Investment

Article 1 (Purpose)

This regulation provides for comprehensive management and appropriate disclosure of the company's internal information in order to ensure prompt and accurate disclosure and prevent insider trading by executives and employees in accordance with the Capital Markets and Financial Investment Services Act (hereinafter referred to as the Act) and related laws and regulations.

Article 2 (Scope of Application)

Matters related to disclosure, insider trading, and internal information management shall be governed by these regulations, except as provided in the relevant laws or articles of incorporation.

Article 3 (Definition of terms)

1. In this regulation, “internal information” refers to the disclosure obligations pursuant to Part 1 of the KOSDAQ Market Disclosure Regulations (hereinafter referred to as “Disclosure Regulations”) of the Korea Exchange (hereinafter referred to as “Exchange”) and other matters related to the company’s management or property status, etc.
2. In these regulations, “disclosure officer” refers to a person who can perform reporting duties on behalf of the company in accordance with Article 2 (4) of the disclosure regulations.
3. In these regulations, “executives” refers to directors (including persons falling under any subparagraph of Article 401-2 (1) of the Commercial Act) and auditors.
4. In these regulations, “head of the department in charge of public disclosure” refers to the head of the department in charge of the company’s public disclosure work in accordance with the company’s business and organizational regulations.
5. In addition to paragraphs 1 to 4, the definitions of terms used in these regulations shall be governed by the definitions of terms used in relevant laws and regulations.

Article 4 (Management of internal information)

1. Executives and employees must strictly manage the company's internal information learned in the course of work, and must not leak internal information inside or outside the company, except when necessary for work.
2. If an executive or employee unintentionally leaks internal information, the head of the disclosure department must be notified of this fact without delay.
3. The head of the disclosure department who has received the notification in the preceding paragraph must report the facts to the disclosure manager and take necessary measures, such as fair disclosure, upon receiving instructions from the disclosure manager.
4. The CEO must take necessary measures to manage internal information, such as setting specific standards for storage, delivery, and destruction of internal information and related documents.

Article 5 (Disclosure Officer)

1. The CEO must designate a person responsible for disclosure and report it to the exchange without delay.
2. The person in charge of disclosure is in charge of tasks related to the establishment and operation of the internal information management system and performs the following tasks.
   1. Enforcement of Disclosure
   2. Check and evaluate the operation status of the internal information management system
   3. Review of internal information and decision on whether to disclose it
   4. Measures necessary to operate the internal information management system, such as training for executives and employees
   5. Directing and supervising departments or executives and employees in charge of internal information management or disclosure work.
   6. Other work recognized by the CEO as necessary for the operation of the internal information management system
3. The person in charge of public disclosure has the following authority in performing his/her duties:
   1. The right to request submission of and view various documents and records related to internal information
   2. The right to hear necessary opinions from executives and employees of departments in charge of accounting or audit work, and other departments in charge of work related to the creation of internal information.
4. In carrying out his/her duties, the person in charge of disclosure may consult with executives in charge of related work if necessary and may seek assistance from experts at the company's expense.
5. The person responsible for disclosure must regularly report the operation status of the internal information management system to the CEO (or the Board of Directors).

Article 6 (Disclosure Officer)

1. The CEO must appoint a person in charge of disclosure and report it to the exchange without delay.
2. The public disclosure officer is under the direction of the public disclosure manager in relation to internal information management and performs the following duties.
   1. Collection and review of internal information and reporting to the person responsible for disclosure
   2. Tasks required to execute public notice
   3. Confirmation of matters necessary for management of internal information, such as changes in disclosure-related laws and reports to the person responsible for disclosure
   4. Other matters deemed necessary by the CEO or public disclosure officer

Article 7 (Concentration of internal information)

1. Executives and heads of each department must provide information to the person in charge of disclosure in a timely manner in any of the following cases.
   1. When internal information occurs or is expected to occur (Revised on August 1, 2017)
   2. When a reason to cancel or change internal information that has already been disclosed occurs or is expected to occur (revised on August 1, 2017)
   3. In addition, if there is a request from the head of the department in charge of disclosure

Article 7-2 (Management of information related to the largest shareholder)

1. In order to smoothly carry out the disclosure of disclosure obligations and inquiry disclosure requirements related to the largest shareholder, the person in charge of public disclosure must fully explain relevant facts to the largest shareholder and establish an information delivery system so that the information can be delivered in a timely manner.

Article 7-3 (Concentration of internal information of subsidiaries) (Note added on August 1, 2017)

1. If internal information related to mandatory disclosure occurs or is expected to occur in a subsidiary, the company must have the subsidiary immediately notify the company's public disclosure officer or public disclosure officer.
2. In order to efficiently manage internal information related to the disclosure obligations under Paragraph 1, the company shall have a person in charge of managing disclosure-related information in its subsidiaries, and in case of designation or change, the company's disclosure manager or public disclosure officer shall be notified immediately.
3. The company may request subsidiary companies to submit related data to the extent necessary for disclosure.

Article 8 (Provision of internal information to external parties)

1. If an executive or employee is inevitably required to provide internal information to the company's counterparties, external auditors, agents, or persons with whom the company has entered into an advisory contract such as legal advice or management consulting, etc. for business reasons, the disclosure officer shall be notified of this.
2. In the case of paragraph 1, the person in charge of public disclosure must take necessary measures, such as concluding a contract to maintain confidentiality of related internal information.
3. If a fair disclosure obligation arises in providing internal information pursuant to paragraph 1, this must be disclosed without delay (excluding cases falling under the application exceptions of Article 15 of the Disclosure Regulations).

Article 9 (Types of disclosure)

The company's disclosures are classified as follows.

1. Reporting and disclosure of major management matters in accordance with Part 1, Chapter 2, Section 1 of the Disclosure Regulations
2. Inquiry and disclosure in accordance with Part 1, Chapter 2, Section 2 of the Disclosure Regulations
3. Fair disclosure in accordance with Part 1, Chapter 2, Section 3 of the Disclosure Regulations
4. Voluntary disclosure in accordance with Part 1, Chapter 3 of the Disclosure Regulations
5. Submission of securities report, etc. in accordance with Chapter 1 of Part 3 of the Act
6. Submission of business reports, etc. in accordance with Articles 159, 160, and 165 of the Act and Part 1, Chapter 2, Section 4 of the Public Disclosure Regulations
7. Submission of key facts report pursuant to Article 161 of the Act 8. Public disclosure pursuant to other laws and regulations

Article 9-2 (Confirmation of Disclosure Subject)

1. In determining whether disclosure obligations, including fair disclosure, are applicable in accordance with these regulations, care must be taken to ensure that matters that have or may have a significant impact on stock prices or investment decisions under Article 6, Paragraph 1, Item 4 of the Disclosure Regulations are also included.

Article 10 (Implementation of public notice)

1. If a disclosure matter stipulated in Article 10 occurs, the person in charge of disclosure must prepare the necessary information, prepare the necessary documents, etc. and report it to the head of the department in charge of disclosure and the person in charge of disclosure.
2. The person responsible for public disclosure must review whether the contents and documents in Paragraph 1 do not violate relevant laws and regulations, report this to the CEO, and then make the public announcement.

Article 10-2 (Prompt implementation of public notice)

1. If a disclosure matter pursuant to Article 9 occurs, the person in charge of disclosure must make every effort to ensure that the relevant internal information is disclosed in a timely manner even before the disclosure deadline in accordance with the disclosure regulations.

Article 11 (Follow-up action after disclosure)

If there is an error or omission in the disclosed content or if they wish to cancel or change it, the public disclosure officer and public disclosure officer must take measures to correct it, such as making a correction and public announcement in accordance with Article 30 of the public disclosure regulations, without delay.

Article 12 (Media coverage, etc.)

1. If there is a request for coverage of the company from a media outlet, etc., in principle, the CEO or person in charge of disclosure responds.
2. If you wish to distribute a press release containing important information to investors, such as internal information, to a media outlet, you must reach an agreement with the head of the disclosure department prior to distribution.
3. If the information delivered through the press release falls under the fair disclosure provisions of Article 10, Paragraph 3, the person in charge of public disclosure must prepare a fair disclosure document and publicize it with the approval of the head of the public disclosure department or the person in charge of public disclosure.
4. Executives and employees who learn that media reports are different from facts must report this to the person responsible for public disclosure.

Article 12-2 (Confirmation of press contents)

1. The person in charge of disclosure, the person in charge of disclosure, and the department generating internal information must routinely check company-related reports from media outlets and other sources, and take action to correct any content that is different from the facts.

Article 13 (Corporate Briefing Session)

1. The CEO must recognize that IR activities are a management responsibility of a corporation listed on the KOSDAQ market and strive to build trust with investors by voluntarily and continuously holding corporate information sessions.
2. A corporate briefing session on the company's management details, business plans and prospects, etc. must be held in consultation with the person in charge of disclosure.
3. The public disclosure officer or public disclosure officer must announce the date and time, location, and contents of the corporate briefing session by the day before the briefing session is held, and post related data on the exchange disclosure submission system before the briefing session is held.
4. All executives and employees of the company must be careful to ensure that any information subject to fair disclosure that has not been disclosed in advance is disclosed during the corporate briefing session.

Article 13 2 (Rumors)

1. If a rumor is spread in the market, the person responsible for public disclosure must check whether the rumor is true and whether it constitutes internal information by inquiring the opinions of the relevant business department.
2. As a result of the confirmation in accordance with paragraph 1, if the rumor falls under the disclosure requirements according to the disclosure regulations, the relevant information must be disclosed.

Article 13-3 (Request for provision of information)

1. If a request is made to disclose information related to the company from shareholders or stakeholders, the public disclosure officer must review the legality of the request and decide whether to provide the relevant information.
2. In order to decide whether to provide information, the public disclosure officer may listen to the opinions of the legal department or external legal experts on whether the information requested may affect investors' investment decisions and stock prices.
3. If information is provided pursuant to the decision in paragraph 1, Article 12 (3) shall apply mutatis mutandis.

Article 14 (Return of short-term trading profits)

1. Executives and employees specified in Article 172 (1) of the Act and Article 194 of the Enforcement Decree of the Act may sell or sell specified securities, etc. within 6 months after purchasing them (hereinafter referred to as “specific securities, etc.”) under Article 172 (1) of the Act.
   1. Executives and employees engaged in establishing, changing, promoting, and disclosing key management matters and other related work.
   2. Employees engaged in work related to finance, accounting, planning, and research and development
2. If a shareholder of a company requests the company to request the return of short-term trading profits from a person who has earned short-term trading profits pursuant to paragraph (1), the company must take necessary measures within two months from the date of receiving the request.
3. If the Securities and Futures Commission notifies the company of the occurrence of short-term trading profits pursuant to Paragraph 1, the person responsible for public disclosure shall immediately announce the following matters on the company's Internet homepage.
   1. Status of person who must return short-term trading profits
   2. Short-term trading profit amount
   3. The date on which the Securities and Futures Commission notified the occurrence of short-term trading profits.
   4. Short-term trading profit return claim plan
   5. A shareholder of a company may request the company to request the return of short-term trading profits from the person who obtained the short-term trading profits, and if the company does not make the claim within two months from the date of receiving the request, the shareholder may subrogate the company.
4. The disclosure period under Paragraph 3 shall be two years from the date on which the Securities and Futures Commission notifies the occurrence of short-term trading profits or until the date on which the short-term trading profits are returned, whichever comes first.

Article 15 (Notification on trading of specific securities, etc.)

When executives and employees stipulated in Article 15, Paragraph 1 engage in trading or other transactions of specific securities, etc., they must notify the public disclosure officer of the fact.

Article 16 (Prohibition of use of undisclosed important information)

Executives and employees must not use, or allow others to use, undisclosed important information (including undisclosed important information of affiliated companies) stipulated in Article 174, Paragraph 1 of the Act in the trading of specific securities or other transactions.

Article 17 (Education)

The person responsible for public disclosure and the person in charge of public disclosure must complete training on public disclosure work in accordance with Article 36 and Paragraph 5 of Article 44 of the Public Disclosure Regulations, and the head of the department in charge of public disclosure must make the contents of the training known to relevant executives and employees.

Article 18 (Opening and closing of regulations)

The enactment, revision or abolition of these regulations shall be made by the CEO.

Article 19 (Publication of regulations)

These regulations are published on the company's website.