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This policy serves to stipulate general management and appropriate disclosure of the company’s inside information for the purposes of ensuring fast and accurate announcement of such information and of preventing employees of the company from engaging in insider trading in accordance with the Financial Investment Services and Capital Markets Act (hereafter referred to as “the Act”) and other relevant laws and regulations.

① Insider Information, as used herein, refers to mandatory announcements as defined in Korea Exchange’s (hereinafter referred to as “the Exchange”) KOSDAQ Announcement Regulations (hereinafter referred to as “the Announcement Regulations”) Part 1 and other pieces of information that pertain to the company’s management and assets and could influence the decisions of investors.

② Announcement Supervisor, as used herein, refers to the individual tasked to submit reports at the as a representative of the company and in accordance with Article 2-4 of the Announcement Regulations.

③ Executives, as used herein, refers to directors (individuals who meet any one of the criteria stipulated under Article 401-2-1 of the Commercial Act) and auditors.

④ Terms that are used herein and are not otherwise defined under above Paragraphs ① through ③ shall follow their respective definitions under relevant laws and regulations.

Matters pertaining to announcements, insider trading, and management of insider information are as stipulated herein, unless specified otherwise under relevant laws and regulations or the company’s articles of incorporation.

① Employees are required to manage insider information they come to acquire in the course of performing their work with the utmost care and are prohibited from leaking insider information neither within the company nor to individuals outside the company unless required to do so in performing their work.

② The CEO is required to take necessary measures for proper management of insider information, such as establishing detailed conditions and requirements pertaining to the storage, distribution, and destruction of insider information and related documents thereof.

④ The announcement supervisor may confer with relevant employees in performing their duties and seek the counsel of experts at the company’s expense.

⑤ The announcement supervisor is required to submit regular reports pertaining to the status of the insider information management policy’s implementation to the CEO (or the board of directors).

① The CEO is required to designate an announcement manager and report the appointment to the Exchange without delay. The same applies in the event of an announcement manager replacement.

② The announcement supervisor and the CEO are required to deploy, in an efficient manner, an internal communication system for timely dissemination of insider information as per Paragraph ① and make arrangements so that employees can seek the assistance of the announcement supervisor in authorizing tasks related to announcement requirements.

The announcement supervisor is to provide the largest shareholder a sufficient explanation pertaining to announcement requirements concerning the largest shareholder and inquiry notices and to deploy a communication system for timely receipt of relevant information.

① If new insider information requiring disclosure emerges or is expected to emerge from a subsidiary, the company must order the concerned subsidiary to inform the announcement supervisor or the announcement manager of the matter without delay.

② The company is to instruct its subsidiaries to appoint individuals responsible for overseeing announcement-related information for the efficient management of insider information as per Paragraph ① and to instruct its subsidiaries to report, without delay, to the announcement supervisor or the announcement manager of such appointments and changes thereof.

③ The company may request relevant documents from its subsidiaries within the scope of need pertaining to the execution of announcement-related tasks.

① Should it become necessary for an employee to disclose insider information to a business contact outside the company, to an external

② In the event of extrainstitutional disclosure of insider information as per Paragraph ①, the announcement supervisor must implement a non-disclosure agreement and take other necessary actions.

③ Should a fair disclosure requirement arise in the course of extrainstitutional disclosure of insider information as per Paragraph ①, the announcement must be made without delay (excluding as exempted under Article 15 of the Announcement Regulations).

In determining announcement and fair announcement requirements as per the policy herein, information that seriously influences or has the potential to seriously influence share prices and investor decisions as per Article 6-1-4 of the Announcement Regulations must be included.

① Once a need to make an announcement as per Article 9 herein arises, the announcement manager is to document the information and report to the announcement supervisor along with necessary documentation.

② The announcement supervisor is then to review the report and documentation as per Paragraph ① to ensure they are not in violation of relevant laws and regulations, report the findings to the CEO, and make the announcement.

Once a need to make an announcement as per Article 9 herein arises, the announcement supervisor is to make best effort to ensure that the concerned insider information is announced on time, even if the announcement deadline as per the Announcement Regulations has not been reached yet.

Should a previously made announcement contain a mistake or be incomplete and therefore need to be revised or retracted, the announcement supervisor and the announcement manager are to immediately issue a revision announcement and take other necessary actions as per Article 30 of the Announcement Regulations.

① When requested for information by the press, the CEO or the announcement supervisor shall, as a rule, be the one to respond. It is, however, possible for individuals from relevant teams and departments to respond if necessary.

② The announcement supervisor must be consulted before the distribution of any press release. The announcement supervisor is to report to the CEO on matters related to press-release distributions when necessary.

③ Should a press release as per Paragraph ② contain information that needs to be announced, the announcement supervisor is to announce said information prior to the distribution of the press release.

④ Employees who come to realize information reported by the press is not factual are required to report the matter to the announcement supervisor. The announcement supervisor is then to report the matter to the CEO and take necessary actions.

The announcement supervisor, the announcement manager, and individuals from teams and departments whence insider information originates are to regularly monitor press coverage of the company and, if a reporting is inaccurate, take necessary actions to correct the misinformation.

① The CEO, in recognition of IR activities being a responsibility of corporations listed on the KOSDAQ exchange, is to provide voluntary corporate presentations on an ongoing manner to earn and maintain the trust of investors.

② Said corporate presentations are to address the company’s management status, business plan, and forecasts and to be given in consultation with the announcement supervisor.

③ The announcement supervisor or the announcement manager is to announce the date, time, venue, and details of each corporate presentation in advance of the presentation and post relevant information via the Exchange’s announcement submission system also in advance of the presentation. All employees of the company must take caution not to disclose previously undisclosed information that is intended to be released as a fair announcement at a corporate presentation.

① If there is a rumor circulating in the market, the announcement supervisor is to gather opinions concerning the relevant team or department, ascertain the validity of the rumor, and determine whether the rumor amounts to insider information. If the rumor is verified as being information that needs to be announced in accordance with the Announcement Regulations, the announcement supervisor is to announce said information.

① In the event of an information request from a shareholder or an interested party, the announcement supervisor is to review the lawfulness of said request and decide whether or not to provide the requested information.

② The announcement supervisor may, when determining whether or not to provide requested information, consult the legal department or an external legal consultant to see if said information could influence the decisions of investors and/or share prices.

③ Stipulations under Article 12-3 shall apply if a decision is made to release requested information as per Paragraph ①.

① If an executive or an employee as per Article 172-1 of the Act and Article 194 of the Act’s enforcement ordinance buys specific shares as per Article 172-1 of the Act (hereinafter referred to as “Specific Shares”) and sells said shares within six months or sells Specific Shares and buys them back for a profit within six months, said executive or employee must return the profits (hereinafter referred to as “Short-term Trade Profits”) to the company.

② Should a company’s shareholders (including individuals holding shares, equity securities, or depository receipts and applies throughout this article) request an individual who acquired Short-term Trade Profits as per Paragraph ① to return said Short-Term Trade Profits, the company shall take necessary actions within two months following receipt of said request.

④ The deadline for the announcements as per Paragraph ③ is whichever is sooner between two years following notification of Short-term Trade Profits from the Securities and Futures or receipt of Short-term Trade Profits.

If an executive or an employee as per Article 172-1 of the Act and Article 194 of the Act’s enforcement ordinance trades Specific Shares, that executive or employee must report the matter to the announcement supervisor.

The company’s employees are prohibited from using or having a third party use undisclosed key information as per Article 174-1 of the Act (including undisclosed key information of affiliates) to trade Specific Shares or engage in any other form of trading.

※ The company may register itself on Korea Exchange’s KRX-Insider Trading Alarm Service, a platform for preventing insiders from using undisclosed key information, facilitating the restitution of short-term trade profits, preventing unfair trade practices, and reporting share status, and use the service to complete notices and reports as per Articles 14 through 16.

① The announcement supervisor and the announcement manager are to complete announcement training as per Article 36 and Article 44-5 of the Announcement Regulations. The announcement supervisor is to notify employees of information related to said training.

② The CEO is to provide employees with training to prevent insider trading as per Articles 14 through 16 and relevant laws and regulations and take other sufficient steps.

This policy may be revised or abolished by the CEO.

This policy is to be announced on the company’s website. Revised versions of the policy are also to be announced in the same manner.