The First Chapter. General rules

Article 1【Purpose】
The purpose of this regulation is to establish matters concerning the comprehensive management and proper public announcement of company internal information in order to promptly and accurately disclose information according to laws and regulations and to prevent insider trading of officers and employees.

Article 2【The definition of a term】
① The term "internal information" in this Regulation refers to the public announcement requirements of Part 1 of the KOSDAQ Market public announcement Regulations (here in after referred to as the "public announcement Regulations") of the Korea Exchange (the "Exchange"). It refers to matters that may affect investors' investment decisions.
② "public announcement Officer" means a person who is able to perform the reporting business on behalf of the Company pursuant to Paragraph 4 of Article 2 of the public announcement Regulations.
③ "Officers" means directors (including persons falling under any of the subparagraphs of paragraph 1 of Article 401 of the Commercial Act) and auditors.
④ In addition to paragraphs 1 to 3, the definition of terms used in this regulation shall be as defined in the terms used in the relevant laws and regulations.

Article 3【A range of application. 】
Except as otherwise provided in applicable laws or the Articles of Incorporation, these regulations shall be followed, about public announcement, insider trading and internal information management.

The second chapter. Insider information management

Article 4【Insider information management】
① Executives and employees shall strictly control the internal information of the company that they have learned in their work, and shall not disclose internal information to the inside or outside of the company, except when necessary for business purposes.
② The representative director or public announcement officer shall take necessary measures for internal information management, such as setting specific standards for custody, transmission and destruction of internal information and related documents.

Article 5【Public announcement Officer】
① The CEO shall declare the officer in charge of public announcement and immediately report it to the Exchange. The same shall apply when the person responsible for public announcement is changed.
② The officer responsible for public announcement shall oversee the tasks related to the establishment and operation of the internal information management system and perform the following duties.
1. Enforcement of public notice
2. Checking and evaluating the operation of internal information management system
3. Review of internal information and determination of public announcement
4. Measures necessary for the operation of the internal information management system, such as training for officers and employees
5. Directing and supervising internal information management or department or officer / employee in charge of public announcement
③ The officer in charge of public announcement shall have the following rights in carrying out his duties.
1. The right to request and view the submission of documents and records related to internal information
2. The authority to listen to the necessary comments from the officers and employees of the department responsible for the creation of internal information and the department responsible for accounting or auditing
④ The public announcement officer may consult with the officer in charge of carrying out the duties, and may seek expert assistance at the expense of the company.
⑤ The public announcement officer shall periodically report to the representative director (or the board of directors) the operational status of the internal information management system.

Article 6【Public announcement officer】
① The representative director or the public announcement officer shall determine the person responsible for public announcement and notify the Exchange immediately without delay. It is also the same when the public announcement officer is changed.
② The public announcement officer shall be under the direction of the leading officer of public announcement in relation to internal information management and shall perform the following duties.
1. Collecting and reviewing internal information and reporting to the person in charge of public announcement
2. Duties necessary for execution of public announcement
3. Identification of matters necessary for the management of internal information, such as changes in laws and regulations related to public announcement , and reporting of public announcement officers
4. Other matters deemed necessary by the CEO or the public announcement officer

Article 7【Centralization of insider information】
①The officers and the heads of the respective departments shall provide information to the public announcement officer in cases where any of the following falls
1. Internal information occurs or is expected to occur
2. If there is any reason to cancel or change the already announced internal information, or if it is expected to happen
3. If there is a request from the public announcement officer
② The public announcement officer and the representative director shall establish an information delivery system within the company for timely provision of internal information pursuant to Paragraph 1. If necessary, the public announcement officer may be assisted in the process of approval of the duties related to the public notice requirements.

Article 7-2【Management of the largest shareholder-related information】
The information sharing system should be established by the public announcement officer, so that the largest shareholder can fully explain the relevant facts and receive relevant information in a timely manner, to facilitate public notice of public announcement obligations and public announcement requirements related to the largest shareholder,

Article 7-3【Centralization of internal information of subsidiary company 】
① If the internal information related to the public announcement requirements arises or is expected to occur in the subsidiary company, the Company shall promptly notify the subsidiary company of the information to the company's public notice officer or leading officer of public announcement.
② In order to efficiently manage the internal information related to the public announcement obligations pursuant to Paragraph 1, the Company shall have a person who manages public announcement related information in its subsidiary company. If designated or changed, the Company shall notify the public announcement officer or the leading officer of public announcement immediately do.
③ The Company may require subsidiary company to submit relevant materials to the extent necessary for their public announcement duties.

Article 8【Providing internal information to outside the company】
① If an officer or employee must inevitably provide internal information to a counter party, an external auditor or agent of the company, a person who has concluded an advisory contract with the company, legal advice, management consultation, etc. for business reasons, it should be reported to public announcement officer.
②In the case of Paragraph 1, the public announcement officer shall take necessary measures, such as concluding a contract on the confidentiality of relevant internal information.
③ If an obligation for fair disclosure occurs in providing internal information pursuant to Paragraph 1, it shall be disclosed without delay (Exceptions to the application of Article 15 of the Public announcement Regulations)

The Third Chapter. Disclosure of Internal Information

Article 9【Type of public announcement】
The public announcement of the Company is divided into the following.
① Reporting and public announcement of Major Management Matters in accordance with Article 1, Chapter 2, Section 1 of the public announcement Regulations
② Public announcement in accordance with Article 2, Section 2 of Part 1, public announcement Regulations
③ Public announcement of fairness pursuant to Part 2, Section 3 of Part 1,
④ Public announcement pursuant to Article 3 of Part 1 of the Public announcement Regulations
⑤ Submission of securities report in accordance with Chapter 1 of Chapter 3 of the Act on Capital Market and Financial Investment Business (here in after referred to as the "Law")
⑥ Submission of business reports in accordance with Articles 159, 160 and 165 and Article 4 of the Regulations.
⑦ Submission of important matters report under Article 161 of the law
⑧ Public announcement in accordance with other laws and regulations

Article 9-2 【Confirmation of Public announcement target】
According to this regulation, care should be taken to include matters that may or may not materially affect share prices or investment decisions under Article 6 (1) 4 of the public announcement Regulations, In determining whether it is necessary to public announcement information including fair public announcement.

Article 10【Execution of Public announcement】
① The public announcement officer shall prepare the necessary information in the event of the disclosure prescribed in Article 9 and provide the necessary documents and report it to the leading officer of public announcement.
② The public announcement officer shall examine whether the contents and documents in Paragraph (1) are not in violation of relevant laws and regulations, and report the information to the representative director.

Article 10-2 【Prompt implementation of public announcement】
The public announcement officer shall make every effort to ensure that the internal information is disclosed in a timely manner even if the public announcement is made pursuant to Article 9, in accordance with the notification regulations.

Article 11【Follow-up action after public announcement】
Public announcement officers and leading officers of public announcement shall take corrective measures to correct such public announcement errors or omissions or to cancel or change them in accordance with Article 30 of the public announcement.

Article 12【Covering of media ,etc.】
① If there is a request for covering from a media company or the like, the representative director or the officer in charge of public announcement shall respond accordingly. If necessary, the officers and staff of relevant departments may be allowed to respond.
② If you want to distribute press releases to media companies, you should obtain the approval of the official in charge of public announcement. If necessary, the public announcement officer should report to the CEO about the distribution of the press release.
③ If the contents of the press release distributed pursuant to Paragraph 2 fall under the fair public announcement subject, the public announcement officer shall disclose it before distribution of the press release.
④ Any officer or employee who finds that the media reports are different from the facts, shall report them to the public announcement officer.
The public announcement officer shall report the matter to the representative director and take necessary measures.

Article 12-2【Confirmation of contents reported】
Public announcement officer, leading officer of public announcement, and internal information public announcement department shall routinely check the news reports of companies such as media companies and take measures to rectify any facts that are different from the facts.

Article 13【Company presentation】
① The CEO shall recognize the fact that IR activities are the management responsibilities of KOSDAQ listed companies, and shall endeavor to build trust with investors by holding company briefings continuously and voluntarily.
② A company briefing on the management content, business plans and prospects of the company should be held with the approval of the public announcement officer.
③ The public announcement officer or leading officer of public announcement shall disclose the date, place, and contents of the company until the day before the meeting, and post the relevant data to the KOTS public announcement system before the presentation.
④ All executives and employees of the company should be careful not to disclose any items not disclosed in advance of the fair public announcement subject information during the company briefing process.

Article 13-2【Rumor】
① The public announcement officer should confirm whether the contents of the story are true or not, by inquiring about related business department, if there is a rumor in the market.
② If the result of verification in accordance with Paragraph 1 above is applicable to public announcement requirements in accordance with the public announcement rules, relevant information shall be disclosed.

Article 13-3【Request of information】
① Shareholders and stakeholders, the public announcement officer shall examine the legality of the request and decide whether to provide the relevant information.
② The public announcement officer may hear opinions from the Legal Department or external legal experts on whether the information requested to be provided may determine the investor's investment decisions and share price to determine whether to provide the information.
③ Where information is provided pursuant to the decision of paragraph (1), Article 12 (3) shall apply.

The Fourth Chapter. Regulation on Insider Trading

Article 14【Return of short-term trading gains】
① If an officer and an employee (Article 194 of the Enforcement Decree of the Enforcement Decree of the Act shall be limited to the person who can know the undisclosed material information of Article 174 (1) of the Commercial Act. The same shall apply in Article 15 hereafter.) acquire a certain securities under Article 172 (1) of the Act (hereinafter referred to as "the specified securities, etc.") and sell the securities within six months or sell the specified securities, (Hereinafter referred to as "short-term trading profits") to the Company.
② The shareholders of the Company (including those who own equity securities or securities deposited securities other than sovereigns, the same shall apply in this Article hereinafter) require the Company to request the return of short-term trading profits to the person who obtained the short- In such case, the disclosure officer 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 the short-term trading gains pursuant to Paragraph 1, the public announcement officer shall immediately public announcement the following matters on the Company's Internet homepage.
1. The status of the person who should return the short-term trading gains
2. short-term trading gains
3. Date of notification of short-term trading gains from the Securities & Futures Commission
4. Plan for restoration of an estate in trust of short-term trading gains
5. A shareholder of the Company may require the Company to request the return of short-term trading gains to the person who earns the short-term trading profits. And if the Company fails to make such a request within two months from the date of the request, shareholder can charge them for it instead of the company.
④ The public announcement period of Paragraph (3) is 2 years from the date of notification of short-term trading gains, or the returning date, whichever is less.

Article 15【Notification of sales of particular stock】
An officer and an employee prescribed by Article 172, Paragraph 1 of the Law and the Enforcement Decree of the Law shall notify the public announcement officer of the fact that they engage in the sale or other transaction of a specific security.

Article 16【Prohibition of use of non-public important information】
Officers and employees shall not use undisclosed material information (including undisclosed material information of affiliated companies)as prescribed in Article 174 (1) of the Law, for sale or other transactions of specified securities, or make them available to others.

The Fifth Chapter. Supplementary Rules

Article 17【Training】
① The public announcement officer and the leading officer of public announcement must complete the training session related to the disclosure duties under Article 36 and Article 44 (5) of the Disclosure Regulations, and the public announcement officer shall ensure that the contents of education are disseminated to the relevant officers and employees.
② The Representative Director shall make sufficient efforts to the officers and employees, including the provisions of Articles 14 to 16 and the implementation of education to prevent insider trading prescribed by other laws.

Article 18【Revision and revocation of the regulations】
Revision or the revocation of these regulations shall be made by the representative director.

Article 19【Official announcement of regulations】
These regulations shall be officially announced on the website of the Company. The same shall apply when the Regulations are revised.

Supplementary provision

1. This regulation shall be effective from December 19, 2013.

Supplementary provision

1. This regulation shall be effective from May 23, 2017.