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Chapter 1: General Provisions

Article 1 (Purpose)

This regulation is intended to comprehensively manage and appropriately disclose internal information within the company for the purpose of ensuring prompt and accurate disclosure in accordance with the “Capital Market and Financial Investment Business Act” (hereinafter referred to as the “Act”) and other relevant regulations, as well as preventing insider trading by executives and employees.

Article 1 (Purpose)

In this regulation, “internal information” refers to matters subject to disclosure obligations under Part 1 of the KOSDAQ Market Disclosure Regulations of the Korea Exchange (hereinafter referred to as the “Exchange”), as well as other matters related to the company's management or financial status that may influence investors' investment decisions.

In this regulation, the term “disclosure officer” refers to a person who can perform reporting duties on behalf of the company in accordance with Article 2, Paragraph 4 of the Disclosure Regulations.

In this regulation, the term “executive” refers to directors (including those falling under any of the provisions of Article 401-2(1) of the Commercial Act) and auditors.

The definitions of terms used in this regulation, other than those in Paragraphs 1 to 3, shall be governed by the definitions in relevant laws and regulations.

Article 3 (Scope of Application)

Except as otherwise provided by applicable laws or articles of incorporation, matters pertaining to disclosure, insider trading, and internal information management shall be governed by these regulations.

Chapter 2: Management of Internal Information

Article 4 (Management of Internal Information)

Executives and employees must strictly manage the internal information of the company that they come to know in the course of their duties, and except when necessary for business purposes, they shall not disclose internal information to internal or external parties.

The CEO shall take necessary measures for the management of internal information, including the establishment of specific guidelines for the storage, transmission, and disposal of internal information and related documents.

Article 5 (Disclosure Officer)

The CEO shall promptly appoint a Disclosure Officer and report it to the exchange without delay. The same applies when changing the Disclosure Officer.

The Disclosure Officer shall oversee the establishment and operation of the internal information management system and perform the following duties.

1Execution of Disclosure 2Monitoring and Evaluation of the Operation of the Internal Information Management System 3Review and Determination of Disclosure of Internal Information 4Measures Necessary for the Operation of the Internal Information Management System, including Education for Executives and Employees 5Supervision and Oversight of Departments or Executives/Employees Responsible for Internal Information Management or Disclosure Tasks 6Other tasks recognized by the CEO as necessary for the operation of the internal information management system

The Disclosure Officer has the following authorities in performing their duties

1The authority to request the submission and inspection of various documents and records related to internal information 2The authority to solicit opinions from executives or employees of departments responsible for accounting, auditing, and other tasks related to the generation of internal information

The Disclosure Officer may, when necessary, consult with executives responsible for related tasks and, at the company's expense, seek the assistance of experts in the performance of their duties

The Disclosure Officer may, as necessary for the performance of their duties, consult with the executive responsible for related tasks, and may seek the assistance of experts at the company's expense

Article 6 (Disclosure Manager)

The CEO is to designate the Disclosure Manager and report it to the Korea Exchange (KRX). The CEO is to do the same when replacing the Disclosure Manager.

The Disclosure Manager is responsible for internal information management and operates under the guidance of the Disclosure Officer, performing the following tasks.

1Collection and review of internal information and reporting to the Disclosure Officer. 2Performing tasks necessary for the execution of disclosures. 3Confirming and reporting on matters necessary for the management of internal information due to changes in disclosure-related regulations or other factors. 4Any other matters recognized as necessary by the CEO or the Disclosure Officer.

Article 7 (Consolidation of Internal Information)

Executives and heads of each department must provide information to the Disclosure Officer in a timely manner in any of the following cases:

1When internal information arises or is expected to arise. 2When there is a reason to cancel or change previously disclosed information within internal information or an expectation that such a reason may arise. 3In response to the request of the Disclosure Officer. 4In response to the request of the Disclosure Officer.

The Disclosure Officer and CEO must efficiently establish an information transmission system within the company to ensure the timely provision of internal information. They may involve the cooperation of the Disclosure Officer in the approval process for business-related tasks if required.

Article 7-2 (Management of Information Related to the Largest Shareholder)

The Disclosure Officer must establish an information communication system with the largest shareholder to perform the disclosure tasks related to the largest shareholder's obligations to report and request information in a timely manner.

Article 7-3 (Consolidation of Internal Information from Subsidiaries)

When internal information relevant to disclosure requirements is expected to occur or has occurred within a subsidiary company, the parent company must ensure that the content is immediately reported to the parent company's Disclosure Officer or Disclosure Manager.

The parent company must efficiently manage internal information related to the subsidiary company by appointing an information manager within the subsidiary company or notifying the parent company's Disclosure Officer or Disclosure Manager of such an appointment or change, as necessary.

The parent company may request the submission of relevant information from the subsidiary company to the extent necessary for the disclosure tasks.

Article 8 (Disclosure of Internal Information to Third Parties)

When an executive or employee is required to provide internal information to third parties such as the company's trading partners, external auditors, or legal and management advisors due to work-related reasons, the Disclosure Officer must report this to the Disclosure Manager.

In cases of the Article 8 Paragraph 1, the Disclosure Officer must take necessary measures, such as entering into agreements on the confidentiality of related internal information.

If providing internal information under the Article 8 Paragraph 1 leads to a requirement for fair disclosure obligation, it must be disclosed without delay, excluding cases that fall under the application exceptions of Article 15.

Chapter 3 Disclosure of Internal Information

Article 9 (Types of Disclosures)

The company's disclosure can be classified as follows.

1.

Reporting and disclosure of important management matters according to Part 1, Chapter 2, Section 1 of the disclosure regulations.

2.

Inquiry disclosures according to Part 1, Chapter 2, Section 2 of the disclosure regulations.

3.

Fair disclosures according to Part 1, Chapter 2, Section 3 of the disclosure regulations.

4.

Voluntary disclosures according to Part 1, Chapter 3 of the disclosure regulations.

5.

Submission of securities reports or others according to Part 3, Chapter 1 of the law.

6.

Submission of business reports, including those under Article 159, Article 160, and Article 165 of the law and Part 1, Chapter 2, Section 4 of the disclosure regulations.

7.

Submission of significant matter reports as per Article 161 of the law.

8.

Other disclosures according to different regulations.

Article 9-2 (Confirmation of Disclosure Targets)

When determining the applicability of the disclosure obligation under these regulations, care must be taken to include matters that may have a significant impact on stock prices or investment judgments in accordance with Article 6, Paragraph 1, Item 4, of the disclosure regulations.

Article 10 (Execution of Disclosures)

The Disclosure Manager must promptly compile the required information and documents upon the occurrence of the matters subject to disclosure as per Article 9 and report them to the Disclosure Officer.

The Disclosure Officer must review the content and documents under Paragraph 1 for compliance with relevant regulations, and upon approval to the CEO, the disclosure must be made.

Article 10-2 (Prompt Execution of Disclosures)

The Disclosure Officer must make every effort to ensure that the information is disclosed promptly so that the internal information can be disclosed on time, even before the prescribed disclosure deadline as per Article 9.

Article 11 (Post-Disclosure Measures)

The Disclosure Officer and Disclosure Manager must take corrective action promptly if there are errors or omissions in the disclosed information or if it needs to be canceled or amended. They must follow the procedures set forth in Article 30 of the disclosure regulations.

Article 12 (Interviews by the Media, etc.)

In the case of interview requests related to the company from media outlets, the CEO or Disclosure Officer should generally respond. When necessary, executives or employees of the relevant department may participate in interviews.

When the company wishes to distribute press releases to media outlets, it should coordinate with the Disclosure Officer. If the content of the press release falls under the fair disclosure subjects, it must be disclosed before distribution.

The Disclosure Officer must disclose any content considered fair disclosure subject, in accordance with Article 12 Paragraph 2, prior to the distribution of the press release.

Executives or employees who discover that the information in the media is different from the facts must report this to the Disclosure Officer. The Disclosure Officer must inform the CEO of the matter and take any necessary actions.

Article 12-2 (Verification of Media Content)

The Disclosure Officer, Disclosure Manager, and departments responsible for internal information must regularly verify the content of media reports related to the company for accuracy and take corrective actions if there are discrepancies between the reported information and the facts.

Article 13 (Investor Relations Activities)

The CEO must acknowledge that investor relations activities are part of the company's management responsibility as a KOSDAQ-listed company and make voluntary, continuous efforts to hold investor relations events to build trust with stakeholders.

Investor relations activities concerning the company's management, business plans, prospects, etc., must be held in consultation with the Disclosure Officer.

The date, time, location, and content of investor relations events must be disclosed through the company's Internet homepage and the related materials must be made available prior to the event.

All executives and employees must ensure that internal information that has not been previously disclosed does not become public during the investor relations process.

Article 13-2 (Rumors)

The Disclosure Officer must promptly verify the content of rumors in the market, using, among other methods, opinions and inquiries from the relevant department, to determine the veracity of the rumors and whether they relate to internal information.

If, in accordance with the Article 13 Paragraph 1, the rumors are related to internal information and are subject to fair disclosure, the Disclosure Officer must promptly disclose such information.

Article 13-3 (Information Request)

If shareholders or stakeholders request information disclosure related to the company, the Disclosure Officer must determine whether to provide the requested information based on the legality of the request and other factors.

In determining whether to provide the requested information, the Disclosure Officer may seek the opinion of the legal department or external legal experts regarding whether the information requested has the potential to impact investors' investment decisions and stock prices.

When providing information under the Article 13 Paragraph 1, Article 12 Paragraph 3 applies.

Chapter 4 Insider Trading Policy

Article 14 (Return of short-swing profit)

Executives and employees designated under Article 172-1 of the act, and Article 194 of the Enforcement Decree, are required to return any short-term trading gains (hereinafter 'short-swing profit') made within 6 months after buying and selling specific securities, or buying and selling specific securities within 6 months after selling.

If the company's shareholders demand the return of short-swing profit to a person who has made short-swing profit as defined in the article 14-1, the company must take necessary actions to meet the shareholder's request within two months of receiving the request.

If the Financial Supervisory Service(hereunder 'FSS') notifies the company of the occurrence of short-swing profit under the article 14.1, the Disclosure Officer must promptly disclose the following information on the company's website.

1The position of the person who is to return the short-swing profit 2The amount of short-swing profit generated 3The date of notification of short-swing profit from the FSS 4A plan for claiming the return of the short-swing profit 5A shareholder of the Company may request that the company request the return of the short-swing profit from the person who has made such profit. In case the Company fails to claim the return within two months following the Company receiving said request to make such a claim, the shareholder may make the claim in subrogation of the company.

The disclosure period under Article 14-3 is to be two years from the date of notification of short-swing profit from the FSS or until the date on which short-swing profit is returned, whichever comes first.

Article 15 (Notification of Trading in Specific Securities)

Executives and employees designated in accordance with Article 172, Paragraph 1 of the law and Article 194 of the Presidential Decree must notify the Disclosure Officer of trading and other transactions related to specific securities.

Article 16 (Prohibition of the Use of Unpublished Material Information)

Executives and employees must not use the material nonpublic information as defined in Article 174, Paragraph 1 of the act, including such information related to subsidiary companies, for trading, or make it available to others.

Chapter 5 Addendum

Article 17 (Education)

The Disclosure Officer and Disclosure Manager must complete the education on the disclosure tasks as defined in Article 36 and Article 44, Paragraph 5 of the disclosure regulations. The Disclosure Officer must inform the relevant executives and employees about the education content.

The CEO must make sufficient efforts to provide training on the matters from Article 14 to Article 16 to executives and employees to prevent insider trading and other related activities.

Article 18 (Amendment and Abolition of Regulations)

Amendments or abolitions of these regulations are made by the CEO.

Article 19 (Publication of Regulations)

These regulations are published on the company's homepage. Even when these regulations are amended, they must be similarly published.