CHAPTER I. GENERAL PROVISIONS

Article 1. Purposes
The purposes of these Regulations are to ensure that all publicly disclosed information of Daekyo Co., Ltd. (hereinafter, referred to as the “Company”) is disclosed accurately, completely, fairly, and timely in accordance with applicable laws and regulations, while providing for matters necessary for disclosure-related duties and procedures, management of disclosure information, etc. in order to prevent unfair trades by its employees.

Article 2. Scope of Application
Matters concerning public disclosure activities and the control of disclosure information shall be subject to what is prescribed in these Regulations unless otherwise set forth in any of the applicable laws or regulations or in the Company’s Articles of Incorporation.

Article 3. Definitions
① “Disclosure Information” refers to any matters subject to public disclosure and related information, which may influence an investor’s investment decisions in relation to the Company's management, assets, etc. and are set forth under applicable laws and regulations, including the Financial Investment Services and Capital Market Act (the “Act”) and its enforcement decree (the “Decree”), the Regulations on Securities Issuance and Disclosures (the “Issuance Disclosure Regulations”) of the Financial Services Commission (the “FSC”), and the Securities Market Disclosure Regulations (the “Disclosure Regulations”) of the Korea Exchange (KRX).
② “Disclosure Document” refers to a declaration and report document submitted for the disclosure of information and other documents attached to it.
③ “Disclosure Control System” refers to all activities conducted by the Company’s relevant internal organization to control disclosure information in accordance with certain control procedures.
④ “Disclosure Control Organization” refers to the Representative Director, the Disclosure Officer, Disclosure Department, and other business departments related to the generation of disclosure information, which conduct activities related to public disclosure, such as the creation, collection and review of disclosure information and the preparation and approval of disclosure documents.
⑤ “Disclosure Officer” refers to a person who is designated by the Representative Director to oversee the Company’s public disclosure activities and registered at the KRX as the Company's Disclosure Officer in accordance with Article 88 (1) of the Disclosure Regulations.
⑥ “Disclosure Department” refers to the department in charge of the Company’s public disclosure activities in accordance with its Business and Organization Policy. In this case, the Disclosure Department shall include at least two “disclosure personnel” registered at the KRX in accordance with Article 88 (2) of the Disclosure Regulations.
⑦ “Business Department” refers to any department that performs activities related to the generation of the Company’s disclosure information.
⑧ “Regular Disclosure” refers to submitting the Company’s Business Report, Semi-annual Report, and Quarterly Report concerning its overall business information, including its business and financial developments and business results, to the FSC or the KRX, in accordance with Articles 159, 160 and 165 of the Act, Articles 168 and 170 of the Decree, Article 4-3 of the Issuance Disclosure Regulations, and Article 21 of the Disclosure Regulations.
⑨ “Occasional Disclosure” refers to the submission or disclosure of material facts or decisions, which would influence investment decisions in relation to the Company’s business activities, to the KRX in accordance with Article 7 of the Disclosure Regulations.
⑩ “Fair Disclosure” refers to disclosing to the KRX any information that is not subject to disclosure obligation under the applicable laws and regulations or the disclosure date of which has not arrived yet, when the Company selectively provides a specific person with such information so that the investing public can also be aware of it at the same time (or before it is selectively provided to that specific person) in accordance with Articles 15 and 16 of the Disclosure Regulations and the Fair Disclosure Operation Guideline of the KRX.
⑪ “Inquired Disclosure” refers to disclosing to the KRX information required to ascertain whether any rumor or media report related to the Company is true or not or whether certain material information exists or not upon the request of the KRX in accordance with Article 12 of the Disclosure Regulations.
⑫ “Voluntary Disclosure” refers to disclosing to the KRX information other than matters subject to occasional disclosure under Paragraph (9) hereof that the Company believes would make material influence on the Company’s business and assets or an investor’s investment decisions or information not subject to disclosure obligation when the Company judges that it is necessary to disclose such information, in accordance with Article 28 of the Disclosure Regulations and Article 8 of the Enforcement Rules of the Disclosure Regulations.
⑬ “Disclosure of Issuance and Reporting of Material Matters” refers to submitting to the FSC a report concerning changes in the Company’s organization or its acquisitions or dispositions of securities as prescribed in applicable laws and regulations, including subscription of securities, sales or mergers, spin-offs, and business transfers, in accordance with Articles 119, 121 to 123, 130, and 161 of the Act, Articles 120 to 122, 137, and 171 of the 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.
⑭ Unless otherwise specified herein, the terms used herein shall have the same meaning as defined in applicable laws and regulations.

CHAPTER II. BASIC AUTHORITIES AND RESPONSIBILITIES OF DISCLOSURE CONTROL ORGANIZATION

Article 4. Representative Director
① The Representative Director shall oversee overall operations relating to the disclosure control system.
② The Representative Director shall conduct the following activities to ensure the disclosure control system is operated effectively.
1. Establish a policy regarding the design and operation of the disclosure control system;
2. Establish an authority, responsibility and reporting system for the disclosure control system;
3. Conduct final inspection of the operation status of the disclosure control system and final evaluation of its results;
4. Approve all policies related to the disclosure control system; and
5. Deal with other required matters.

Article 5. Disclosure Officer
① The Disclosure Officer shall be designated by the Representative Director.
② Disclosure Officer shall oversee activities related to the design and operation of the disclosure control system, and conduct the following activities.
1. Conduct activities related to the review, approval and implementation of disclosure information and documents (including related documents. Hereafter the same shall apply);
2. Take actions required to have the Company’s employees comply with laws and regulations related to disclosure (such as providing relevant training, preparing guidelines, etc.);
3. Identify risks associated with disclosure and establish and implement countermeasures;
4. Conduct constant monitoring of the disclosure control system, regular inspection of its operation status, and evaluation of its results;
5. Determine whether to disclose any matters not subject to public disclosure by applicable laws and regulations and the extent of such disclosure;
6. Direct and supervise the Disclosure Department;
7. Establish and execute plans for training employees related to disclosure activities;
8. Approve detailed guidelines, etc. required to enforce all policies related to the design and operation of the disclosure control system; and
9. Conduct other matters the Representative Director recognizes to be necessary in relation to the disclosure control system.
③ In performing their duties, Disclosure Officer shall have the following authorities if necessary.
1. The authority to request submission of books and records related to disclosure information and access them; and
2. The authority to hear opinions of employees from accounting or audit departments and other departments related to creating disclosure information and preparing disclosure documents.
④ If necessary in performing their duties, Disclosure Officer may consult with directors in charge or auditors (audit members) and hear opinions of external experts.

Article 6. Disclosure Department
① The Representative Director shall organize the department in charge of disclosure activities including persons who have professional knowledge about disclosure activities. Two persons in the department shall be appointed as Disclosure Personnel in accordance with Article 88 (2) of the Disclosure Regulations.
② The Disclosure Department shall be directed by Disclosure Officer in relation to disclosure activities and perform the following activities.
1. Collect and review various disclosure information;
2. Prepare disclosure documents and implement disclosures;
3. Establish annual disclosure business plan and check progress status;
4. Review actions required for compliance, such as constant monitoring of establishments and revisions of laws and regulations related to disclosure, and report results to Disclosure Officer;
5. Identify, inspect, evaluate and manage risks associated with disclosure throughout the company; and
6. Deal with other matters the Representative Director or Disclosure Officer recognizes to be necessary.

Article 7. Business Department
① The head of each business department shall inform the Disclosure Department in a timely manner in any of the following cases:
1. Where any matter subject to disclosure under laws and regulations related to disclosure occurs or is expected to occur;
2. Where it is uncertain whether to disclose any matter that would materially affect the Company’s business;
3. Where any reason for canceling or changing a disclosed matter occurs or is expected to occur; and
4. Where requested by Disclosure Officer or the head of the Disclosure Department.
② Where a business department delivers the disclosure information under the preceding paragraph to the Disclosure Department, it must also deliver relevant details and copies of supporting and reference documents and retain their originals. In the event of emergency or any unavoidable reason, however, it may be delivered by appropriate means other than documents first and written copies of the relevant details shall be delivered subsequently.

CHAPTER III. ACTIVITIES AND OPERATION OF DISCLOSURE CONTROL

Section 1. Regular Disclosure

Article 8. Regular Disclosure
The Company shall prepare quarterly disclosure documents and submit them to the FSC and the KRX by the applicable due date.

Article 9. Business Department
① The head of each business department shall establish and execute detailed implementation plan by checking activities assigned to their department for regular disclosures, disclosure schedule, etc., in accordance with the annual disclosure business plan and check the progress every month and deliver the inspection results to the Disclosure Department.
② The head of each business department shall perform activities assigned to their department for regular disclosures, and submit results to the Disclosure Department by the due date specified by the annual disclosure business plan.
③ Where the head of each business department expects that the due date under the preceding paragraph cannot be observed due to delay in pushing ahead with activities, etc., he/she shall immediately notify the Disclosure Department, and take necessary action as requested by the head of the Disclosure Department.

Article 10. Disclosure Department
① For regular disclosures, the head of the Disclosure Department shall check matters to be disclosed and the disclosure schedule, establish an annual disclosure business plan including activities assigned to each business department, and deliver it in writing to each business department after obtaining approval from the Disclosure Officer.
② Where the head of the Disclosure Department is concerned about failing to observe the statutory submission deadline based on the findings and notification from business departments, he/she shall report to Disclosure Officer and take necessary action as instructed by Disclosure Officer, and to this end, may request business departments to provide necessary support.
③ The head of the Disclosure Department shall compile data from business departments and prepare regular disclosure documents using the forms and entry methods as set forth in applicable laws and regulations, and submit them to Disclosure Officer by the due date as specified in the annual disclosure business plan.
④ The head of the Disclosure Department shall obtain approval from the Disclosure Officer and the Representative Director and implement regular disclosures by the statutory submission deadline. In this case, a certificate by the Representative Director, etc. shall be attached if required by applicable laws and regulations.

Article 11. Disclosure Officer
① The Disclosure Officer shall check the progress of activities required for regular disclosures, and take necessary action if he/she is concerned about failing to observe the statutory submission deadline.
② The Disclosure Officer shall review regular disclosure documents submitted by the head of the Disclosure Department to determine whether they have been prepared properly in accordance with applicable laws and regulations as well as their accuracy, completeness, etc. and report the result to the Representative Director to obtain approval and have the head of the Disclosure Department execute disclosures.

Article 12. Representative Director
The Representative Director shall check and review in person the adequacy, etc. of regular disclosure documents reported by the Disclosure Officer, approve them, and certify them as required by applicable laws and regulations.

Article 13. Post Inspection of the Contents of Disclosure
① The head of the business department related to preparation of regular disclosure documents and the head of the Disclosure Department shall inspect the adequacy of the disclosed information immediately after disclosure.
② The head of the Disclosure Department shall take action required to immediately correct any entry errors or omissions found from inspection.

Section 2. Occasional Disclosure

Article 14. Occasional Disclosure
The Company shall prepare occasional disclosure documents and submit them to the KRX by the applicable due date.

Article 15. Business Department
① Where any matter requiring occasional disclosure or any reason for canceling or changing already disclosed information occurs or is expected to occur, the relevant business department shall immediately inform the Disclosure Department of such information.
② The business department shall immediately respond to any request from the head of the Disclosure Department to submit supplementary or additional materials for the information specified in Paragraph (1). Where the head of the business department judges that the information requires material security or confidentiality, he/she shall report it to Disclosure Officer and follow his/her instructions.

Article 16. Disclosure Department
① Where the Disclosure Department receives information on occasional disclosure, etc. from a business department, it shall immediately review the information to determine whether it is subject to disclosure as well as its accuracy and completeness. The head of the Disclosure Department may request the business department to submit supplementary or additional materials for the information if necessary.
② Where the results of the review under the preceding paragraph show that the matter is subject to occasional disclosure, the head of the Disclosure Department shall prepare a review report and occasional disclosure documents for the information, submit them to Disclosure Officer, obtain approval from Disclosure Officer, and make disclosure in accordance with the method as prescribed in the applicable laws and regulations. Where it is difficult to obtain approval from Disclosure Officer due to, for example, his/her absence, however, the head of the Disclosure Department may make disclosure, in which case he/she shall subsequently report to Disclosure Officer.
③ Where the results of the review under Paragraph (1) show that the matter is not subject to disclosure, the head of the Disclosure Department shall document the reason and review details and report to Disclosure Officer.

Article 17. Disclosure Officer
① Disclosure Officer shall review whether the review details and disclosure documents under Paragraphs (2) and (3) of the preceding Article have been prepared appropriately in accordance with applicable laws and regulations, and decide whether to approve disclosure.
② The Disclosure Officer shall report material matters related to occasional disclosure to the Representative Director.

Article 18. Post Inspection of the Contents of Disclosure
Provisions under Article 13 shall apply mutatis mutandis to occasional disclosures. In this case, “regular disclosure document” shall be substituted by “occasional disclosure document.”

Section 3. Fair Disclosure

Article 19. Fair Disclosure
The Company shall prepare fair disclosure documents and submit them to the KRX by the applicable due date.

Article 20. Prohibition on Circumvention of Fair Disclosure Obligation
The fair disclosure information provider (as defined in Article 15 (2) of the Disclosure Regulations) may not indirectly provide information subject to fair disclosure to fair disclosure information recipients (as defined in Article 15 (3) of the Disclosure Regulations) before disclosure by providing information on various ratios, amount of variation, etc.

Article 21. Notes for Disclosure
① When making fair disclosure, the Disclosure Officer, the Disclosure Personnel, and the Business Department related to the information subject to fair disclosure and their contact information shall be specified, so that investors can easily make an inquiry into the details of fair disclosure.
② When requested by the KRX, the summarized contents of fair disclosure information and the website information shall be posted as well when the disclosure is made on the KRX, and the said summary contents and original texts shall be posted on the Company’s website.
Article 22. Application with Necessary Modification
Provisions under Articles 13 and 15 to 17 shall apply mutatis mutandis to fair disclosure. In this case, “regular disclosure documents” under Article 13 shall be substituted by “fair disclosure documents” and “occasional disclosure” under Articles 15 to 17 by “fair disclosure.”

Section 4. Inquired Disclosure

Article 23. Inquired Disclosure
The Company shall prepare inquired disclosure documents and submit them to the KRX by the applicable due date.

Article 23. Inquired Disclosure
① Upon receiving a request from the KRX for inquired disclosure, the head of the Disclosure Department shall immediately check facts and any material information, prepare disclosure documents accordingly, obtain approval from the Disclosure Officer and make inquired disclosure.
② To check facts and any material information as set forth in the preceding paragraph, the head of the Disclosure Department may request each business department to submit materials or provide opinions. Where the head of the business department judges that the information requires material security or confidentiality, he/she shall report it to Disclosure Officer and follow his/her instructions.
③ When the Company receives a request for inquired disclosure and makes disclosure of the fact that it is in the process of decision making (the “Disclosure of Non-determination”) accordingly, the head of the Disclosure Department shall check the determined details or progress of the matter subject to disclosure, obtain approval from the Disclosure Officer, and make re-disclosure within one month after the disclosure of non-determination was made. Where he/she determines it is practically impossible to make a re-disclosure within one month, he/she shall specify the deadline for re-disclosure and make the disclosure accordingly.

Article 25. Application with Necessary Modification
Provisions under Article 13 and Article 17 and the proviso to Article 16 (2) shall apply mutatis mutandis to inquired disclosure. In this case, “regular disclosure” under Article 13 shall be substituted by “inquired disclosure”, “occasional disclosure” in Article 17 by “inquired disclosure”, and “review details and disclosure documents under Paragraphs (2) and (3)” in Article 17 (1) by “checked details and disclosure documents under Paragraph (1).”

Section 5. Voluntary Disclosure

Article 26. Voluntary Disclosure
The Company may prepare voluntary disclosure documents and submit them to the KRX by the applicable due date.

Article 25. Application with Necessary Modification
① Where any matter considered to require voluntary disclosure or any reason for canceling or changing already disclosed information occurs or is expected to occur, the Disclosure Officer may order the head of the Disclosure Department to collect necessary information and prepare disclosure documents.
② When any matter is judged to require voluntary disclosure or any reason for canceling or changing already disclosed information occurs or is expected to occur, or if there is an order from the Disclosure Officer under the preceding paragraph, the head of the Disclosure Department may request the head of the business department to provide necessary information or to submit materials.
③ When any matter is judged to require voluntary disclosure or any reason for canceling or changing already disclosed information occurs or is expected to occur, or if there is a request from the head of the Disclosure Department to provide necessary information or submit materials in relation to this in accordance with the provisions under the preceding paragraph, the head of the business department shall immediately deliver such information or materials in documents to the Disclosure Department through the method as prescribed in Article 7 (2).
④ Upon receiving a request from the head of the Disclosure Department for supplementary or additional materials for the delivered information under the preceding paragraph, the head of the business department shall immediately respond to the request. Where he/she judges that the information requires material security or confidentiality, however, he/she shall report it to the Disclosure Officer and follow his/her instructions.

Article 28. Application with Necessary Modification
Provisions under Articles 13, 16 and 17 shall apply mutatis mutandis to voluntary disclosure. In this case, “regular disclosure” under Article 13 shall be substituted by “voluntary disclosure”, “review the information to determine whether it is subject to disclosure” under Article 16 (1) by “review the information to determine whether it requires disclosure”, “when the matter is subject to disclosure” under Paragraph (2) of the same Article by “when the matter is judged to require disclosure”, “the matter is not subject to disclosure” under Paragraph (3) of the same Article by “the matter is judged not to require disclosure”, and “occasional disclosure” under Articles 16 and 17 by “voluntary disclosure.”

Section 6. Issuance Disclosure and Essential Information Reporting

Article 29. Issuance Disclosure and Essential Information Reporting
The Company shall prepare issuance disclosure and essential information reporting documents and submit them to the FSC by the applicable due date.

Article 30. Establishment of a Business Plan
When any matter subject to issuance disclosure or essential information reporting under Subparagraphs 6 to 8 of Article 161 (1) of the Act occurs or is expected to occur, the head of the Disclosure Department shall check matters to be disclosed, disclosure schedule, etc., and establish a business plan for issuance disclosure and essential information reporting including assigning activities to each business department, obtain approval from the Disclosure Officer, and deliver it in documents to each business department.

Article 31. Application with Necessary Modification
① The provisions under Article 9 (3), Article 10 (2) to (3), and Articles 11 to 13 shall apply mutatis mutandis to issuance disclosure and essential information reporting under the preceding Article. In this case, “annual disclosure business plan” under Article 10 (3) shall be substituted by a “business plan for issuance disclosure and essential information reporting”, and “regular disclosure documents” under Article 10 (3) and Articles 11 to 13 by “issuance disclosure and essential information reporting documents.”
② The provisions under Articles 15 to 18 shall apply mutatis mutandis to essential information reporting under Subparagraphs 1 to 5 and 9 of Article 161 (1). In this case, “occasional disclosure” and “occasional disclosure documents” shall be substituted by “essential information reporting” and “essential information reporting documents.”

CHAPTER IV. INFORMATION AND COMMUNICATION

Article 32. Collection, Keeping and Management of Information
① Each Disclosure Control Organization shall collect, keep, and manage necessary information and supporting data related to its duties obtained from both inside and outside the Company in order to achieve the accuracy, completeness, fairness and timeliness of disclosure information.
② The Representative Director may establish an information management system or give necessary business instructions to ensure that employees can collect, keep, and manage the information in the preceding paragraph and utilize it for related duties.

Article 33. Communication
The Representative Director shall put efforts to arrange a necessary communication system such as the establishment of a reporting system for smooth exchange of information and communication between each disclosure control organization and employees in the course of performing disclosure duties.

CHAPTER V. EVALUATION AND CONTROL OF DISCLOSURE RISK

Article 34. Control of Disclosure Risk
The Representative Director and the Disclosure Officer shall ensure that the following disclosure risks that can negatively affect the accuracy, completeness, fairness and timeliness of disclosure information are inspected in a timely manner and managed continuously.
1. Financial information errors: Disclosure risk from disparity between actual financial condition and disclosed information caused by accounting errors or miscommunication between personnel.
2. Missing or incorrect entries in forms: Disclosure risk from missing or incorrect entries in forms relating to disclosure caused by lack of understanding of how to prepare forms, typos, etc.
3. Ambiguity, insufficiency and inaccuracy of disclosed information: Disclosure risk from use of jargons and abbreviations the general public cannot understand, insufficient explanation of relevant information, and disparity between actual occurrence and disclosed information, etc.
4. Failing to meet disclosure deadline as prescribed in applicable laws and regulations: Disclosure risk from failing to meet disclosure deadline due to delay in delivering information, delay in approval, misunderstanding of disclosure deadline, etc.
5. Omission, concealment and understatement of disclosed information: Disclosure risk from omission of disclosure caused by failing to properly understand disclosure obligations or concealment/understatement of information that would negatively affect the Company.
6. Risk from disclosing predicted information: Disclosure risk from information predicted not based on rational grounds or assumptions, intentional false entries, omission of material information, etc.
7. Leakage of non-public information: Disclosure risk from leakage of non-public information through an unusual route, such as an employee selectively providing such information to a certain person.
8. Risk from changes in the disclosure system: Disclosure risk from changes in laws and regulations relating to disclosure, changes in government policies, changes in the exchange market on which the Company is listed, changes in the personnel or activities of related supervisory authorities or market operation agencies, etc.
9. Change in disclosure personnel: Disclosure risk from failure to transfer information or continue to fulfill disclosure obligations due to change in disclosure personnel.
10. Other disclosure risks that would negatively affect disclosure information.

Article 35. Business Department
① Where any disclosure risk occurs or is likely to occur in the course of performing disclosure activities, each business department shall immediately inform the Disclosure Department and conduct appropriate control as instructed by the Disclosure Officer to ensure disclosure risk does not occur.
② The head of each business department shall make a list of disclosure risks related to their department and ensure such risks are inspected and controlled properly by, for example, conducting monthly inspections.
Article 36. Disclosure Department
① The Disclosure Department shall oversee activities to inspect and control disclosure risks throughout the Company.
② The head of the Disclosure Department shall make a list of disclosure risk factors and establish and implement an annual business plan after obtaining approval from the Disclosure Officer to ensure continuous inspection and management.
③ The head of the Disclosure Department shall make a separate list of material disclosure risks whose outcomes would materially affect the Company and ensure such risks are inspected and controlled properly by, for example, conducting daily or monthly inspections, etc.

CHAPTER VI. MONITORING

Section 1. Ordinary Monitoring

Article 37. Ordinary Monitoring
① The head of each business department, the head of the Disclosure Department and the Disclosure Officer shall check through ordinary monitoring whether activities related to disclosure are performed in accordance with the disclosure control system and in the event of any weakness found, shall take any necessary action to correct and improve it in a timely manner, and subsequently check whether such action has been properly implemented.
② For ordinary monitoring, they may approve related documents, request to submit reference materials, interview with personnel related to disclosed information, and hear the opinions of accounting or audit departments.

Section 2. Inspection of Operational Status and Evaluation of Operational Results

Article 38. Main Agents and Timing
① The Representative Director and the Disclosure Officer shall conduct inspection of the operation status of the disclosure control system and evaluation of its results.
② Inspection of operation status and evaluation of operation results shall be conducted after end of each business year before submission of the business report, provided that such inspection and evaluation may also be conducted during the business year if the Representative Director recognizes it necessary to do so.

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-inspection results to the Disclosure Officer by the due date designated by the Disclosure Officer within the period as specified in Paragraph (2) of the preceding Article.
② The Disclosure Officer shall conduct inspection of the operation status of the Company’s disclosure control system and evaluation of its results on the basis of the reports submitted by each business department and the head of the Disclosure Department, and report the result to the Representative Director. In this case, the Disclosure Officer may consult with auditors (the audit committee), internal audit team, external experts, etc.
③ The Representative Director shall conduct inspection of the operation status of the Company’s disclosure control system and evaluation of its results based on the results reported by the Disclosure Officer.

Article 40. Methods and Considerations
① For the inspection of the operation status of the disclosure control system and evaluation of its results, the Representative Director and the Disclosure Officer may use various combinations of methods, including interviewing those involved in disclosure procedures such as creating and forwarding information, reviewing related documents, hearing opinions of external experts, etc.
② When inspection of the operation status of the disclosure control system and evaluation of its results are conducted, the following matters should be taken into consideration.
1. Whether there has occurred any change that affects the function of the disclosure control system after the previous inspection and evaluation.
2. Whether the disclosure control system designed and operated by the Company contributes to producing continuous and accurate information and reducing disclosure risks.
3. Whether there is any illegal or defective part in the Company’s disclosure control system.
4. Whether there are sufficient procedures to check the accuracy of financial and non-financial information.
5. Whether prior review and ex-post inspection of the Company’s disclosed information are conducted sufficiently.
6. Whether those involved in the Company’s disclosure control process are all aware of their responsibilities.
7. Whether evaluation and control of previous disclosure risks and material disclosure risks are conducted properly.
8. Whether previous risks could have been avoided through the existing disclosure control system.
③ The Disclosure Officer may prepare and use a separate checklist through consultation for any matter, other than specified in each subparagraph of the preceding paragraph, he/she recognizes necessary.

Article 41. Utilization of Evaluation Results
① The Representative Director and the Disclosure Officer shall take any necessary action to improve weaknesses in control found from the inspection of the operation status of the disclosure control system and the evaluation of its results.
② The Disclosure Officer shall conduct a post inspection for whether the action under the preceding paragraph is being implemented.

CHAPTER VII. PROHIBITION ON UNFAIR TRADING BY EMPLOYEES

Article 42. General Principles
An employee shall not use essential non-public information related to activities, etc. prescribed in Article 174 (1) of the Act (hereinafter referred to as the “Essential Non-public Information”) in trading of specific securities, etc. as prescribed in Article 172 (1) of the Act (hereinafter referred to as the “Specific Securities, Etc.”) or other transactions or allow others to use such information.

Article 43. Trading of Specific Securities, Etc. by Employees
① When an employee intends to trade Specific Securities, Etc. or conduct any other transaction regardless of whether he/she uses Essential Non-public Information or not, he/she shall notify the internal audit officer or legal officer of the relevant situations in advance.
② Upon receiving such notification under the preceding paragraph, the internal audit officer or legal officer may prohibit such trading or other transactions if they could be considered as a transaction using Essential Non-public Information. In this case, the employee in question shall follow such prohibition.
③ When an employee trades Specific Securities, Etc. or conducts any other transaction, he/she shall report details on the transaction (type of Specific Securities, Etc., quantity and date of trade) to the internal audit officer or legal officer within 10 days after end of the quarter in which the transaction was made.

Article 44. Control of Essential Non-public Information
① The Representative Director or the Disclosure Officer shall take necessary action to ensure Essential Non-public Information is under control according to the following subparagraphs.
1. Documents containing Essential Non-public Information shall be kept in a secure place only authorized employees can access.
2. Employees shall not discuss Essential Non-public Information in any place where others can hear their conversation, such as elevators and corridors.
3. Documents containing Essential Non-public Information shall not be placed in a public place, and when it comes to the destruction, such documents shall be destroyed through an appropriate method such as shredding to ensure the content of documents is not readable.
4. An employee shall keep Essential Non-public Information in their possession secure both inside and outside the Company.
5. Electronic transmission of documents related to Essential Non-public Information through fax, computer communications, etc. shall only be conducted with security guaranteed.
6. Unnecessary copying of documents containing Essential Non-public Information should be avoided if possible, and documents used in any conference room or business-related place should be removed promptly.
7. Extra copies of a document containing Essential Non-public Information shall be destroyed thoroughly using a method such as shredding.
② An employee shall not leak the Company’s Essential Non-public Information, provided that, in case where he/she has to unavoidably share Essential Non-public Information with a counterpart of transaction, legal representative, outside auditor, etc., he/she shall share only minimum required information by checking with the Disclosure Officer or the head of the Disclosure Department in advance.
③ When an employee leaks Essential Non-public Information by mistake, he/she shall immediately notify the head of the Disclosure Department.
④ Upon receiving the notification under the preceding paragraph, the head of the Disclosure Department shall report it to the Disclosure Officer and take any necessary action, such as making fair disclosure, as instructed by the Disclosure Officer.

Article 45. Essential Non-public Information of Subsidiaries
Provisions under Articles 42 to 44 shall apply mutatis mutandis to prohibition on use of Essential Non-public Information of the Company’s subsidiaries by an employee.

Article 46. Return of Short-swing Profits, Etc.
① When any employee specified in the following subparagraphs gains profits by buying Specific Securities, Etc. and then selling within six months or selling it and then buying within six months, they shall return such profits to the Company in accordance with Article 172 of the Act.
1. Employees involved in the establishment, change, promotion and disclosure of any matter subject to essential information reporting under Article 3 (13) and other related activities; and
2. Employees involved in activities related to finance, accounting, planning and R&D
② When any shareholder of the Company (including those who own equity securities or depository receipts as well as stock certificates. Hereafter the same shall apply in this Article) files a claim against the Company’s employee who obtained short-swing profits to return such profits, the head of the Disclosure Department shall report it to the Disclosure Officer.
③ The Disclosure Officer shall proceed with a procedure required to have such profits returned, including filing a suit against the employee, within two months after the request under the preceding paragraph was made.
④ The Disclosure Officer shall immediately have the following matters posted on the Company’s website for two years from the date on which a notice of short-swing profits from the Securities and Futures Commission (the “SFC”) was received, unless the profits have already been returned.
1. The position of the person who is obliged to return the short-swing profits;
2. The amount of the short-swing profits (referring to the sum of profits by employees or major shareholders);
3. The date on which the notice of short-swing profits was received from the SFC;
4. The relevant corporation’s plan for filing a claim for return of short-swing profits; and
5. A shareholder of the corporation (including those who own equity securities or depository receipts as well as stock certificates. Hereafter the same shall apply in this subparagraph) may demand the corporation to file a claim against the person who gained such short-term profits for return of such profits, or may subrogate him/herself in the position of the corporation to file such a claim unless the corporation files such a claim within two months after it was demanded to do so.

CHAPTER VIII. OTHER DISCLOSURE CONTROLS

Section 1. Contact with Media Including Distribution of Press Releases

Article 47. Distribution of Press Releases
① As for the distribution of press releases to the mass media, such as the press, the head of each business department shall submit such press release to the Disclosure Department in advance and obtain approval of the Disclosure Officer before distributing it. In this case, where the Disclosure Officer considers necessary, he/she shall report to the Representative Director and follow his/her instructions..
② Where the information released through the press release is subject to fair disclosure as prescribed in Article 19, the head of the Disclosure Department shall prepare fair disclosure documents, obtain approval of the Disclosure Officer, and make fair disclosure in accordance with Articles 21 and 22.

Article 48. Hearing Opinions
If necessary, the Disclosure Officer may hear opinions from employees or external experts who have professional knowledge on the information to be released through a press release.

Article 49. Post Inspection of Press Report
The head of the business department which created a press release and the head of the Disclosure Department shall conduct post inspection on the press report published after the distribution of the press release and report any incorrectly reported information to the Disclosure Officer and take necessary action as instructed by the Disclosure Officer.

Article 50. Press Coverage, Etc.
① When mass media, such as the press, request coverage, etc. to the Company, the person under the following subparagraphs may respond to such coverage, etc., provided that, if the situation demands, the Disclosure Officer may designate the person who will respond to such coverage, etc.
1. Representative Director
2. Disclosure Officer
3. IR officer
4. Financial officer
② In the event of a request for coverage, etc. as prescribed in the preceding paragraph, the head of the Disclosure Department shall receive a list of questions from the press in advance or prepare a document of expected questions and answers, have it reviewed by the Disclosure Officer, and deliver it to the person who will respond to such coverage, etc.
③ The head of the Disclosure Department shall look into the press report made by mass media, such as the press, and report any incorrectly reported information to the Disclosure Officer and take necessary action as instructed by the Disclosure Officer.

Section 2. Market Rumors, Etc.

Article 51. Market Rumors
① In principle, the Company shall not comment on any market rumors.
② The Disclosure Officer or the head of the Disclosure Department shall check whether the content of a market rumor is consistent with material non-public information through consultation with the relevant business department, etc., and if so, take any necessary action to ensure that public disclosure of the information is made immediately.
③ Even when the market rumor is not consistent with the material non-public information, the Disclosure Officer or the head of the Disclosure Department must establish and execute appropriate countermeasures if he/she considers that the issue would negatively affect the Company’s interests.

Article 52. Request for Information
① Upon receiving a request from any shareholder or stakeholder for disclosure of information related to the Company, the Disclosure Officer shall review the legality of the request and decide whether to provide the information.
② In the event of providing information according to the decision made under the preceding paragraph, the Disclosure Officer may hear opinions from the legal department or external legal experts regarding whether the information to be provided would affect an investor’s investment decisions and the share price. When the information is subject to fair disclosure or would affect an investor’s investment decisions and the share price, he/she shall take necessary action to ensure the information is disclosed to the general public at the same time when (or before) it is provided to the person who requested it.

Article 53. IR Presentations
① When an IR presentation such as an investment presentation, analyst meeting, etc. (hereinafter, referred to as the “IR presentation”) is held, the head of the business department in charge of it shall report to the Disclosure Officer materials to be distributed at the presentation and a list of expected questions and answers in writing and obtain his/her approval.
② When an IR presentation is held, the head of the business department in charge of it shall inform the Disclosure Department of the date, venue, targets, etc. of the presentation, and the head of the Disclosure Department shall make a public announcement of the presentation before it is held.
③ In the event where non-public information is provided at an IR presentation through a Q&A session, etc., the head of the Disclosure Department shall take necessary action to ensure that the information is disclosed to the general public without delay.

Article 54. Provision of Information through Website, Email, Etc.
① Where information related to the Company is provided through website, email, etc., the head of each business department shall deliver the information to the Disclosure Department in advance to obtain approval from the Disclosure Officer before providing such information.
② Provisions under Article 47 (2), Article 48 and Article 49 shall apply mutatis mutandis to this Article. In this case, “press release” and “information to be released through a press release” shall be substituted by “information provided through website, email, etc.”

CHAPTER IX. SUPPLEMENTARY PROVISIONS

Article 55. Education
① The Disclosure Officer shall establish and execute an annul education plan about the disclosure control system to ensure all the Company’s employees fully understand the system and can perform related activities properly. In this case, business departments that generate disclosure information frequently and the Disclosure Department shall be provided with specialized education or training.
② The head of the Disclosure Department shall check the schedule of mandatory education provided by the KRX or the Korea Listed Companies Association, complete such education, and take necessary action to ensure the content of the education is disseminated to relevant employees.

Article 56. Penalty
The Company may impose a penalty or punishment on any employee who violates these Regulations in accordance with the Company’s relevant policy.

Article 57. Establishment and Repeal of Regulations
These Regulations shall be established or repealed by the Representative Director.

CHAPTER X. SUPPLEMENTARY PROVISIONS

Article 1. Effective Date
These Regulations shall enter into force on February 1, 2008.

Article 2. Repeal of Internal Information Management Regulations
Upon the enforcement of these Regulations, the Company's Internal Information Management Regulations will be repealed.

These Regulations shall enter into force on September 1, 2009.