Article 1 Purpose

The purpose of these regulations is to ensure that all of our public information is disclosed accurately, completely, fairly, and timely in accordance with relevant laws and regulations, and to prevent unfair trade by officers and employees by establishing necessary matters regarding public disclosure-related tasks and procedures, and management of public disclosure information.

① “Public information” refers to matters that may affect investors’ investment decisions regarding the company’s management and assets, etc., and refers to disclosure matters stipulated in relevant laws and regulations, such as the Capital Market and Financial Investment Business Act (hereinafter referred to as the “Act”) and its Enforcement Decree (hereinafter referred to as the “Decree”), the Financial Services Commission’s (hereinafter referred to as the “FSC”) Regulations on Issuance and Disclosure of Securities (hereinafter referred to as the “Issuance Disclosure Regulations”), and the Korea Exchange’s (hereinafter referred to as the “Exchange”) Securities Market Disclosure Regulations (hereinafter referred to as the “Disclosure Regulations”), and information related thereto.
② “Public disclosure documents” refers to reports and notifications (including electronic documents) submitted for the disclosure of disclosure information and documents attached thereto.
③ “Disclosure control system” refers to all business activities to manage disclosure information in accordance with certain control procedures by relevant organizations within the company.
④ “Disclosure Control Organization” means the CEO, Disclosure Officer, Disclosure Manager, and Disclosure Information Generation Department related to the creation of disclosure information that perform tasks related to disclosure, such as creation, collection, review, preparation, and approval of disclosure documents, pursuant to these Regulations.
⑤ “Disclosure Officer” means a person who has been designated by the CEO to substantially oversee the disclosure work of our company and has been registered with the Exchange as a Disclosure Officer pursuant to Article 88, Paragraph 1 of the Disclosure Regulations.
⑥ “Disclosure Officer” means a person in charge of the disclosure work of our company pursuant to the regulations on business and organization of our company. In this case, the Disclosure Officer must have at least two “Disclosure Officers” registered with the Exchange pursuant to Article 88, Paragraph 2 of the Disclosure Regulations.
⑦ “Disclosure Information Generation Department” means a department that performs tasks related to the generation of our company’s disclosure information.
⑧ “Regular disclosure” refers to the submission of business reports, semi-annual reports, and quarterly reports to the Financial Services Commission or the Exchange in accordance with Articles 159, 160, and 165 of the Act, Articles 168 and 170 of the Enforcement Decree, Article 4-3 of the Issuance Disclosure Regulations, and Article 21 of the Disclosure Regulations regarding the Company’s overall corporate content, including its business and financial status and management performance.
⑨ “Periodic disclosure” refers to the disclosure of key management matters, reporting or disclosing key facts or decision contents that affect investment decisions related to the Company’s management activities to the Exchange in accordance with Article 7 of the Disclosure Regulations.
⑩ “Fair Disclosure” means that when our company selectively provides information that is not subject to disclosure obligations under relevant laws or information for which the disclosure deadline has not yet arrived to a specific person, we disclose such information to the exchange so that general investors can be aware of it at the same time (or before the selective provision to a specific person) in accordance with Articles 15 and 16 of the Disclosure Regulations and the Exchange’s Fair Disclosure Operation Standards.
⑪“Inquiry Disclosure” means disclosure made upon request from the Exchange in accordance with Article 12 of the Disclosure Regulations to confirm the truth of rumors and reports related to our company or the presence of important information.
⑫ “Voluntary Disclosure” means disclosure made to the Exchange in accordance with Article 28 of the Disclosure Regulations and Article 8 of the Enforcement Rules when our company determines that disclosure is necessary regarding information that may have a significant impact on the company’s management, assets, and investors’ investment decisions, or information that is not subject to disclosure obligations, in addition to the matters subject to periodic disclosure under Paragraph 9.
⑬ “Issuance Disclosure and Report of Key Matters” refers to the submission of a report to the Financial Services Commission in accordance with Articles 119, 121 to 123, 130, and 161 of the Act, Articles 120 to 122, 137, and 171 of the Enforcement Decree, and Articles 2-4, 2-6, 2-14, 2-17, 4-5, 5-8 to 5-10, and 5-15 of the Issuance Disclosure Regulations regarding changes in the organization of the Company, such as the offering and sale of securities, mergers, divisions, and transfers of business, as defined in relevant laws and regulations.
⑭ The terms used in these regulations shall follow the examples of terms used in relevant laws and regulations, except in cases where these regulations specifically provide otherwise.

Article 3 (Representative Director)

1. he CEO shall oversee all work related to the disclosure control system.
2. he CEO shall perform the following tasks to ensure that the disclosure control system operates effectively:
 ① Establishment of policies on the design and operation of the disclosure control system
 ② Establishment of authority, responsibility, and reporting systems for the disclosure control system
 ③ Final inspection of the operating status of the disclosure control system and final evaluation of operating performance
 ④ Approval of regulations related to the disclosure control system
 ⑤ Other necessary matters

Article 4 (Definition of terms)

1. The person responsible for disclosure is appointed by the CEO.
2 The person responsible for disclosure oversees the work related to the design and operation of the disclosure control system and performs the following tasks:
 ① Work related to review, approval, and implementation of disclosure information and disclosure documents (including related documents; hereinafter the same shall apply).
 ② Measures necessary for officers and employees to comply with disclosure-related laws and regulations (conducting related education, preparing guidelines, etc.).
 ③ Identification of disclosure risk factors and establishment and implementation of countermeasures.
 ④ Continuous monitoring of the disclosure control system, regular inspection of the operating status, and evaluation of operating performance
 ⑤ Decision on whether to disclose and the scope of matters not explicitly specified to be disclosed in related laws and regulations.
 ⑥ Direction and supervision of the department in charge of disclosure.
 ⑦ Establishment and implementation of education plans for officers and employees related to disclosure work.
 ⑧ Approval of detailed guidelines for the implementation of regulations related to the design and operation of the disclosure control system.
 ⑨ 기Other matters deemed necessary by the CEO in relation to the disclosure control system.
3 The person responsible for disclosure has the following authority when necessary in performing his/her duties.
 ① Right to request submission and inspect various ledgers and records related to public disclosure matters
 ② Right to hear opinions from officers and employees of the accounting or auditing departments, or other departments related to the creation of public disclosure information and preparation of public disclosure documents
4 The public disclosure officer may, when necessary in performing his/her duties, consult with the executive officer in charge or auditors (audit committee members) and hear opinions from external experts.

Article 5 (Department in charge of public disclosure)

1 The CEO shall organize a department in charge of disclosure work, including a person with specialized knowledge of disclosure work. Two of these persons shall be designated as disclosure officers in accordance with Article 88, Paragraph 2 of the Disclosure Regulations.
2 The disclosure department shall be under the direction of the disclosure officer in relation to disclosure work and shall perform the following tasks:
 ① Collection and review of various disclosure information
 ② Preparation of disclosure documents and disclosure execution
 ③ Establishment of annual disclosure work plan and inspection of progress status
 ④ Review of measures necessary for compliance with laws and regulations, such as periodic inspection of the contents of enactment and amendment of disclosure-related laws and regulations, and reporting to the disclosure officer
 ⑤ Identification, inspection, evaluation, and management of disclosure risks at the company-wide level
 ⑥ Other matters deemed necessary by the CEO or the disclosure officer.

Article 6 (Business Department)

1 In the event that any of the following applies, the head of each business division shall promptly deliver information on the matter to the department in charge of public disclosure.
 ① When a matter subject to public disclosure as stipulated in laws and regulations related to public disclosure occurs or is expected to occur
 ② When it is unclear whether or not to disclose a matter that has a significant impact on the company’s management
 ③ When a reason to cancel or change a matter already disclosed occurs or is expected to occur
 ④ When requested by the person in charge of public disclosure or the head of the department in charge of public disclosure 2. When delivering the public disclosure information in the preceding paragraph, copies of the relevant content and necessary supporting documents and reference materials shall be delivered in writing to the department in charge of public disclosure, and the originals thereof shall be kept. However, in cases of emergency or unavoidable circumstances, the matter may be delivered by an appropriate means other than writing, but a copy of the relevant content may be delivered in writing afterwards.

Section 1 Regular Disclosure

Article 7 (Regular Disclosure)

The company must prepare regular disclosure documents and submit them to the Financial Services Commission and the stock exchange within the disclosure deadline.

Article 8 (Department in charge of public disclosure)

1 The head of the department in charge of public disclosure shall confirm the matters to be disclosed and the schedule for disclosure in order to implement the disclosure of regular disclosure matters, establish an annual disclosure work plan, obtain approval from the person in charge of public disclosure, and implement it
2 he head of the department in charge of public disclosure may, if necessary for regular disclosure, request the heads of each business department to submit information and supporting materials related to the preparation of regular disclosure documents, in which case the relevant business department shall comply. 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 this to the person in charge of public disclosure and follow the instructions.
3 The head of the department in charge of public disclosure shall prepare regular disclosure documents in accordance with the format and description method stipulated in the relevant laws and regulations and submit them to the person in charge of public disclosure by the submission deadline stipulated in the annual disclosure work plan. In this case, if there is concern that the submission deadline may not be met, he/she shall report this to the person in charge of public disclosure, receive instructions on necessary measures, and implement them.
4 The head of the public disclosure department shall obtain the approval of the public disclosure manager and the CEO and execute regular public disclosure within the statutory submission deadline. In this case, if certification by the CEO, etc. is required according to relevant laws and regulations, the certification shall be attached.

Article 9 (Person in charge of public disclosure and CEO)

1 The person responsible for public disclosure shall check the status of the work required for public disclosure implementation of regular public disclosure, and if there is concern that the statutory submission deadline may not be met, the necessary measures shall be taken..
2 The person responsible for public disclosure shall review whether the regular public disclosure documents submitted by the head of the public disclosure department have been properly prepared in accordance with relevant laws and regulations, and the accuracy and completeness of the information disclosed through the relevant regular public disclosure documents, report this to the CEO, and obtain the CEO’s approval to have the head of the public disclosure department implement the disclosure.
3 he CEO shall directly confirm and review the appropriateness of the regular public disclosure documents reported by the head of the public disclosure department, and give approval, and obtain the necessary certifications under relevant laws and regulations.

Article 10 (Post-inspection of public notice contents)

1 The head of the business department involved in preparing the periodic disclosure documents and the head of the department in charge of disclosure must immediately check the appropriateness of the disclosure content after disclosure..
2 If the head of the department in charge of disclosure discovers any errors or omissions in the information as a result of the inspection, he or she must immediately take necessary measures, such as making a corrective disclosure, to correct such errors or omissions.

Section 2 Periodic Disclosure

Article 11 (Periodic Disclosure)

The company must prepare periodic disclosure documents and submit them to the exchange within the disclosure deadline.

Article 12 (Business Department)

1 In the event that a matter for periodic disclosure occurs or is expected to occur, or in the event that a reason for cancellation or change of information already disclosed occurs or is expected to occur, each business division shall immediately forward the relevant information to the department in charge of disclosure.
2 In the event that the head of the department in charge of disclosure requests the submission of supplementary or additional data to the information in Paragraph 1, the business division shall immediately respond. However, if the head of the business division determines that the matter in question requires significant security or confidentiality, he/she shall report this to the person in charge of disclosure and follow the instructions.

Article 13 (Department in charge of public disclosure)

1 When the department in charge of public disclosure receives information on matters subject to periodic disclosure from a business department, it must immediately review whether the information in question is subject to periodic disclosure and review the accuracy, completeness, etc. of the information. The head of the department in charge of public disclosure may, if necessary, request the business department in question to supplement the information or submit additional materials.
2 When the review result of the preceding paragraph indicates that the information is subject to periodic disclosure, the head of the department in charge of public disclosure must prepare a review report and periodic disclosure documents for the information in question and report them to the person in charge of public disclosure, and must then obtain the approval of the person in charge of public disclosure and execute the disclosure in accordance with the disclosure method stipulated in the relevant laws and regulations. However, when it is difficult to obtain the approval of the person in charge of public disclosure due to the absence of the person in charge of public disclosure, the head of the department in charge of public disclosure may execute the disclosure, and in this case, this must be reported to the person in charge of public disclosure afterwards.
3 When the review result of paragraph 1 indicates that the information is not subject to periodic disclosure, the head of the department in charge of public disclosure must prepare a document containing the reason therefor and the review results of the information in question and report it to the person in charge of public disclosure.

Article 14 (Person responsible for public disclosure)

1 The person responsible for public disclosure shall review whether the review contents of Paragraphs 2 and 3 of the preceding Article and the public disclosure documents, etc. have been properly prepared in accordance with relevant laws and regulations, and shall approve whether or not to make a public disclosure.
2 The person responsible for public disclosure shall report important matters related to periodic public disclosure to the CEO.

Article 15 (Post-inspection of public notice contents)

The provisions of Article 1 shall apply to periodic disclosure. In this case, “regular disclosure documents” shall be deemed as “periodical disclosure documents.”

Section 3 Public notice

Article 16 (Fair Disclosure)

The company must prepare periodic disclosure documents and submit them to the exchange within the disclosure deadline.

Article 17 (Prohibition of indirect provision of information subject to fair disclosure)

A provider of fair disclosure information (a person as defined in Article 15, Paragraph 2 of the Disclosure Regulations) shall not indirectly provide fair disclosure information to a recipient of fair disclosure information (a person as defined in Article 15, Paragraph 3 of the Disclosure Regulations) prior to disclosure through various ratios, increase/decrease scales, etc.

Article 18 (Notes)

1 In the case of implementing a fair disclosure, the disclosure manager, disclosure officer, business department related to the fair disclosure subject information, and contact information must be specified so that investors who want to know detailed information related to the contents of the fair disclosure can easily make inquiries.
2 In the case of a request from the exchange, the fair disclosure summary and website address must be stated and the disclosure must be implemented on the exchange, and the summary and original text must be posted on the company's website. Article 19

Article 19 (Application)

The provisions of Articles 11, 13 to 15 shall apply to fair disclosure. In this case, “regular disclosure documents” in Article 1 shall be deemed as “fair disclosure documents” and “periodical disclosure” in Articles 13 to 15 shall be deemed as “fair disclosure.”

Section 4 Public notice

Article 20 (Public Inquiry)

The company must prepare a public disclosure document and submit it to the exchange within the public disclosure deadline.

Article 21 (Department in charge of public disclosure)

1 When the head of the department in charge of public disclosure receives a request for an inquiry disclosure from the exchange, he/she shall immediately confirm the facts and the presence of important information, prepare a disclosure document, obtain the approval of the person in charge of public disclosure, and respond to the inquiry disclosure.
2 The head of the department in charge of public disclosure may request each business department to submit data or express opinions in order to confirm the facts or the presence of important information in the preceding paragraph, and in this case, the business department in question shall respond. However, if the head of the business department determines that the matter in question requires significant security or must be kept confidential, he/she shall report this to the person in charge of public disclosure and follow the instructions.
3 When the head of the department in charge of public disclosure receives a request for an inquiry disclosure and discloses that the decision-making process is in progress (hereinafter referred to as “unconfirmed disclosure”), he/she shall grasp the confirmed contents or progress of the relevant disclosure matter, obtain the approval of the person in charge of public disclosure, and execute a re-disclosure within one month from the date of the unconfirmed disclosure. In this case, if it is judged that it is practically impossible to execute the re-disclosure within one month, the disclosure must be executed by specifying the deadline for re-disclosure.

The provisions of Article 11, Article 14 Paragraph 2, Proviso, and Article 15 shall apply to public notices for inquiry. In this case, the term “regular public notice” in Article 1 shall be deemed as “public notice for inquiry,” the term “periodic public notice” in Article 15 shall be deemed as “public notice for inquiry,” and the term “review contents and public notice documents of Paragraphs 2 and 3 of Article 15 Paragraph 1 shall be deemed as “confirmation contents and public notice documents of Paragraph 1.”

Section 5 Voluntary Disclosure

Article 23 (Voluntary Disclosure)

A company may prepare a voluntary disclosure document and submit it to the exchange within the disclosure deadline.

Article 24 (Judgment of voluntary disclosure matters and collection of information)

1 If the person responsible for public disclosure determines that voluntary disclosure is necessary or if a reason arises or is expected to arise for the cancellation or change of content already voluntarily disclosed, he/she may instruct the head of the department in charge of public disclosure to collect necessary information and prepare disclosure documents.
2 If the head of the department in charge of public disclosure determines that voluntary disclosure is necessary or if a reason arises or is expected to arise for the cancellation or change of content already voluntarily disclosed, or if there is an instruction from the person responsible for public disclosure pursuant to the preceding paragraph, he/she may request the head of the business department to provide necessary information or submit materials.
3.If the head of the business department determines that voluntary disclosure is necessary or if a reason arises or is expected to arise for the cancellation or change of content already voluntarily disclosed, or if he/she receives a request from the head of the department in charge of public disclosure to provide necessary information or submit materials in relation thereto pursuant to the provisions of the preceding paragraph, he/she shall immediately forward the information or materials related thereto in writing to the department in charge of public disclosure in accordance with the method prescribed in Article 7, Paragraph 2.
4 If the head of the business department receives a request from the head of the department in charge of public disclosure to submit supplementary or additional information regarding the contents of the notification in the preceding paragraph, he/she shall respond immediately. However, if it is determined that the matter in question requires significant security or confidentiality, he/she shall report this to the person in charge of public disclosure and follow the necessary instructions.

Article 25 (Application)

The provisions of Articles 11, 14, and 15 shall apply to voluntary disclosure. In this case, ""regular disclosure"" in Article 1 shall be considered ""voluntary disclosure,"" ""review of whether it corresponds to a disclosure item"" in Article 14 Paragraph 1 shall be considered ""review of the necessity of disclosure,"" ""in case of a matter subject to disclosure"" in Paragraph 2 of the same Article shall be considered ""in case disclosure is deemed necessary,"" ""in case of not corresponding to a matter subject to disclosure"" in Paragraph 3 of the same Article shall be considered ""in case disclosure is deemed unnecessary,"" and ""in case of periodic disclosure"" in Articles 14 and 15 shall be considered ""voluntary disclosure.""

Section 6 Reporting on issuance and major matters

Article 26 (Issuance announcement and reporting of major matters)

The company must prepare issuance disclosure and major matter report documents and submit them to the Financial Services Commission within the disclosure deadline.

Article 27 (Establishment of business promotion plan)

In the event that matters requiring public disclosure or reporting of important matters under Article 161, Paragraph 1, Subparagraphs 6 through 8 of the Act arise or are expected to arise, the head of the public disclosure department shall confirm the necessary public disclosure matters and public disclosure schedule, establish a business promotion plan for public disclosure and reporting of important matters, obtain approval from the person responsible for public disclosure, and deliver this in writing to each business department.

Article 28 (Application)

1 The provisions of Article 9, Paragraphs 2 through 4, Article 10 and Article 11 shall apply to the issuance public notice and the reporting of major matters in the preceding Article. In this case, the “annual public notice business plan” in Article 9, Paragraph 3 shall be deemed as the “issuance public notice and major matter report business promotion plan,” and the “regular public notice documents” in Article 9, Paragraph 3, Article 10 and Article 1 shall be deemed as issuance public notice and major matter report documents.
2 Articles 13 through 16 shall apply to the major matter reports in Article 161, Paragraph 1, Subparagraphs 1 through 5 and Subparagraph 9 of the Act. In this case, “periodical public notice and “periodical public notice documents” shall be deemed as “major matter reports and major matter report documents.”

Article 29 (Collection, Maintenance, and Management of Information)

Each public disclosure control organization must collect, maintain, and manage the necessary internal and external information and supporting data related to its assigned duties. This is to ensure the accuracy, completeness, fairness, and timeliness of public disclosure information.

Article 30 (Management of Public Disclosure Risks)

1. To this end, the CEO and the officer responsible for disclosures shall ensure that the following disclosure risks, which may negatively affect the accuracy, completeness, fairness, and timeliness of disclosure information, are identified promptly and managed continuously:
 ① Financial Information Errors: Risks arising from inconsistencies between the actual financial status and disclosed content due to accounting errors, miscommunications, or discrepancies among responsible personnel.
 ② Insufficient or Erroneous Documentation: Risks caused by omissions or errors in the preparation of required disclosure documentation, often resulting from a lack of understanding of documentation guidelines, typographical errors, or formatting mistakes.
 ③ Unclear, Inadequate, or Inaccurate Disclosure Content: Risks associated with the use of technical jargon, abbreviations, or insufficient explanations that may make disclosure content difficult for the general public to understand.
 ④ Non-Compliance with Statutory Disclosure Deadlines: Risks arising from delayed information delivery, approval delays, or misunderstandings of statutory deadlines, leading to non-compliance with disclosure submission timelines.
 ⑤ Omission, Concealment, or Downplaying of Disclosure Items: Risks associated with failure to include mandatory disclosure items, deliberate omission, or underrepresentation of negative information about the company.
 ⑥ Risks Related to Forecast Disclosures: Risks stemming from the disclosure of forecast information that lacks reasonable assumptions or grounds, includes intentional misstatements, or omits critical details.
 ⑦ Leakage of Non-Public Information: Risks that occur when undisclosed information is leaked through unauthorized or non-standard channels, such as selective provision by employees to specific individuals.
 ⑧ Risks Due to Changes in the Disclosure System: Potential risks arising from regulatory changes, shifts in government policy, modifications to the exchange market where the company operates, or changes in personnel and practices of supervisory agencies and market operators.
 ⑨ Changes in Disclosure Personnel: Risks caused by disruptions in the transfer of disclosure-related information or loss of continuity in fulfilling disclosure obligations due to personnel changes.
 ⑩ Other disclosure risks that may have a negative impact on disclosure information
2 The head of the disclosure department, under the direction of the officer responsible for disclosures, shall maintain a list of disclosure risk factors and conduct continuous inspections and management of these risks.

Article 31 (General Principles)

Employees shall not use or cause others to use material non-public information (hereinafter referred to as ""MNPI"") defined in Article 174(1) of the Act for the purchase, sale, or other transactions of specific securities, etc. (hereinafter referred to as ""Specific Securities"") defined in Article 172(1) of the Act.

Article 32 (Employee Transactions Involving Specific Securities)

1 Employees intending to engage in the purchase, sale, or other transactions of Specific Securities, regardless of whether such transactions involve the use of MNPI, must notify the internal audit officer or legal officer in advance.
2 he internal audit officer or legal officer who receives such notification may prohibit the transaction if it is deemed likely to involve the use of MNPI. Employees must comply with such instructions.
3 mployees who have engaged in the purchase, sale, or other transactions of Specific Securities must report the transaction details (type of Specific Securities, quantity, transaction date) to the internal audit officer or legal officer within ten (10) days from the end of the quarter in which the transaction occurred.

Article 33 (Management of MNPI)

1 The CEO or the officer in charge of disclosures shall take necessary measures to ensure the proper management of MNPI, as follows:
 ① Documents containing MNPI must be stored securely in locations accessible only to authorized personnel.
 ② Employees must not discuss MNPI in locations where conversations may be overheard, such as elevators or hallways.
 ③ Documents containing MNPI must not be left in public areas, and such documents must be destroyed in a manner that prevents recovery of the information.
 ④ Employees must maintain the confidentiality of MNPI, both externally and within the company.
 ⑤ The electronic transmission of documents related to MNPI via fax or other communication methods must be conducted securely.
 ⑥ Unnecessary duplication of documents containing MNPI should be avoided, and such documents should be promptly organized in appropriate locations such as meeting rooms or workspaces.
 ⑦ Extra copies of documents containing MNPI must be completely destroyed by shredding or equivalent methods.
2 Employees must not disclose the company’s MNPI. However, if disclosure is unavoidable for business purposes (e.g., with transaction counterparties, legal representatives, or external auditors), such information must be shared within the necessary scope only after consulting the officer in charge of disclosures or the head of the disclosure department.
3 If an employee inadvertently discloses MNPI, they must promptly notify the head of the disclosure department.
4 Upon receiving such notification, the head of the disclosure department must report the incident to the officer in charge of disclosures and take necessary measures, including fair disclosure.

Article 34 (MNPI of Affiliates)

The provisions of Articles 32 to 34 shall apply mutatis mutandis to prohibit employees from engaging in the use of MNPI of the company’s affiliates.

Article 35 (Return of Short-Swing Profits)

1 Executives and the following employees must return any profits gained from the purchase and sale of Specific Securities within a six (6)-month period to the company, pursuant to Article 172 of the Act: .
 ① Employees involved in the establishment, modification, implementation, or disclosure of key matters as defined in Article 3(3), as well as related duties.
 ② Employees engaged in finance, accounting, planning, or research and development.
2 If the company’s shareholders (including those who own equity securities or depositary receipts, hereinafter the same applies) request the company to claim the return of short-swing profits from an employee engaged in such transactions, the head of the disclosure department must report the matter to the officer in charge of disclosures.
3 The officer in charge of disclosures must initiate necessary procedures, including legal claims, to recover such profits within two (2) months from the date of the request.
4 The officer in charge of disclosures must disclose the following information on the company’s website for two (2) years from the date of notification by the Securities and Futures Commission (hereinafter referred to as the ""SFC"") regarding short-swing profits, except when the profits have been returned:
 ① The status of the individual required to return the profits.
 ② he amount of short-swing profits (aggregated by executives, employees, or major shareholders).
 ③ The date the SFC notified the company of the short-swing profits.
 ④ The company’s plan for claiming the return of short-swing profits.
 ⑤A statement that shareholders (including those who own equity securities or depositary receipts) may request the company to claim the return of short-swing profits and, if the company fails to do so within two (2) months of the request, that the shareholders may file such claims on behalf of the company.

Article 36 (Distribution of Press Releases)

1 Heads of each business department intending to distribute press releases to media outlets must first submit the materials to the Disclosure Management Department and obtain prior approval from the Disclosure Officer. If deemed necessary, the Disclosure Officer may escalate the matter to the Representative Director for further guidance.
2If the information contained in the press release falls under fair disclosure requirements as specified in Article 17, the Disclosure Management Department shall prepare fair disclosure documents, secure approval from the Disclosure Officer, and disclose the information in accordance with Articles 19 and 20.

Article 37 (Consultation of Expert Opinions)

The Disclosure Officer may consult employees or external experts with specialized knowledge regarding the information included in press releases, as needed.

Article 38 (Post-Distribution Review of Media Content)

After the distribution of press releases, the originating business department and the Disclosure Management Department must conduct a post-review of the media coverage. If any inaccuracies are found, they must report the matter to the Disclosure Officer and take corrective measures as directed.

Article 39 (Media Inquiries)

1 When receiving media inquiries, only the following individuals are authorized to respond:
 ① Representative Director
 ② Disclosure Officer
 ③ IR Officer
 ④ CFO
2 In exceptional circumstances, the Disclosure Officer may designate another individual to respond.The Disclosure Management Department must collect questions from media outlets in advance or prepare anticipated Q&A materials, have them reviewed by the Disclosure Officer, and provide them to the designated respondent.
3 The Disclosure Management Department must monitor the resulting media coverage and, in cases of inaccuracies, report to the Disclosure Officer and implement corrective actions as instructed.

1 As a general principle, the company does not comment on market rumors.
2 The Disclosure Officer or the Disclosure Management Department must verify whether the content of market rumors aligns with undisclosed material information by consulting relevant business departments. If the rumors align with such information, immediate steps must be taken to ensure proper disclosure.
3 Even if the rumors do not match undisclosed material information, if they are deemed potentially damaging to the company’s interests, the Disclosure Officer or Disclosure Management Department must develop and implement appropriate response measures.

Article 41 (Requests for Information Disclosure)

1 Upon receiving a request for company-related information disclosure from shareholders or stakeholders, the Disclosure Officer must review the legality of the request and decide whether to provide the information.
2 If the decision is made to disclose information, the Disclosure Officer may seek opinions from the Legal Department or external legal experts to determine whether the information could influence investment decisions or stock prices. If the information is subject to fair disclosure requirements or could affect investment decisions or stock prices, it must be publicly disclosed simultaneously (or prior) to providing it to the requesting party.

Article 42 (Corporate Presentations)

1 For corporate presentations such as investor briefings or analyst meetings, the head of the relevant business department must submit presentation materials and anticipated Q&A documents to the Disclosure Officer in advance for approval.
2 The head of the relevant business department must notify the Disclosure Management Department of the presentation’s date, time, location, and target audience. The Disclosure Management Department shall ensure that the details of the presentation are disclosed publicly before it takes place..
3 If non-public information is disclosed during Q&A sessions at corporate presentations, the Disclosure Management Department must take immediate steps to publicly disclose the information without delay.

Article 43 (Provision of Information via Website or Email)

1 When providing company-related information via the website or email, the head of the relevant business department must submit the information to the Disclosure Management Department in advance and obtain approval from the Disclosure Officer prior to dissemination.
2 The provisions of Articles 37(2), 38, and 39 apply mutatis mutandis to this Article, with “press releases” and “information provided through press releases” interpreted as “information provided via website or email.”

Article 44 (Education)

1 The Disclosure Officer shall establish and implement an annual education plan regarding the disclosure control system to ensure that all employees acquire a thorough understanding of the system and perform their related duties accurately. Specialized training or workshops must be completed by business units with frequent disclosure activities and the disclosure management department.
2 The Head of the Disclosure Management Department shall monitor the schedules of mandatory training provided by the Exchange or the Korea Listed Companies Association, ensure attendance, and take necessary measures to disseminate the training content to relevant personnel.

This regulation comes into effect on September 1, 2009.