IR
Chapter 1
General Provisions
Article 1(Purpose)

The purpose of this Regulation is to ensure all of our company's disclosed information is disclosed accurately, completely, fairly, and in a timely manner in accordance with relevant laws and regulations, as well as specify the matters necessary for disclosure-related tasks and procedures, the management of disclosed information, etc., in order to prevent unfair transactions by executives and employees.

Article 2(Scope of application)

Matters related to the performance of public disclosure work and management of disclosure information shall be governed by these regulations, except as provided in laws, related regulations, or the articles of association.

Article 3 (Definitions)
  • ① “Disclosure information” refers to matters that may affect investors’ investment decisions regarding the company’s management and assets, etc., which are the disclosure matters and relevant information stipulated in relevant laws and regulations such as Capital Markets and Financial Investment Services Act (hereinafter referred to as the “Act”) and the Enforcement Decree of the Act (hereinafter referred to as the “Enforcement Decree”), Regulations on the Issuance and Disclosure of Securities of the Financial Services Commission(hereinafter referred to as “the Financial Services Commission”) (hereinafter referred to as “Issuance and Disclosure Regulations”), Regulations on the Disclosure of Securities Market of the Korea Exchange (hereinafter referred to as “Exchange”) (hereinafter referred to as “Disclosure Regulations”), etc.
  • ② “Disclosure documents” refers to the declarations and reports documents (including electronic documents) submitted for the purpose of public disclosure of disclosure information and the documents attached thereto.
  • ③ “Disclosure control system” refers to all business activities in which disclosure information is managed by related organizations within the company according to its certain control procedures.
  • ④ “Disclosure control organization” refers to the CEO, person in charge of disclosure, disclosure department, and business division related to creation of disclosure information that perform tasks related to disclosure, such as creation, collection, review of disclosure information, preparation and approval of disclosure documents, etc. in accordance with these regulations.
  • ⑤ “Person in charge of disclosure” refers to a person who is appointed by the CEO to direct the company’s public disclosure work and is registered with the Exchange as a public disclosure manager in accordance with Article 88, Paragraph 1 of the Disclosure Regulations.
  • ⑥ “Disclosure department” refers to the department in charge of the company’s disclosure work in accordance with our company’s business and organization regulation. In this case, the disclosure department must have at least two “disclosure officers” registered with the Exchange in accordance with Article 88, Paragraph 2 of the disclosure regulations.
  • ⑦ “Business department” refers to the department that performs work related to the generation of the company’s disclosure information.
  • ⑧ “Regular disclosure” refers to submitting business reports, semi-annual reports, and quarterly reports regarding the matters related to the company’s overall business, financial situation, and management performance, etc., 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 Decree, Article 4-3 of the Issuance and Disclosure Regulations and Article 21 of the Disclosure Regulations.
  • ⑨ “Occasional disclosure” refers to the declaration or disclosure of key management matters, such as reporting major facts or decisions that affect investment decisions in relation to the company’s management activities to the Exchange in accordance with Articles 7 and 8-2 of the Disclosure Regulations.
  • ⑩ “Fair disclosure” refers to discloure of information to the Exchange so that general investors can know it at the same time (or before it is selectively provided to specific people) in the cases where the company selectively provides information to specific people that is not subject to disclosure obligations under relevant laws or information for which the disclosure deadline has not yet arrived, in accordance with Articles 15 and 16 of the Disclosure Regulations and the Fair Disclosure Operating Standards of the exchange.
  • ⑪ “Inquiry Disclosure” refers to the disclosure regarding confirmation of the truth of rumors and reports related to the company or the presence or absence of important information upon request from the Exchange in accordance with Article 12 of the Disclosure Regulations.
  • ⑫ “Free disclosure” refers to the disclosure of the information that the company determines that it may have a significant impact on the company’s management, assets, and investors’ investment decisions, in addition to the occasional disclosure matters in Paragraph 9, or that it is necessary to disclose such information that is not subject to disclosure obligations, to the Exchange in accordance with Article 28 of the Disclosure Regulations and Article 8 of its Operartion Rules.
  • ⑬ “Publicly announced disclosure and major points reporting” refers to submitting the relevant declaration forms regarding the matters related to changes in the company’s organization such as public offering and sales of securities, mergers, divisions, and business transfers, etc., acquisition and disposal of treasury stocks, etc., to the Financial Services Commission in accordance with Article 119, Articles 121 to 123, Article 130, and 161 of the Act, Articles 120 to 122, Article 137, and 171 of the Decree, Articles 2-4, 2-6, and 2-14, 2-17, 4-5, 5-8 to 5-10 of the Issuance and Disclosure Regulations.
  • ⑬-2. “Subsidiary company” refers to a subordinate company among the companies in a controlling/subordinate relationship pursuant to Article 7, Paragraph 1 of the Act on External Audit of Stock Companies, etc.
  • ⑭ The terms used in these regulations shall follow the examples of the terms used in relevant laws and regulations, except in cases specifically provided for in these regulations.
Chapter 2
Basic authority and
responsibility of the
disclosure control
organization
Article 4 (CEO)
  • ① The CEO is in charge of all affairs related to the disclosure control system.
  • ② The CEO approves the regulations related to the disclosure control system, including the contents of the following items, so that the disclosure control system can be operated effectively.
  • 1. Establishment of authority, responsibility, and a reporting system for the disclosure control system
  • 2. Final inspection of the operational status of the disclosure control system and final evaluation of operational performance
  • 3. Other necessary matters
Article 5 (Person in Charge of Disclosure)
  • ① The person in charge of disclosure shall be appointed by the CEO.
  • ② The person in charge of disclosure shall oversee the work related to the design and operation of the disclosure control system and perform 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 executives and employees to comply with disclosure-related laws (conducting related training, preparing guidelines, etc.)
  • 3. Constant monitoring of the disclosure control system, regular operation status inspection, and operational performance evaluation
  • 4. Determinating whether disclosure to be made and scope of matters not explicitly specified to be disclosed in the relevant laws and regulations
  • 5. Command and supervision of the disclosure department
  • 6. Establishment and implementation of training plans for executives and employees related to the disclosure work
  • 7. Approval of detailed guidelines, etc. for implementation of regulations related to the design and operation of the disclosure control system
  • 8. 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 when necessary in performing his/her duties.
  • 1. Request for submission and right to view various books and records related to disclosure matters
  • 2. Right to hear opinions from executives and employees of accounting or auditing departments and other departments related to the creation of disclosure information and preparation of disclosure documents
  • ④ The person in charge of disclosure may consult with executives or auditors when necessary in performing his/her duties and may listen to the opinions of external experts.
Article 6 (Disclosure Department)
  • ① The CEO shall form a department in charge of disclosure work, including persons with professional knowledge of public disclosure work. Two of these people shall be appointed as public disclosure officers in accordance with Article 88, Paragraph 2 of the Disclosure Regulations.
  • ② The disclosure department shall be under the direction of the person in charge of disclosure and perform the following tasks in relation to disclosure work.
  • 1. Collection and review of various disclosure information
  • 2. Preparation of disclosure documents and execution of disclosure
  • 3. Establishment of annual disclosure work plan and inspection of progress status
  • 4. Review of measures necessary to comply with laws and regulations, such as regular inspection of the enactment and revision of disclosure-related laws and reports 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 person in charge of disclosure
Article 7 (Business Department)
  • ① In any of the following respective subparagraphs, the head of each business department shall deliver relevant information to the disclosure department in a timely manner.
  • 1. In the event that disclosure matters specified in disclosure-related laws occur or are expected to occur
  • 2. In the event that it is a matter that has a significant impact on the company's management and it is unclear to judge whether to disclose it or not.
  • 3. In the event that there is a reason for cancellation or change of matters that have already been disclosed occur or are expected to occur
  • 4. In the event of receiving other requests from person in charge of disclosure or the head of the disclosure department
  • ② In the event of delivering the disclosure information set forth in the preceding paragraph, the relevant content, necessary evidence and reference materials, etc. shall be delivered in writing to the disclosure department. Provided that, if there is an emergency or unavoidable reason, it will be delivered in an appropriate way other than in writing.
Chapter 3
Disclosure control
activities and operations
Section 1 Regular Disclosure
Article 8 (Regular Disclosure)

The company shall prepare regular disclosure documents and submit them to the Financial Services Commission and the Exchange within the disclosure deadline.

Article 9 (Business Department)
  • ① The head of each business department shall perform the tasks assigned to the relevant business department to execute regular disclosure of the regular disclosure matters and submit them to the disclosure department by the submission deadline set in the annual disclosure work plan.
  • ② In the event that the head of each business department is expected to be unable to comply with the submission deadline set forth in the preceding paragraph due to delays in business promotion, etc., he/she shall immediately notify the disclosure department of such and take necessary measures at the request of the disclosure department head.
Article 10 (Disclosure Department)
  • ① The head of the disclosure department shall establish disclosure matters and an annual disclosure plan to execute regular disclosure of the regular disclosure matters, and collect opinions from the heads of each business department when necessary.
  • ② The head of the disclosure department shall compile the contents, etc. received from each business department, prepare regular disclosure documents according to the format and writing method prescribed by relevant laws and regulations, and submit them to the person in charge of disclosure by the submission deadline set in the annual disclosure plan.
  • ③ The head of the disclosure department shall obtain approval from the person in charge of disclosure and the CEO and execute regular disclosure within the statutory submission deadline. In this case, in the event that certification by the CEO, etc. is required pursuant to relevant laws and regulations, the certification shall be attached.
Article 11 (Person in Charge of Disclosure)
  • ① The person in charge of public disclosure shall check the status of business progress necessary for the execution of regular disclosure and take necessary measures if there is a risk of failure to meet the statutory submission deadline.
  • ② The person in charge of disclosure shall review whether the regular disclosure documents submitted by the head of the disclosure department have been appropriately prepared in accordance with relevant laws and regulations and the accuracy and completeness, etc. of the information disclosed through the regular disclosure documents and report this to the CEO to ensure that the head of the disclosure department execute the disclosure with CEO’s approval.
Article 12 (CEO)

The CEO shall personally confirm, review and approve the appropriateness, etc. of the regular disclosure documents reported by the person in charge of disclosure and provide certification as required under relevant laws and regulations.

Article 13 (Post-examination of disclosure contents)
  • ① The head of the business department and the head of the disclosure department involved in the preparation of regular disclosure documents shall check the appropriateness of the disclosure contents immediately after the disclosure.
  • ② In the event of error(s) or omission(s) in information as a result of the inspection, the head of the disclosure department shall take necessary measures, such as a corrective announcement, etc., to immediately correct them.
Section 2 Occasional disclosure
Article 14 (Occasional Disclosure)

The company shall prepare occasional disclosure documents and submit them to the Exchange within the disclosure deadline.

Article 15 (Business Department)
  • ① In the event that occasional disclosure matters occurs or is expected to occur, or there is a reason for cancellation or change to information that has already been occasionally disclosed occurs or is expected to occur, each business department shall immediately provide the relevant information regarding this to the disclosure department.
  • ② In the event that the business department receives a request from the head of the disclosure department to supplement the information in paragraph 1 or submit additional data, etc., the business department shall immediately respond to such request. Provided that, in the event that the head of the business department determines that the matter requires significant security or must be kept confidential, he/she shall report this to the person in charge of disclosure and follow instructions.
Article 16 (Disclosure Department)
  • ① In the event that the disclosure department receives information on occasional disclosure matters, etc. from the business department, it shall immediately review whether the information corresponds to disclosure matters and review the accuracy and integrity 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 In the event that the the head of the disclosure department finds that the information falls under occasional disclosure matters as a result of the review in the preceding paragraph, he/she shalll prepare a review of the relevant information and occasional disclosure documents, obtain approval from the CEO, and execute the disclosure in accordance with the disclosure method stipulated in relevant laws and regulations.
Article 17 (Person in Charge of Disclosure)
  • ① The person in charge of disclosure shall review whether the review contents and disclosure documents in Paragraph 2 of the preceding Article have been appropriately prepared in accordance with relevant laws and regulations.
  • ② In the event that important matters are discovered during the review process, the person in charge of disclosure shall report them to the CEO.
Article 18 (Post-examination of disclosure contents)

The provisions of Article 13 shall apply mutatis mutandis to occasional disclosure. In this case, “regular disclosure documents” shall be considered “regular disclosure documents.”

Section 3 Fair Disclosure
Article 19 (Fair Disclosure)

The company shall prepare fair disclosure documents and submit them to the Exchange within the disclosure deadline.

Article 20 (Prohibition of indirect provision of information subject to fair disclosure)

A fair disclosure information provider (refers to a person specified in Article 15, Paragraph 2 of the Disclosure Regulations) shall not indirectly provide the fair disclosure information to a person receiving fair disclosure information (as defined in Article 15, Paragraph 3 of the Disclosure Regulations) before public disclosure of fair disclosure matters through various ratios and scales of increase or decrease, etc.

Article 21 (Notes)
  • ① In the event of execution of fair disclosure, the person in charge of disclosure, contact information for the person in charge of disclosure, etc. shall be specified so that inquiries from investors who wish to know detailed information regarding the contents of fair disclosure can be easily made.
  • ② In the event of a request from the Exchange, a summary of the fair disclosure and the homepage address may be entered to execute the disclosure to the Exchange, and the summary and the original text may be posted on the company's website.
Article 22 (Application mutatis mutandis)

The provisions of Articles 13, 15 to 17 shall apply mutatis mutandis to fair disclosure. In this case, “regular disclosure documents” in Article 13 shall be regarded as “fair disclosure documents,” and “occasional disclosure” in Articles 15 to 17 shall be regarded as “fair disclosure.”

Section 4 Inquiry Disclosure
Article 23 (Inquiry Disclosure)

The company shall prepare inquiry disclosure documents and submit them to the Exchange within the disclosure deadline.

Article 24 (Disclosure Department)
  • ① In the event that the head of the disclosure department receives a request for inquiry disclosure from the Exchange, he/she shall immediately confirm the facts and the presence of important information, etc., prepare disclosure documents, and obtain review by the person in charge of disclosure and approval from the CEO to respond to the inquiry disclosure.
  • ② The head of the disclosure department may request submission of data or statement of opinion from each business department to confirm the facts and the presence of important information, etc. mentioned the preceding paragraph, and in this case, the business department shall respond to such request. Provided that, in the event that the head of the business department determines that the matter requires significant security or must be kept confidential, he or she shall report this to the person in charge of disclosure and follow instructions.
  • ③ In the event that the head of the disclosure department receives a request for inquiry disclosure, and a disclosure is made with the content that the decision-making process is in progress (hereinafter referred to as 'unconfirmed disclosure'), the head of the disclosure department shall identify the confirmed details or progress of the disclosure in question, obatain review of the person in charge of disclosure and approval of the CEO to make re-disclosure within 1 month. In this case, if it is judged to be impossible to re-disclose within one month, the time limit for re-disclosure shall be specified when the disclosure is executed.
Article 25 (Application mutatis mutandis)

The provisions of Article 13, the proviso to Article 16, Paragraph 2, and Article 17 shall apply mutatis mutandis to inquiry disclosure. In this case, “regular disclosure” in Article 13 shall be considered as “inquiry disclosure,” “occasional disclosure” in Article 17 shall be considered as “inquiry disclosure,” and in Article 17 Paragraph 1, “review details in Paragraphs 2 and 3 and “Disclosure documents” shall be regarded as “confirmation details and disclosure documents in Paragraph 1.”

Section 5 Free Disclosure
Article 26 (Free disclosure)

A company may preare free disclosure documents and submit them to the Exchange within the disclosure deadline.

Article 27 (Judgment of free disclosure matters and collection of information)
  • ① The person in charge of disclosure may instruct the head of the disclosure department to collect the necessary information and prepare disclosure documents in the event that free disclosure is deemed necessary or when reasons for cancellation or change of freely disclosed information occur or are expected to occur.
  • ② In the event that voluntary disclosure is deemed necessary a reason for cancellation or change of content that has already been voluntarily disclosed occurs or is expected to occur, or when there is an instruction from the disclosure manager pursuant to the preceding paragraph, the head of the disclosure department may request to provide or submit the information or data required by the head of the business department.
  • ③ The head of the business department may request, in accordance with the provisions of the preceding paragraph, the head of the disclosure department to provide the necessary information or If you are requested to submit data, you must immediately deliver the relevant information or data in writing to the disclosure department in accordance with the method prescribed in Article 7, Paragraph 2.
  • ④ In the event that the head of the business department receives a request from the head of the disclosure department to supplement the content of the notification in the preceding paragraph or submit additional data, he/she shall immediately respond. Provided that, in the event that it is judged that the matters require significant security or must be kept confidential, it shall be reported to the person in charge of disclosure and follow necessary instructions.
Article 28 (Application mutatis mutandis)

The provisions of Articles 13, 16, and 17 shall apply mutatis mutandis to free disclosure. In this case, “regular disclosure” in Article 13 shall be regarded as “free disclosure,” “review of whether it falls under disclosure matters” in Article 16, Paragraph 1 shall be regarded as “review of the need for disclosure,” and the clauses, “cases that fall under disclosure matters” in Paragraph 2 of the same Article shall be regarded as “cases where disclosure is deemed necessary,” and “cases that do not fall under disclosure matters” in Paragraph 3 of the same Article shall be regarded as “cases where disclosure is deemed not necessary”, and the “occasional disclosure” in Articles 16 and 17 shall be regarded as “free disclosure”.

Section 6 Issuance Disclosure and Key Matters Reporting
Article 29 (Issuance announcement and reporting of key matters)

The company shall prepare issuance disclosure and key matters reporting documents and submit them to the Financial Services Commission within the disclosure deadline.

Article 30 (Establishment of business promotion plan)

In the event that issuance disclosures and major matters reported under Article 161, Paragraph 1, Items 6 to 8 of the Act occur or are expected to occur, the head of the disclosure department shall check the necessary disclosure matters and schedules, etc. and when necessary, establish the issuance disclosure including segregation of duties f each business department and business promotion plan of major matter reporting to get approval by the person in charge of disclosure, and deliver such in writing to each business department.

Article 31 (Application mutatis mutandis)
  • ① The provisions of Article 9, Paragraph 2, Article 10, Paragraphs 2 to 3, and Articles 11 to 13 shall apply mutatis mutandis to the issuance discosure and the major points reporting in the preceding Article. In this case, the “annual disclosure plan” in Article 10, Paragraph 3 shall be considered as the “Issuance Disclosure and major points reporting business promotion plan” and the “regular disclosure documents” in Articles 10, Paragraph 3 and Articles 11 to 13 shall be regarded as a “Issuance Disclosure and major points reporting documents”.
  • ② Articles 15 to 18 shall apply mutatis mutandis to the reporting of major matters under Article 161, Paragraph 1, Subparagraph 1 to 5 and Subparagraph 9. In this case, “occasional disclosure” and “occasional disclosure documents” shall be regarded as “major points reporting” and “major points reporting documents.”
Chapter 4
Information and
Communication
Article 32 (Collection, maintenance, and management of information)
  • ① Each disclosure control organization shall collect, maintain, and manage necessary information and supporting data from within and outside the company related to its duties in order to ensure the accuracy, integrity, fairness, and timeliness of disclosure information.
  • ② The CEO may establish an information management system or make necessary work instructions so that executives and employees can collect, maintain, and manage the information set forth in the preceding paragraph and utilize it for related work.
Article 33 (Communication)

In the process of performing disclosure duties, the CEO shall strive to ensure that necessary communication systems, such as the establishment of a reporting system, etc. are in place for smooth information exchange and communication between each disclosure control organization and executives and employees.

Chapter 5
Evaluation and
management of
disclosure risk
Article 34 (Management of Disclosure Risk)

The CEO and person in charge of disclosure shall ensure that the following disclosure risks that may have a negative impact on the accuracy, integrity, fairness, and timeliness of disclosure information are timely checked and continuously managed.

  • ① Financial information error: Disclosure risk due to inconsistency between the actual financial status and the disclosed content caused by errors in accounting processing or inconsistencies in communication between responsible persons, etc.
  • ② Omissions, errors in filling out the forms: Disclosure risk due to omission or error in the information required in the disclosure-related form due to lack of understanding of information instructions, typos, etc.
  • ③ Unclearness, insufficiency, and inaccuracy of the disclosure contents: Disclosure risk due to the use of technical terms and abbreviations that are difficult for the general public to understand, lack of sufficient explanation of related content, and inconsistency between the actual facts and the disclosed content, etc.
  • ④ Failure to comply with the obligation to meet the disclosure deadline stipulated in relevant laws and regulations: Disclosure risk in case of failure to meet 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 information: Disclosure risk due to omission of disclosure due to failure to understand disclosure obligations or concealment or reduction of information that is negative to the company.
  • ⑥ Risks resulting from disclosure of forecast information: Disclosure risk due to forecast information not being based on reasonable grounds or assumptions, intentional misrepresentation, omission of important information, etc.
  • ⑦ Leakage of undisclosed information: Disclosure risk when information that has not been 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: Disclosure risks that may arise due to changes in disclosure-related laws, changes in government policies, changes in the exchange market to which the company belongs, changes in personnel or practices of relevant supervisory agencies and market operation agencies, etc.
  • ⑨ Change of person in charge of disclosure: Disclosure risks that may arise due to interruption of information succession due to change in the person in charge of disclosure, loss of continuity in performance of disclosure obligations, etc.
  • ⑩ Other disclosure risks that may have a negative impact on disclosure information
Article 35 (Business Department)

In the event that a disclosure risk occurs or is likely to occur during the performance of disclosure-related tasks, each business department shall immediately convey this to the disclosure department and manage appropriately to prevent disclosure risks from occurring according to the instructions of the person in charge of disclosure.

Article 36 (Disclosure Department)
  • ① The disclosure department shall oversee the inspection and management of disclosure risks at the company-wide level.
  • ② The head of the disclosure department shall ensure that appropriate inspection and management are carried out, such as conducting frequent inspections of the risk factors specified in Article 34 (Management of Disclosure Risks).
  • ③ The head of the disclosure department shall separately classify major disclosure risks that have a significant impact on the company and ensure appropriate inspection and management to be conducted.
Chapter 6
Monitoring
Section 1 Daily Monitoring
Article 37 (Daily monitoring)
  • ① The head of each business department, the head of the disclosure department, and the person in charge of disclosure shall check whether disclosure-related work is being processed in accordance with the disclosure control system through daily monitoring, and if vulnerabilities are discovered, shall take necessary measures to ensure timely correction and improvement and confirm that such measures have been taken afterwards.
  • ② For daily monitoring, a request for approval of documents, submission of reference materials, interview with employees related to disclosure information, and listening to opinions from accounting or audit department may be made.
Section 2 Operation status inspection and operation performance evaluation
Article 38 (Subject and Period)
  • ① The CEO and the person n charge of disclosure shall inspect the operation status of the disclosure control system and evaluate the operational performance.
  • ② Operational status inspection and operational performance evaluation shall be conducted after the end of each fiscal year and before submitting the business report. Provided that, if the CEO deems it necessary, it may be implemented even during the fiscal year.
Article 39 (Procedures)
  • ① The head of each business department and the head of the disclosure department shall submit the operational status of each department based on the evaluation details and related evidence required by the internal accounting management system by the date determined by the person in charge of disclosure within the period specified in paragraph 2.
  • ② The person in charge of disclosure shall inspect the operation status and evaluate the operational performance of the company's disclosure control system based on the reports submitted by each business department and the head of the disclosure department and report the results to the CEO. In this case, the person in charge of disclosure may obtain advice from auditors, the internal audit team, and external experts.
  • ③ The CEO shall inspect the operation status and evaluate the operational performance of the company's disclosure control system based on the results reported by the person in charge of disclosure.
Article 40 (Methods and Considerations)
  • ① In order to inspect the operational status of the disclosure control system and evaluate its operational performance, the CEO and the person in charge of disclosure may use various methods, such as interviewing those involved in the disclosure process such as the creation and delivery of information, reviewing related documents, and hearing opinions from external experts.
  • ② In the event of inspecting the operation status and evaluating the operational performance of the disclosure control system, the following matters may be considered.
  • 1. Whether any changes affecting the function of the disclosure control system have occurred since the previous inspection and evaluation was performed.
  • 2. Whether the disclosure control system designed and operated by the company contributes to the continuous production of accurate information and reduction of disclosure risk.
  • 3. Whether there are any illegal or defective aspects of the company’s disclosure control system.
  • 4. Whether the procedures in place to check the accuracy of financial and non-financial information is sufficient
  • 5. Whether sufficient prior and post-inspection are being conducted on the company’s disclosures.
  • 6. Whether all parties involved in the disclosure control process understand their responsibilities.
  • 7. Whether the evaluation and management of previously occurred disclosure risks and major disclosure risks are being appropriately carried out.
  • 8. Whether previously occurred risks could have been avoided through the existing disclosure control system
  • ③ In addition to the matters set forth in the preceding suparagraphs, the person in charge of disclosure may prepare and utilize a separate checklist, etc. through consultation regarding matters deemed necessary.
Article 41 (Use of evaluation results)
  • ① The CEO and the person in charge of disclosure shall take necessary measures to improve weaknesses in the control system revealed through inspection of the operation status and evaluation of operational performance of the disclosure control system.
  • ② The person in charge of disclosure shall, if necessary, post-assess whether the measures in the preceding paragraph are being implemented.
Chapter 7
Prohibition of unfair
trading by executives
and employees
Article 42 (General principles)

Executives and employees may not use or allow others to use the undisclosed important information (hereinafter referred to as “undisclosed important information”) related to business as prescribed in Article 174, Paragraph 1 of the Act to transactions of specific securities, etc. as prescribed in Article 172, Paragraph 1 of the Act (hereinafter referred to as “Specified Securities, etc.”) and other transactions.

Article 43 (Transactions of specific securities, etc. by executives and employees)
  • ① In the event that an executive or employee intends to buy or sell specific securities, etc., or engage in any other transactions, regardless of whether he or she uses undisclosed important information, he or she shall notify the head of the disclosure department or the person in charge of disclosure of the situation in advance.
  • ② The head of the disclosure department or the person in charge of disclosure who has received the notification in the preceding paragraph may prohibit the sale or other transactions if it is judged that there is a risk that it may be considered a transaction using undisclosed important information. In this case, the executives and employees concerned shall follow such instruction.
  • ③ If an executive or employee makes a purchase or other transaction of specific securities, etc., he or she must report the details of the transaction (type of specific securities, etc., trading quantity, transaction date) to the head of the disclosure department or 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 important information)
  • ① The CEO or person in charge of disclosure shall take necessary measures to ensure that undisclosed important information is managed in accordance with the following subparagraphs.
  • 1. Documents containing undisclosed important information shall be stored in a safe place where only authorized executives and employees can use them.
  • 2. Executives and employees shall not discuss undisclosed important information in places where others can hear the conversation, such as in elevators or hallways, etc.
  • 3. Documents containing undisclosed important information shall not be stored in public places, and when disposing of the documents, they must be destroyed through appropriate methods such as shredding so that the contents of the documents cannot be identified.
  • 4. Executives and employees shall maintain the confidentiality of undisclosed important information held by them not only externally but also within the company.
  • 5. Electronic transmission of documents related to undisclosed important information by fax, computer communication, etc. shall be carried out only when its confidentiality is guaranteed.
  • 6. Unnecessary copying of documents containing undisclosed important information shall be avoided as much as possible, and documents shall be quickly organized in a conference room or work-related location.
  • 7. Excess copies of documents containing undisclosed important information shall be completely destroyed by shredding or other methods.
  • ② Executives and employees shall not divulge any undisclosed important information of the company. Provided that, if it is unavoidable to share undisclosed important information with the other party to the transaction, legal representative, external auditor, etc. in business, the inquiry shall be made in advance to the person in charge of disclosure or the head of the disclosure department to ensure that it is shared only to the extent necessary.
  • ③ In the event that an executive or employee unintentionally leaks important undisclosed information, the head of the disclosure department shall be notified of this fact without delay.
  • ④ The head of the disclosure department who has received the notification in the preceding paragraph shall, if necessary, report the facts to the disclosure manager and take necessary measures, such as fair disclosure, under his/her instructions.
Article 45 (Undisclosed important information of affiliated companies)

Articles 42 to 44 shall apply mutatis mutandis to the prohibition of executives and employees from using undisclosed important information of our affiliates.

Article 46 (Return of Short-swing Profits, etc.)
  • ① In the event that the executives and the following employees sell specific securities, etc. within six months after purchasing them or make profits by purchasing them within six months after selling them, they must return such profits to the company in accordance with the provisions of Article 172 of the Act.
  • 1. Employees engaged in the establishment, change, promotion, disclosure, and other related work of matters subject to reporting of major matters under Article 3, Paragraph 13.
  • 2. Employees engaged in work related to finance, accounting, planning, and research and development
  • ② In the event that the company is requested by the Company’s shareholder (including those who own equity securities or securities depository receipts in addition to stock certificates. Hereinafter, the same shall apply in this Article) to return of profits from an executive or employee who engaged in short-term trading arbitrage, the head of the disclosure department shall report to the person in charge of disclosure.
  • ③ The person in charge of disclosure shall proceed with the necessary procedures to return the profits, including filing a judicial claim against the relevant executive or employee, within two months from the date of receiving the request in the preceding paragraph.
  • 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 receiving notification of the occurrence of short-swing profits from the Securities and Futures Commission (hereinafter referred to as “SFC”). Provided that, this does not apply in the event that short-wing profits have been returned.
  • 1. Status of person who must return short-wing profits
  • 2. Amount of short-wing profits (refers to the sum of each executive, employee, or major shareholders)
  • 3. The date on which the Securities and Exchange Commission was notified of the occurrence of short-term trading profits
  • 4. Plan to claim refund of short-wing profits of the relevant corporation
  • 5. Shareholders of the relevant corporation (including those who own equity securities or securities depositary receipts other than stocks; hereinafter the same shall apply in this subparagraph) may request the corporation to request a refund of the short-swing profits from the person who obtained the short-swing profits. This means that if the corporation does not make the claim within two months from the date of receiving the request, the shareholder may make the claim on behalf of the corporation.
Chapter 8
Other disclosure controls
Section 1 Contact with the media, including distribution of press releases
Article 47 (Distribution of press releases)
  • ① In the event htat the head of each business department wishes to distribute a press release to mass media such as the press, etc., he or she shall forward it to the disclosure department in advance and obtain approval from the person in charge of disclosure. In this case, if the person in charge of disclosure deems it necessary, he or she shall report to the CEO and follow his instructions.
  • ② In the event that the information delivered through the press release falls under the fair disclosure matters mentioned in Article 19, the head of the disclosure department shall prepare a fair disclosure document, ask the person in charge of disclosure to review it and obtain approval from the CEO, and conduct fair disclosure in accordance with Articles 21 and 22.
Article 48 (Hearing opinions)

If necessary, the person in charge of disclosure may hear the opinions of executives and employees or external experts, etc. with professional insight regarding the information provided through press releases.

Article 49 (Post-examination of reporting contents)

The head of the business department that created the press release and the head of the disclosure department conduct a follow-up inspection of the reported content after distribution of the press release, and if any content that is different from the reported facts, shall report it to the person in charge of disclosure and take necessary measrues following the instructions of the person in charge of disclosure as necessary.

Article 50 (Press Interview, etc.)
  • ① In the event that mass media such as press companies request coverage from the company, the following individuals may respond to the coverage. Provided that, in unavoidable cases, the person in charge of disclosure may designate a person who responds to interviews, etc.
  • 1. CEO
  • 2. Person in Charge of Disclosure
  • 3. IR executive
  • 4. Financial executive
  • ② In the event that there is a request for coverage, etc. as set forth in the preceding paragraph, the head of the disclosure department shall receive questions in advance from the relevant media company or prepare expected questions and answers and deliver them to the person responding to the coverage after a review by the person in charge of disclosure.
  • ③ The head of the disclosure department shall check the contents reported by mass media such as the press, etc. and if any information that is different from the reported facts, shall 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 Rumors)
  • ① In principle, the company shall not make any comments on 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 undisclosed important information through inquiries into the opinions of the relevant business departments, and if it is consistent, it is necessary to immediately take necessary measures so that the relevant information can be disclosed.
  • ③ Even if the contents of market rumors do not match important information that has not been disclosed, the person in charge of disclosure or the head of the disclosure department shall establish and implement an appropriate response plan if it is judged to be an issue that may have a negative impact on the company's interests.
Article 52 (Request for provision of information)
  • ① When a request is made to disclose information related to the company from shareholders, stakeholders, etc., the person in charge of disclosure or the head of the disclosure department shall review the legitimacy of the request and decide whether to provide the relevant information.
  • ② When information is provided in accordance with the decision in the preceding paragraph, the person in charge of disclosure or the head of the disclosure department may hear the opinions of the legal department or external legal experts on whether the provided information may affect investment decisions and stock prices, and if the information is subject to fair disclosure or has an impact on investment decisions and stock prices, necessary measures shall be taken to ensure that the information is disclosed to the public simultaneously at the time when or before the information is provided to the person requesting the information.
Article 53 (Business Briefing Session)
  • ① In the event of holding a business briefing session such as an investment briefing session or analyst meeting, etc. (hereinafter referred to as “Business briefing session”), the head of the business department in charge of the relevant work shall report the materials to be distributed at the business briefing session and the contents of the expected questions and answers in writing to the head of the disclosure department to obtain a prior approval.
  • ② In the event of holding a businss 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, etc. of the business briefing session, and the head of the disclosure department shall make a disclosure regarding the holding of the business briefing session prior to the holding of the business briefing session. do.
  • ③ In the event of provision of the information that has not been disclosed to the public through questions and answers at business briefing sessions, the head of the disclosure department shall take necessary measures to ensure that the information is disclosed to the public without delay.
Article 54 (Provision of information through website, e-mail, etc.)
  • ① In the event of providing information related to the company through the website or e-mail, etc., the head of each business department shall forward the information to the disclosure department in advance and obtain approval from the person in charge of disclosure.
  • ② Article 47, Paragraph 2, Article 48, and Article 49 shall apply mutatis mutandis to this Article. In this case, “press release” and “information provided through press release” shall be considered as “information provided through website, e-mail, etc.”
Chapter 9
Supplementary Rules
Article 55 (Training)
  • ① The person in charge of disclosure shall establish an annual training plan related to the disclosure control system, reflect it in the business plan, and implement it so that all executives and employees of the company can fully understand the disclosure control system and perform related tasks properly. In this case, professional education or training shall be completed for business departments and disclosure departments where disclosure information is generated frequently.
  • ② The head of the disclosure department shall understand the mandatory training schedule conducted by the Exchange or the Korea Listed Companies Association, to ensure that the training is completed, and take necessary measures to ensure that the training content is disseminated to relevant executives and employees.
Article 55-2 (Notification to the company of the subsidiary company’s disclosure information)
  • ① The company shall have its subsidiaries immediately notify the company's disclosure department of the disclosure information when it occurs or is expected to occur.
  • ② The company shall take measures such as having its subsidiaries establish disclosure information management regulations for efficient disclosure control. In this case, the subsidiary shall have a person in charge of disclosure work, and if the person in charge of disclosure is appointed or changed, the company shall be notified of such immediately.
  • ③ The company may request subsidiary companies to submit related data to the extent necessary for disclosure. In the event that the company cannot obtain the necessary data or needs to confirm the contents of the data submitted by the subsidiary, it may investigate the business and property status of the subsidiary.
Article 56 (Penalties)

The company may hold a separate disciplinary committee for executives and employees who violate this regulation and impose penalties or sanctions based on the results.

Article 57 (Opening and closing of regulations)

This regulation shall be opened and closed by the CEO.

Supplementary provision
  • 1. This Regulations enters into force from September 10, 2009.
  • 2. This Regulations enters into force from June 10, 2022.