SHINHAN FINANCIAL GROUP CO LTD

We have adopted a code of ethics for our principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions as required under Section 406 of the Sarbanes-Oxley Act of 2002, together with an insider reporting system in compliance with Section 301 of the Sarbanes-Oxley Act. We have not granted any waiver, including an implicit waiver, from a provision of the code of ethics to any of the above-mentioned officers during our most recently completed fiscal year. As a further detailed guideline to the code of ethics, we have also adopted a code of ethics applicable to all the officers and employees of our holding company and our subsidiaries which sets forth standards for both the performance of duties andday-to-day conduct. Furthermore, each of our subsidiaries has established and implemented its own code of conduct, which allows us to systematically improve the ethical awareness of officers and employees on a group-wide level.

Our code of ethics outlines seven standards that all employees must adhere to, which encompass guidelines for customers, shareholders and investors, society, interactions among employees, performance of duties, external communications, and relationships with partner companies and competitors. Additionally, our employees are required under our code of ethics to report internal misconduct, prevent money laundering, manage internal accounting, and ensure transparent financial reporting. In the event of a violation of our code of ethics, employees may face penalties and disciplinary actions in accordance with applicable laws and internal regulations. Our code of ethics is available on our websitewww.shinhangroup.com.