Article 1 (Purpose)

Article 1 (Purpose) The purpose of these regulations is to establish the comprehensive management and appropriate disclosure of internal information to ensure prompt and accurate public disclosure and prevent insider trading by executives and employees, in accordance with the ｢Financial Investment Services and Capital Markets Act｣ (hereinafter referred to as the "Act") and related laws and regulations.

Article 2 (Definitions of Terms)

① "Internal information" refers to matters subject to disclosure under Chapter 1 of the KOSDAQ Market Disclosure Regulations (hereinafter "Disclosure Regulations") of the Korea Exchange (hereinafter "the Exchange") and other information regarding the company's management or financial status that may affect investor judgment.

② "Disclosure officer" refers to a person authorized to represent the company in reporting duties under Article 2, Paragraph 4 of the Disclosure Regulations.

③ "Executive" refers to directors (including those under Article 401-2, Paragraph 1 of the Commercial Act) and auditors.

④ Terms not defined in Paragraphs 1 through 3 follow the definitions provided in relevant laws and regulations.

Article 3 (Scope of Application)

Matters related to disclosure, insider trading, and internal information management are governed by these regulations unless specified otherwise by applicable laws or the company’s Articles of Incorporation.

Article 4 (Management of Internal Information)

① Executives and employees must strictly manage internal information learned during the course of their duties and must not disclose such information internally or externally unless required for work purposes.

② The CEO must take necessary measures to manage internal information, including establishing specific standards for the storage, transmission, and destruction of such information.

※ In the case of a company with an executive officer, ‘CEO’ is modified to ‘Representative Executive Officer’. The following is the same (Annotation Newly Established 2017.05.23.)

Article 5 (Disclosure Officer)

① The CEO must appoint a disclosure officer and promptly report the appointment to the Exchange. The same applies when a disclosure officer is replaced. (Revised 2017.05.23.)

② The disclosure officer oversees the establishment and operation of the internal information management system and performs the following duties.

1. Execution of public disclosures
2. Inspection and evaluation of the internal information management system
3. Review of internal information and decision-making on disclosure
4. Education and other measures necessary for the operation of the internal information management system
5. Supervision of departments or personnel handling internal information or disclosure duties
6. Other tasks deemed necessary by the CEO for the operation of the internal information management system

③ The disclosure officer has the authority to the following.

1. Request and review all documents and records related to internal information한
2. Seek opinions from relevant personnel responsible for accounting, auditing, or generating internal information

④ If necessary, the disclosure officer may consult with executives or seek expert assistance at the company's expense

⑤ The disclosure officer must report the status of the internal information management system to the CEO (or the Board of Directors).

Article 6 (Disclosure Manager)

① The CEO must appoint a disclosure manager and report the appointment to the Exchange. The same applies when a disclosure manager is replaced. (Annotation Newly Established 2017.05.23.)

② The disclosure manager works under the direction of the disclosure officer and performs the following tasks.

1. Collection and review of internal information and reporting to the disclosure officer
2. Tasks necessary for the execution of public disclosures
3. Confirmation of changes in disclosure-related laws and reporting to the disclosure officer
4. Other matters deemed necessary by the CEO or disclosure officer

Article 7 (Centralization of Internal Information)

① Executives and department heads must promptly provide the disclosure officer with information in the following cases.

1. When internal information arises or is expected to arise (Annotation Newly Established 2017.05.23.)
2. When a reason to cancel or change internal information that has already been disclosed occurs or is expected to occur (Annotation Newly Established 2017.05.23.)
3. In other cases where there is a request from the person in charge of disclosure

② The disclosure officer and the CEO must establish an efficient information delivery system within the company to ensure the timely provision of internal information under Paragraph 1. If necessary, the approval process for tasks related to disclosure obligations may involve the cooperation of the disclosure officer. (Newly established 2017.05.23.)

Article 7-2 (Management of Information Related to Major Shareholders)

The disclosure officer must establish an information delivery system to effectively manage disclosure obligations and inquiry-related disclosure requests concerning major shareholders. This system must ensure the timely receipt of relevant information by adequately explaining the details to the major shareholder. (Newly established 2017.05.23.)

Article 7-3 (Consolidation of Subsidiary Internal Information) (Annotation Newly Established 2017.05.23.)

① If internal information related to disclosure obligations arises or is anticipated at a subsidiary, the company must ensure that the subsidiary promptly notifies the company's disclosure officer or disclosure manager.

② To efficiently manage internal information related to disclosure obligations under Paragraph 1, the company must designate a person responsible for managing disclosure-related information at the subsidiary. Any designation or change must be promptly communicated to the company's disclosure officer or disclosure manager.

③ The company may request the subsidiary to provide relevant materials necessary for disclosure obligations.

Article 8 (External Provision of Internal Information)

① If executives or employees must provide internal information to counterparties, external auditors, agents, or legal/management consultants for business purposes, they must report this to the disclosure officer. In such cases, the disclosure officer must take necessary measures, such as entering into confidentiality agreements regarding the internal information.

② In such cases, the disclosure officer must take necessary measures, such as entering into confidentiality agreements regarding the internal information.

③ If the provision of internal information under Paragraph 1 triggers fair disclosure obligations, it must be disclosed promptly, except in cases where it is exempt under Article 15 of the Disclosure Regulations. (Newly established 2017.05.23.)

Article 9 (Types of Disclosures)

The company’s disclosures are categorized as follows.

1. Reporting and disclosure of major management matters under Part 1, Chapter 2, Section 1 of the Disclosure Regulations
2. Inquiry disclosures under Part 1, Chapter 2, Section 2 of the Disclosure Regulations
3. Fair disclosures under Part 1, Chapter 2, Section 3 of the Disclosure Regulations
4. Voluntary disclosures under Part 1, Chapter 3 of the Disclosure Regulations
5. Submission of securities registration statements, etc., under Part 3, Chapter 1 of the Act
6. Submission of business reports, etc., under Articles 159, 160, and 165 of the Act, and Part 1, Chapter 2, Section 4 of the Disclosure Regulations
7. Submission of major issues reports under Article 161 of the Act
8. Other disclosures required by laws and regulations

Article 9-2 (Confirmation of Disclosure Targets)

When determining whether disclosure obligations, including fair disclosures, apply under these regulations, care must be taken to ensure that matters significantly affecting stock prices or investment decisions, as described in Article 6, Paragraph 1, Subparagraph 4 of the Disclosure Regulations, are also included. (Newly established 2017.05.23.)

Article 10 (Execution of Disclosures)

① The disclosure manager must prepare the necessary details and documentation when a disclosure event occurs as defined in Article 9 and report these to the disclosure officer.

② The disclosure officer must review the content and documentation for compliance with applicable laws and regulations, report the findings to the CEO, and then proceed with disclosure.

Article 10-2 (Prompt Execution of Disclosure)

The disclosure officer must ensure that internal information subject to disclosure under Article 9 is disclosed promptly, even before the mandatory deadline specified in the Disclosure Regulations, if possible. (Newly established 2017.05.23.)

Article 11 (Post-Disclosure Measures)

If errors, omissions, cancellations, or changes occur in disclosed content, the disclosure officer and manager must promptly correct them by following Article 30 of the Disclosure Regulations or take other corrective measures. (Amended 2017.05.23.)

Article 12 (Media Inquiries, etc.)

① When the company receives media inquiries, the CEO or disclosure officer will generally respond. Related executives or employees may respond if deemed necessary.

② If the company intends to distribute press releases, it must consult with the disclosure officer, who may report the details to the CEO if necessary.

③ If the press release contains information subject to fair disclosure, the disclosure officer must disclose it prior to its distribution. (Newly established 2017.05.23.)

④ If an executive or employee becomes aware that a media report contains inaccuracies, they must report it to the disclosure officer, who will then notify the CEO and take corrective measures. (Moved and amended 2017.05.23.)

Article 12-2 (Verification of Reported Content)

The disclosure officer, manager, and departments generating internal information must regularly verify media reports related to the company. If inaccuracies are found, corrective measures must be taken. (Newly established 2017.05.23.)

Article 13 (Corporate Presentations)

① The CEO must recognize IR activities as a responsibility of KOSDAQ-listed companies and strive to build trust with investors through regular, voluntary corporate presentations.

② Presentations on management, business plans, and projections must be coordinated with the disclosure officer.

③ The disclosure officer or manager must announce the date, location, and content of the presentation by the day prior and submit related materials to the disclosure system before the presentation.

④ All executives and employees must ensure that undisclosed information subject to fair disclosure is not revealed during the presentation. (Fully revised 2017.05.23.)

Article 13-2 (Rumors)

① If market rumors arise, the disclosure officer must confirm their accuracy and whether they involve internal information by consulting relevant departments.

② If the rumor relates to matters subject to mandatory disclosure under the Disclosure Regulations, the information must be disclosed. (Newly established 2017.05.23.)

Article 13-3 (Requests for Information)

① If shareholders or stakeholders request disclosure of company-related information, the disclosure officer must assess the legality of the request and decide whether to provide the information.

② The disclosure officer may seek opinions from the legal department or external legal experts to determine whether the requested information could affect investors' investment decisions or stock prices when deciding whether to provide the information.

③ If information is provided based on the decision under Paragraph 1, the provisions of Article 12, Paragraph 3 shall apply. (Newly established 2017.05.23.)

Article 14 (Return of Short-Swing Profits)

① Executives and employees specified under Article 172, Paragraph 1 of the Act and Article 194 of its Enforcement Decree who buy specific securities (hereinafter referred to as "specific securities") and sell them within six months, or sell specific securities and buy them back within six months, must return any profits (hereinafter referred to as "short-swing profits") to the company.

1. Employees involved in establishing, modifying, implementing, or disclosing major management matters or related tasks
2. Employees engaged in finance, accounting, planning, or R&D-related tasks

② If a shareholder (including holders of equity securities other than stock or securities deposit certificates) requests the company to claim such profits, the company must take necessary actions within two months from the request date.

③ If the Financial Supervisory Commission informs the company of the occurrence of short-swing profits under Paragraph 1, the disclosure officer must promptly disclose the following on the company’s website.

1. The position of the person required to return the profits
2. The amount of short-swing profits
3. The date the Financial Supervisory Commission notified the company of the profits
4. Plans for claiming the short-swing profits
5. A statement that shareholders may demand the company to claim the profits within two months of the request, and if the company fails to act, the shareholders may claim the profits on behalf of the company

④ The disclosure period under Paragraph 3 shall last for two years from the notification date by the Financial Supervisory Commission or until the profits are recovered, whichever comes first.

Article 15 (Notification of Trades in Specific Securities)

Executives and employees specified under Article 172, Paragraph 1 of the Act must notify the disclosure officer of any trades or transactions involving specific securities.

Article 16 (Prohibition of the Use of Non-Public Material Information)

Executives and employees must not use or allow others to use material non-public information, including that of subsidiaries, for trading specific securities or other transactions as defined under Article 174, Paragraph 1 of the Act.

Article 17 (Education)

① The disclosure officer and disclosure manager must complete education related to disclosure duties under Articles 36 and 44, Paragraph 5 of the Disclosure Regulations and communicate the training content to relevant executives and employees.

② The CEO must make every effort to educate executives and employees on the matters specified in Articles 14 to 16 and other legal requirements to prevent insider trading. (Newly established 2017.05.23.)

Article 18 (Amendment or Repeal of Regulations)

The amendment or repeal of these regulations shall be determined by the CEO. (Amended 2017.05.23.)

Article 19 (Publication of Regulations)

These regulations and any amendments must be published on the company’s website.

These regulations take effect on May 25, 2017.