provision

The purpose of these regulations is to specify matters necessary for the comprehensive management and appropriate disclosure of the company's internal information, as well as to prevent insider trading by officers and employees in accordance with the laws related to the capital market and financial investment industry (hereinafter referred to as "the Law"). (Established May 26, 2017)

① "Internal Information" as used in these regulations refers to matters that may influence investors' decisions related to company transactions as prescribed by the Capital Markets Act and other related regulations. (Revised May 26, 2017)
② ."Disclosure Officer" refers to the person authorized to perform disclosure duties on behalf of the company under the stock market disclosure regulations.
③ "Executive" refers to any individual who participates in the board of directors or holds a similar position within the company.
④ Definitions of terms not covered in these regulations shall follow the definitions in related laws and regulations.

These regulations apply to matters related to the management of internal transactions and internal information unless otherwise specified by laws, regulations, or standards.

① Officers and employees must diligently manage the company's internal information learned in the course of their duties. Unless necessary for business purposes, such internal information must not be disclosed or leaked to outside parties. ② Disclosure officers or those responsible for public disclosure must take the necessary measures to properly store, protect, and manage internal information, including safeguarding documents related to public disclosures and preventing loss or damage.

① The CEO must designate a Disclosure Officer and promptly notify the Korea Exchange. The same applies when changing the Disclosure Officer. (Revised May 26, 2017)
② The Disclosure Officer is responsible for the overall establishment and operation of the internal information management system and performs the following duties:
③ The Disclosure Officer has the following authority in performing their duties:
④ The Disclosure Officer may consult with executives in charge of related duties if necessary and may seek expert assistance at the company's expense.
⑤ The Disclosure Officer must regularly report the status of the internal information management system's operation to the CEO.

① The CEO must designate Disclosure Staff and promptly notify the Korea Exchange. The same applies when changing the Disclosure Staff. (Revised May 26, 2017)
② The Disclosure Staff operates under the supervision of the Disclosure Officer regarding internal information management and performs the following duties:

① Executives and heads of departments must promptly provide information to the Disclosure Officer in the following cases: (Revised May 26, 2017) ② The Disclosure Officer and CEO must establish an efficient information transmission system within the company to ensure the timely provision of internal information. In necessary cases, the Disclosure Officer's cooperation may be required in the approval process for tasks related to disclosure obligations. (Newly established May 26, 2017)

The Disclosure Officer must build an information transmission system to explain relevant facts to the largest shareholder and ensure timely receipt of related information to facilitate the disclosure obligations and response to inquiry disclosures related to the largest shareholder. (Newly established May 26, 2017)

① The company must ensure that internal information related to disclosure obligations occurring in subsidiaries is immediately reported to the company's Disclosure Officer or Disclosure Staff.
② To efficiently manage internal information related to disclosure obligations, the company must designate a person responsible for managing disclosure-related information. In cases of designation or change, the subsidiary must promptly notify the company’s Disclosure Officer or Disclosure Staff.
③ The company may request subsidiaries to submit relevant materials necessary for disclosure. (Newly established May 26, 2017)

① When executives or employees must provide internal information to external parties such as counterparties, external auditors, agents, or consultants due to business requirements, they must report the matter to the Disclosure Officer.
② In such cases, the Disclosure Officer must take necessary measures, such as signing confidentiality agreements regarding the internal information.
③ If the provision of internal information requires fair disclosure, it must be disclosed without delay, except in cases where exemptions under Article 15 of the Disclosure Regulations apply. (Newly established May 26, 2017)

The company's disclosures are classified as follows:
1. Major management issues report and disclosure 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 disclosure under Part 1, Chapter 2, Section 3 of the Disclosure Regulations
4. Voluntary disclosure under Part 1, Chapter 3 of the Disclosure Regulations
5. Submission of securities registration statements under Part 3, Chapter 1 of the Act
6. Submission of business reports under Articles 159, 160, and 165 of the Act and Section 4 of the Disclosure Regulations
7. Submission of major issues reports under Article 161 of the Act
8. Other disclosures required by laws or regulations

In determining whether an obligation for fair disclosure or other disclosure requirements applies under these regulations, the company must carefully consider matters that may significantly impact the stock price or investor decision-making, as stipulated in Article 6, Paragraph 1, Item 4 of the Disclosure Regulations. (Newly established May 26, 2017)

When a disclosure obligation arises, the Disclosure Staff must prepare the necessary materials and documents and report them to the Disclosure Officer.

The Disclosure Officer must make every effort to ensure that internal information is disclosed promptly, even before the deadline set by the Disclosure Regulations, if disclosure obligations arise. (Newly established May 26, 2017)

If there is an error, omission, or need for cancellation or correction in the disclosed information, the Disclosure Officer and Disclosure Staff must take corrective measures without delay, such as issuing a correction disclosure in accordance with Article 30 of the Disclosure Regulations. (Revised May 26, 2017)

① The CEO or Disclosure Officer will respond to media inquiries about the company. If necessary, relevant department executives or employees may respond.
② When the company distributes press releases, the approval of the Disclosure Officer must be obtained. The Disclosure Officer must report matters related to press release distribution to the CEO if necessary.
③ If the contents of the press release are subject to fair disclosure, the Disclosure Officer must ensure that the information is disclosed before the release. (Newly established May 26, 2017)
④ If executives or employees discover that media reports differ from the facts, they must report this to the Disclosure Officer. The Disclosure Officer must report to the CEO and take necessary actions. (Moved from Paragraph 3 in 2017 revision)

The Disclosure Officer, Disclosure Staff, and departments that generate internal information must routinely check media reports related to the company. If the report contains inaccurate information, corrective measures must be taken. (Newly established May 26, 2017)

① The CEO shall recognize that IR (Investor Relations) activities are a responsibility of KOSDAQ-listed companies and shall voluntarily and continuously hold corporate presentations to build trust with investors.
② Corporate presentations covering business operations, plans, and outlooks shall be conducted in consultation with the public disclosure officer.
③ The public disclosure officer or designee must announce the date, location, and content of the corporate presentation no later than the day before its occurrence and upload relevant materials to the exchange’s disclosure system prior to the event.
④ All executives and employees of the company shall ensure that no undisclosed material information subject to public disclosure is revealed during the corporate presentation. [Amended May 26, 2017]

① When market rumors are circulating, the public disclosure officer shall confirm the facts through consultation with the relevant business department to determine the accuracy and whether the rumors involve internal information.
② If the results of the investigation confirm that the rumor involves information subject to disclosure under the disclosure regulations, the relevant information must be disclosed. [Newly established May 26, 2017]

① When shareholders or stakeholders request disclosure of information related to the company, the public disclosure officer shall review the legitimacy of the request and decide whether to provide the information.
② The public disclosure officer may seek legal opinions from the legal department or external legal experts on whether the requested information could affect investment decisions or stock prices.
③ .If information is provided under this Article, Article 12, Paragraph 3 shall apply. [Newly established May 26, 2017]

① Executives and employees (limited to those able to access non-public important information in accordance with Article 174, Paragraph 1 of the Act and Article 194 of the Enforcement Decree) who buy or sell specific securities and make a profit within six months must return such profit to the company.
② .If shareholders request the company to demand the return of such short-swing profits, the public disclosure officer shall take necessary measures within two months from the date of the request.
③ If the Securities and Futures Commission notifies the company of the occurrence of short-swing profits, the public disclosure officer shall disclose the following on the company’s website without delay: ④ The disclosure period shall be two years from the date of notification by the Securities and Futures Commission or until the short-swing profits are returned, whichever is earlier.

Executives and employees as defined in Article 172, Paragraph 1 of the Act and Article 194 of the Enforcement Decree must notify the public disclosure officer of any transactions involving specific securities.

Executives and employees shall not use non-public important information (including that of affiliated companies) for transactions involving specific securities, nor allow others to do so.

① The public disclosure officer and designee must complete training on disclosure responsibilities in accordance with Articles 36 and 44, Paragraph 5 of the disclosure regulations. The public disclosure officer must ensure the content of such training is communicated to relevant executives and employees.
② The CEO shall make sufficient efforts to provide training to executives and employees on the matters stipulated in Articles 14 to 16, and to prevent insider trading. [Newly established May 26, 2017]

The CEO shall amend or repeal these regulations.

These regulations shall be published on the company’s website, and any amendments to the regulations shall also be published.

These regulations shall take effect from November 10, 2015.
These regulations shall take effect from May 26, 2017.