Ethics & Compliance
Governance
Strategy
Risk Management
Metrics and Targets
Decision-Making and Implementation Framework
Board Level
Studio Dragon establishes and operates the Compliance Management Committee as its dedicated compliance support body in accordance with compliance control standards. As of 2025, the committee comprises the CEO as chair, one Compliance Officer, and four department head-level members representing each business division, and oversees the operational performance of its anti-corruption, ethics management, and fair trade compliance programs. The Compliance Officer reports key ethics & compliance management performance—including compliance risk identification findings and the operational performance of compliance coordinators—to the Compliance Management Committee at least once a year. In addition, the Committee places on its agenda matters requiring the CEO's decision on ethics and compliance issues, as well as major disputes with significant business impact, deriving effective courses of action through in-depth deliberation. To enable the Committee to regularly report its major discussion agenda and the results of compliance control standard reviews to the Board of Directors and the CEO, Studio Dragon has incorporated the related procedures into its compliance control standards, thereby strengthening operational accountability.
Studio Dragon Ethics & Compliance Management Governance
* As of March 2025
Management Level
Studio Dragon's Corporate Audit Team operates as a direct reporting unit to the CEO, maintaining independence while overseeing ethics & compliance management across the organization. The Legal Affairs & Compliance Team operates a Compliance Coordinator program that supports compliance control functions within each operational department, thereby improving compliance-related work processes and strengthening monitoring. The IP Commerce Team operates a review coordination body for production support, sponsorship, and advertising clearance, establishing internal consensus on review compliance and conducting company-wide training to enhance compliance awareness while managing media, content review, and regulatory risks. The Finance Team performs accounting, tax, and fund management functions, operating internal controls to ensure the accuracy and reliability of financial information. The team also checks compliance with applicable laws and internal regulations during fund execution and accounting processes, and contributes to creating a transparent business environment through external audit coordination and financial disclosure support.
Studio Dragon Ethics & Compliance Management Organization Chart
Ethics & Compliance Management Risks and Opportunities
Studio Dragon proactively identifies and manages ethics and compliance risks that may arise across content production and business operations. The company recognizes potential violations of fair trade, subcontracting and outsourcing management, copyright and the right of publicity, occupational safety regulations, and personal data protection as key risks with particular focus on managing ethical risks—such as conflicts of interest and improper cost execution—that may arise at content production sites. Through these efforts, Studio Dragon is enhancing transparency in the production process, reinforcing stakeholder trust, and continuously expanding its capacity to deliver responsible content production aligned with global standards.
Assessment of Ethics & Compliance Management Risks and Opportunities
Category | Risks and Opportunities | Potential Financial Impact | Significance | Expected Timeline |
|---|---|---|---|---|
Regulatory Risk | Incurring corruption and compliance violations | Incurring direct costs from litigation, fines, and penalties; potential restrictions on business operations | High | Short, medium, and long term |
Reputational Risk | Eroding stakeholder trust due to ethics violations | Diminishing brand value, losing investment and partnership opportunities, decreasing revenue | High | Short, medium, and long term |
Strategic Risk | Operating with an inadequate ethics & compliance management framework | Increasing risk occurrence due to weakened internal controls; long-term competitive disadvantage | Medium | Short and medium term |
Operational Opportunity | Establishing an ethics & compliance framework and strengthening of internal controls | Proactively preventing risks and reducing legal costs; securing stable operational foundation | High | Short and medium term |
Strategic Opportunity | Strengthening transparent decision-making and responsible management | Attracting investment and expanding global partnerships to enhance long-term corporate value | Medium | Medium to long term |
Compliance Management Strategy
Compliance Management Action Plan
To effectively manage compliance risks, in 2026, Studio Dragon plans to strengthen compliance capabilities through an employee-led approach and embed fundamental compliance practices across the organization. To this end, the company will strengthen its process for preventing conflicts of interest with business partners and continuously monitor the use of pre-existing music within its series to proactively control risks that may arise at production sites. Additionally, through CP (chief producer)–led briefing sessions for each production and training based on scripted series dispute case studies, Studio Dragon aims to strengthen employees' practical compliance capabilities. Compliance coordinator activities will be operated in a manner that strengthens employees’ autonomy and initiative. The company will also refine its internal regulations and departmental guidelines and improve the operation of the Compliance Management Committee to support management's responsible decision-making, thereby establishing an effective compliance management system.
Ethics & Compliance Management Principles
Ethics & Compliance Management Regulations
Studio Dragon has established its internal regulations aligned with CJ Group's principles of legal compliance, ethics management, and fair trade. Together with its employees and business partners, the company upholds applicable laws and practices fair trade that promotes mutual growth with business partners, within the bounds of societal ethics. In addition, Studio Dragon complies with the CJ Global Supply Chain Ethics Policy, the Code of Ethical Conduct, the Business Partner Code of Conduct, and Business Partner Transaction Management Regulations. Through these commitments, the company works to maintain fair and transparent dealings with its business partners.
Studio Dragon Ethics & Compliance Management Regulations
→ Studio Dragon Guidelines for Compliance with Improper | |
Studio Dragon Partner Transaction Management Regulations |
Content Production Ethics & Compliance Guidelines
Studio Dragon has established the Content Production Guidelines and Generative AI Usage Guidelines, and revised the Music Copyright Clearance Guidelines to systematize ethics and compliance standards across content production. The Content Production Guidelines specify production ethics standards and processes that all employees must follow throughout the series production process, with the aim of firmly establishing a culture of responsible and transparent production. The Generative AI Usage Guidelines were developed to address the expanding use of generative AI in production and include stage-specific usage criteria, terms and license verification standards, and practical checklists. These guidelines enhance production efficiency while systematically managing legal and ethical risks. The Music Copyright Clearance Guidelines were revised to proactively prevent music copyright risks that may arise during series production, with a particular focus on clarifying the scope of approvals for using pre-existing music to minimize the potential for copyright infringement and disputes. Through these initiatives, Studio Dragon aims to advance ethics and compliance standards across the entire content production process and continue strengthening a culture of responsible production.
Content Production Guidelines | Generative AI Usage Guidelines | Music Copyright Clearance Guidelines |
|---|---|---|
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Photo Credit: Studio Dragon
Fostering an Ethics & Compliance Culture
Ethics & Compliance Training
Studio Dragon strengthens ethics & compliance management through regular training on fraud prevention and production guidelines for all employees, including contract workers and partners. In 2025, the company conducted 13 training sessions. In particular, Studio Dragon conducted case-based training to prevent disputes during series production. The company also provided training on generative AI and copyright issues, as well as copyright clearance guidelines for the use of pre-existing compositions in scripted series. Additionally, all employees completed CJ Group's first-half online compliance training and submitted ethics management pledges to cultivate the fundamental ethical values expected of CJ Group members and to enable employees to put them into practice.
To enhance training effectiveness, Studio Dragon conducts in-person training for departments with identified training needs and operates online training, adopting customized approaches tailored to different audiences. Going forward, the company plans to continuously expand training topics and strengthen ethics & compliance management through effective, field-oriented training.
2025 Ethics & Compliance Training Performance
Training Topic | Date | Target Audience | |
|---|---|---|---|
Fundamentals and Compliance Principles Training | (Q1) Fraud Prevention Tool Guidance | Apr. 2025 | All employees |
(Q2) Management Assessment Results and Department Head Responsibilities | Jul. 2025 | Leaders and production workforce | |
(Q3) Fraud Prevention Q&A and Conflict of Interest Prevention Guidance | Oct. 2025 | Production workforce | |
Online | Nov. 2025 | All employees | |
Training and discussion session for scripted series in-house production department | Jan. 2025 | Production chief producer | |
Scripted Series Music Copyright Clearance Guidelines Training | Apr. 2025 | All employees | |
Scripted Series Dispute Case Study Training | Jun. 2025 | ||
Content IP Legal Issues | Oct. 2025 | ||
Generative AI and Copyright Issues | Sep. 2025 | Coordinator | |
Media Industry and Compliance Risk | Aug. 2025 | Independent director | |
Generative AI and Copyright Issues | Mar. 2025 | Management | |
CJ Group First Half Online Compliance Training | Mar. 2025 | All employees | |
CJ Group Second Half Online Compliance Training | Oct. 2025 | ||
Ethics & Compliance Risk Management
Compliance Risk Management Framework
Studio Dragon systematically manages legal and ethical risks that may arise throughout the production process by identifying and assessing departmental risks in advance through a Compliance Portal System. Each year, Studio Dragon reviews all applicable laws and internal regulations related to content production to identify emerging risks. In 2025, Studio Dragon conducted departmental reviews focused on potential violations of fair trade and media-related laws, as well as breaches of ethics standards such as the CJ Code of Business Conduct.
Identified risks are evaluated on a five-point scale based on likelihood and impact, then classified into L (Low), M (Medium), and H (High) categories for management purposes. In 2025, Studio Dragon identified a total of 88 risks (27 Low, 38 Medium, 23 High) and conducted self-assessments across 8 departments, with each department reviewing one designated risk item. The company also established and implemented control measures tailored to risk level and characteristics, and continuously monitored improvement effectiveness to minimize the probability of risk occurrence. In 2026, Studio Dragon plans to strengthen item-by-item risk control reviews and enhance the effectiveness of its risk management approach by enabling each department to autonomously establish its own self-assessment topics. This shift will move beyond checklist-driven compliance reviews to establish a proactive, department-led risk management system tailored to the operational characteristics of each business unit.
Photo Credit: Studio Dragon
Compliance and Fair Trade Risk Management Process
Step 1. | → | Step 2. | → | Step 3. | → | Step 4. | → | Step 5. | |
|---|---|---|---|---|---|---|---|---|---|
Monitoring | Interviews | Risk Identification | Impact Assessment | Implementation of Actions | |||||
Risk Monitoring by Department | Interview with the Legal Affairs & Compliance Team | Risk Identification for Compliance Obligations | Evaluation of Causes and Impact for Each Risk | Development of Control Measures and Implementation of Actions for Identified Risks | |||||
Risk Identification Targets | Assessment Methodology | ||||||||
| Likelihood of Occurrence × Impact (5-point scale) = Final Risk Level Evaluation (High, Medium, Low) | ||||||||
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Compliance Risk Identification and Management Overview
Item1) | Management Plan | Mitigation Actions | Risk Mitigation Level2) |
|---|---|---|---|
Copyright Law Violation Risk | Pre-review request from relevant departments | Legal review conducted for business activities related to production support, commerce, licensing, and pop-up stores | High → Low |
Broadcasting Law Violation Risk | Pre-review request from relevant departments | Cross-review of regulatory compliance conducted with the channel review team | Medium → Low |
Serious Accidents Punishment Act Violation Risk | Pre-training provided to supervisory personnel | Safety Management Team conducts safety and health training and regular on-site inspections | High → Low |
Animal Protection Law Violation Risk | Establishment and revision of company regulations, guidelines, and manuals | Distribution of animal appearance guidelines and mandatory training for staff | High → Medium |
Financial Investment Services and Capital Markets Act Violation Risk | Establishment and revision of company regulations, guidelines, and manuals | Development of guidelines for major disclosure standards and internal approval procedures | High → Medium |
1) Risk items have been disclosed by grouping similar risk categories together.
2) Risk levels were assessed by selecting representative cases from various risks and documenting improvements in risk levels.
Compliance Coordinator Program Operations
Studio Dragon operates the Compliance Coordinator Program to strengthen the execution of ethics & compliance management and expand participation across operational departments. Compliance coordinators are designated by the CEO upon recommendation from the Compliance Officer and work collaboratively with the compliance support organization to proactively identify risks and establish control measures through the Compliance Portal System. The program includes twice-yearly regular coordination meetings, as well as ad hoc briefings and training sessions, where compliance coordinators share and discuss compliance control activities, major regulatory trends, and response strategies. In 2025, Generative AI Usage and Related Copyright Issues were addressed as a key agenda item. The Compliance Officer reports on the program's operational status to the Compliance Management Committee at least once a year to monitor the system's implementation and effectiveness.
Fair Trade Risk Management Framework
To proactively respond to the tightening of regulations governing subcontracting transactions, Studio Dragon closely monitors the status of subcontracting practices across different areas of the content industry. In particular, the company conducts detailed inspections focused on key compliance priorities—eliminating the failure to provide written documentation, preventing unfair special provisions, and ensuring compliance with the Fair Transactions in Subcontracting Act (the ‘Subcontracting Act’)—to identify and implement effective improvement measures. Additionally, to ensure thorough compliance with the Subcontracting Act, Studio Dragon has revised and applied internal standard contracts, and also operates a systematic monitoring process to respond to compliance risks that may arise during subcontracting transactions.
Subcontracting Monitoring Process
Step 1. | → | Step 2. | → | Step 3. | → | Step 4. | → | Step 5. |
|---|---|---|---|---|---|---|---|---|
Risk Extraction from Proposals | Contract Classification by Type | Verification of Key Compliance Requirements | Identification of Improvement Opportunities | Implementation of Improvements |
Subcontracting Risk Identification and Mitigation Measure
Identified Risks | Risk Mitigation Actions |
|---|---|
Statutory Requirements Not Reflected | Content Production Service Agreement Revision
|
Written Documentation Not Provided | Subcontracting Act Training Implementation
|
Unfair Terms Included | Strengthening Subcontracting Provisions in Standard Contracts
|
Ethics & Compliance Reporting and Audit
Misconduct Reporting and Whistleblower Protection System
Studio Dragon operates internal and external reporting channels to prevent misconduct throughout the production process and enhance transparency. The company receives reports of misconduct, irregularities, and unfair trade practices through the CJ Group Hotline System, operated by CJ Group, and K-Whistle, an external reporting channel operated by the Korea Business Ethics Institute. Reported cases are categorized and managed according to the nature of the violation—legal violations, internal policy violations, or breaches of the Code of Ethics. Depending on the case, the company implements measures to protect whistleblowers from retaliation and carries out follow-up actions, including fact-finding investigations and the submission of disciplinary recommendations. Investigation results are reported to the Personnel Committee, and a decision-making framework is in place whereby the CEO and the Personnel Committee determine final disciplinary action through deliberation. Additionally, Studio Dragon maintains reporting channel guidance posters and QR code-based promotional materials in key company spaces to enhance employee accessibility and increase utilization of reporting channels, thereby continuously fostering an internal reporting culture.
Whistleblowing system
01. Report Submission → | 02. Report Receipt & Investigation → | 03. Investigation Results Review |
|---|---|---|
The reporter/informant should submit the details of the case and their factual background based on the five Ws and one H principle under his/her real name or anonymously | Submission The case submitted is accepted by the manager. Review The details of the submitted case are reviewed, and requests for complementary information are made if deemed necessary. Investigation Investigations proceed sequentially in the order received. Completion The investigation comes to an end after verifying the credibility of the submitted information through identifying and examining its objective grounds. | The results of the investigation can be confirmed through the report submission channel.
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Ethics & Compliance Audits
Studio Dragon conducts regular and irregular audits annually to manage compliance with internal regulations and ensure the appropriateness of business processes. Audits are performed on employees and subsidiaries in accordance with the parent company CJ ENM's CJ ENM Entertainment Division Audit Regulations. The company also conducts audits on ethics standards and guidelines, including the CJ Code of Business Conduct and continues to work toward risk mitigation.
Metrics and Targets
Studio Dragon manages ethics and compliance-related risks across all business operations through regular monitoring of ethics & compliance training—including media and content ethics & compliance education—and regulatory violations. The company plans to strengthen ethics & compliance management in 2026 to further reinforce stakeholder trust. For 2026, Studio Dragon has established a goal to develop action plans that enable each department to autonomously and proactively select topics for departmental risk and self-assessment items.
Category | Unit | 2023 | 2024 | 2025 | ||
|---|---|---|---|---|---|---|
Ethics Training | Ethics Training Hours | Hour | 298 | 471 | 300 | |
Number of Employees Completing Ethics Training | Person | 166 | 174 | 166 | ||
Mandatory Online Compliance Training Completion Rate | % | 96 | 94 | 97 | ||
Ethics Reporting | Number of Ethics & Compliance Reports Received1) | Case | 2 | 0 | 2 | |
Number of Valid & Resolved Ethics & Compliance Reports2) | Case | 2 | 0 | 1 | ||
Legal and Regulatory Violations | Marketing and Labeling | Case | 0 | 0 | 0 | |
Fair Competition | Case | 0 | 0 | 0 | ||
Anti-Corruption | Case | 0 | 0 | 0 | ||
1) Total number of reports received, including invalid reports. The 2023 figure has been corrected due to a data entry error
2) Valid and invalid reports are classified according to internal standards, and actual investigations and corrective actions are based on the number of valid reports