Article 1 (Purpose) The purpose of this Regulation is to regulate matters on the general management of the corporate information and disclosure of the information for the quick and accurate public disclosure and prevention of insider trading between executive officers and employees in accordance with “Financial Investment Services and Capital Markets Act” (hereinafter referred to as “Act”) and related statutes.

Article 2 (Definition of Terms) ① “Inside Information” means the matters regarding the obligations of public disclosure under Part 1 of the Disclosure of the KOSDAQ Market (hereinafter referred to as “Disclosure Regulation”) and other matters including the status of business or property that may affect the investor’s investment judgment.
② “Disclosure Officer” means a person who is capable of filing the registration statement on behalf of the Company in accordance with Paragraph 4, Article 2 of the Disclosure Regulation.
③ “Executive Officer” means a director (including a person falling under any Subparagraphs of Paragraph 1, Article 401-2 of “Commercial Act”) and an auditor.
④ The definition of the terms used in this Regulation in addition to Paragraph 1 to Paragraph 3 shall follow the definitions of the terms used in the relevant Acts and statutes.

Article 3 (Scope of Application) The matters regarding the public disclosure, insider trading, and inside information management shall be in compliance with this Regulation unless otherwise regulated in the relevant Acts or Articles of Association.

Article 4 (Management of Inside Information) ① Executive officers and employees shall thorough manage the inside information obtained in the course of business and shall not leak the inside information internally or externally unless otherwise necessary for the business.
② Representative Director shall take necessary measures for management of the inside information, such as specifying the criteria for the storage, transmission, destruction, etc. of the inside information and other relevant documents.

Article 5 (Disclosure Officer) ① Representative Director shall designate a Disclosure Officer and report to the Korea Exchange. This shall also apply in case of changing the Disclosure Officer.
② The Disclosure Officer shall be in charge of the tasks related to establishment and operation of the Inside Information Management System and shall perfume following task : 1. Execute a public disclosure;
2. Inspect and evaluate on operation of Inside Information Management System;
3. Examine the inside information and make decisions on public disclosure;
4. Take necessary measures for operating Inside Information Management System such as education on the executive officer and employees;
5. Direct and supervise the department, executive officer, or employee in charge of managing the inside information or public disclosure;
6. Other affairs that are deemed necessary by the Representative Director for operating the Inside Information Management System. ③ Disclosure Officer shall be given following rights in performing the duties : 1. The right to request the submission of, and view, various documents and records related to the inside information;
2. The right to request the opinions from the executive officers and employees from the department in charge of accounting, auditing, or other affairs related to generation of the inside information. ④ The Disclosure Officer may consult with the executive officer in charge of the related affairs when necessary, and may ask for the assistance from the experts at the expense of the Company.
⑤ The Disclosure Officer shall make a regular report to the Representative Director (or Board of Director) of the status of the International Information Management System.

Article 6 (Disclosure Manager) ④ The Representative Director shall designate a Disclosure Manager and report to the Korea Exchange. This shall also apply in case of changing the Disclosure Manager.
① The Disclosure Manager shall perform the following tasks under the direction of the Disclosure Officer : 1. Collect and review inside information and report to the Disclosure Officer;
2. Perform affairs necessary for the execution of the public disclosure;
3. Confirm on matters necessary for the management of inside information, such as changes in public disclosure-related regulations, and shall report to the Disclosure Officer;
4. Other matters that are deemed necessary by the Representative Director or Disclosure Officer.

Article 7 (Concentration of Inside Information) ① The executive officer and head of each department shall provide the corresponding information to the Disclosure Officer in time when falling under any of the following cases : 1. Where inside information occurs or is expected to occur;
2. Where there occurs or expected to occur any reasons for cancelling or changing the previously disclosed matters among the inside information;
3. Any other cases requested by the Disclosure Officer. ② Disclosure Officer and the Representative Director shall establish the information delivery system to deliver the inside information pursuant to Paragraph 1 in time and may have cooperation of the Disclosure Officer in the process of approving the affairs related to the required public disclosure, if necessary.

Article 8 (Management of Information Regarding The Largest Shareholder) The Disclosure Officer shall explain the largest shareholder of the all relevant facts and shall establish the information delivery system to deliver the corresponding information in time for the smooth execution of the public disclosure obligations associated with the largest shareholder and requests on the inquiry.

Article 9 (Concentration of Inside Information of Subsidiary Company) ① Where internal information associated with the public disclosure obligations occur or is expected to occur at the Subsidiary Company, the Company shall have the Subsidiary Company notify the related matters to the Disclosure Officer or Disclosure Manager of the Company.
② The Company shall have the Subsidiary Company designate a person in charge of managing the public disclosure-related information for the efficient management of the internal information associated with the public disclosure obligations under Paragraph 1. In case of designating or changing the person in charge, the Subsidiary Company shall notify such matter to the Disclosure Officer or Disclosure Manager of the Company.
③ The Company may request the Subsidiary Company to suggest the related materials to the extend necessary for the public disclosure affairs.

Article 10 (External Provision of Inside Information) ① When any executive officers or employees provide the inside information due to unavoidable cause to the Counterparty, External Auditor, Agent or Parties that entered into advisory contracts such as legal advice or business advice, the executive officers or employees shall report the Disclosure Officer of the related matters.
② In case of Paragraph 1, the Disclosure Officer shall take necessary measures, such as signing a contract on the confidentiality of the relevant inside information.
③ When Fair Disclosure is associated in providing the inside information pursuant to Paragraph 1, the inside information shall be disclosed immediately (Excluding any cases falling under the clause of exceptions in Article 15 of Disclosure Regulations)

Article 11 (Types of Disclosure) The disclosure of the Company shall be classified as follows : 1. Report and disclosure of the main business matters pursuant to Section 1, Chapter 1, Part 1 of the Disclosure Regulation
2. Inquiry disclosure pursuant to Section 2, Chapter 2, Part 1 of the Disclosure Regulation
3. Fair disclosure pursuant to Section 3, Chapter 2, Part 1 of the Disclosure Regulation
4. Voluntary disclosure pursuant to Chapter 3, Part 1 of the Disclosure Regulation
5. Submission of the securities report, etc., pursuant to Chapter 1, Part 3 of the Act
6. Submission of the business reports, etc., pursuant to Article 159 , 160, and 165 of the Act and Section 4, Chapter 2, Part 1 of the Disclosure Regulation
7. Submission of the major report matters pursuant to Article 161 of the Act
8. Disclosure in accordance with other regulations

Article 12 (Confirmation of the Disclosure Subject) In determining whether certain matters fall under the disclosure obligations including the fair disclosure, the matters that may have significant influences on the stock price or investment judgment under Subparagraph 4, Paragraph 1, Article 6 of the Disclosure Regulation shall be included.

Article 13 (Execution of Disclosure) ① When there exists any disclosure matters specified in Article 11, the Disclosure Manager shall prepare the necessary matters, arrange the necessary documents and report to the Disclosure Officer.
② The Disclosure Officer shall review whether the contents and documents from Paragraph 1 are in compliance with the regulated regulations, report to Representative Director, and execute the public disclosure.

Article 14 (Prompt Execution of Disclosure) When there exists any disclosure matters specified in Article 11, the Disclosure Officer shall make every effort to disclose the relevant inside information in time, even before the time of public disclosure stated in the Disclosure Regulation.

Article 15 (Follow-Up Measures After Disclosure) In case of any error, omission, or matters to be cancelled or changed in the disclosed matters, the Disclosure Manager and Disclosure Officer shall take corrective measures such as correcting the disclosure immediately in accordance with Article 30 of the Disclosure Regulation.

Article 16 (Media Coverage, Etc.) ① In case of the request on coverage from the media, the Representative Director of the Disclosure Officer shall respond in principle. If necessary, the executive officers and employees of the relevant department may respond to the coverage, too.
② The Company shall consult with the Disclosure Officer before distributing the press release to the media. If necessary, the Disclosure Officer shall report the Representative Director of the matters associated with the distribution of the press release.
③ Where the executive officer or employee becomes aware that the matters covered in the media are different from the actual facts, he or she shall report such matters to the Disclosure Officer. The Disclosure Officer shall report the matters to the Representative Director and shall take necessary measures.
④ When the contents of the press release distributed pursuant to Paragraph 2 apply to the fair disclosure, the Disclosure Officer shall disclose the matters before distributing the press release.

Article 17 (Confirmation of the Coverage) The Disclosure Officer, Disclosure Manager, and departments associated with inside information shall check on the media coverage related to the Company on a regular basis. When the covered matters are different from the facts, the Disclosure Officer, Disclosure Manager, and departments associated with inside information shall take corrective measures.

Article 18 (Investor Relations) ① The Representative Director shall be aware that the IR activities are part of the managerial responsibilities of the KOSDAQ-listed corporate and shall hold the IR sessions voluntarily and steadily to build up trusts with investors.
② The IR session on the corporate management, business plans, and prospects shall be held after consulting with the Disclosure Officer.
③ The Disclosure Officer or Disclosure Manager shall disclose the date, location, and contents of the IR session until the day before holding the session and shall post the related data to the Public Disclosure Submission System of the exchange before holding the IR session.
④ All executive officers and employees shall be careful about disclosing any fair disclosure information matters that were not disclosed in advance during the IR session.

Article 19 (Rumors) ① In case of any rumors in the market, the Disclosure Officer ask opinions from the relevant departments and shall check on whether the rumors are true and whether they are associated with the inside information.
② When it is found out, from Paragraph 1, that the rumors fall under the disclosure obligation matters in accordance with the Disclosure Regulation, the relevant information shall be disclosed.

Article 20 (Request on Provision of Information) ① When the shareholder or stakeholders requests on disclosing the information related to the Company, the Disclosure Officer shall review on the legitimacy of the request and shall decide whether to provide the relevant information or not.
② In deciding whether to provide information or not, the Disclosure Officer may hear opinions from the legal department or external legal expert on whether the information requested may influence on the investment judgment of the investor and the stock prices.
③ In providing the information according to the decision made in Paragraph 1, it shall be in compliance with the Paragraph 4, Article 16.

Article 21 (Return of Gains on Short-Term Trading) ① If executive officer and employee defined according to Paragraph 1, Article 172 of the Act and Article 194 of the Enforcement Decree of the Act gained profits by purchasing specific securities (hereinafter referred to as “Specific Securities, Etc.”) and selling them within 6 months or by selling specific securities and purchasing them within 6 months, the executive officer and employee shall return the profits (hereinafter referred to as “Gains on Short-Term Trading”) to the Company.
② If a shareholder (including a person who owns equity securities or depository securities other than the share. This shall apply the same in this Article) requests the Company to have the person who has obtained “Gains on Short-Term Trading” pursuant to Paragraph 1 return the gains, the Company shall take measures within two months from the date of request.
③ If Securities and Futures Commission notifies the Company of the “Gains on Short-Term Trading” pursuant to Paragraph 1, the Disclosure Officer shall immediately disclose the following matters on the website of the Company : 1. Position of the person who is required to return Gains on Short-Term Trading; 2. Amount of Gains on Short-Term Trading; 3. The date of receiving the notification on Gains on Short-Term Trading from Securities and Futures Commission; 4. Plans on claiming the return of Gains on Short-Term Trading; 5. The share holder of the Company may have the Company the request the person who has obtained “Gains on Short-Term Trading” return the gains. If the Company fails to make a claim within two months from receiving such request, the shareholder may make a claim in substitute of the Company. ④ The disclosure period under Paragraph 3 shall be whichever happens earlier between two years from the date of receiving the notification on Gains on Short-Term Trading from Securities and Futures Commission or the date of receiving the return of Gains on Short-Term Trading.

Article 22 (Notification of Sales, Etc. of Specific Securities) The executive officer and employee defined according to Paragraph 1, Article 172 of the Act and Article 194 of the Enforcement Decree of the Act shall notify the Disclosure Officer in case of purchasing, buying, or doing any other transactions of the specific securities.

Article 23 (Prohibition on Use of Undisclosed Material Information) ① The executive officer and employee shall not trade, use, or have other Parties use the undisclosed material information (including the undisclosed material information of the affiliates) stated in Paragraph 1, Article 174 of the Act.
② To prevent the use of undisclosed material information, prevent the unfair trading such as Gains on Short-Term Trading, and report the shares, the Company may register “KRX-Insider Trading alarm Service” provided by Korea Exchange and utilize them for making any notifications and reports from Article 14 to Article 16.

Article 24 (Education) ① The Disclosure Officer and Disclosure Manager shall complete the education on the disclosure work in accordance with Article 36 and Paragraph 5, Article 44 of the Disclosure Regulation. The Disclosure Officer shall also notify the relevant executive officers and employees about the education details.
② The Representative Director shall endeavor to provide the executive officers and employees of the education on preventing the matters from Article 21 to Article 23 and insider trading as stated in the Act.

Article 25 (Amendment and Repeal of Regulation) The amendment and repeal of this Regulation shall be made under the resolutions of board of directors.

Article 26 (Publication of Regulation) This Regulation shall be published on the website of the Company. The same shall also apply to any amendments on the regulation.

This Regulation shall enter into force on November 01, 2021