THE E&M

Article 2 [Definitions]

①	Internal Information: In this regulation, "Internal Information" refers to matters subject to disclosure under Part 1 of the KOSDAQ Market Disclosure Regulations (hereinafter referred to as the "Disclosure Regulations") of the Korea Exchange (hereinafter referred to as the "Exchange") and any other matters related to the Company's management or financial status that may affect investors' investment decisions.
②	Disclosure Officer: "Disclosure Officer" refers to the person authorized to perform reporting duties on behalf of the Company in accordance with Article 2, Paragraph 4 of the Disclosure Regulations.
③	Executive: "Executive" refers to directors (including those who fall under any of the subparagraphs of Article 401-2, Paragraph 1 of the Commercial Act) and auditors.
④	For terms not defined in Paragraphs 1 to 3 of this Article, the definitions provided in the relevant laws and regulations shall apply.

Article 4 [Management of Internal Information]

①	Duties of Executives and Employees: Executives and employees must strictly manage the Company's internal information that they become aware of during the course of their duties. Except for cases where it is necessary for business purposes, internal information must not be disclosed either within or outside the Company.
②	Responsibilities of the CEO: The CEO must implement necessary measures for the management of internal information. This includes establishing specific standards for the storage, transmission, and destruction of internal information and related documents.

Article 5 [Disclosure Officer]

①	The CEO must appoint a disclosure officer and report it to the exchange without delay. The same applies when changing the disclosure officer.
②	The disclosure officer is responsible for overseeing the establishment and operation of the internal information management system and performs the following tasks: 1. Executing disclosures 2. Checking and evaluating the operation of the internal information management system 3. Reviewing internal information and deciding on the necessity of disclosure 4. Taking necessary measures for the operation of the internal information management system, including educating executives and employees 5. Directing and supervising departments or executives and employees responsible for managing internal information or handling disclosure tasks 6. Performing other tasks deemed necessary by the CEO for the operation of the internal information management system
③	The disclosure officer has the following authorities in performing their duties: 1. The authority to request and review various documents and records related to internal information 2. The authority to seek necessary opinions from executives and employees in charge of accounting, auditing, or other tasks related to the generation of internal information
④	The disclosure officer may consult with relevant executives when necessary and can seek expert assistance at the company’s expense.
⑤	The disclosure officer must regularly report the status of the internal information management system to the CEO (or the board of directors).

Article 6 [Disclosure Manager]

①

The CEO must appoint a disclosure manager and report it to the exchange without delay. The same applies when changing the disclosure manager.

②

The disclosure manager works under the direction of the disclosure officer and performs the following tasks:

1. Collecting and reviewing internal information and reporting to the disclosure officer
2. Performing tasks necessary for executing disclosures
3. Verifying changes in disclosure-related regulations and reporting to the disclosure officer
4. Performing other tasks deemed necessary by the CEO or disclosure officer

Article 7 [Concentration of Internal Information]

①	Executives and department heads must promptly provide the disclosure officer with information when: 1. Internal information arises or is expected to arise 2. Reasons for canceling or changing already disclosed information arise or are expected to arise 3. The disclosure officer requests it
②	The disclosure officer and CEO must efficiently establish an information transmission system within the company and may require the disclosure officer’s cooperation in the approval process related to disclosure obligations.

Article 7-3 [Concentration of Subsidiary Internal Information]

①	When internal information related to disclosure obligations arises or is expected to arise at a subsidiary, the subsidiary must immediately notify the company’s disclosure officer or disclosure manager.
②	To efficiently manage internal information related to disclosure obligations, the company must appoint someone at the subsidiary to manage disclosure-related information and immediately inform the company’s disclosure officer or disclosure manager of any appointments or changes.
③	The company may request the submission of related materials from the subsidiary within the scope necessary for disclosure tasks.

Article 8 [Provision of Internal Information Outside the Company]

①	If executives or employees must provide internal information to business partners, external auditors, agents, or consultants due to business reasons, they must report this to the disclosure officer.
②	In such cases, the disclosure officer must take necessary measures, such as entering into confidentiality agreements, to protect the internal information.
③	If the provision of internal information creates a fair disclosure obligation, it must be disclosed without delay (except where Article 15 of the disclosure regulations applies).

Article 9 [Types of Disclosures]

Company disclosures are classified as follows:

①	Major management matters reporting and disclosure according to Article 1, Chapter 2, Section 1 of the Disclosure Regulations
②	Inquiry disclosures according to Article 1, Chapter 2, Section 2 of the Disclosure Regulations
③	Fair disclosures according to Article 1, Chapter 2, Section 3 of the Disclosure Regulations
④	Voluntary disclosures according to Article 1, Chapter 3 of the Disclosure Regulations
⑤	Submission of securities registration statements and related documents according to Article 1, Chapter 1 of the Act
⑥	Submission of business reports and other documents according to Articles 159, 160, and 165 of the Act and Article 1, Chapter 2, Section 4 of the Disclosure Regulations
⑦	Submission of major matters reports according to Article 161 of the Act
⑧	Other disclosures required by different regulations

Article 12 [Media Inquiries, etc.]

①	In principle, the CEO or disclosure officer should respond to media inquiries about the company. If necessary, relevant department staff may be involved in responding.
②	If the company wishes to distribute press releases to the media, it must consult with the disclosure officer. The disclosure officer should report to the CEO on matters related to the distribution of press releases if necessary.
③	If the content of the press release distributed under Paragraph 2 falls under the category of fair disclosure, it must be disclosed before the distribution of the press release.
④	Employees who become aware that media reports are inaccurate must report this to the disclosure officer. The disclosure officer should report the matter to the CEO and take necessary actions.

Article 13 [Investor Relations (IR) Meetings]

①	The CEO must recognize that IR activities are a managerial duty for KOSDAQ-listed companies and strive to voluntarily and continuously hold IR meetings to build trust with investors.
②	IR meetings regarding the company's management, business plans, and outlook should be held in consultation with the disclosure officer.
③	The disclosure officer or disclosure manager must disclose the date, location, and content of the IR meeting before the event and post related materials on the exchange's disclosure submission system before the meeting.
④	All executives and employees must ensure that undisclosed fair disclosure information is not revealed during the IR meeting.

Article 13-3 [Requests for Information]

①	When shareholders or stakeholders request information related to the company, the disclosure officer must review the legality of the request and decide whether to provide the information.
②	To decide whether to provide the information, the disclosure officer may seek opinions from the legal department or external legal experts on whether the requested information could affect investors' decisions or stock prices.
③	If the decision is made to provide the information under Paragraph 1, the provisions of Article 12, Paragraph 3, apply.

Article 14 [Return of Short-Term Trading Profits]

①	Obligation to Return Profits: Executives and employees defined under Article 172, Paragraph 1 of the Act and Article 194 of the Enforcement Decree of the Act must return any profits (hereinafter referred to as "Short-Term Trading Profits") obtained from buying specific securities (hereinafter referred to as "Specific Securities") and selling them within six months or from selling Specific Securities and buying them within six months.
②	Shareholder Requests: If a shareholder (including those owning non-stock equity securities or securities deposit certificates) requests the Company to demand the return of Short-Term Trading Profits under Paragraph 1, the Company must take necessary actions within two months from receiving the request.
③	Disclosure Requirements: If the Securities and Futures Commission notifies the Company of the occurrence of Short-Term Trading Profits under Paragraph 1, the Disclosure Officer must promptly disclose the following information on the Company’s website: 1. Position of the person required to return Short-Term Trading Profits 2. Amount of Short-Term Trading Profits 3. Date of notification from the Securities and Futures Commission regarding the occurrence of Short-Term Trading Profits 4. Plan for claiming the return of Short-Term Trading Profits 5. Information that shareholders can request the Company to claim the return of Short-Term Trading Profits from the person, and that if the Company fails to make the claim within two months of receiving the request, the shareholders may claim it on behalf of the Company.
④	Disclosure Period: The disclosure period under Paragraph 3 lasts for two years from the date of notification by the Securities and Futures Commission or until the date of receiving the Short-Term Trading Profits, whichever comes first.

Article 17 [Training]

①	Training Requirements: The Disclosure Officer and disclosure staff must complete training related to disclosure duties under Article 36 and Article 44, Paragraph 5 of the Disclosure Regulations, and the Disclosure Officer must inform relevant executives and employees of the training content.
②	Efforts by the CEO: The CEO must make sufficient efforts to provide training to executives and employees on matters related to Articles 14 through 16 and other regulations to prevent insider trading.

①	The disclosure manager must prepare the necessary content and documents and report them to the disclosure officer when a disclosure matter specified in Article 9 occurs.
②	The disclosure officer must review whether the content and documents comply with relevant regulations and report to the CEO before making the disclosure.

①	If rumors are circulating in the market, the disclosure officer must verify the factual accuracy and whether the rumors involve internal information through consultations with relevant departments.
②	If the rumors are found to be subject to disclosure obligations according to the Disclosure Regulations, the related information must be disclosed.