Chairman Kim Hong-guk of Harim's 'Napoleon Gallery' Illegally Modified and Operated for One Year

Unauthorized Use Change Without Local Government Approval
Opened 11 Months Before Use Approval
Judicial Punishment Not Possible Due to Statute of Limitations

Kim Hong-guk, chairman of Harim Group, purchased the ‘Napoleon Hat’ at an auction for about 2.6 billion KRW, and it was later confirmed that the gallery exhibiting the hat was illegally repurposed and operated for nearly a year without permission.

Chairman Kim Hong-guk of Harim Group is attending the opening ceremony of the Napoleon Gallery held in March 2017 at the NS Home Shopping annex in Pangyo, Gyeonggi Province, answering reporters' questions.
[Photo by NS Home Shopping]

According to Asia Economy’s investigation on the 24th, the ‘Napoleon Gallery’ located on the first floor of the NS Home Shopping annex in Sampyeong-dong, Bundang-gu, Seongnam-si, Gyeonggi Province, was remodeled without approval from the local district office and opened in March 2017. Under the Enforcement Decree of the Building Act, galleries are classified as ‘cultural and assembly facilities,’ but at the time of opening, the location of the Napoleon Gallery was registered as a Type 2 neighborhood living facility and an automobile-related facility. The space, which could only be used as a restaurant or parking lot, was illegally converted into a gallery, constituting a clear violation.

To install and operate a gallery (exhibition hall) in a building registered as a neighborhood living facility, one must obtain a change-of-use permit from the local district office before construction. If the floor area exceeds 100㎡, approval for use must also be obtained after construction is completed. The Napoleon Gallery has a floor area of 104.19㎡, so use approval was required for operation. However, the gallery received the change-of-use permit one month after opening in April 2017 and the use approval in February of the following year, after it had already been operating. This means the gallery was illegally remodeled and operated arbitrarily for nearly a year.

Such unauthorized change of use results in a correction order upon detection, and if not complied with, a coercive fine is imposed. Separate from administrative measures, violations can be punished under the Building Act with imprisonment of up to three years or a fine of up to 500 million KRW. However, since the Napoleon Gallery’s use was changed to a cultural and assembly facility in February 2018, it does not qualify as a ‘continuing offense’ and thus cannot be punished. Under current law, the statute of limitations for unauthorized change of use and other Building Act violations is five years.

Interior view of Napoleon Gallery located on the 1st floor of the NS Home Shopping annex in Sampyeong-dong, Bundang-gu, Seongnam-si, Gyeonggi Province. Eight related artifacts, including Napoleon's bicorne hat, are on display.
[Photo by NS Home Shopping]

Kim chairman is behind the establishment of the Napoleon Gallery in the NS Home Shopping annex. In 2014, Kim won the Napoleon bicorne hat owned by the Monaco royal family at a world hat auction for a record high price of 1,884,000 euros (approximately 2.6 billion KRW at the time). At that time, Kim promised to publicly exhibit the bicorne hat, and the result was the Napoleon Gallery inside the NS Home Shopping annex. The gallery exhibits eight related artifacts, including the bicorne hat, portraits, and medals received from the King of Denmark.

NS Home Shopping is a key affiliate of Harim Group. In March, Kim’s eldest son, Kim Jun-young, was newly appointed as an inside director. The appointment caused controversy as proper consent procedures were not followed at the shareholders’ meeting and board of directors. NS Home Shopping currently operates under two executives: CEO Jo Hang-mok and Director Kim, with Kim serving as a non-executive director without a separate position.

This content was produced with the assistance of AI translation services.