• Chapter 1 General Rules

    • Article 1 (Purpose)

      This regulation applies to prompt and accurate disclosure in accordance with the "Capital Market and Financial Investment Business Act" (hereinafter referred to as the "Act") and all laws and regulations, and for the comprehensive management and appropriate disclosure of the company's internal information in order to prevent insider trading by executives and employees. The purpose is to determine the relevant matters.

    • Article 2 (Definitions)

      ① In these regulations, "inside information" refers to the disclosure obligations pursuant to Title 1 of the KOSDAQ Market Disclosure Regulations (hereinafter referred to as the "Disclosure Regulations") of the Korea Exchange (hereinafter referred to as the "Exchange") and other matters relating to the Company's management or property situation, etc. It refers to matters that may affect the investor's investment decision.
      ② In these regulations, the term "disclosure officer" refers to a person who can carry out reporting on behalf of the company in accordance with Article 2, Paragraph 4 of the Disclosure Regulations.
      ③ For the purposes of these regulations, "officers" refers to directors (including persons falling under any of the items in paragraph 2(1) of Article 401 of the Commercial Code) and auditors.
      ④ Other than Paragraphs 1 to 3, the definitions of terms used in these Regulations shall be based on the definitions of terms used in the relevant laws and regulations.

    • Article 3 (Scope of Application)

      Matters related to disclosure, insider trading, and internal information management shall be subject to these regulations, except as stipulated in the relevant laws or articles of incorporation.

  • Chapter 2 Management of Internal Information

    • Article 4 (Management of Internal Information)

      ① Executives and employees shall strictly manage the company's internal information learned in the course of their work, and shall not leak internal information within or outside the company except when it is necessary for business purposes.
      ② The CEO shall take necessary measures for internal information management, such as setting specific standards for the storage, transmission, and destruction of internal information and related documents.

    • Article 5 (Disclosure Officer)

      ① The CEO shall appoint a person in charge of disclosure and report it to the exchange without delay. The same is true when the person in charge of disclosure is changed.
      ② The person in charge of disclosure shall oversee the establishment and operation of the internal information management system and perform the following tasks. 1. Enforcement of Disclosure
      2. Inspection and evaluation of the operation status of the internal information management system
      3. Review of internal information and decision on whether to disclose it
      4. Measures necessary for the operation of the internal information management system, such as training for executives and employees
      5. Directing and supervising departments or officers and employees who are in charge of managing internal information or disclosing
      6. Other tasks recognized by the CEO as necessary for the operation of the internal information management system       ③ The person in charge of disclosure shall have the following powers in performing his or her duties: 1. Authority to request and view various documents and records related to internal information
      2. Departments in charge of accounting or auditing, and other tasks related to the generation of internal information. Authority to hear necessary opinions from officers and employees of the department       ④ The person in charge of disclosure may, if necessary, consult with the officer in charge of the relevant work in the performance of his or her duties. You can seek professional assistance at your company's expense.
      ⑤ The person in charge of disclosure shall regularly report the operation status of the internal information management system to the CEO.

    • Article 6 (Disclosure Officer)

      ① The CEO shall appoint a person in charge of disclosure and report it to the exchange without delay. ball It's also the same when you change the person in charge of the city.
      ② The person in charge of disclosure shall be under the direction of the person in charge of disclosure in relation to internal information management and shall perform the following tasks: Perform. 1. Collection and review of internal information and report to the person responsible for disclosure
      2. Duties necessary for the execution of disclosure
      3. Confirmation of matters necessary for the management of internal information, such as changes in laws and regulations related to disclosure, and to the person in charge of disclosure One report
      4. Other matters deemed necessary by the CEO or the person in charge of disclosure

    • Article 7 (Concentration of Internal Information)

      ① In the event that an officer or the head of each department falls under any of the following clauses: Information on the matter shall be provided to the person in charge of disclosure in a timely manner. 1. When internal information occurs or is expected to occur
      2. There is a reason to cancel or change the internal information that has already been disclosed, or it is expected to occur. If the
      3. In the event of any other request from the person in charge of disclosure       ② The person in charge of disclosure and the CEO shall provide information within the company for the timely provision of internal information in accordance with Paragraph 1. The system must be established efficiently, and if necessary, it shall be disclosed in the approval process of the work related to the disclosure obligations. You may want to get the cooperation of the person in charge.

    • Article 7(2) (Management of Information Relating to the Largest Shareholders)

      The person in charge of disclosure shall be responsible for the disclosure obligations related to the largest shareholder and the inquiry In order to smoothly carry out the disclosure work on the city's requirements, the largest shareholder should be fully informed of the relevant facts. An information delivery system should be established so that the relevant information can be delivered in a timely manner.

    • Article 7(3) (Concentration of internal information of subsidiaries)

      ① The Company shall provide internal information related to disclosure obligations from a subsidiary company. If it occurs or is expected to occur, the subsidiary company shall report the contents to the company's disclosure officer or disclosure statement. The person concerned should be notified immediately.
      ② The Company shall conduct a subordinate meeting in order to efficiently manage internal information related to the disclosure obligations pursuant to Paragraph 1. The company shall have a person who manages the information related to disclosure, and if it is designated or changed, the company's disclosure The person in charge or the person in charge of disclosure should be notified immediately.
      ③ The Company may require the subsidiary company to submit relevant data to the extent necessary for the disclosure business.

    • Article 8 (Provision of Internal Information Externally)

      ① Executives and employees are the company's counterparties, external auditors, and v. Inevitably for those who have signed consulting contracts such as legal advice and management advice with the company. If it is necessary to provide internal information, the matter shall be reported to the person in charge of disclosure.
      ② In the case of Paragraph 1, the person in charge of disclosure shall take necessary measures, such as concluding a contract regarding the confidentiality of relevant internal information.
      ③ In the event that a fair disclosure obligation arises in providing internal information pursuant to Paragraph 1, it shall be disclosed without delay. (Except in cases where there is an exception to the application of Article 15 of the Disclosure Regulations).

  • Chapter 3 Disclosure of Internal Information

    • Article 9 (Types of Disclosure)

      The Company's disclosures are classified as follows: 1. Reporting and Disclosure of Major Management Matters in accordance with Chapter 2, Section 1 of Title 1 of the Disclosure Regulations
      2. Inquiry Disclosure Pursuant to Chapter 2 of Title 1, Disclosure Regulations
      3. Fair Disclosure in accordance with Section 3 of Chapter 2 of Title 1 of the Disclosure Regulations
      4. Voluntary Disclosure in accordance with Chapter 3 of Title 1 of the Disclosure Regulations
      5. Submission of securities declarations, etc. pursuant to Chapter 1 of Title 3 of the Act
      6. Articles 159, 160 and 165 of the Act and business reports in accordance with Section 1, Chapter 2, Section 4 of Title 1 of the Disclosure Regulations. Exodus
      7. Submission of a report on major matters in accordance with Article 161 of the Act
      8. Disclosure in accordance with other laws and regulations

    • Article 9(2) (Confirmation of Disclosure Object)

      In accordance with this regulation, we determine whether disclosure obligations, including fair disclosure, apply. It has a significant impact on the stock price or investment judgment pursuant to Article 6, Paragraph 1, Paragraph 4 of the Disclosure Regulations, or Care should be taken to include possible implications.

    • Article 10 (Execution of Disclosure)

      ① The person in charge of disclosure shall prepare the necessary information in the event of a disclosure as stipulated in Article 9. and report to the person in charge of disclosure with the necessary documents.
      ② The person in charge of disclosure shall examine whether the contents and documents in Paragraph 1 do not violate the relevant laws and regulations. It must be disclosed after reporting to the CEO.

    • Article 10(2) (Prompt Implementation of Publicity)

      The person in charge of disclosure shall comply with the disclosure regulations in the event of a disclosure pursuant to Article 9. Even before the disclosure deadline, the Company shall make its best efforts to ensure that the internal information is disclosed in a timely manner.

    • Article 11 (Follow-up Measures After Publication)

      The person in charge of disclosure and the person in charge of disclosure shall make any errors or omissions in the disclosure. If you wish to sue or change it, you will correct it without delay by correcting or disclosing it in accordance with Article 30 of the Disclosure Regulations. Measures should be taken to do so.

    • Article 12 (Coverage by the media, etc.)

      ① In principle, when there is a request from a media company to cover the company. The CEO or the person in charge of disclosure shall respond to the request. If necessary, officers and staff of the relevant departments will respond to the interview. You can do it all the time.
      ② If the Company intends to distribute a press release to a media company, it shall consult with the person in charge of disclosure. Disclosure If necessary, the employee shall report to the CEO on matters related to the distribution of the press release.
      ③ If the contents of the press release distributed pursuant to Paragraph 2 fall under fair disclosure, Disclosure must be made before the release of the press release.
      ④ Officers and employees who find out that the contents of the media report are not true shall report it to the person in charge of public disclosure. It should be. The person in charge of disclosure shall report the relevant matters to the CEO and take necessary measures.

    • Article 12(2) (Confirmation of Contents of Reports)

      The person in charge of disclosure, the person in charge of disclosure and the department that generates inside information is a company such as a media company. Routinely checking related reports and correcting any inconsistencies in the facts You have to take action.

    • Article 13 (IR Presentation)

      ① The CEO recognizes that IR activities are the management responsibility of a company listed on the KOSDAQ Market, and voluntarily Efforts should be made to build trust with investors by holding corporate briefings on a continuous basis.
      ② A corporate briefing session on the company's management, business plan, and prospects shall be held in consultation with the person in charge of disclosure. It should be.
      ③ The person in charge of disclosure or the person in charge of disclosure shall announce the date, place, and contents of the briefing session by the day before the meeting. and the relevant data shall be posted on the exchange's disclosure submission system before the briefing session is held.
      ④ All officers and employees of the Company shall not disclose the information subject to fair disclosure in the course of the corporate briefing session. Care must be taken not to disclose the information.

    • Article 13(2) (Hearsay)

      ① The person in charge of disclosure shall give an opinion to the relevant business department if rumors are circulating in the market. It is necessary to check whether the contents of the rumors are true and whether they correspond to inside information through inquiries.
      ② If, as a result of confirmation pursuant to Paragraph 1, the rumor falls within the disclosure obligation under the Disclosure Regulations, the relevant determination Disclosure shall be made.

    • Article 13(3) (Request for Provision of Information)

      ① Requests from shareholders and stakeholders to disclose information related to the company. In this case, the person in charge of disclosure will review the legality of the request and whether to provide the relevant information. You have to decide.
      ② The person in charge of disclosure shall determine whether or not to provide the information, and the information required to be provided is the investor's investment version. However, whether it may affect the stock price, such as the legal department or an outside legal expert, etc. Opinions are heard.
      ③ In the case of providing information pursuant to the decision set forth in Paragraph 1, Article 12, Paragraph 3 shall apply.

  • Chapter 4 Regulation of Insider Trading, etc.

    • Article 14 (Return of short-term trading profits)

      ① Officers and employees as prescribed by Article 172(1) of the Act and Article 194 of the Enforcement Decree of the Act Within six months of the purchase of specified securities (hereinafter referred to as "specified securities") under Article 172(1) of the Act, In the event that you make a profit by buying or selling certain securities within 6 months, the profit (hereinafter referred to as "Short-term trading profits") must be returned to the company.
      ② Shareholders of the Company (including those who own equity securities or securities depository securities other than stock certificates; hereinafter referred to as in this Article) The same) shall file a request for the return of the short-term trading profit to the person who has obtained the short-term trading profit pursuant to Paragraph 1 against the Company. In the event of such a request, the Company shall take necessary measures within two months from the date of receipt of the request.
      ③ If the Securities and Futures Commission notifies the Company of the occurrence of short-term trading profit pursuant to Paragraph 1, the person in charge of disclosure shall: Without delay, the following matters shall be posted on the Company's Internet website. 1. The status of the person who should return the short-term trading profit
      2. Amount of short-term trading profit
      3. The date on which the Securities and Futures Commission notified the occurrence of short-term trading profits.
      4. Short-term profit return claim plan
      5. If a shareholder of the company makes a request for the return of the short-term trading profit to the person who has obtained the short-term trading profit. If the Company does not make the request within two months from the date of receipt of the request. Ue means that the shareholder can make a claim on behalf of the company.       ④ The disclosure period under Paragraph 3 is two years from the date of notification of short-term trading profit from the Securities and Futures Commission. or until the date on which the short-term trading profit is returned, whichever comes first.

    • Article 15 (Notification of Sale of Specified Securities, etc.)

      Officers and Officers Article 172(1) and Article 194 of the Enforcement Decree of the Act In the event that an employee buys or sells certain securities or conducts other transactions, he or she shall notify the person in charge of disclosure. Shall

    • Article 16 (Prohibition of Use of Undisclosed Important Information)

      Officers and employees are not disclosed as defined in Article 174(1) of the Act. (including undisclosed material information of affiliated companies) for the sale of specified securities and other transactions, or Do not allow others to use you.

  • Chapter 5 Supplementary Rules

    • Article 17 (Education)

      ① The person in charge of disclosure and the person in charge of disclosure shall carry out disclosure duties in accordance with Articles 36 and 44(5) of the Disclosure Regulations. Relevant training must be completed, and the person in charge of disclosure shall inform the relevant officers and employees of the training.
      ② The CEO shall notify officers and employees of the matters set forth in Articles 14 to 16 and other insider trading as prescribed by law, etc. Sufficient efforts should be made to prevent this, such as the implementation of education.

    • Article 18 (Amendment and Closing of Regulations)

      Amendments or repeals of these regulations shall be made by the CEO.

    • Article 19 (Publication of Regulations)

      These regulations shall be published on the Company's website. The same is true when the regulations are revised.

  • Addendum

    • [Article 1] (Effective Date)

      These regulations will come into effect on September 22, 2017 by the Company.