Chapter 1: General Provisions

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Article 1 [Purpose)

This regulation ensures that all disclosed information of the Company is disclosed accurately, completely, fairly and in a timely manner in accordance with relevant laws and regulations, as well as necessary for disclosure-related tasks and procedures, management of disclosure information, etc. to prevent unfair trade by employees. The purpose is to set matters.

Article 2 (Scope of Application)

Matters related to the performance of disclosure duties and management of disclosure information shall be governed by the provisions of these regulations, except those provided for in laws, related regulations, or articles of incorporation.

Article 3 (Definition of Terms)

① “Disclosure information” refers to matters that may affect investors’ investment decisions regarding the Company’s management and property, etc. Enforcement Decree”), the Financial Services Commission (hereinafter referred to as the “Financial Commission”) regulations on the issuance and disclosure of securities (hereinafter referred to as the “Issuance Disclosure Regulations”), and securities of the Korea Exchange (hereinafter referred to as the “Exchange”) Refers to disclosure matters and related information stipulated in relevant laws such as market disclosure regulations (hereinafter referred to as “disclosure regulations”).

② “Disclosure documents” refer to reports and reports (including electronic documents) submitted for disclosure of public information and documents attached thereto.

③ “Disclosure control system” refers to all business activities in which disclosure information is managed according to a certain control procedure in the relevant organization within the company.

④ “Disclosure control organization” refers to the representative director, disclosure manager, disclosure department and creation of disclosure information that performs disclosure related tasks such as creation, collection, review, preparation and approval of disclosure documents in accordance with this regulation. related business units.

⑤ “Person in charge of disclosure” refers to a person who has been designated by the CEO and is in charge of the company's disclosure business, and is registered with the Exchange as the person in charge of disclosure in accordance with Article 88 (1) of the Disclosure Regulations.

⑥ The “disclosure department” refers to the department in charge of the company's disclosure duties in accordance with the company's business and organization regulations. In this case, two or more “disclosure officers” registered with the exchange pursuant to Article 88 (2) of the Disclosure Regulations shall belong to the disclosure department.

⑦ “Business department” refers to a department that performs tasks related to the generation of the Company's publicly disclosed information.

⑧ “Regular disclosure” refers to matters related to the company’s business, financial situation and business performance in general, such as Article 159, Article 160, Article 165 of the Act, Article 168, Article 170 of the Enforcement Decree, and Disclosure Regulations Submission of business reports, semi-annual reports, and quarterly reports to the FSC or the Exchange in accordance with Article 4-3 and Article 21 of the Disclosure Regulations.

⑨ “Occasional disclosure” refers to the disclosure of major business matters, and reporting or disclosing to the exchange in accordance with Article 7 of the Disclosure Regulations, major facts or decisions affecting investment decisions related to the Company’s business activities.

⑩ “Fair disclosure” refers to Articles 15 and 16 of the Disclosure Regulations and fair disclosure operation of the exchange when the Company selectively provides information that is not subject to disclosure obligations under relevant laws or that has not reached the disclosure deadline to a specific person. It refers to the disclosure of the information on the exchange so that general investors can know it at the same time (or until it is selectively provided to a specific person) in accordance with the standards.

⑪ “Inquiry and Disclosure” refers to the confirmation of the facts of rumors and reports related to the Company, or the disclosure of material information upon request from the Exchange pursuant to Article 12 of the Disclosure Regulations.

⑫ “Voluntary disclosure” means that the Company judges that it may have a significant impact on the company's management, property, and investors' investment decisions other than the occasional disclosure in Paragraph 9, or that it is necessary to disclose information that is not subject to disclosure In this case, it refers to the disclosure on the exchange in accordance with Article 28 of the Disclosure Regulations and Article 8 of the Concurrent Regulations.

⑬ “Issuance disclosure and reporting of major matters” refers to matters related to the company’s organizational change, such as the solicitation of securities, sales, merger, division, business transfer, etc., or the acquisition and disposal of treasury stocks under Article 119, Article 119 of the Act. Articles 121 to 123, 130, 161, Article 120 to Article 122, Article 137, Article 171 of the Enforcement Decree, Articles 2-4, 2-6, Article 2- It refers to the submission of related reports to the FSC in accordance with Articles 14, 2-17, 4-5, 5-8 to 5-10, and 5-15.

⑭ Terms used in this regulation are subject to the examples of terms used in related laws and regulations, except as otherwise provided in this regulation.

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​ Chapter 2 Basic Authority and Responsibilities of Disclosure Control Organization

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Article 4 (CEO)
① The CEO is in charge of all affairs related to the disclosure control system.
② The representative director performs the following tasks so that the disclosure control system can be operated effectively.
1. Policy establishment for design and operation of disclosure control system
2. Establishment of authority, responsibility and reporting system for disclosure control system
3. Final inspection of the operation status of the disclosure control system and final evaluation of operational performance
4. Approval of regulations related to disclosure control system
5. Other necessary matters

Article 5 (Person in charge of disclosure)
① The person in charge of disclosure is appointed by the CEO
② The person in charge of disclosure is responsible for the design and operation of the disclosure control system and performs the following duties.
1. Tasks related to review, approval, and enforcement of disclosure information and disclosure documents (including related documents; hereinafter the same shall apply)
2. Measures necessary for employees to comply with laws and regulations related to disclosure (conduct related training, preparation of guidelines, etc.)
3. Identification of disclosure risk factors and establishment and implementation of countermeasures
4. Regular monitoring of the disclosure control system, regular inspection of operational status, and evaluation of operational performance
5. Determination of whether or not to disclose matters not explicitly specified to be disclosed in relevant laws and regulations
6. Directing and supervising the disclosure department
7. Establishment and implementation of education plans for employees related to disclosure duties
8. Approval of detailed guidelines for the implementation of regulations related to the design and operation of the disclosure control system
9. Other matters deemed necessary by the CEO in relation to the disclosure control system
③ The person in charge of disclosure shall have the following authority if necessary for performing his/her duties.
1. Request for submission of various books and records related to disclosure matters and the right to read
2. Right to listen to opinions of executives and employees of accounting or auditing departments, and other departments related to the creation of public information and preparation of public documents
④ The person in charge of disclosure may consult with the executive or auditor (auditor member) if necessary in performing his/her duties, and may listen to the opinions of external experts.

Article 6 (Disclosure Department)
① The representative director shall organize a department in charge of public disclosure, including those with specialized knowledge regarding disclosure. Two of them must be appointed as the person in charge of disclosure in accordance with Article 88 (2) of the Disclosure Regulations.
② The disclosure department shall be under the direction of the disclosure manager in relation to disclosure affairs and perform the following tasks.
1. Collection and review of various public information
2. Preparation of disclosure documents and execution of disclosure
3. Establishment of the annual disclosure work plan and inspection of the current status of implementation
4. Review of measures necessary for compliance with laws, such as regular inspection of the enactment and revision of disclosure-related laws and regulations, and reporting to the person in charge of disclosure
5. Identification, inspection, evaluation and management of disclosure risks at the company-wide level
6. Other matters deemed necessary by the CEO or the person in charge of disclosure

Article 7 (Business Department)
① The head of each business department shall, in cases falling under any of the following subparagraphs, deliver relevant information to the disclosure department in a timely manner.
1. In the event that disclosures stipulated in the disclosure laws occur or are expected to occur
2. When it is unclear whether or not to disclose a matter that has a significant impact on the management of the company
3. When reasons for cancellation or change of previously disclosed matters occur or are expected to occur
4. In case of receiving a request from the person in charge of disclosure or the head of the disclosure department
② In the case of delivering the disclosure information in the preceding paragraph, a copy of the relevant contents and necessary evidence and reference materials shall be delivered in writing to the disclosure department and the original shall be kept. However, if it is urgent or there are unavoidable reasons, it may be delivered by an appropriate method other than a document, but a copy of the relevant content may be delivered as a document afterwards.

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​ Chapter 3 Disclosure Control Activities and Operation

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Section 1 Periodic Disclosure

Article 8 (Regular Disclosure)
The company shall prepare regular disclosure documents and submit them to the FSC and the Exchange within the disclosure deadline.

Article 9 (Business Department)
① The head of each business department shall establish and implement a detailed implementation plan by checking the tasks assigned to the relevant department and the disclosure schedule, etc. for the disclosure of regular disclosure matters in accordance with the annual disclosure work plan The inspection contents shall be delivered to the disclosure department.
② The head of each business department shall perform the duties assigned to the relevant business department for the purpose of public disclosure of regular disclosure matters and submit it to the disclosure department by the submission deadline set in the annual disclosure business plan.
③ If the head of each business department is expected to fail to comply with the deadline for submission of the preceding paragraph due to delay in business implementation, etc., he/she shall immediately notify the disclosure department and take necessary measures upon the request of the disclosure department head.

Article 10 (Disclosure Department)
① The head of the disclosure department shall check the disclosure matters and the disclosure schedule for the implementation of the disclosure of regular disclosure matters, establish an annual disclosure work plan including the division of duties by business division, obtain approval from the disclosure manager, and deliver it to each business department in writing. do.
② If there is a risk that the statutory submission deadline may not be observed based on the inspection and notification details of the business department, the head of the disclosure department shall report it to the person in charge of disclosure and receive instructions for taking necessary measures. you can request
③ The head of the disclosure department shall prepare regular disclosure documents in accordance with the format and method prescribed by the relevant laws by synthesizing the information received from each business department, and submit them to the disclosure manager by the deadline set in the annual disclosure work plan.
④ The head of the disclosure department shall obtain the approval of the disclosure manager and the CEO, and execute regular disclosure within the statutory submission deadline. In this case, if certification of the CEO, etc. is required in accordance with relevant laws, the certification shall be attached.

Article 11 (Person in charge of disclosure)
① The person in charge of disclosure shall check the current status of business promotion necessary for the implementation of regular disclosure and take necessary measures if there is a risk that the statutory submission deadline may not be observed.
② The disclosure manager shall review whether the periodic disclosure documents submitted by the disclosure department head are properly prepared in accordance with the relevant laws and regulations, and the accuracy and completeness of the information disclosed through the periodic disclosure documents, and report it to the CEO. The disclosure must be made to the head of the disclosure department with the approval of the company.

Article 12 (CEO)
The representative director must directly confirm, review, and approve the appropriateness of the periodic disclosure documents reported by the disclosure manager, and provide necessary certifications under relevant laws and regulations.

Article 13 (Follow-Up Inspection of Disclosure Content)
① The head of the business department involved in the preparation of regular disclosure documents and the head of the disclosure department shall immediately check the appropriateness of the disclosure contents after disclosure.
② The head of the disclosure department shall take necessary measures, such as correction and disclosure, to immediately correct any errors or omissions in the inspection results.

Section 2 Occasional Disclosure

Article 14 (Occasional Disclosure)
The company shall prepare ad hoc disclosure documents and submit them to the exchange within the disclosure deadline.

Article 15 (Business Department)
① Each business department shall immediately deliver information about ad hoc disclosures to the disclosure department in the event that ad hoc disclosures occur or are expected to occur, or if reasons for cancellation or change of previously disclosed content occur or are expected to occur.
② When a business department receives a request from the head of the disclosure department to supplement the information in Paragraph 1 or to submit additional data, it shall respond immediately. However, if the head of the business department determines that the relevant matter requires significant security or must be kept confidential, he/she shall report it to the person in charge of disclosure and follow the instructions.

Article 16 (Disclosure Department)
① When the disclosure department receives information on ad hoc disclosure matters from the business department, it shall immediately review whether the information falls under the disclosure matters, and review the accuracy and completeness of the information. If necessary, the head of the disclosure department may request the relevant business department to supplement information or submit additional data.
② As a result of the review in the preceding paragraph, if any of the occasional disclosure matters are met, the head of the disclosure department shall prepare a review of the information and occasional disclosure documents and report it to the person in charge of disclosure. Disclosure shall be carried out in accordance with However, if it is difficult to obtain approval from the person in charge of disclosure, such as the absence of a person in charge of disclosure, the head of the disclosure department may execute the disclosure, and in this case, it should be reported to the person in charge of disclosure afterwards.
③ The head of the disclosure department shall write the reason and the details of the review of the relevant information in a document and report it to the person in charge of disclosure if it does not fall under the disclosure matters as a result of the review in Paragraph 1.

Article 17 (Person in charge of disclosure)
① The person in charge of disclosure shall review whether the contents of the review in Paragraphs 2 and 3 of the preceding Article and disclosure documents are properly prepared in accordance with the relevant laws, and approve the disclosure.
② The person in charge of disclosure shall report important matters related to ad hoc disclosure to the CEO.

Article 18 (Follow-up inspection of disclosure contents)
The provisions of Article 13 shall apply mutatis mutandis to ad hoc disclosure. In this case, “regular disclosure documents” shall be construed as “ad-hoc disclosure documents”.

Section 3 Fair Disclosure

Article 19 (Fair Disclosure)
A company must prepare a fair disclosure document and submit it to the exchange within the disclosure deadline.

Article 20 (Prohibition of Bypass Provision of Information Subject to Fair Disclosure)
The fair disclosure information provider (referring to the person specified in Article 15 Paragraph 2 of the Disclosure Regulations) is a person subject to fair disclosure information in a detour (in Article 15 Paragraph 3 of the Disclosure Regulations) It shall not be provided to the person who determines it).

Article 21 (Notes)
① In the case of fair disclosure, the person in charge of disclosure, the person in charge of disclosure, the business department and contact information related to the information subject to fair disclosure, etc. should be specified.
② If there is a request from the exchange, the information on the summary of fair disclosure and the address of the website shall be disclosed to the exchange, and the summary and the original text shall be posted on the website of the company.

Article 22 (Application Mutatis Mutandis)
The provisions of Articles 13 and 15 through 17 shall apply mutatis mutandis to fair disclosure. In this case, “regular disclosure documents” in Article 13 shall be construed as “fair disclosure documents”, and “occasional disclosure” in Articles 15 through 17 as “fair disclosure”.

Section 4 Inquiry Disclosure

Article 23 (Inquiry and Disclosure)
The company shall prepare the inquiry disclosure document and submit it to the exchange within the disclosure deadline.

Article 24 (Disclosure Department)
① When the head of the disclosure department receives a disclosure request from the Exchange, he/she shall immediately check the facts and the existence of important information, prepare disclosure documents, and obtain approval from the disclosure manager to respond to inquiry disclosure.
② The head of the department in charge of disclosure may request each business department to submit data or state opinions in order to confirm the facts or the existence of important information in the preceding paragraph, and in this case, the relevant business department shall comply with the request. However, if the head of the business department determines that the relevant matter requires significant security or that confidentiality must be maintained, he/she shall report it to the person in charge of disclosure and follow the instructions.
③ In the event that the head of the disclosure department is requested to disclose information, if the disclosure is in the process of decision-making (hereinafter referred to as 'unconfirmed disclosure'), he/she obtains approval from the person in charge of disclosure after identifying the final details or progress of the disclosure. Re-disclosure must be carried out within 1 month from the date of unconfirmed disclosure. In this case, if it is judged that it is practically impossible to implement the re-disclosure within one month, the re-disclosure deadline shall be specified and the disclosure shall be carried out.

Article 25 (Application Mutatis Mutandis)
Article 13, the proviso to Article 16 Paragraph 2, and the provisions of Article 17 apply mutatis mutandis to inquiry and disclosure. In this case, “regular disclosure” in Article 13 is “inquiry disclosure”, “frequent disclosure” in Article 17 is “inquiry disclosure”, and “reviewed in paragraphs 2 and 3” in Article 17 (1) Disclosure documents” shall be construed as “confirmed contents and disclosure documents in Paragraph 1”.

Section 5 Voluntary Disclosure

Article 26 (Voluntary Disclosure)
A company may prepare a voluntary disclosure document and submit it to the exchange within the disclosure deadline.

Article 27 (Judgment of voluntary disclosure matters and collection of information)
① The disclosure manager may instruct the head of the disclosure department to collect necessary information and prepare disclosure documents for matters deemed necessary for voluntary disclosure or when reasons for cancellation or change of previously disclosed contents occur or are expected to occur.
② Information necessary for the head of the business department when the head of the disclosure department determines that voluntary disclosure is necessary, when a reason for cancellation or change of previously disclosed contents occurs or is expected to occur, or when there is an instruction from the person in charge of disclosure pursuant to the preceding paragraph You may be asked to provide or submit data.
③ When the head of a business department determines that voluntary disclosure is necessary, or when a reason for cancellation or change of previously disclosed contents occurs or is expected to occur, or in accordance with the provisions of the preceding paragraph, the head of the disclosure department provides or In the event of a request to submit data, the information or data related thereto shall be immediately delivered in writing to the disclosure department in accordance with the method stipulated in Article 7 (2).
④ When the head of the business department receives a request from the head of the disclosure department to supplement the notice in the preceding paragraph or to submit additional data, he/she shall respond immediately. However, if it is judged that the relevant matter requires significant security or confidentiality must be maintained, it must be reported to the person in charge of disclosure and must follow the necessary instructions.

Article 28 (Application Mutatis Mutandis)
Articles 13, 16 and 17 shall apply mutatis mutandis to voluntary disclosure. In this case, “regular disclosure” in Article 13 is “voluntary disclosure,” and “review on whether disclosure matters” in Article 16 Paragraph 1 is “review on the necessity of disclosure”, and Article 2 In the preceding paragraph, “cases subject to disclosure” shall be deemed “cases deemed necessary”, and “cases that do not fall under disclosure matters” in Paragraph 3 of the same Article shall be deemed “cases determined not to require disclosure”; In Articles 16 and 17, “ad-hoc disclosure” is construed as “voluntary disclosure”.

Section 6 Issuance Disclosure and Report on Major Issues

Article 29 (Issuance Disclosure and Report on Major Issues)
The company shall prepare the issuance disclosure and major matters reporting documents and submit them to the FSC within the disclosure deadline.

Article 30 (Establishment of Business Promotion Plan)
The head of the disclosure department confirms the required disclosure items and schedule, etc., and issues the issuance, including the division of duties by business division, when the major issues reported in Article 161 (1) Nos. 6 to 8 of the Act occur or are expected to occur. Disclosure and major matters reporting work implementation plan should be established and approved by the person in charge of disclosure, and delivered in writing to each business department.

Article 31 (Application Mutatis Mutandis)
① The provisions of Article 9 (3), 10 (2) to (3), and Articles 11 to 13 shall apply mutatis mutandis to the issuance disclosure and reporting of major matters in the preceding Article. In this case, “annual disclosure business plan” in Article 10 (3) is “issuance disclosure and major matters reporting business promotion plan”, and “regular disclosure documents” in Article 10 (3) and Articles 11 to 13 It is regarded as 'documents to be published and reported on major issues'.
② Articles 15 through 18 shall apply mutatis mutandis to the reporting of major matters under Article 161, Paragraph 1, Nos. 1 to 5 and 9 of the Act. In this case, “ad-hoc disclosure” and “ad-hoc disclosure document” shall be construed as “report on major issues” and “documents for report on major issues”.

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Chapter 4 Information and Communication

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Article 32 (Collection, Maintenance, and Management of Information)
① Each disclosure control organization shall collect, maintain, and manage necessary information and supporting data both inside and outside the company related to its duties in order to secure the accuracy, completeness, fairness and timeliness of the disclosure information.
② The CEO may prepare an information management system or give necessary business instructions so that executives and employees can collect, maintain, and manage the information in the preceding paragraph and utilize it for related business.

Article 33 (Communication)
The representative director shall endeavor to establish a necessary communication system such as the establishment of a reporting system for smooth information exchange and communication between each disclosure control organization and executives and employees in the process of disclosure duties.

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Chapter 5 Assessment and Management of Disclosure Risks

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Article 34 (Management of Disclosure Risk)
The CEO and the person in charge of disclosure shall ensure that the following disclosure risks, which may negatively affect the accuracy, completeness, fairness and timeliness of disclosure information, are checked in a timely manner and continuously managed.
1. Financial information error: Disclosure risk due to discrepancy between the actual financial condition and disclosure content caused by mistakes in accounting or inconsistency in communication between the person in charge
2. Insufficient form description, error in description: Risk of disclosure due to omission or error in the information required in the form required for disclosure due to lack of understanding of the instructions, etc., typos, etc.
3. Unclearness, insufficiency, and inaccuracy of disclosure content: use of technical terms and abbreviations that are difficult for the general public to understand, lack of sufficient explanation for related contents, disclosure risk due to discrepancy between actual occurrence and disclosure contents
4. Non-fulfillment of the obligation to comply with the disclosure deadline under the relevant laws: Disclosure risk in case of failure to comply with the disclosure deadline due to delay in information delivery, delay in payment, misunderstanding of the disclosure deadline, etc.
5. Omission, concealment, or reduction of disclosure matters: Risk of disclosure due to omission of disclosure due to misunderstanding of disclosure obligations or concealment or reduction of information negative to the company
6. Risk of disclosure of forecast information: The risk of disclosure due to whether the forecast information is not based on rational grounds or assumptions, intentionally false statements, or omission of important matters
7. Leakage of undisclosed information: Risk of disclosure when information that is not disclosed to the public is leaked through abnormal channels, such as being selectively provided to specific people by executives and employees
8. Risks due to changes in the disclosure system: Disclosures that may occur due to changes in disclosure related laws, government policies, changes in the exchange market to which the company belongs, or changes in the person in charge or practice of related supervisory agencies and market operating agencies, etc. danger
9. Change of person in charge of disclosure: Disclosure risk that may occur due to interruption of information succession or loss of continuity in performance of disclosure obligations due to change of person in charge of disclosure
10. Disclosure risk that may negatively affect other disclosed information

Article 35 (Business Department)
① Each business department shall, if a disclosure risk arises or is likely to occur in the course of the performance of disclosure-related tasks, immediately notify the disclosure department and manage appropriately so that disclosure risk does not occur according to the instructions of the disclosure manager.
② The head of each business department shall list the disclosure risks related to the business department and conduct a monthly inspection to ensure proper inspection and management.

Article 36 (Disclosure Department)
① The disclosure department oversees the inspection and management of disclosure risks at the company-wide level.
② The head of the disclosure department shall list the disclosure risk factors and establish an annual work plan to ensure continuous inspection and management, and shall implement it with the approval of the disclosure manager.
③ The head of the disclosure department shall separately classify major disclosure risks, which have a large impact on the company, and conduct daily and monthly inspections to ensure proper inspection and management.

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Chapter 6 Monitoring

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Section 1 Routine Monitoring

Article 37 (Routine Monitoring)
① The head of each business department, the head of the disclosure department, and the disclosure manager check whether disclosure-related tasks are being processed in accordance with the disclosure control system through daily monitoring and, if vulnerabilities are found, take necessary measures to correct and improve them in a timely manner. and check the implementation of the measures afterwards.
② For daily monitoring, approval of documents, requests for submission of reference materials, interviews with employees related to disclosure information, and opinions from accounting or auditing departments can be heard.

Section 2 Operational Status Inspection and Operational Performance Evaluation

Article 38 (Subject and Time)
① The CEO and the person in charge of disclosure shall check the operating status of the disclosure control system and evaluate the performance of the disclosure.
② Operational status check and operational performance evaluation shall be conducted after the end of each business year and before the submission of the business report. However, if the CEO deems it necessary, it can be implemented even during the business year.

Article 39 (Procedures)
① The head of each business department and the head of the disclosure department shall submit a report on the operation status of each department, including self-evaluation, to the disclosure manager within the period of Paragraph 2 of the preceding Article by the date determined by the disclosure manager.
② The disclosure manager shall inspect the operational status of the Company’s disclosure control system and evaluate the operational performance based on the report submitted by each business department and the head of the disclosure department, and report the result to the CEO. In this case, the person in charge of disclosure may obtain advice from the auditor (audit committee), internal audit team, external experts, etc.
③ Based on the results reported by the person in charge of disclosure, the representative director inspects the operating status of the company's disclosure control system and evaluates the operation performance.

Article 40 (Method and Considerations)
① The CEO and the person in charge of disclosure shall conduct a variety of activities such as interviewing with persons involved in the disclosure process, such as generation and delivery of information, reviewing related documents, and listening to opinions of external experts, in order to check the operational status of the disclosure control system and evaluate the operational performance. methods can be used in parallel.
② The following matters shall be considered in the operation status check and operational performance evaluation of the disclosure control system.
1. Whether any changes have occurred that affect the functioning of the disclosure control system since the previous inspection and evaluation
2. Whether the disclosure control system designed and operated by the Company contributes to continuous and accurate information production and reduction of disclosure risk
3. Whether there are any illegal or defective parts in our disclosure control system
4. Whether procedures are sufficient to check the accuracy of financial and non-financial information;
5. Whether sufficient pre-review and post-inspection are being carried out on the matters disclosed by the Company
6. Whether all parties involved in our disclosure control process understand their responsibilities
7. Whether the previously occurring disclosure risks and major disclosure risks are properly evaluated and managed
8. Whether the risk that occurred previously was avoidable through the existing disclosure control system
③ The disclosure manager may prepare and utilize a separate checklist, etc. through consultation on matters deemed necessary in addition to the matters specified in each subparagraph of the preceding paragraph.

Article 41 (Utilization of Evaluation Results)
① The CEO and the person in charge of disclosure shall take necessary measures to improve the weaknesses in control revealed through the operation status check and operational performance evaluation of the disclosure control system.
② The person in charge of disclosure shall check whether the measures in the preceding paragraph are being implemented or not.

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Chapter 7 Prohibition of unfair trade by executives and employees

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Article 42 (General Principles)
Executives and/or employees shall collect material undisclosed information (hereinafter referred to as 'undisclosed material information') related to work, etc. stipulated in Article 174 Paragraph 1 of the Act on specific securities, etc. (hereinafter referred to as 'specific securities, etc.') as stipulated in Article 172 Paragraph 1 of the Act. It shall not be used for the sale or other transaction of) or let others use it.

Article 43 (Transaction of Specified Securities, etc. by Executives and Employees)
① Executives and/or employees must notify the person in charge of disclosure of the circumstances in advance when they intend to trade or sell specific securities, regardless of whether or not they use material undisclosed information.
② The person in charge of disclosure who has received the notice in the preceding paragraph may prohibit the sale or other transaction if it is judged that it is likely to be regarded as a transaction using undisclosed material information. In this case, the relevant executives and employees shall comply with it.
③ Executives and/or employees shall, in the case of trading or other transaction of specific securities, report the transaction details (type of specific securities, etc., trading quantity, transaction date) to the person in charge of disclosure within 10 days from the end of the quarter to which the transaction date belongs.

Article 44 (Management of Undisclosed Material Information)
① The CEO or the person in charge of disclosure shall take necessary measures so that undisclosed material information can be managed in accordance with each of the following subparagraphs.
1. Documents containing undisclosed material information must be kept in a safe place where only authorized executives and employees can use it.
2. Executives and employees shall not discuss important, undisclosed information in places where others can hear the conversation, such as in elevators and hallways.
3. Documents containing undisclosed important information should not be kept in a public place, and when the document is destroyed, it must be destroyed so that the contents of the document cannot be grasped through appropriate methods such as shredding.
4. Executives and employees must maintain the security of their non-disclosed important information not only outside the company but also inside the company.
5. Electronic transmission of documents related to undisclosed important information by fax or computer communication must be performed only in a state where security is guaranteed.
6. Unnecessary copying of documents containing undisclosed important information should be avoided as much as possible, and documents should be organized promptly in a meeting room or work-related place.
7. Any extra copies of documents containing undisclosed important information shall be completely destroyed by shredding or other methods.
② Executives and employees shall not divulge important, undisclosed information of the company. However, if undisclosed material information is inevitably shared with the counterparty of the transaction, legal representative, external auditor, etc., the disclosure manager or the head of the disclosure department should be contacted in advance to share only within the necessary limits.
③ In the event that an executive or employee unintentionally divulges undisclosed material information, he/she shall notify the fact to the head of the disclosure department without delay.
④ The head of the disclosure department, who has received the notice in the preceding paragraph, shall report the fact to the person in charge of disclosure and take necessary measures such as fair disclosure upon receiving instructions.

Article 45 (Important Undisclosed Information of Affiliates)
Articles 42 to 44 shall apply mutatis mutandis to the prohibition of the use of undisclosed important information of the Company's affiliates to executives and employees.

Article 46 (Return, etc. of Profits from Short-Term Trading)
① Executives and employees falling under each of the following subparagraphs shall return the profits to the Company in accordance with Article 172 of the Act if they sell specific securities, etc.
1. An employee engaged in the establishment, change, promotion, disclosure, and other related work of matters subject to the report of major matters under Article 3 (13)
2. Employees engaged in business related to finance, accounting, planning, and R&D
② The head of the disclosure department requests the Company's shareholders (including those who hold equity securities or depository securities other than stock certificates; hereafter the same shall apply in this Article) to request the return of the profits from the Company's executives and employees who made short-term arbitrage transactions. If received, it must be reported to the person in charge of disclosure.
③ The person in charge of disclosure shall proceed with the necessary procedures to receive the profits back within two months from the date of receipt of the request in the preceding paragraph, including judicial claims against the relevant executives and employees.
④ The person in charge of disclosure shall ensure that the following matters are disclosed on the Company's website without delay for two years from the date of receipt of notice of short-term trading gains from the Securities and Futures Commission (hereinafter referred to as the "Seoul Securities and Futures Commission"). However, this is not the case when short-term trading profits are returned.
1. The status of the person to whom short-term trading profits are to be returned;
2. Short-term trading profit amount (referring to the sum of each executive, employee, or major shareholder)
3. The date on which the SSC is notified of the occurrence of short-term trading gains;
4. The company's short-term trading profit return claim plan
5. Shareholders of the relevant corporation (including those who hold equity securities or depository securities other than stock certificates; hereinafter the same shall apply in this subparagraph) may request the corporation to request the return of short-term trading profits from those who have obtained profits from short-term trading. If the corporation does not file a claim within two months from the date of receipt of the request, the shareholder may file a claim on behalf of the corporation.

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Chapter 8 Other Disclosure Controls

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Section 1 Contact with the media, such as distribution of press releases

Article 47 (Distribution of Press Releases)
① When the head of each business department intends to distribute press releases to mass media such as media companies, it must be delivered to the disclosure department in advance and distributed with the approval of the person in charge of disclosure. In this case, if the disclosure manager deems it necessary, he/she shall report it to the CEO and follow the instructions.
② When the information delivered through the press release falls under the fair disclosure requirements of Article 19, the head of the disclosure department shall prepare a fair disclosure document and obtain approval from the person in charge of disclosure and disclose it in a fair manner in accordance with Articles 21 and 22.

Article 48 (Hearing of Opinion)
If necessary, the person in charge of disclosure may listen to the opinions of executives and employees or external experts with professional knowledge regarding the information provided through the press release.

Article 49 (Post-Inspection of Report Content)
The head of the business department that created the press release and the head of the disclosure department conduct a post-inspection on the reported content after distribution of the press release. action should be taken

Article 50 (Interview, etc. by Media)
① When a mass media such as a media company requests an interview, etc. from the company, the person falling under each of the following subparagraphs may respond to the interview, etc. However, in unavoidable cases, the person in charge of disclosure may designate a person who responds to the interview, etc.
1. CEO 2. Disclosure officer 3. IR officer 4. Finance officer
② When there is a request for coverage, etc. in the preceding paragraph, the head of the disclosure department shall receive inquiries from the relevant media company, etc. in advance or prepare expected questions and answers and deliver them to the person who responds to the coverage after review by the person in charge of disclosure.
③ The head of the disclosure department shall check the contents of the reports of mass media such as the media, and if there is any news that is different from the facts, report it to the person in charge of disclosure and take necessary measures according to the instructions of the person in charge of disclosure.

Section 2 Market Rumors, etc.

Article 51 (Market Rumor)
① In principle, the company does not make any comments about market rumors.
② The person in charge of disclosure or the head of the disclosure department shall check whether the contents of market rumors are consistent with important information that has not been disclosed through an opinion inquiry on the relevant business department, etc. Action must be taken.
③ The disclosure manager or the head of the disclosure department shall establish and implement appropriate countermeasures if it is determined that it is a matter that may negatively affect the interests of the company even if the contents of market rumors do not match material information that has not been disclosed.

Article 52 (Request for Provision of Information)
① When a request for disclosure of company-related information is received from shareholders and stakeholders, the disclosure manager shall review the legality of the request and decide whether to provide related information.
② When information is provided in accordance with the decision in the preceding paragraph, the disclosure manager may listen to the opinions of the legal department or external legal experts on whether the information provided may affect investment decisions and stock prices, and In the case of relevant information or information that affects investment judgment and stock price, necessary measures shall be taken so that it can be disclosed to the public at the same time (or before the information is provided) to the person who requested the information.

Article 53 (Business Briefing)
① In case of holding a company briefing session (hereinafter referred to as “company briefing session”), such as an investment briefing session or a meeting with analysts, the head of the business department in charge of the relevant business reports the data to be distributed at the business briefing session and the contents of expected questions and answers in writing in advance to the person in charge of disclosure and must be approved. ② In the case of holding a business briefing session, the head of the business department in charge of the relevant business shall notify the disclosure department of the date, place, and target of the business briefing session, and the head of the public disclosure department shall make the public announcement on holding the business briefing session before the event is held. do.
③ The head of the disclosure department shall take necessary measures so that the information can be disclosed to the public without delay if information that has not been disclosed to the public is provided through Q&A at the company briefing session.

Article 54 (Provision of information through website, e-mail, etc.)
① When the head of each business department provides company-related information through the website or e-mail, etc., the information must be delivered to the disclosure department in advance and provided with the approval of the disclosure manager.
② Article 47 (2), 48, and 49 shall apply mutatis mutandis in this Article. In this case, "press release" and "information provided through press release" shall be construed as "information provided through website, e-mail, etc.".

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Chapter 9 Supplement

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Article 55 (Education)
① The disclosure manager shall establish and implement an annual training plan related to the disclosure control system so that all executives and employees of the company can fully understand the disclosure control system and perform related tasks properly. In this case, specialized education or training must be completed for business departments and the disclosure department with a high frequency of disclosure information.
② The head of the disclosure department shall identify the compulsory training schedule, etc. conducted by the Korea Exchange or the Korea Listed Companies Association, make sure to complete it, and take necessary measures so that the training content can be disseminated to related executives and employees.

Article 56 (Penal Provisions)
The company may impose penalties or sanctions on executives and employees who violate this regulation according to the company's related regulations.

Article 57 (Opening and Closing of Regulations)
The opening and closing of this regulation is done by the CEO.