Chapter 1 General Provisions

Article 1 (Purpose)

The purpose of this regulation is to prescribe matters concerning the comprehensive management and appropriate disclosure of the company’s internal information for prompt and accurate disclose according to the Financial Investment Services and Capital Markets Act (hereinafter referred to as the "Act") and various laws and regulations and to prevent insider trading of executives and employees.

Article 2 (Definition of Terms)

• ① In this regulation, the term "internal information" refers to matters that may affect investors' investment judgment in relation to the disclosure obligations under Part 1 of the KOSDAQ Market Disclosure Regulation (hereinafter referred to as “Disclosure Regulation") of the Korea Exchange (hereinafter referred to as "Exchange") and the management or property situation of the company.
• ② In this regulation, the term "disclosure manager" means a person who can perform reporting on behalf of the company pursuant to Article 2 (4) of the Disclosure Regulation.
• ③ In this regulation, the term "executives" means directors (including persons falling under any subparagraph of Article 401-2 (1) of the Commercial Act) and auditors.
• ④ Apart from paragraphs (1) through (3), the definition of terms used in this regulation shall be governed by the definition of terms used in relevant laws and regulations.

Article 3 (Scope of Application)

Matters concerning disclosure, insider trading, and internal information management shall be governed by this regulation, except as prescribed by relevant laws and regulations or articles of association.

Chapter 2 Management of Internal Information

Article 4 (Management of Internal Information)

• ① Executives. executives and employees shall strictly manage the internal information of the company they have learned in business, and shall not leak such internal information to inside or outside the company except where necessary for business.
• ② The CEO shall take necessary measures for internal information management, such as setting specific standards for storage, delivery, and destruction of internal information and related documents, etc.

Article 5 (Disclosure Manager)

• ① The CEO shall determine the disclosure manager and report it to the Exchange without delay. The same applies when the disclosure manager is changed.
• ② The disclosure manager oversees the affairs related to the establishment and operation of the internal information management system and performs the following tasks:
  • 1. Execution of disclosure
  • 2. Inspection and evaluation of the operation status of the internal information management system
  • 3. Review of internal information and decision on whether to disclose
  • 4. Measures necessary for the operation of the internal information management system, such as training for executives and employees
  • 5. Command and supervision of departments or executives and employees in charge of managing internal information or taking care of disclosure
  • 6. Other duties recognized by the CEO as necessary for the operation of the internal information management system
• ③ The disclosure manager has the following authority in performing his/her duties.
  • 1. The authority to request and view various documents and records related to internal information
  • 2. The authority to hear necessary opinions from executives and employees of the department in charge of accounting or audit affairs, or other departments in charge of affairs related to the generation of internal information.
• ④ The disclosure manager may consult with an executive in charge of related tasks, if necessary in conducting his/her duties, and seek expert assistance at the company's expense.
• ⑤ The disclosure manager shall regularly report the operation status of the internal information management system to the CEO (or the board of directors).

Article 6 (Disclosure Staff)

• ① The CEO shall appoint a disclosure staff and report it to the Exchange without delay. The same applies when the disclosure staff is changed.
• ② The disclosure staff person shall perform the following duties under the direction of the disclosure manager in relation to internal information management.
  • 1. Collection and review of internal information and reporting to the disclosure manager
  • 2. Tasks necessary for the execution of disclosure
  • 3. Confirmation of matters necessary for the management of internal information, such as changes in laws and regulations related to disclosure, and reporting to the disclosure manager
  • 4. Other matters deemed necessary by the CEO or the disclosure manager

Article 7 (Concentration of Internal Information)

• ① Executives and the head of each department shall provide the information to the disclosure manager in a timely manner in any of the following cases.
  • 1. Where internal information occurs or is expected to occur
  • 2. Where there is a reason to cancel or change the matters already disclosed in the internal information, or if it is expected to occur,
  • 3. In other cases requested by the disclosure manager
• ② The disclosure manager and the CEO shall efficiently establish an information delivery system within the company to provide internal information pursuant to paragraph 1 in a timely manner, and if necessary, shall seek cooperation from the disclosure manager in the process of approval of work related to disclosure obligations.

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

In order to smoothly perform disclosure obligations and inquiry disclosure requirements related to the largest shareholder, the disclosure manager shall establish an information delivery system to fully explain the relevant facts to the largest shareholder and receive the information in a timely manner.

Article 7-3 (Concentration of Internal Information of Subsidiaries)

• ① If internal information related to disclosure obligations occurs or is expected to occur in a subsidiary, the company shall have the subsidiary immediately notify the disclosure manager or the disclosure staff of the company.
• ② In order to efficiently manage internal information related to disclosure obligations under paragraph 1, the company shall ensure that a subsidiary has a person who manages disclosure-related information, and immediately notify the company's disclosure manager or disclosure staff if designated or changed,
• ③ The company may request a subsidiary to submit relevant data to the extent necessary for the disclosure work.

Article 8 (Provision to Outside of Internal Information)

• ① If an executive or employee has to provide internal information to the company's counterparty, external auditor, agent or a person who has signed an advisory contract for legal advice, management advisory, etc. for business reasons, he/she shall report this to the disclosure manager.
• ② In the case of paragraph 1, the disclosure manager shall take necessary measures, such as signing a contract on the confidentiality of related internal information.
• ③ In the event that there is a fair disclosure obligation in providing internal information pursuant to paragraph 1, it shall be disclosed without delay. (Except cases falling under the exception to the application of Article 15 of the Disclosure Regulation).

Chapter 3 Disclosure of Internal Information

Article 9 (Type of Disclosure)

The company's disclosures are classified as follows:

• 1. Report and disclosure of major management matters pursuant to Section 1 of Chapter 2 of Part 1 of the Disclosure Regulation.
• 2. Disclosure of inquiry pursuant to Section 2 of Chapter 2 of Part 1 of the Disclosure Regulation.
• 3. Fair disclosure pursuant to Section 3 of Chapter 2 of Part 1 of the Disclosure Regulation.
• 4. Autonomous disclosure pursuant to Chapter 3 of Part 1 of the Disclosure Regulation.
• 5. Submission of a securities report, etc. pursuant to Chapter 1 of Part 3 of the Act.
• 6. Submission of business reports, etc. pursuant to Articles 159, 160 and 165 of the Act and Section 4 of Chapter 2 of Part 1 of the Disclosure Regulation.
• 7. Submission of a report on major matters pursuant to Article 161 of the Act.
• 8. Disclosure in accordance with other laws and regulations.

Article 9-2 (Confirmation of Matters subject to Disclosure)

In determining whether subject to disclosure obligations, including fair disclosure, according to this regulation, care should be taken to include matters that may significantly affect or affects stock prices or investment judgments under Article 6 (1) 4 of the Disclosure Regulation.

Article 10 (Execution of Disclosure)

In determining whether subject to disclosure obligations, including fair disclosure, according to this regulation, care should be taken to include matters that may significantly affect or affects stock prices or investment judgments under Article 6 (1) 4 of the Disclosure Regulation.

• ① Where a matter subject to disclosure prescribed in Article 9 occurs, disclosure staff shall prepare necessary contents and documents, etc. and report them to the disclosure manager.
• ② The disclosure manager shall review whether the contents and documents of paragraph 1 violate the relevant laws and regulations, report them to the CEO, and afterwards disclose them.

Article 10-2 (Fast Implementation of Disclosure)

Where a matter subject to disclosure prescribed in Article 9 occurs, the disclosure manager shall make every effort to ensure that the relevant internal information is disclosed in a timely manner even before the disclosure deadline under the Disclosure Regulation.

Article 11 (Post-disclosure Measures)

The disclosure manager and disclosure staff shall take measures to correct the disclosure, such as corrective disclosure, in accordance with Article 30 of the Disclosure Regulation without delay in the case where there is an error or omission in the disclosed contents, or in the case of intending to cancel or change them.

Article 12 (Press Coverage, etc.)

• ① If there is a request for coverage of the company from the press, etc. in principle, the CEO or the disclosure manager shall respond to it. If necessary, executives and employees of related departments may be required to respond to the coverage.
• ② If the company intends to distribute press releases to the press, etc. it shall consult with the disclosure manager. The disclosure manager shall, if necessary, report matters related to the distribution of press releases to the CEO.
• ③ If the contents of the press release distributed pursuant to paragraph 2 are subject to fair disclosure, the disclosure manager shall disclose them before the distribution of the press release.
• ④ executives and employees who find that the content of the press is different from the facts must report it to the disclosure manager. The disclosure manager shall report the relevant matters to the CEO and take necessary measures.

Article 12-2 (Confirmation of the Contents of the Press)

The disclosure manager and disclosure staff, and internal information generation department shall routinely check the company-related contents of the press, etc., and take measures to correct them if there are any contents different from the facts.

Article 13 (Corporate Briefing)

• ① In recognition that IR activities are the management responsibility of KOSDAQ-listed corporations the CEO shall endeavor to build trust with investors by voluntarily and continuously holding corporate briefings.
• ② Corporate briefings for the company's management, business plans and prospects, etc. shall be held in consultation with the disclosure manager.
• ③ The disclosure manager or disclosure staff shall disclose the date, place, and contents of the corporate briefing until the day before holding it and post related data on the Exchange's disclosure submission system before the briefing is held.
• ④ All executives and employees of the company shall be careful not to disclose matters not announced beforehand among information subject to fair disclosure in the process of corporate briefing.

Article 13-2 (Rumors)

• ① When rumors are circulating in the market, the disclosure manager shall check whether the rumors are true and whether they fall under internal information through inquiring the relevant department.
• ② If such rumors are confirmed to fall under the disclosure obligations according to the Disclosure Regulation as a result to paragraph 1, relevant information shall be disclosed.

Article 13-3 (Request for Information)

• ① If requested to provide information related to the company from shareholders and stakeholders, etc. the disclosure manager shall review the legality of such request, and determine whether or not to provide relevant information.
• ② In order to determine whether to provide information, the disclosure manager may listen to opinions from the legal department or external legal experts on whether the information requested can affect investors' investment decisions and stock prices.
• ③ Article 12 (3) shall apply mutatis mutandis to providing information according to the decision under paragraph 1.

Chapter 4 Regulation on Insider Transactions, etc.

Article 14 (Return of Short-term Trading Gains)

• ① executives and employees prescribed in Article 172 (1) of the Act and Article 194 of the Enforcement Decree of the Act shall return the profits obtained by selling within 6 months after purchasing specific securities, etc. under Article 172 (1) of the Act (hereinafter referred to as "specific securities, etc.") or purchasing within 6 months after selling specific securities, etc. (hereinafter referred to as "short-term trading gains") to the company.
• ② In the event that the shareholders of the company (including those who own equity securities or securities deposits other than stock certificates. Hereinafter, the same applies) request the company to claim the return of the short-term trading gains from the person who has obtained short-term trading gains under paragraph 1, the company shall take necessary measures within 2 months from the date of receipt of such request.
• ③ When the Securities and Futures Commission notifies the company of the occurrence of short-term trading gains under paragraph 1, the disclosure manager shall disclose the following matters on the company's Internet homepage without delay.
  • 1. The position of a person who is required to return short-term trading gains.
  • 2. Amount of short-term trading gains.
  • 3. The date of being notified of the occurrence of short-term trading gains from the Securities and Futures Commission.
  • 4. A plan to claim the return of profits from short-term sales.
  • 5. A shareholder of the company may request the company to claim the return of the short-term trading gains from the person who has obtained short-term trading gains, and if the company fails to make the claim within 2 months from the date of receipt of the request, the shareholder can subrogate the company.
• ④ The period of disclosure under paragraph 3 shall be 2 years from the date of receipt of the notification of short-term trading gains from the Securities and Futures Commission, or the date of return of short-term trading gains, which is earlier.

Article 15 (Notification of the Trading, etc. of Specific Securities, etc.)

executives and employees prescribed by Article 172 (1) of the Act and Article 194 of the Enforcement Decree of the Act shall notify the disclosure manager of the fact in the event of trading or other transactions of specific securities, etc.

Article 16 (Prohibition of Use of Important Undisclosed Information)

executives and employees shall not use or have others use important undisclosed information (including important undisclosed information of affiliates) prescribed in Article 174 (1) of the Act for trading or other transactions of specific securities, etc.

Chapter 5 Supplementary Provisions

Article 17 (Education)

• ① The disclosure manager and disclosure staff shall complete education, etc. on disclosure pursuant to Articles 36 and 44 (5) of the Disclosure Regulation, and the disclosure manager shall inform the relevant executives and employees of the contents of education.
• ② The CEO shall make sufficient efforts, such as the implementation of training to executives and employees to prevent matters under Articles 14 through 16 and other insider transactions, etc. prescribed by the Act.

Article 18 (Revision or Abolition of Regulation)

The revision or abolition of this regulation shall be made by the CEO.

Article 19 (Publication of Regulation)

This regulation shall be published on the company's website. The same applies when revising the regulation.

Additional Clause

This regulation takes effect on September 1, 2017.