Terms and Conditions of Internal Information Management

Chapter 1 General Provisions

Article 1 Purpose

The purpose of this guideline is to outline and guide the contents and terms related to integrated management of our company's internal information and relevant disclosure in order to ensure that all disclosures of our company are disclosed accurately, completely, and rapid pursuant to Financial Investment Services and Capital Markets Act ('relevant laws') and related regulations and to prevent insider transaction of all executives and employees of our company.

Article 2 Terminology

1. "Internal information" refers to any content and/or factor that may have an effect on in.vestor's decision-making included but not limited to related contents of duty of disclosure and information related to the company's management and financial state prescribed in Article 1 of 'Disclosure Regulations KOSDAQ'('Disclosure Regulations) issued by Korea Exchange('Exchange')
2. "Manager in charge of disclosure" refers to a person designated to implement disclosure works on behalf of the company in accordance with Disclosure Regulation Article 2 Clause 4.
3. "Executive" refers to an auditor and a director who is relevant to any or each of Commercial Act Article 401-2 clause 1.
4. With regards to the terminologies used in clause 1 to 3, the example of terminologies used in the relevant acts and regulations excluding special cases set forth by this regulation shall be applicable.

Article 3. Range of Regulations

All issues related to disclosure, insider transaction, and management of internal information shall be set forth by these regulations except for the issues separately regulated and determined by applicable laws and the articles of association.

Chapter 2 Management of Internal Information

Article 4 Management of Internal Information

1. All executives and employees of the company are obligated to manage the company's internal information strictly. All sorts inf internal information shall not be disclosed in and out of the office except for cases of necessity.
2. Chief executive officer is obligated to implement any required measurement to manage internal information by establishing detailed regulations and standards of storage, delivery, and destroy of internal information and any related document.
※ Executive director shall be in charge of the tasks described in clause 2 on behalf of the chief executive office when the company appointed an executive director.

Article 5 Manager in Charge of Disclosure

1. Chief executive officer shall appoint a manager in charge of disclosure and report the appointment to Exchange. Change of a manager in charge of disclosure shall be reported as well.
2. A manager in charge of disclosure is entitled to direct all and any task related to the establishment and operation of internal information management regulations including the tasks mentioned below.
     ① Execution of disclosure
② Inspection and evaluation of internal information management system
③ Decision making related to disclosure and examination of internal information
④ Implementation of required measures for an operation of an internal information management system including but not limited to education and training for executives and employees
⑤ Direction and supervision toward executives, employees, and departments in charge of internal information and disclosure
⑥ Any other necessary tasks which the chief executive officer acknowledges the necessity for operation of an internal information management system.
3. A manager in charge of disclosure is entitled to perform the tasks as below.
     ① Request for any and all relevant documents and reports as to internal information for the purpose of reading
② Listening to necessary opinions and ideas from executives and employees who are in charge of any task that may generate the company's internal information and/or departments in charge of accounting and auditing.
4. A manager in charge of disclosure is entitled to discuss relevant issues with executives in charge of related business and seek expert advice at the company's expense.
5. A manager in charge of disclosure is obligated to regularly report the situation of the internal information management system to the chief executive officer (or board of directors)

Article 6 Director in Charge of Disclosure

1. Chief executive officer shall appoint a director in charge of disclosure and report the appointment to Exchange. Change of a director in charge of disclosure shall be reported as well.
2. A director in charge of disclosure is entitled to direct all and any task related to the establishment and operation of internal information management regulations including the tasks mentioned below.
     ① Collecting and reviewing internal information and report the relevant information
② Required tasks to execute the disclosure
③ Checking required issues for internal information management including amendment of regulations of disclosure and reporting toward a manager in charge of disclosure
④ Any other necessary tasks which the chief executive officer acknowledges the necessity for operation of an internal information management system.

Article 7 Concentration of Internal Information

1. Executives and heads of each department are obligated to provide the estrequired information to a director in charge of management in cases mentioned below.
     ① In cases where internal information is generated or expected to be generated
② In cases where disclosed internal information must be amended or canceled
③ In cases where a director in charge of disclosure requests
2. Chief executive officer and a director in charge of disclosure shall establish an information delivery system for the purpose of the timely provision of internal information. A director in charge of disclosure has a right to cooperate with the chief executive officer to approve any process related to disclosure.

Article 7-2 Management of Information Related to the Largest Shareholder

A director in charge of disclosure is obligated to establish an information delivery system to deliver and explain the situation and relevant information to the largest shareholder for the purpose of smooth implementation of required disclosure task.

Article 7-3 Concentration of Subsidiary's Internal Information

1. The company shall immediately notify its subsidiaries' manager or director in charge of disclosure of situations or possibility that the company may generate or possibly generate internal information related to the obligations of disclosure.
2. The company shall appoint a person in charge of managing disclosure-related information in order to efficiently manage internal information related to the obligations of disclosure. The company is obligated to immediately notify the company's manager or director in charge of disclosure of change or amendment.
3. The company is entitled to request relevant information to its subsidiary within the purview of necessity for disclosure.

Article 8 Provision of Internal Information Outside the Company

1. All executives and employees are obligated to report to a director in charge of disclosure in cases where the company's internal information must be provided to any third party including but not limited to a trading partner, external auditor, deputy, legal advisor, and business consultant for the purpose of establishing business relation.
2. In cases of Clause 1, the director in charge of disclosure shall implement required countermeasures including but not limited to making non-disclosure agreement.
3. In cases where an issue is caused relevant to the obligation of fair disclosure, the company shall disclose the relevant information without delay (except for the exception determined by Disclosure Regulations article 15)

Chapter 3 Disclosure of Internal Information

Article 9 Sorts of Disclosure

The company's disclosure of information is categorized as below.
1. Report and disclosure of the major state of business according to Disclosure Regulation Part 1 Chapter 2 Clause 1
2. Inquiry notice according to Disclosure Regulation Part 1 Chapter 2 Clause 2
3. Fair disclosure according to Disclosure Regulation Part 1 Chapter 2 Clause 3
4. Self-disclosure according to Disclosure Regulation Part 1 Chapter 3
5. Provision of securities report according to the applicable law Part 3 Chapter 1
6. Provision of the business report according to the applicable law article 159, article 160, article 165, and Disclosure Regulation Part 1 Chapter 2 Clause 4
7. Provision of Major Statement Report according to the applicable law article 161
8. Any other sorts of disclosure according to applicable laws

Article 9-2 Object of Disclosure

In accordance with Disclosure Regulation Article 6 Clause 1 Prescript 4, the company shall take care of inclusion of contents and factors that may cause a significant effect on stock price or investment decision in cases where the company determines whether the object is included in the obligations of disclosure.

Article 10 Implementation of Disclosure

1. A manager in charge of disclosure is obligated to write required documents and report them to the director in charge of disclosure in cases where matters subject to disclosure in accordance with Article 9.
2. A director in charge of disclosure is obligated to review and determine the legality of the reported contents and documents and report the result of the determination to the chief executive officer before disclosure.

Article 10-2 Immediate Implementation of Disclosure

A director in charge of disclosure shall do his/her best to disclose the relevant internal information in a timely manner even before the time limit of disclosure in cases where matters subject to disclosure in accordance with Article 9.

Article 11 Post Management of Disclosure

In cases where the disclosed information has an error or omits any of required contents, a director and manager in charge of disclosure shall implement any required countermeasure immediately including but not limited to change or cancellation of the disclosed contents in accordance with Disclosure Regulation Article 30.

Article 12 News Coverage and Others

1. The chief executive officer or a director in charge of disclosure shall accept the request for an interview in accordance with the general rules. In case of necessity, a head or employee of the relevant department may accept the request if an interview.
2. The company shall consult with a director in charge of disclosure before distribution of press release. A director in charge of disclosure may report the relevant issue as to the distribution of press release to the chief executive officer in case of necessity.
3. In cases where the released information is an object of fair disclosure in accordance with Clause 2, a director in charge of disclosure shall disclose the information before the press release.
4. Any executive or employee is entitled to report a factual error included in the released information to a director in charge of disclosure when he/she recognizes it. The director in charge of disclosure is obligated to report the relevant issue to the chief executive officer and implement proper measures.

Article 12-2 Review of Released Information

Directors and managers in charge of disclosure and the related department shall review the relevant released information routinely and implement proper countermeasure in cases where the released information have any factual error.

Article 13 Company Presentation

1. The chief executive officer is obligated to do his/her best to establish the trust relationship with investors by holding company presentation consistently and spontaneously with the recognition of responsibilities to Investor Relations as a CEO of the company listed in KOSDAQ.
2. Any company presentation shall be held by consultation with a director in charge of disclosure in consideration of the company's business management, business plan, and perspective.
3. Directors and managers in charge of disclosure are obligated to disclosure the date, place, and contents of a scheduled company presentation a day before the presentation and publish the relevant information on the exchange's report system.
4. All executives and employees shall take care not to disclose non-disclosed information during the company presentation.

Article 13-2 Rumor

1. A director in charge of disclosure is obligated to check that the authenticity and confidentiality of certain rumors by a discussion with relevant department in cases where a rumor is diffused in the market.
2. A director in charge of disclosure shall notify the related information in cases where the rumor is the object of the obligations of disclosure.

Article 13-3 Request of Provision of Information

1. In cases where a shareholder or a person concerned requests provision of the company's information, a director in charge of disclosure shall determine whether the company discloses the requested information or not in consideration of legality.
2. A director in charge of disclosure is entitled to ask advice and opinion from external legal advisors and/or the company's legal team in order to determine whether the requested information causes an effect on the stock price or investment decision.
3. Article 12 Clause 3 shall be applied to the case of provision of the requested information in accordance with Clause 1.

Chapter 4 Regulations of Insider Transaction

Article 14 Profits on a Short-Term Trade

1. Executives and employees who pursuant to Article 172 Clause 1 and Article 194 of the applicable law shall return the profits gained by buying the particular securities ("particular securities") within 6 months before selling these securities("Profits on Short-term Trade").
2. In cases where the company's stockholder(including but not limited to an owner of equity security and security depository) requests the company to claim the return of profits on a short-term trade, the company shall implement required measures within 2 months from the date when the stockholder requests.
3. In cases when Securities and Futures Commission notifies the company of an occurrence of profits on short-term trade, a director in charge of disclosure is obligated to release the information below on the company's official webpage.
     ① The position of a person who is obligated to return his/her profits on short-term trade
② The amount of profit on short-term trade
③ The date of notification of the occurrence of profits on short-term trade from Securities and Futures Commission
④ The plan of the return of profits on short-term trade
⑤ Stockholders of the company are entitled to request a claim of return of profits on short-term trade. The stockholders are entitled to claim the return of profits on short-term trade on behalf of the company in cases where the company does not claim the return within two months from the date when the stockholder requests.
4. The period of disclosure shall be 2 (two) years from the date of notification of the occurrence of profits on short-term trade from Securities and Futures Commission or the date of return of the profits on short-term trade (earlier date has the priority)

Article 15 Notification of Sales of Particular Securities

The company shall notify a director in charge of disclosure of any and all occurrence of insider transaction or the sales of particular securities performed by executives and employees who pursuant to Article 172 Clause 1 and Article 194 of the applicable law.

Article 16 Prohibition of Usage of Undisclosed Important Information

All and any executives and employees shall not make use of undisclosed important information prescribed by the applicable law Article 174 clause 1 for the purpose of transaction of particular securities or other sorts of transactions nor make others use these sorts of information.

Chapter 5 Supplementary Provisions

Article 17 Training

1. Directors and managers in charge of disclosure shall complete the courses and training relevant to public disclosure in accordance with Disclosure Regulation Article 36 and Article 44 Clause 5. A director in charge of disclosure shall notify related executives and employees of the contents of the education.
2. Chief executive officer is obligated to do his/her best to train in executives and employees to prevent insider transactions in accordance with the applicable law Article 14, 15, and 16.

Article 18 Amendment and Cancel of Regulations

Chief executive officer is entitled to amend or cancel the regulations.

Article 19 Declaration of Regulations

The regulations shall be notified on the company's official website as well as amendment and cancellation of the regulations.

Appendix