Internal Information Management Regulation

General Provisions

1. Purpose
The purpose of these Regulations is to establish comprehensive management and appropriate disclosure of internal information of the Company in order to ensure prompt and accurate disclosure in accordance with the “Financial Investment Services and Capital Markets Act” (hereinafter referred to as the “Act”) and relevant regulations, and to prevent insider trading by officers and employees.
2. Scope of Application
Matters concerning disclosure, insider trading, and internal information management shall be governed by these Regulations, except as otherwise provided by applicable laws and regulations or the Articles of Incorporation.
3. Definitions

1. In these Regulations, “Internal Information” means matters subject to mandatory disclosure pursuant to Part 1 of the KOSDAQ Market Disclosure Regulations (hereinafter referred to as “Disclosure Regulations”) of the Korea Exchange (hereinafter referred to as the “KRX”), as well as other matters relating to the management or financial status of the Company that may affect investment decisions of investors.

2. In these Regulations, “Chief Disclosure Officer” means a person who is authorized to perform reporting duties on behalf of the Company pursuant to Article 2, Paragraph 4 of the Disclosure Regulations.

3. In these Regulations, “Officer” means directors (including those falling under any subparagraph of Article 401-2, Paragraph 1 of the Commercial Act) and auditors.

4. The definitions of terms used in these Regulations other than those set forth in Paragraphs 1 through 3 shall be governed by the definitions used in applicable laws and regulations.

Management of Internal Information

4. Management of Internal Information

1. Officers and employees shall strictly manage Internal Information obtained in the course of their duties and shall not disclose Internal Information internally or externally, except where required for business purposes.

2. The Chief Executive Officer shall take necessary measures for the management of Internal Information, including establishing specific standards for the storage, transmission, and destruction of Internal Information and related documents.

5. Chief Disclosure Officer

1. The Chief Executive Officer shall designate the Chief Disclosure Officer and promptly report such designation to the KRX. The same shall apply when the Chief Disclosure Officer is changed.

2. The Chief Disclosure Officer shall oversee all duties related to the establishment and operation of the internal information management system and shall perform the following duties:

  • • Execution of disclosure
  • • Monitoring and evaluation of the operation of the internal information management system
  • • Review of Internal Information and determination of whether to disclose
  • • Necessary measures for the operation of the internal information management system, including education of officers and employees
  • • Direction and supervision of departments or officers and employees in charge of internal information management or disclosure duties
  • • Other duties recognized by the CEO as necessary for the operation of the internal information management system

3. In performing his/her duties, the Chief Disclosure Officer shall have the following authorities:

  • • Authority to request submission of and inspect various documents and records related to Internal Information
  • • Authority to hear necessary opinions from officers and employees of departments in charge of accounting or audit duties, and other departments in charge of duties related to the generation of Internal Information

4. In performing his/her duties, the Chief Disclosure Officer may consult with officers in charge of relevant duties when necessary, and may seek assistance from external experts at the Company’s expense.

5. The Chief Disclosure Officer shall regularly report the operation status of the internal information management system to the CEO (or the Board of Directors).

6. Disclosure Officer

1. The Chief Executive Officer shall designate a Disclosure Officer and promptly report such designation to the KRX. The same shall apply when the Disclosure Officer is changed.

2. The Disclosure Officer shall carry out the following duties under the direction of the Chief Disclosure Officer with respect to internal information management:

  • • Collection and review of Internal Information and reporting to the Chief Disclosure Officer
  • • Duties necessary for the execution of disclosure
  • • Confirmation of matters necessary for the management of Internal Information, such as changes in disclosure-related laws and regulations, and reporting to the Chief Disclosure Officer
  • • Other matters recognized as necessary by the CEO or the Chief Disclosure Officer
7. Centralization of Internal Information

1. Officers and heads of each department shall promptly provide the Chief Disclosure Officer with relevant information in any of the following cases:

  • • When Internal Information arises or is expected to arise
  • • When a reason arises or is expected to arise for cancelling or changing already-disclosed Internal Information
  • • Upon request by the Chief Disclosure Officer

2. The Chief Disclosure Officer and the CEO shall efficiently establish an information delivery system within the Company for the timely provision of Internal Information pursuant to Paragraph 1, and may, if necessary, require the approval process for duties related to mandatory disclosure matters to involve the cooperation of the Chief Disclosure Officer.

8. Management of Information Relating to Largest Shareholders
The Chief Disclosure Officer shall establish an information delivery system to ensure that the largest shareholders are sufficiently informed of relevant facts and that relevant information is received in a timely manner, in order to smoothly perform disclosure duties related to mandatory disclosure matters and inquiry disclosure requests relating to the largest shareholders.
9. External Provision of Internal Information

1. When officers and employees inevitably need to provide Internal Information to the Company’s counterparties, external auditors, agents, or parties with whom the Company has entered into advisory agreements (including legal and management advisory agreements) for business reasons, they shall report such matters to the Chief Disclosure Officer.

2. In the case of Paragraph 1, the Chief Disclosure Officer shall take necessary measures, including entering into a confidentiality agreement with respect to the relevant Internal Information.

3. If a fair disclosure obligation arises in connection with the provision of Internal Information pursuant to Paragraph 1, such information shall be disclosed without delay (except in cases falling under the exceptions to the application of Article 15 of the Disclosure Regulations).

Disclosure of Internal Information

10. Types of Disclosure

The Company’s disclosures shall be categorized as follows:

  • 1. Filing and disclosure of major management matters pursuant to Section 1, Chapter 2, Part 1 of the Disclosure Regulations
  • 2. Inquiry disclosure pursuant to Section 2, Chapter 2, Part 1 of the Disclosure Regulations
  • 3. Fair disclosure pursuant to Section 3, Chapter 2, Part 1 of the Disclosure Regulations
  • 4. Voluntary disclosure pursuant to Chapter 3, Part 1 of the Disclosure Regulations
  • 5. Submission of securities registration statements, etc. pursuant to Chapter 1, Part 3 of the Act
  • 6. Submission of business reports, etc. pursuant to Articles 159, 160, and 165 of the Act and Section 4, Chapter 2, Part 1 of the Disclosure Regulations
  • 7. Submission of material change reports pursuant to Article 161 of the Act
  • 8. Other disclosures pursuant to applicable laws and regulations
11. Confirmation of Disclosure Targets
In determining whether a matter, including fair disclosure, falls under mandatory disclosure obligations pursuant to these Regulations, care shall be taken to include matters that have or may have a material effect on stock prices or investment decisions pursuant to Article 6, Paragraph 1, Subparagraph 4 of the Disclosure Regulations.
12. Execution of Disclosure

1. When a disclosure event set forth in Article 9 occurs, the Disclosure Officer shall prepare the necessary content and gather the necessary documents and report to the Chief Disclosure Officer.

2. The Chief Disclosure Officer shall review whether the content and documents of Paragraph 1 comply with applicable laws and regulations, report to the CEO, and then make the disclosure.

13. Prompt Execution of Disclosure
When a disclosure event pursuant to Article 9 occurs, the Chief Disclosure Officer 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 Regulations.
14. Post-Disclosure Follow-up Measures
When disclosed content contains errors or omissions, or when the Company wishes to cancel or change the disclosed content, the Chief Disclosure Officer and the Disclosure Officer shall take measures to correct such issues without delay, including filing a corrective disclosure pursuant to Article 30 of the Disclosure Regulations.
15. Media Coverage, etc.

1. In principle, the CEO or the Chief Disclosure Officer shall respond to media coverage requests regarding the Company. If necessary, officers and employees of relevant departments may be allowed to respond to media inquiries.

2. When the Company intends to distribute press releases to media outlets, it shall consult with the Chief Disclosure Officer. The Chief Disclosure Officer shall, if necessary, report matters related to the distribution of press releases to the CEO.

3. If the content of a press release distributed pursuant to Paragraph 2 falls under the subject of fair disclosure, it shall be disclosed before the distribution of the press release.

4. Officers and employees who become aware that media coverage contains inaccurate information shall report such matters to the Chief Disclosure Officer. The Chief Disclosure Officer shall report the relevant matters to the CEO and take necessary measures.

16. Verification of Media Coverage
The Chief Disclosure Officer, the Disclosure Officer, and the department where Internal Information is generated shall routinely review media coverage related to the Company and take measures to correct any inaccuracies.
17. Investor Relations Events

1. The CEO shall recognize that IR activities are a management responsibility of companies listed on the KOSDAQ market and shall make efforts to voluntarily and continuously hold investor relations events to build trust with investors.

2. Investor relations events regarding the Company’s management, business plans, and prospects shall be held in consultation with the Chief Disclosure Officer.

3. The Chief Disclosure Officer or the Disclosure Officer shall disclose the date, venue, and content of investor relations events by the day before the event, and post relevant materials on the KRX disclosure submission system before the event.

4. All officers and employees of the Company shall take care not to disclose any fair disclosure information that has not been previously disclosed during investor relations events.

18. Rumors

1. When rumors are circulating in the market, the Chief Disclosure Officer shall verify whether the content of the rumors is true and whether it constitutes Internal Information, including by soliciting opinions from relevant business departments.

2. If, as a result of the verification pursuant to Paragraph 1, the rumor falls under mandatory disclosure obligations under the Disclosure Regulations, the relevant information shall be disclosed.

19. Requests for Information

1. When a request for disclosure of Company-related information is received from shareholders or interested parties, the Chief Disclosure Officer shall review the legality of the request and decide whether to provide the relevant information.

2. In order to decide whether to provide information, the Chief Disclosure Officer may seek opinions from the legal department or external legal experts as to whether the requested information may affect investors’ investment decisions or stock prices.

3. When information is provided pursuant to the decision under Paragraph 1, Article 12, Paragraph 3 shall apply mutatis mutandis.

Regulation of Insider Trading

20. Return of Short-Swing Profits

1. Officers and employees designated under Article 172, Paragraph 1 of the Act and Article 194 of the Enforcement Decree of the Act shall return to the Company any profits (hereinafter referred to as “Short-Swing Profits”) earned by purchasing specified securities, etc. under Article 172, Paragraph 1 of the Act (hereinafter referred to as “Specified Securities, etc.”) and selling them within 6 months, or by selling Specified Securities, etc. and repurchasing them within 6 months.

2. If a shareholder of the Company (including a holder of equity securities other than share certificates or depositary receipts; hereinafter the same in this Article) requests the Company to demand the return of Short-Swing Profits from a person who has obtained Short-Swing Profits pursuant to Paragraph 1, the Company shall take necessary measures within 2 months from the date of receiving such request.

3. When the Securities and Futures Commission notifies the Company of the occurrence of Short-Swing Profits pursuant to Paragraph 1, the Chief Disclosure Officer shall promptly disclose the following matters on the Company’s website:

  • • Position of the person required to return Short-Swing Profits
  • • Amount of Short-Swing Profits
  • • Date of notification from the Securities and Futures Commission of the occurrence of Short-Swing Profits
  • • Plan for demanding the return of Short-Swing Profits
  • • A statement that a shareholder of the Company may request the Company to demand the return of Short-Swing Profits from the person who has obtained Short-Swing Profits, and that if the Company fails to make such a claim within 2 months from the date of receiving such a request, the shareholder may make the claim on behalf of the Company

4. The disclosure period under Paragraph 3 shall be for 2 years from the date of notification from the Securities and Futures Commission of the occurrence of Short-Swing Profits, or until the date on which the Short-Swing Profits are returned, whichever comes first.

21. Notification of Trading of Specified Securities, etc.
Officers and employees designated under Article 172, Paragraph 1 of the Act and Article 194 of the Enforcement Decree of the Act shall notify the Chief Disclosure Officer when they trade or otherwise transact in Specified Securities, etc. However, trading records notified to the Company through the KRX Listed Company Executive and Employee Insider Trading Alert Service (K-ITAS) shall be deemed to have been notified to the Chief Disclosure Officer.
22. Prohibition on Use of Material Non-Public Information
Officers and employees shall not use material non-public information specified in Article 174, Paragraph 1 of the Act (including material non-public information of affiliated companies) in trading Specified Securities, etc. or in other transactions, or cause others to use such information.

Supplementary Provisions

23. Education

1. The Chief Disclosure Officer and the Disclosure Officer shall complete training on disclosure duties pursuant to Articles 36 and 44, Paragraph 5 of the Disclosure Regulations, and the Chief Disclosure Officer shall inform relevant officers and employees of the training content.

2. The CEO shall make sufficient efforts to provide education to officers and employees on matters set forth in Articles 14 through 16 and other insider trading prevention measures prescribed by law.

Addendum

These Regulations shall be enacted and come into effect on March 12, 2025.