Disclosure Policy

Disclosure Information Management Policy

Chapter 1. General Provisions

Article 1 (Purpose) The purpose of this Policy is to ensure that all disclosure information of the Company is disclosed accurately, completely, fairly, and in a timely manner in accordance with relevant laws and regulations, and to establish necessary matters regarding disclosure-related duties, procedures, and the management of disclosure information to prevent unfair trading by executives and employees.

Article 2 (Scope of Application) Matters concerning the execution of disclosure duties and the management of disclosure information shall be governed by this Policy, except as otherwise provided by laws, relevant regulations, or the Articles of Incorporation.

Article 3 (Definitions)
① "Disclosure Information" refers to matters concerning the Company's management and property that may affect investors' investment decisions, and information related to disclosure matters prescribed by relevant laws and regulations, such as the Financial Investment Services and Capital Markets Act (hereinafter referred to as the "Act") and its Enforcement Decree (hereinafter referred to as the "Decree"), the Regulations on the Issuance and Disclosure of Securities of the Financial Services Commission (hereinafter referred to as the "FSC"), and the KOSPI Market Disclosure Regulations (hereinafter referred to as the "Disclosure Regulations") of the Korea Exchange (hereinafter referred to as the "KRX").
② "Disclosure Documents" refers to reports and documents (including electronic documents) submitted for the disclosure of Disclosure Information, as well as attached documents.
③ "Disclosure Control System" refers to all business activities through which the Company's internal relevant organizations manage disclosure information according to designated control procedures.
④ "Disclosure Control Organization" refers to the Representative Director, the Disclosure Officer, the Disclosure Department, and Business Departments related to the generation of disclosure information that perform duties related to disclosure, such as generation, collection, review of disclosure information, and the preparation and approval of disclosure documents, under this Policy.
⑤ "Disclosure Officer" refers to a person designated by the Representative Director to practically oversee the Company's disclosure duties, registered with the KRX as a Disclosure Officer in accordance with Article 88, Paragraph 1 of the Disclosure Regulations.
⑥ "Disclosure Department" refers to the department in charge of the Company's disclosure duties pursuant to the Company's business and organizational rules. In this case, at least two "Disclosure Managers" registered with the KRX pursuant to Article 88, Paragraph 2 of the Disclosure Regulations must belong to the Disclosure Department.
⑦ "Business Department" refers to a department that performs duties related to the generation of the Company's disclosure information.
⑧ "Periodic Disclosure" refers to the submission of business reports, half-year reports, and quarterly reports to the FSC or KRX concerning the Company's overall corporate details, including business and financial status and management performance.
⑨ "Timely Disclosure" refers to the reporting or disclosing of major facts or decisions affecting investment decisions related to the Company's management activities to the KRX.
⑩ "Fair Disclosure" refers to the disclosure of information to the KRX so that general investors can know it simultaneously when the Company selectively provides information that is not subject to mandatory disclosure or whose disclosure deadline has not arrived to specific persons.
⑪ "Inquiry Disclosure" refers to disclosing information upon request from the KRX to confirm the truth of rumors and news reports related to the Company or the existence of material information.
⑫ "Voluntary Disclosure" refers to disclosing information to the KRX when the Company deems it necessary to disclose matters that may have a material impact on the Company's management, property, and investors' investment decisions other than the Timely Disclosure items.
⑬ "Issuance Disclosure and Report of Material Facts" refers to the submission of related reports to the FSC regarding matters such as the public offering or sale of securities, merger, division, transfer of business, structural changes of the Company, or the acquisition and disposal of treasury stocks.
⑭ Terms used in this Policy shall be governed by the definitions in relevant laws and regulations, unless otherwise specified herein.

Chapter 2. Basic Authority and Responsibility of Disclosure Control Organization

Article 4 (Representative Director)
① The Representative Director shall oversee all duties related to the Disclosure Control System.

Article 5 (Disclosure Officer)
① The Disclosure Officer shall be designated by the Representative Director.
② The Disclosure Officer shall oversee duties related to the design and operation of the Disclosure Control System.
③ The Disclosure Officer may consult with relevant departments and listen to the opinions of external experts if necessary to perform their duties.

Article 6 (Disclosure Department)
① The Representative Director shall organize a department in charge of disclosure duties, including persons with professional knowledge of disclosure. Two of them must be designated as Disclosure Managers.
② The Disclosure Department shall be under the direction of the Disclosure Officer and perform the following duties:

Collection and review of various disclosure information

Preparation of disclosure documents and execution of disclosures

Review of necessary measures for legal compliance, such as frequent checks on enactments and amendments of disclosure-related laws, and reporting to the Disclosure Officer

Identification, inspection, evaluation, and management of disclosure risks at the corporate level

Other matters deemed necessary by the Representative Director or the Disclosure Officer

Article 7 (Business Department) ① The head of each Business Department shall promptly transmit relevant information to the Disclosure Department in any of the following cases:

When a disclosure item stipulated in relevant laws occurs or is expected to occur

When a reason for cancellation or change of an already disclosed matter occurs or is expected to occur

Upon request from the Disclosure Officer or the head of the Disclosure Department
② When transmitting the disclosure information, copies of relevant contents, necessary evidence, and reference materials must be provided to the Disclosure Department in writing, and the original copies must be retained.

Chapter 3. Disclosure Control Activities and Operations

Section 1. Periodic Disclosure
Article 8 (Periodic Disclosure) The Company shall prepare periodic disclosure documents and submit them to the FSC and KRX within the disclosure deadline.
Article 9 (Business Department) ① The head of each Business Department shall perform the duties assigned for periodic disclosure and submit them to the Disclosure Department by the designated deadline. ② If delays are expected, the head of the Business Department must immediately notify the Disclosure Department and take necessary measures.
Article 10 (Disclosure Department) The head of the Disclosure Department shall compile the information, prepare the periodic disclosure documents, and submit them to the Disclosure Officer. The disclosure shall be executed within the statutory deadline upon approval.
Article 11 (Disclosure Officer) The Disclosure Officer shall check the progress of periodic disclosure, review the accuracy and completeness of the documents, report to the Representative Director, and order the execution of the disclosure upon approval.
Article 12 (Representative Director) The Representative Director shall personally verify, review, and approve the adequacy of the periodic disclosure documents.
Article 13 (Post-Check) The Disclosure Department and the related Business Department shall check the adequacy of the disclosed contents immediately after disclosure and take corrective measures, such as corrective disclosure, if any errors or omissions are found.

Section 2. Timely Disclosure
Article 14 (Timely Disclosure) The Company shall prepare timely disclosure documents and submit them to the KRX within the deadline.
Article 15 (Business Department) Each Business Department shall immediately deliver information to the Disclosure Department when a timely disclosure item occurs or is expected to occur.
Article 16 (Disclosure Department) The Disclosure Department shall review whether the delivered information constitutes a disclosure item and its accuracy. It shall prepare disclosure documents, report to the Disclosure Officer, and execute the disclosure upon approval.
Article 17 (Disclosure Officer) The Disclosure Officer shall review the adequacy of the documents and approve the disclosure. Important matters shall be reported to the Representative Director.
Article 18 (Post-Check) The provisions of Article 13 shall apply mutatis mutandis to timely disclosure.

Section 3. Fair Disclosure
Article 19 (Fair Disclosure) The Company shall prepare fair disclosure documents and submit them to the KRX within the deadline.
Article 20 (Prohibition of Indirect Provision) Providers of fair disclosure information shall not provide fair disclosure items indirectly to targeted recipients prior to official disclosure.
Article 21 (Precautions) When executing fair disclosure, contact information shall be specified for investor inquiries. If requested by the KRX, summaries and website URLs shall be disclosed, and full texts shall be posted on the Company's website.
Article 22 (Application Mutatis Mutandis) Articles 13, and 15 through 17 shall apply mutatis mutandis to fair disclosure.

Section 4. Inquiry Disclosure
Article 23 (Inquiry Disclosure) The Company shall submit inquiry disclosure documents to the KRX within the deadline.
Article 24 (Disclosure Department) Upon receiving a request for inquiry disclosure, the Disclosure Department shall immediately verify facts, prepare documents, and respond with the approval of the Disclosure Officer. If an 'unconfirmed disclosure' is made, a re-disclosure must be executed within one month.
Article 25 (Application Mutatis Mutandis) Articles 13, 16, and 17 shall apply mutatis mutandis to inquiry disclosure.

Section 5. Voluntary Disclosure
Article 26 (Voluntary Disclosure) The Company may submit voluntary disclosure documents to the KRX.
Article 27 (Judgment and Collection of Information) The Disclosure Officer may instruct the collection of information for voluntary disclosure. Business Departments shall provide necessary materials upon request.
Article 28 (Application Mutatis Mutandis) Articles 13, 16, and 17 shall apply mutatis mutandis to voluntary disclosure.

Section 6. Issuance Disclosure and Report of Material Facts
Article 29 (Issuance Disclosure) The Company shall submit issuance disclosure and material fact report documents to the FSC within the deadline.
Article 30 (Application Mutatis Mutandis) Relevant provisions from Sections 1 and 2 shall apply mutatis mutandis to issuance disclosure and material fact reports.

Chapter 4. Information and Communication

Article 31 (Collection and Management of Information) Each disclosure control organization must collect, maintain, and manage necessary internal and external information to ensure the accuracy, completeness, fairness, and timeliness of disclosure information.
Article 32 (Communication) The Disclosure Officer shall strive to establish necessary communication systems for smooth information exchange among disclosure control organizations and employees.

Chapter 5. Evaluation and Management of Disclosure Risks

Article 33 (Management of Disclosure Risks) The Representative Director and Disclosure Officer must continuously monitor and manage disclosure risks that may negatively affect the accuracy and timeliness of disclosure information, including financial information errors, misstatements, ambiguity, delayed deadlines, omission/concealment of facts, forecast information risks, and leakage of undisclosed information.
Article 34 (Business Department) Business Departments must immediately notify the Disclosure Department if a disclosure risk occurs or is likely to occur.
Article 35 (Disclosure Department) The Disclosure Department oversees the inspection and management of disclosure risks at the corporate level and separately manages major risks.

Chapter 6. Monitoring

Article 36 (Routine Monitoring) The head of each Business Department, the head of the Disclosure Department, and the Disclosure Officer shall verify whether disclosure-related tasks are processed according to the system through routine monitoring and take corrective actions if vulnerabilities are found.

Chapter 7. Prohibition of Unfair Trade by Executives and Employees

Article 37 (General Principle) Executives and employees shall not use material non-public information related to their duties for trading specific securities, nor allow others to use it.
Article 38 (Trading of Specific Securities by Employees) Executives and employees must notify the internal audit or legal officer in advance when trading specific securities. They must also report the transaction details within 10 days from the end of the quarter in which the transaction occurred.
Article 39 (Management of Material Non-Public Information) The Representative Director and Disclosure Officer must take necessary measures to manage material non-public information safely. Employees must not leak such information and must immediately notify the Disclosure Department if unintended leakage occurs.
Article 40 (Affiliates) Articles 37 to 39 shall apply mutatis mutandis to the prohibition of using material non-public information of the Company's affiliates.
Article 41 (Return of Short-Swing Profits) Executives and specific employees who gain profits by purchasing and selling specific securities within six months must return the profits to the Company. The Disclosure Officer must take necessary procedures for the return of such profits and disclose related facts on the website.

Chapter 8. Other Disclosure Controls

Section 1. Contact with Media
Article 42 (Distribution of Press Releases) Business Departments must obtain approval from the Disclosure Officer before distributing press releases to the media. If the information constitutes fair disclosure, it must be disclosed accordingly.
Article 43 (Listening to Opinions) The Disclosure Officer may listen to the opinions of internal and external experts regarding information provided through press releases.
Article 44 (Post-Check) The Business Department and Disclosure Department must conduct post-checks on reported contents and take necessary actions if incorrect information is published.

Section 2. Market Rumors
Article 45 (Market Rumors) In principle, the Company makes no comments on market rumors. However, if a rumor matches undisclosed material information, immediate disclosure shall be executed.
Article 46 (Request for Information Provision) If information disclosure is requested by shareholders or stakeholders, the Disclosure Officer shall review its legality and determine whether to provide it. If it affects investment decisions, it must be disclosed to the public simultaneously.
Article 47 (Investor Relations Meetings) When holding an IR meeting, the responsible department must obtain prior approval from the Disclosure Officer for the materials to be distributed. The Disclosure Department must execute a disclosure regarding the holding of the IR meeting beforehand.

Chapter 9. Supplementary Provisions

Article 48 (Education) The Disclosure Officer must ensure that all employees fully understand the Disclosure Control System. The Disclosure Department shall mandate necessary training sessions.
Article 49 (Penalties) The Company may impose penalties or sanctions on executives and employees who violate this Policy.
Article 50 (Amendment and Abolition) The amendment and abolition of this Policy shall be made by the Representative Director.

Addendum

Article 1 (Enforcement Date) This Policy shall enter into force in October 2016.