Chapter 1. General Provisions

Article 1 [Purpose]

The purpose of these regulations is to establish comprehensive management and appropriate disclosure of the company's internal information, as well as to prevent insider trading by executives and employees, in accordance with the Capital Markets and Financial Investment Business Act (hereinafter referred to as the "Act") and related laws.

Article 2 [Definitions]

① In these regulations, "inside information" refers to disclosure obligations under 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 that may affect the company's management, financial status, or investors' investment decisions.

② In these regulations, "disclosure officer" refers to a person authorized to perform reporting duties on behalf of the company pursuant to Article 2, Paragraph 4 of the Disclosure Regulations.

③ In these regulations, "executive" refers to directors (including those specified in Article 401-2, Paragraph 1 of the Commercial Act) and auditors.

④ Terms used in these regulations, other than those defined in Paragraphs 1 through 3, shall follow the definitions provided in relevant laws and regulations.

Article 3 [Scope of Application]

Matters concerning disclosure, insider trading, and inside information management shall be governed by these regulations, except as otherwise provided by relevant laws or the company's articles of incorporation.

Chapter 2. Management of Inside Information

Article 4 [Management of Inside Information]

① Executives and employees must strictly manage the company's inside information obtained in the course of their duties and must not disclose such information internally or externally except when necessary for business purposes.

② The CEO shall establish specific standards for the storage, transfer, and destruction of inside information and related documents, and take necessary measures for the management of inside information.

Article 5 [Disclosure Officer]

① The CEO shall appoint a disclosure officer and promptly report this to the Exchange. The same applies when changing the disclosure officer.

② The disclosure officer shall oversee the establishment and operation of the inside information management system and perform the following duties:

  • 1. Execution of disclosures
  • 2. Inspection and evaluation of the operation of the inside information management system
  • 3. Review of inside information and decision on disclosure
  • 4. Necessary measures such as training for officers/employees
  • 5. Direction and supervision of departments or personnel responsible for information management or disclosure
  • 6. Other matters deemed necessary by the CEO

③ The disclosure officer shall have the following authority in performing their duties:

  • 1. Authority to request and inspect documents and records related to inside information
  • 2. Authority to hear necessary opinions from departments related to accounting/audit or other relevant departments

④ The disclosure officer may consult with executives responsible for related tasks when necessary and may seek assistance from experts at the company's expense.

⑤ The disclosure officer shall regularly report the status of the inside information management system to the CEO (or the board of directors).