Enacted on January 1, 2017
Amended on June 12, 2017

Chapter 1 General rules

Article 1(Objective)

The objective of this rule is to prescribe matters over comprehensive management of company's internal information and proper disclosure for rapid and accurate disclosure and prevention of employees' insider trading in accordance with ⌈Financial Investment Services And Capital Markets Act⌋(hereinafter referred to as "Act") and laws and regulations.

Article 2(Definition of terms)

• “Internal information” in this rule refers to disclosure requirements pursuant to part 1 of KOSDAQ market disclosure regulation ( hereinafter referred to as “disclosure regulation”) of Korea Exchange(hereinafter referred to as "exchange") and matters that can affect investors' judgment of investment as ones regarding company's management and property state.
• “Person in charge of disclosure” in this rule refers to those who can conduct a report representing company in accordance with Article 2, Paragraph 4 of disclosure regulation.
• "Executives" in this rule refer to directors (including person who falls under provisions of article 401-2 paragraph 1 of ⌈Commercial Act⌋ ) and auditors.
• Defintion of terms used in this rule except paragraph 1 to 3 is subject to relevant laws and regulations.

Article3(Scope of application)

Matters over disclosure, insider trading and internal information management are subject to this rule except those which are prescribed in relevant laws and regulations or articles of association.

Chapter 2 Management of internal information

Article 4 (Management of internal information)

• Executives and staff members shall manage company's internal information strictly which they learn in the course of conducting business and shall not leak it to outside except cases that are needed in business.
• Representative director shall take measures needed to manage internal information including establishment of concret standard for internal information and storage, delivery, destruction of documents relating to it.

Article 5(Person in chage of disclosure)

• Representative director shall appoint person in charge of disclosure and report it to exchange without delay. The same shall apply to a case which person in charge of disclosure changed.
• Person in charge of disclosure handles every affair which is related to establishment and operation of internal information management system and performs any one of following duties.
• Execution of disclosure
• Inspection and evaluation of operation of internal information management system
• Review of internal information and determination of whether a disclosure is made
• Measures needed for operation of internal information management system such as education for executives and staff members
• Direction and supervision of departments, executives and staff members in charge of management of internal information or disclosure
• Duties which recognize representative director needed for operation of internal information management system
• Person in charge of disclosure has the following authority in doing its duties.
• Authority that can demand submission of various documents and records relating to internal information and read it
• Authority that can hear the opinions from executives and staff members in charge of accounting and audit and creation of internal information
• Person in charge of disclosure can consult with executives who handle relevant duties in performing duties if needed and seek experts' help at company's expense.
• Person in charge of disclosure shall report operation of internal information management system to representative director (or board of directors) regularly.

Article 6(Person who handles disclosure)

• Representative director shall appoint a person who handles disclosure and report it to exchange without delay. The same shall apply to a case which a person who handles disclosure has been changed.
• A person who handles disclosure performs the following duties relating to internal information management under the direction of a person in charge of disclosure.
• Collection and review of internal information and report to a person in charge of disclosure
• Duties needed for execution of disclosure
• Check for matters needed to manage internal information such as a change in disclosure related laws and regulations report to a person in charge of disclosure
• Matters that representative director or a person in charge of disclosure deem necessary

Article 7(Concentration of internal information)

• If falling under any one of following subparagraphs, executives and head of each department shall provide information on them to a person in charge of disclosure in a timely manner.
• Internal information occurred or is expected to occur
• Reason that has to cancel or change already disclosed matters in internal information occurred or is expected to occur
• Case that a person in charge of disclosure demands
• A person in charge of disclosure and representative director shall build information delivery system in a company efficiently for timely provision of internal information pursuant to subparagraph 1 and if needed, they can have a person in charge of disclosure help in the course of approval of duties relating to disclosure requirements.

Article7-2(Management of largest shareholder related information)

A person in charge of disclosure shall give explanation of fact to the largest shareholder and build information delivery system so that relevant information can be delivered in a timely manner in order ro perform disclosure requirement and affairs relating to the largest shareholder.

Article7-3(Concentration of internal information of subsidiary company)

• If internal information relating to disclosure requirements occur or is expected to occur in a subsidiary company, company shall ensure that subsidiary company gives a notice to person in charge of disclosure or person who handles disclosure immediately.
• Company shall ensure that subsidiary company has person who manages disclosure related information to manage internal information relating to disclosure requirements pursuant to subparagraph 1 and if subsidiary company appoints or changes such person, it notifies person in charge of disclosure or person who handles disclosure immediately.
• Company can ask subsidiary company to submit relevant materials within scope needed for disclosure.

Article 8(Provision of internal information to outside a company)

• If executives or staff members have to provide internal information to other party to a transaction, external auditor, agent, person who concluded advisory contract with legal consultation or management consultation for reason of business, they shall report such matters to person in charge of disclosure.
• In case of paragraph 1, person in charge of disclosure shall take measures needed such as conclusion of a contract for confidentiality of relevant internal information.
• In the evant that obligation of fair public notice in providing internal information pursuant to paragraph 1, company shall give a public notice without delay(this shall not apply to a case falling under exception to application under article 15 of disclosure rule).

Chapter 3 Disclosure of internal information

Article 9(Kinds of disclosure)

Disclosure of a company can be classified as follows.

• Report and disclosure of important matters over management pursuant to part 1, chapter 2, section 1 of disclosure rule
• Disclosure of inquiry pursuant to part 1, chapter 2, section 2 of disclosure rule
• Fair disclosure pursuant to part 1, chapter 2, section 3 of disclosure rule
• Autonomous disclosure pursuant to part 1, chapter 3 of disclosure rule
• Submission of securities report etc. pursuant to part 3, chapter 1 of law
• Submission of business report etc. pursuant to articles 159, 160 and 165 and part 1, chapter 2, section 4 of disclosure rule
• Submission of report on important matters pursuant to article 161 of law
• Disclosure pursuant to other laws and regulations

Article 9-2(Confirmation of subject of disclosure)

In judging whether fair requirements including fair disclosure are represented in accordance with this rule, matters that affect or can affect stock price or judgment of investment pursuant to article 6, paragraph 1, subparagraph 4 of disclosure rule are included.

Article 10 (Execution of disclosure)

• In the event that matters subject to disclosure occur prescribed in article 9, person who handles disclosure shall give a report to person in charge of disclosure after preparing contents and documents needed.
• Person in charge of disclosure shall examine whether contents and documents etc. under paragraph 1 go against relevant laws and regulations and report it to representative director and then give a public notice.

Article 10-2(Prompt execution of disclosure)

In the event that matters subject to disclosure pursuant to article 9 occur, person in charge of disclosure shall do the best so that relevant internal information can be notified in a timely manner even before it does not reach deadlime for disclosure.

Article11(Actions after disclosure)

If person in charge of disclosure and person who handles disclosure intend to cancel or change details notified or there is an error or omission in details notified, they shall take actions to correct it such as correction of disclosure pursuant to article 30 of disclosure rule without delay.

Article12(Coverage by the press etc.)

• In the event that the press etc. asks a company for an interview, representative director or a person in charge of disclosure shall respond to it in principle. If needed, representative director or a person in charge of disclosure can have executives and staff members of relevant departments respond to an interview.
• If a company intends to hand out press release to the press etc., it shall discuss such intention with person in charge of disclosure. If needed, person in charge of disclosure shall report matters relating to distribution of press release to representative director.
• In the event that contents of press release handed out pursuant to paragraph 2 fall under subject of fair disclosure, person in charge of disclosure shall give a public notice prior to distribution of press release.
• If executives and staff members find that coverage by the press is not consistent with fact, they shall report it to person in charge of disclosure. person in charge of disclosure shall relevant matters to representative director and take actions needed.

Article12-2(Check for press report details)

A person in charge of disclosure, a person who handles disclosure and departments that internal information occur shall check media report details of a company by the press etc. and if there is any detail which is not consistent with the fact, they shall take actions to correct it.

Article13(Company presentation)

• Representative director shall endeavor to build a trust with persons concerned with investment by recognizing that IR activities are management responsibility of Kosdaq listed companies and holding company presentation voluntarily and continuously.
• Company presentation of management, business plan, prospect etc. shall be held by discussing it with a person in charge of disclosure.
• A person in charge of disclosure or person who handles disclosure shall give a public notice of date and time, place and content of company presentation before company presentation is held and have relevant materials published in disclosure system of exchange before company presentation is held.
• All executives and staff members of a company shall be careful so that matters which are not notified in advance will not be disclosed in company presentation.

Article13-2(Rumor)

• In the event that there is a rumor going around in the market, a person in charge of disclosure shall check whether rumor is consistent with fact and falls under internal information through inquiries of opinions for business departments.
• In the event that relevant rumor falls under disclosure requirements pursuant to disclosure rule after checking it in accordance with paragraph 1, relevant information shall be notified.

Article13-3(Demanding provision of information)

• If shareholders and persons concerned demand disclosure of information relating to a company, a person in charge of shall determine whether relevant information wsill be provided by examining legitimacy of such demand.
• A person in charge of disclosure can hear opinions from department in charge of legal affairs or legal experts etc. about whether information that shareholders and persons concerned demand disclosure can affect investors' judgment of investment and stock price to decide whether information will be provided.
• In the event that information is provided pursuant to decision under patragraph 1, provisions of article 12, paragraph 3 shall be applied.

Chapter 4 Regulation of insider trading etc.

Article 14(Return of profits on a short-term trade)

• In the event that executives and staff members provided by article 172 paragraph 1 of act and article 194 of enforcement ordinance gain profit by purchaing specific securities etc. under article 172 paragraph 1 of act (hereinafter referred to as “specific securities etc.) and selling them within 6 months or purchasing them within 6 months after selling specific securities, they shall return such profits(hereinafter referred to as "profits on a short-term trade") to the company.
• In the event that company's shareholders (including person who owns equity securities or entrusted securities. The same shall apply in this article) ask a company to enter a claim for return of profits on a short term trade against person who gained profits on a short term trade under paragraph 1, company shall take actions needed within 2 months after receiving such demand.
• In the event that Securities & Futures Commission notified a company of occurrence of profits on a short term trade under paragraph 1, person in charge of disclosure shall give public notice of the following on company's website without delay.
• Status of a person who has to return profits on a short term trade
• Amount of profits on a short term trade
• Day on which occurrence of profits on a short term trade is notified by Securities & Futures Commission
• Plan on a claim for return of profits on a short term trade
• Meaning that company's shareholders can ask a company to enter a claim for return of profits on a short term trade against person who gained profits on a short term trade and in the event that a company fails to make a claim within 2 months after receiving such demand, shareholders concerned can claim subrogating a company
• Disclosure period under paragraph 3 shall be two years from a day on which occurrence of profits on a short term trade is notified by Securities & Futures Commission or on a day which profits on a short term trade are returned whichever is sooner.

Article 15(Notification of trading etc. of specific securities etc.)

In the event that executives and staff members provided by article 172 paragraph 1 of act and article 194 of enforcement ordinance transact specific securities etc., they shall notify a person in charge of disclosure about such fact.

Article16(prohibition of using undisclosed important information)

Executives·staff members shall not use undisclosed important information (including undisclosed important information of affiliates) provided in article 174, paragraph 1 nor have others use it in trading of specific securities etc.

Chapter 5 Supplementary rules

Article17(Education)

• A person in charge of disclosure and person who handles disclosure shall complete education about disclosure affairs pursuant to article 36 and article 44, paragraph 5 of disclosure rule and a person in charge of disclosure shall notify executives and staff members of details of education.
• Representative director shall make a considerable effort such as giving education for preventing insider trading provided in provisions of from articles 14 to 16 to executives· staff members.

Article18(Amendment and abolition of rule)

Amendment or abolition of this rule shall be made by representative director.

Article19(Official announcement of rule)

This rule shall be published on website of company. The same shall apply when this rule is amended.

Supplementary provisions

This rule shall enter into force on January 1, 2017.

This rule shall enter into force on June 12, 2017.