Chapter 1: General Provisions

Article 1 (Purpose)

The purpose of this regulation is to establish comprehensive management and appropriate disclosure of internal company information in accordance with the Financial Investment Services and Capital Markets Act (hereinafter referred to as the “Act”) and related regulations, ensuring prompt and accurate disclosures and preventing insider trading by executives and employees.

Article 2 (Definitions of Terms)

1. “Internal Information” in this regulation refers to disclosure obligations stipulated in Part 1 of the KOSDAQ Market Disclosure Regulations (hereinafter referred to as the “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 condition that may influence investors’ investment decisions. (Amended May 23, 2017)
2. “Disclosure Officer” refers to the person authorized to report disclosures on behalf of the company, as defined in Article 2, Paragraph 4 of the Disclosure Regulations.
3. “Executive” refers to directors (including those falling under any of the categories specified in Article 401-2, Paragraph 1 of the Commercial Act) and auditors.
4. Any terms not defined in Paragraphs 1 to 3 shall follow the definitions provided in relevant laws and regulations.

Article 3 (Scope of Application)

Matters related to disclosures, insider trading, and internal information management shall be governed by this regulation unless otherwise stipulated by relevant laws, regulations, or the company’s Articles of Incorporation.

Chapter 2: Management of Internal Information

Article 4 (Management of Internal Information)

1. Executives and employees must strictly manage internal information obtained in the course of their duties and must not disclose it internally or externally unless necessary for business purposes.
2. The CEO must take necessary measures for managing internal information, including setting specific guidelines for storing, transmitting, and disposing of internal information and related documents.
   Note: In companies with an executive officer system, “CEO” shall be replaced with “Chief Executive Officer of Executive Officers.” (Newly added May 23, 2017)

Article 5 (Disclosure Officer)

1. The CEO must designate a Disclosure Officer and promptly report this to the Exchange. The same applies when there is a change in the Disclosure Officer. (Amended May 23, 2017)
2. The Disclosure Officer is responsible for overseeing the establishment and operation of the internal information management system and performs the following duties:
   1. Execution of disclosures
   2. Monitoring and evaluating the operation of the internal information management system
   3. Reviewing internal information and determining whether disclosure is required
   4. Providing education for executives and employees regarding the internal information management system
   5. Supervising departments or personnel responsible for managing internal information or handling disclosure-related tasks
   6. Other tasks necessary for the operation of the internal information management system, as recognized by the CEO
3. The Disclosure Officer has the authority to:
   1. Request submission and review of various documents and records related to internal information
   2. Obtain opinions from departments handling accounting, auditing, or other related tasks that generate internal information
4. If necessary, the Disclosure Officer may consult with relevant executives and 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 (or the Board of Directors).

Article 6 (Disclosure Manager)

1. The CEO must designate a Disclosure Manager and promptly report this to the Exchange. The same applies when there is a change in the Disclosure Manager. (Amended May 23, 2017)
2. The Disclosure Manager works under the supervision of the Disclosure Officer and performs the following duties:
   1. Collecting and reviewing internal information and reporting to the Disclosure Officer
   2. Performing tasks necessary for executing disclosures
   3. Checking changes in disclosure-related laws and regulations and reporting them to the Disclosure Officer
   4. Other tasks deemed necessary by the CEO or the Disclosure Officer

Chapter 3: Disclosure of Internal Information

Article 9 (Types of Disclosure)

The company’s disclosures are classified as follows:

1. Reports and disclosures of significant management matters under Chapter 2, Section 1 of Part 1 of the Disclosure Regulations
2. Inquiry disclosures under Chapter 2, Section 2 of Part 1 of the Disclosure Regulations
3. Fair disclosures under Chapter 2, Section 3 of Part 1 of the Disclosure Regulations
4. Voluntary disclosures under Chapter 3 of Part 1 of the Disclosure Regulations
5. Submission of securities registration statements under Chapter 1 of Part 3 of the Act
6. Submission of business reports under Articles 159, 160, and 165 of the Act and Chapter 2, Section 4 of Part 1 of the Disclosure Regulations
7. Submission of material event reports under Article 161 of the Act
8. Other disclosures required by different regulations

Article 10 (Execution of Disclosure)

1. When a disclosure event occurs, the Disclosure Manager must prepare the necessary content and documents and report them to the Disclosure Officer.
2. The Disclosure Officer must review whether the prepared content and documents comply with relevant laws and report them to the CEO before proceeding with the disclosure.

Article 12 (Media Inquiries and Press Releases)

1. If a media outlet requests an interview with the company, the CEO or the Disclosure Officer shall respond. If necessary, executives or employees from relevant departments may participate.
2. Any press release must be approved by the Disclosure Officer before distribution. The Disclosure Officer may report to the CEO if necessary.
3. If a press release contains fair disclosure information, it must be disclosed before its distribution. (Newly added May 23, 2017)
4. If an executive or employee becomes aware that media coverage contains incorrect information, they must report it to the Disclosure Officer, who will inform the CEO and take appropriate measures. (Moved from Article 12, Paragraph 3, on May 23, 2017)

Chapter 4: Regulation of Insider Trading

Article 14 (Return of Short-Term Trading Profits)

1. Executives and employees specified under Article 174, Paragraph 1 of the Act and Article 194 of its Enforcement Decree must return any profits obtained from buying and selling specified securities within six months.
2. If a shareholder demands the company to claim the short-term trading profit from the beneficiary, the company must take necessary action within two months.
3. If the Securities and Futures Commission notifies the company of a short-term trading profit occurrence, the Disclosure Officer must promptly disclose the following information on the company’s website:
   1. Position of the individual required to return the profit
   2. Amount of short-term trading profit
   3. Date of notification from the Securities and Futures Commission
   4. Plan for claiming the short-term trading profit
   5. Notice that shareholders may request the company to claim the short-term trading profit, and if the company does not do so within two months, the shareholder may claim it on behalf of the company
4. The disclosure period for Paragraph 3 shall be two years from the notification date or until the profit is returned, whichever comes first.

Chapter 5: Supplementary Provisions

Article 18 (Amendment or Abolition of Regulations)

Amendments or abolition of this regulation shall be determined by the CEO. (Amended May 23, 2017)

Article 19 (Publication of Regulations)

This regulation shall be published on the company’s website. The same applies to any amendments.

Supplementary Provisions

• This regulation shall take effect on August 28, 2009.
• This regulation shall take effect on May 23, 2017 (as amended).