The purpose of these regulations is to establish matters related to the comprehensive management and appropriate disclosure of the company’s internal information in accordance with the Financial Investment Services and Capital Markets Act (hereinafter referred to as the “Act”) and relevant laws and regulations, to ensure prompt and accurate disclosure, and to prevent insider trading by executives and employees.

① 1. The term “internal information” in these regulations refers to matters subject to disclosure obligations under Part 1 of the KOSDAQ Market 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 status that may affect investors’ investment decisions.

② 2. The term “disclosure officer” in these regulations refers to a person authorized to perform reporting duties on behalf of the company in accordance with Article 2, Paragraph 4 of the Disclosure Regulations.

③ 3. The term “executive” in these regulations 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 4. Except for the definitions provided in Paragraphs 1 to 3, the definitions of terms used in these regulations shall follow those set forth in relevant laws and regulations.

Matters related to disclosure, insider trading, and internal information management shall be governed by these regulations, except as otherwise provided by applicable laws, regulations, or the company’s articles of incorporation.

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

② 2. The CEO shall take necessary measures to manage internal information, such as establishing specific standards for storing, transmitting, and disposing of internal information and related documents.

① The CEO shall appoint a disclosure officer and promptly report the appointment to the Exchange. The same applies when the disclosure officer is changed.

② The disclosure officer oversees the establishment and operation of the internal information management system and performs the following duties:
1. Execution of disclosures
2. Inspection and evaluation of the operation of the internal information management system
3. Review of internal information and determination of disclosure requirements
4. Implementation of necessary measures such as training for executives and employees on the internal information management system
5. Supervision of departments, executives, and employees responsible for managing internal information or disclosure tasks
6. Other tasks recognized as necessary by the CEO for operating the internal information management system

③ The disclosure officer has the following authorities in performing their duties
1. The right to request and review various documents and records related to internal information
2. The right to obtain opinions from executives and employees in departments responsible for accounting, audit, or other internal information-related functions

④ The disclosure officer may consult with the relevant executives if necessary and may seek expert assistance at the company’s expense.

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

① The CEO shall appoint a disclosure manager and promptly report the appointment to the Exchange. The same applies when the disclosure manager is changed.

② The disclosure manager operates under the direction of the disclosure officer in relation to internal information management and performs the following duties:
1. Collection, review, and reporting of internal information to the disclosure officer
2. Execution of tasks necessary for disclosure
3. Verification of regulatory changes related to disclosures and reporting them to the disclosure officer
4. Other tasks deemed necessary by the CEO or disclosure officer

① Executives and department heads must promptly provide information to the disclosure officer in any of the following cases.
1. When internal information arises or is expected to arise
2. When a reason arises or is expected to arise for canceling or changing previously disclosed internal information
3. When requested by the disclosure officer

② The disclosure officer and CEO shall establish an efficient internal information transmission system to ensure timely provision of internal information as per paragraph 1 and may seek cooperation from the disclosure officer in the approval process of disclosure-related tasks.

The disclosure officer shall establish a system to sufficiently explain disclosure obligations and inquiry disclosure requirements to the largest shareholder and ensure timely receipt of relevant information.

① If internal information related to disclosure obligations arises or is expected to arise in a subsidiary, the company must ensure that the subsidiary promptly notifies the disclosure officer or disclosure manager.

② To efficiently manage disclosure-related internal information, the company shall require subsidiaries to designate personnel responsible for managing disclosure-related information and notify the disclosure officer or disclosure manager of any designations or changes.

③ The company may request subsidiaries to submit necessary materials related to disclosure tasks.

① If an executive or employee must provide internal information to a counterparty, external auditor, agent, or legal/management consultant due to business necessity, they must report the matter to the disclosure officer.

② In such cases, the disclosure officer shall take necessary measures such as entering into a confidentiality agreement regarding the internal information.

③ If the provision of internal information triggers a fair disclosure obligation, it must be disclosed without delay, except in cases exempted under Article 15 of the Disclosure Regulations.

The company's disclosures are classified as follows:
1. Reporting and disclosure of major 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 major issue reports under Article 161 of the Act
8. Other disclosures required by laws and regulations

When determining whether a disclosure obligation, including fair disclosure, applies under these regulations, careful attention shall be given to matters that may significantly impact stock prices or investor decisions under Article 6, Paragraph 1, Item 4 of the Disclosure Regulations.

① When a disclosure matter arises as specified in Article 9, the disclosure manager shall prepare the necessary content and documents and report them to the disclosure officer.

② The disclosure officer shall review the content and documents for compliance with relevant regulations, report to the CEO, and proceed with the disclosure.

The Disclosure Officer shall make every effort to ensure that internal information is disclosed in a timely manner, even before the disclosure deadline stipulated in the disclosure regulations, if a disclosure matter under Article 9 arises.

The Disclosure Officer and Disclosure Staff shall promptly take corrective actions, including revising the disclosure in accordance with Article 30 of the Disclosure Regulations, if there are any errors, omissions, cancellations, or changes in the disclosed information.

① In principle, the CEO or the Disclosure Officer shall respond to requests for interviews from the media. If necessary, executives or employees from relevant departments may be designated to respond.

② When the company intends to distribute press releases to the media, it shall consult with the Disclosure Officer. If necessary, the Disclosure Officer shall report matters related to the distribution of press releases to the CEO.

③ If the content of the press release to be distributed under Paragraph 2 falls under the category of fair disclosure, the Disclosure Officer shall ensure that it is disclosed before the release of the press material.

④ If an executive or employee becomes aware that a media report contains inaccurate information, they shall report it to the Disclosure Officer. The Disclosure Officer shall then report the matter to the CEO and take necessary corrective actions.

The Disclosure Officer, the Disclosure Staff, and the department responsible for internal information shall regularly monitor media reports related to the company and take necessary corrective measures if any inaccurate information is identified.

① The CEO shall recognize that investor relations (IR) activities are a managerial responsibility of a KOSDAQ-listed company and shall make voluntary and continuous efforts to hold corporate briefings to build trust with investors.

② Corporate briefings regarding the company’s management, business plans, and outlook shall be held in consultation with the Disclosure Officer.

③ The Disclosure Officer or Disclosure Staff shall disclose the date, location, and content of the corporate briefing by the day before the event and submit relevant materials to the stock exchange disclosure submission system before the briefing.

④ All executives and employees of the company shall ensure that any information subject to fair disclosure that has not been disclosed in advance is not revealed during the corporate briefing.

① If rumors are circulating in the market, the Disclosure Officer shall verify their accuracy and determine whether they constitute inside information by consulting with the relevant business departments.

② To decide whether to provide information, the Disclosure Officer may seek opinions from the legal department or external legal experts on whether the requested information could affect investors' investment decisions or stock prices.

③ If information is provided based on the determination under Paragraph 1, Article 12, Paragraph 3 shall apply mutatis mutandis.

① When a shareholder or stakeholder requests the disclosure of information related to the company, the disclosure officer must examine the legality of the request and decide whether to provide the relevant information.

② In order to decide whether to provide the information, the disclosure officer may seek the opinion of the legal department or external legal experts regarding whether the requested information could influence investors' investment decisions or the stock price.

③ If information is provided in accordance with the decision in paragraph 1, the provisions of Article 12, Paragraph 3 shall apply mutatis mutandis

① Executives and employees as defined in Article 172(1) of the Act and Article 194 of the Enforcement Decree of the Act (hereinafter referred to as "specific securities, etc.") must return any profits (hereinafter referred to as "short-term trading profits") obtained by purchasing such specific securities and selling them within 6 months or by selling such specific securities and purchasing them within 6 months.

② If a shareholder of the company (including those who own equity securities other than stock certificates or securities depositary receipts, hereinafter referred to as the same in this Article) requests the company to demand the return of short-term trading profits from a person who has obtained them as per paragraph 1, the company must take necessary actions within 2 months from the date the request is received.

③ If the Financial Services Commission notifies the company of the occurrence of short-term trading profits under paragraph 1, the disclosure officer must promptly disclose the following details on the company’s website:
1. The position of the person who must return the short-term trading profits
2. The amount of short-term trading profits
3. The date the company received the notification from the Financial Services Commission regarding the occurrence of short-term trading profits
4. The plan for claiming the return of short-term trading profits
5. The right of the company's shareholders to request the company to demand the return of short-term trading profits from the person who obtained them, and that if the company does not make the demand within 2 months of receiving the request, the shareholder may claim on behalf of the company.

④ The disclosure period in paragraph 3 is for 2 years from the date the company receives the notification of the occurrence of short-term trading profits from the Financial Services Commission, or until the earlier of the date the short-term trading profits are returned.

Executives and employees as defined in Article 172(1) of the Act and Article 194 of the Enforcement Decree of the Act must notify the disclosure officer whenever they engage in the trading or other transactions involving specific securities, etc.

Executives and employees as defined in Article 172(1) of the Act and Article 194 of the Enforcement Decree of the Act are prohibited from trading specific securities, etc., or engaging in other transactions based on non-public important information.

① The disclosure officer and the disclosure staff must complete training related to disclosure tasks as specified in Article 36 and Article 44(5) of the Disclosure Regulations, and the disclosure officer must inform relevant executives and employees about the content of the training.

② The CEO must make sufficient efforts to conduct training for executives and employees on matters from Article 14 to Article 16, as well as other internal trading prevention measures as prescribed by law.

The amendment or repeal of these regulations shall be carried out by the CEO.

These regulations shall be published on the company's website. The same applies when the regulations are amended.