POSCO worldwide: a pattern of conduct beyond Brazil

In 2015, POSCO — and in particular its construction unit (POSCO Engineering & Construction) — was linked, in South Korea, to a cycle of inquiries involving allegations of the creation and use of “slush funds”: opaque cash reserves liable to be used for illegitimate purposes such as bribes and hidden expenses. The suspicions reached embezzlement, fraud, corruption and breach of fiduciary duty, with references to contracts and operations abroad. Public sources from that period recorded searches, the formalization of charges and indictments and the holding to account of several individuals in what became known as the “POSCO corruption scandal,” with references to dozens prosecuted and arrests in connection with the inquiries. (Sources 1–4)

Later, in 2018, news reports indicated that the construction unit's financial governance again became the object of regulatory scrutiny, with mentions of suspected accounting irregularities and questions raised by a financial supervisor. The publicly verifiable point, in this case, is the existence of the regulatory inquiry itself and its reputational impact. (Source 5)

On the competition front, POSCO was cited in administrative decisions relating to price-fixing in the steel sector. In 2012, it was reported that the South Korean antitrust authority fined several steelmakers, including POSCO, for conduct described as price-fixing collusion over a number of years for certain products. The known outcome was the imposition of administrative sanctions. (Sources 6–7)

The competition debate also reached the construction unit, in controversies involving price manipulation and bid rigging in public works tenders. In 2014, a fine and corrective orders were reported in a case involving the construction subsidiary and another company, with references to water and sanitation works, as well as referrals for criminal investigation of individuals. (Sources 8–9) In 2016, another fine was reported in a further bid-rigging case involving the construction unit, reinforcing the recurrence of bid collusion in that segment. (Source 10)

In India, the megaproject in Odisha associated with the POSCO group was described by an international human-rights organization as a risk situation, with allegations of threats to livelihoods, displacements and insufficient safeguards, as well as questions about community consultation and impact assessment. The outcome, according to that source, was the public issuance of the alert and a call for due diligence before advancing measures affecting communities — a context in which the “Anti-POSCO” movement also emerged. (Source 11)

In Myanmar, after the 2021 coup, group companies were pressed over business ties with a corporate entity linked to the armed forces. The controversy was framed as a reputational and compliance risk amid demands from investors and civil society. The known outcome was the announcement, by a group subsidiary, of the end of a joint venture. (Source 12) Still in Myanmar, the debate reached the gas sector and potential financial flows to the project's state partner: POSCO International was reported to be reviewing dividend payments in a given project, against pressure to reduce sources of financing for the regime; in parallel, an OHCHR document recorded concerns about annual revenues that could continue flowing to the state partner. (Sources 13–14)

In Indonesia, allegations of socio-environmental and human-rights impacts in a palm-oil supply chain were brought under the OECD Guidelines mechanism, through a specific instance (complaint) before the South Korean National Contact Point. The case was accepted and went through mediation attempts that ended without agreement, culminating in a final statement with recommendations — including the adoption of NDPE practices (No Deforestation, No Peat, No Exploitation), responsible due-diligence measures and recommendations to institutional financiers. (Sources 15–16)

In 2025 and 2026, POSCO's construction unit reappeared in coverage of safety failures and fatal accidents at construction sites. A court decision was reported imposing a fine for failure to install basic protections at a site, in connection with a worker's death, with subcontracting-chain actors also held responsible. (Source 17) Subsequently, a site manager was reportedly charged in connection with a death involving drilling equipment, under allegations of inadequate protective measures. (Source 18)

At the administrative level, sources reported the imposition of a significant fine and an order to restructure the internal safety system (Source 19), as well as corporate-governance repercussions tied to a succession of accidents — including the construction unit CEO's resignation amid public pressure. (Source 20) The picture combines punitive and corrective measures with reputational impact and executive leadership change.

In Brazil, beyond the Ceará bankruptcy, there is a record of criminal controversies tied to the construction period. There is a federal prosecutor's complaint involving charges such as foreign-exchange evasion and criminal association, under the narrative of using corporate structures to enable remittances and illicit practices; there is also a TRF-5 habeas corpus ruling mentioning elements of the investigation and precautionary measures. What is publicly verifiable is the existence of proceedings and a judicial decision in the federal criminal sphere; the merits of each charge depend on the course of the respective actions. (Sources 21–22)

In the United States, POSCO Holdings INC. has securities traded on the New York Stock Exchange via ADR under ticker PKX, indicated as a Level III ADR with a depositary bank and, consequently, subject to formal reporting obligations before the SEC. (Source 23) This framework involves the annual filing of Form 20-F (for foreign private issuers) and the possibility of updates for “subsequent events” via Form 6-K when material facts materialize after the close of the reported period. (Sources 24–27)

Form 20-F requires the disclosure of litigation in which the company is involved. There is public debate over the scope of this obligation when facts originate in subsidiaries — for instance, subsidiary arbitration or insolvency — particularly under the materiality criterion, a point that gains relevance in light of occurrences across various jurisdictions, including the Brazilian bankruptcy.