details as if they are using a ‘microscope’ to see if there is any legal violation. This requires constant decision-making. Meanwhile, in NC, I tend to focus more on the company’s overall systems and work processes with a bird’s eye view, instead of looking closely into certain cases. Therefore, it is closer to using a ‘telescope’ to view the world, instead of a ‘microscope’. Also, prosecutors exercise the state’s right for punishment through revealing the details of crimes committed in the ‘past’. However, what I do in NC focuses more on improving processes to confirm potential risks and to prevent their recurrence than on handling incidents that took place in the past. Therefore, it is more ‘future-oriented’. I believe that is the most important difference between the roles of a prosecutor and a corporate legal department. The details of the duties that you carry out may be different, but the foundation of both duties lies in ‘laws’. What will be your philosophy and principles as a legal professional?Sometimes I would get lost between different solutions and decisions when faced with difficulties while carrying out duties. In such cases, I strive to be faithful to the principle of fairness and neutrality and go back to basics to think about the important values that I must protect. However, it is difficult to solve all problems simply through sticking to rules and principles. It will be nice if all problems could be solved by rules, but there are many cases where there is a large gap between ideals and realities that such rules try to materialize. From the time when I worked as a prosecutor and until now when I work as the CLO, my duties are mostly related to rules and regulations. However, I try not to view everything and make judgments based on them. When an incident or an act occurs, I believe that it is necessary for me to analyze the surrounding environment to understand why it happened and to develop deeper understanding of the human being that conducted such an act. I try to maintain an embracing attitude and the ability for empathize. Slow but steady; taking steps to materialize corporate ethics Ethical management is one of the rising topics among corporations. Why do you think its importance has increased?Even though the academia has yet to reach a consensus on the concept of ethical management, I believe that ethical management is the management activities to set the standards for ethical decision-making and to encourage their implementation and the activities to prioritize establishment of business processes to implement the standards. Even though companies use different terms including compliant management, righteous management, human-oriented management, and ethical management, and goals, I believe that they all focus on improving their business sustainability through enhancing customers’ trust and assuming social responsibilities. The importance of corporate ethics is growing even further, since regulations to prevent corruption, unfair trade, human rights infringement, etc. are being enhanced. Moreover, from the perspective of ESG management, consumers are expecting companies to improve environment (E), to be socially responsible (S), and to contribute to the community through ensuring soundness in their governance (G) structure. When a company places the utmost priority on ethical values under this environment, it may receive trust and support from consumers and investors. I believe this is why ethical management has become more important. What areas does NC focusing on?Last year, NC newly established the compliance organization to enhance compliance support. As part of such efforts, NC revised the Code of Conduct of its executives and employees last year and revised the regulation to manage internal regulations this year to support establishment and revision of internal regulations of related teams inside the company. In addition, we are establishing a company-wide compliance support system. There are diverse legal issues to be reviewed before launching a game, including the game’s terms and conditions, patent and trade mark issues, and foreign laws and regulations as the number of global launchings increases. Our organization is establishing a system to provide support to the aforementioned issues in a progressive manner. Also, we are giving serious thoughts into diverse issues, including common business practices of each team requiring compliance review and elements to be newly introduced to enhance compliance, with the aim to establish a company-wide risk management system. What are the major tasks of the compliance organization in addition to compliance support?Ethics training held for all employees is also one of the most important duties required to enhance ethical management. NC provides a training on the Code of Conduct to new employees immediately after they get onboard. In addition to the ones that are legally required, NC voluntarily carries out the ethics training once a year to enhance the level of understanding of the executives and employees about internal regulations and to continuously enhance ethical management. Under various situations that they may be faced with at work, employees often wonder how they could make more ethical decisions. Ethics and compliance division of NC plans to provide an ethics training based on actual cases, instead of the one lacking substances, to help employees get practical help in making ethical judgments. This year, we will carry out a company-wide ethics training from June 20 through producing a video focusing on the issues like office bullying, prohibition on the use of undisclosed important information, and prohibition of assumption of concurrent roles and competition without the company’s permission. Part of NC's 2022 Ethics training for all employees It does not seem so easy to establish a company-wide system and to improve the level of the member’s perceptions.We all understand why ethical management is important and is necessary; however, I believe it is nearly impossible to achieve the task of ethical management over the short term inside a gigantic organization like NC. Therefore, I believe that it is important to have the will to take slow but steady steps with the proper ethics and the will for action in mind, instead of being obsessed with delivering short-term results. Building an organization that people wish to work with What do you think is the keyword that NC should bear in mind while trying to achieve ethical management in its own way?I believe there will be different stages and tasks while we transform ourselves into a more ethical business, and I think the most important keywords at this stage would be ‘courage’ and ‘caring for others’. To enhance ethical management, the culture where all the members of the organization would understand its importance and make concerted efforts towards the same end should be established. ‘Courage’ is the will where we would not accept the opinions from our seniors or the existing culture and practice without any critical judgment and we would speak our minds if we disagree. I believe that such courage is required in order to create a healthy organizational culture. ‘Caring for others’ indicates one’s ability to put oneself in other’s shoes. Managers should be able to think from their subordinates’ point of view, and subordinates should be able to put themselves in their manager’s shoes. If such ‘caring’ culture could take root in NC, I believe that the conflicts and unethical issues at work would reduce much.How do you visualize the future of NC?As our company expands in size and its influence grows, NC will be expected to apply even higher ethical standards. I will strive to make sure that NC will be recognized as a company that is fully compliant with laws and rules, meets such expectation from the society, acts responsibly, and is transparent, being fair and free from corruption. Through such efforts, I hope that ultimately NC would become a company that people wish to join and that our industrial partners at home and abroad would consider as a leading game company and the most desirable partner. What would be the role of the CLO in such a process?To put it humorously, I believe the role of the CLO could be seen as a ‘scolder’. As an officer responsible for ethical management, I will establish the ethical management system and will continuously review and improve internal business processes. Personally, I hope that our executives and employees would understand these as a process to ensure fairness and to manage business risks, instead of an undue interference with their work. Lastly, what would be the goal that you wish to achieve in NC?NC is a company that dreams of joy. Through carrying out my supporting role, I would like to make multi-faceted contribution to NC so that it could be a company that gives joy to an even larger number of people. Also, I think that NC is a relatively younger company in Korea. The business areas are future-oriented, and the members of the organization are also relatively younger. Based on young and flexible way of thinking of NC, I would like to contribute to NC’s efforts to create its own mature organizational culture. * The above presents the personal opinions of the interviewee and not the official opinions of NCSOFT.