CHAPTER II DISCLOSURE CONTROL ORGANIZATION

Article 4 Representative Director

Article 5 Disclosure Officer

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.

- Collect and review various disclosure information.
- Prepare disclosure documents and implement disclosures.
- Review actions required for compliance, such as constant monitoring of changes in laws and regulations related to disclosure, and report results to disclosure Officer.
- Identify, inspect, evaluate and manage risks associated with disclosure throughout the company.
- 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 if:

- Any matter subject to disclosure under laws and regulations related to disclosure occurs or is expected to occur.
- It is uncertain whether to disclose any matter that would materially affect the Company’s business.
- Any reason for canceling or changing a disclosed matter occurs or is expected to occur.
- Requested by Disclosure Officer or the head of the Disclosure Department.

CHAPTER III ACTIVITIES AND OPERATION OF DISCLOSURE CONTROL

Article 8 Regular Disclosure

The Company shall prepare quarterly disclosure documents and file them with 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 and disclosure schedule, etc., in accordance with the disclosure business plan distributed by the head of 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 Disclosure Department.
(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 a disclosure business plan including activities assigned to each business department, and deliver it in writing to each business department.
(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 relevant laws and regulations, and submit it to Disclosure Officer by the due date as specified in the 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 relevant 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 for whether it has been prepared properly in accordance with relevant laws and regulations as well as the 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 and approve it, and certify it as required by relevant laws and regulations.

Article 13 Ex-post Inspection of Disclosed Information

(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.

Article 14 Timely Disclosure

The Company shall prepare Timely Disclosure documents and file them with the KRX by the applicable due date.

Article 15 Business Department

(1) Where any matter requiring timely 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.
(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 timely disclosure, etc., from a business department, it shall immediately review the information for 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 timely disclosure, the head of the Disclosure Department shall prepare a review report and timely disclosure documents for the information and submit to Disclosure Officer and obtain approval from Disclosure Officer and make disclosure in accordance with the method as prescribed in the relevant 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 result of the review under Paragraph (1) shows 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.
(4) The head of the Disclosure Department shall review whether the matter subject to timely disclosure falls under “disclosure of large-scale internal trading” prescribed in Article 11-2 of the Monopoly Regulation and Fair Act before making disclosure.

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 relevant laws and regulations, and decide whether to approve disclosure.
(2) The Disclosure Officer shall report material matters related to timely disclosure to the Representative Director.

Article 18 Ex-post Examination of Disclosure Contents

Provisions under Article 13 shall also apply to timely disclosure with any necessary modifications, with “regular disclosure document” substituted by “timely disclosure document.”

Article 19 Fair Disclosure

The Company shall prepare fair disclosure documents and file them with the KRX by the applicable due date.

Article 20 Fair Disclosure Information Provider and Recipient

(1) Fair disclosure information provider refers to any of the following persons.

- The Company and its representative.
- The Company’s directors and officers (directors, auditors or equivalent)
- The Company’s employees with access to FD information

- Legitimate investment traders, investment brokers, investment firms, collective investors, investment advisers and discretionary investment firms and their directors/officers and employees and their delegated or affiliated persons.
- Professional investors (other than specified in Subparagraph 1) and their directors/officers and employees.
- Foreign professional investors and their directors/officers and employees who perform the same or similar activities to those of the persons as specified in Subparagraphs 1 and 2.
- The media, including broadcasting firms under the Broadcasting Act and newspapers and news agencies under the Act on the Guarantee of the Freedom and Function of the Press, and their directors/officers and employees.
- Securities information site operators using information and communications networks under the Act on Promotion of Information and Communications Network Utilization and Information Protection and their directors/officers and employees.
- Securities owners who are expected to trade the Company’s securities using information subject to fair disclosure.
- A person designated by the KRX.

Article 21 Ban 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 22 Application with Necessary Modifications

Provisions under Articles 13 and 15 to 17 shall also apply to fair disclosure with any necessary modifications, with “regular disclosure documents” under Article 13 substituted by “fair disclosure documents” and “timely disclosure” under Articles 15 to 17 substituted by “fair disclosure.”

Article 23 Inquired Disclosure

The Company shall prepare inquired disclosure documents and file them with the KRX by the applicable due date.

Article 24 Disclosure Department

(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, and prepare disclosure documents accordingly, obtain approval from the Disclosure Officer and make inquired disclosure.
(2) To check facts and essential 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, in which case, the business department shall respond to such request. When 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 Modifications

Provisions under Article 13 and Article 17, and proviso of Article 16(2) shall also apply to inquired disclosure with necessary modifications, with “regular disclosure” under Article 13 substituted by “inquired disclosure”, “timely disclosure” under Articles 16 and 17 substituted by “inquired disclosure”, and “review details and disclosure documents under Paragraphs (2) and (3)” substituted by “checked details and disclosure documents under Paragraph (1).”

Article 26 Voluntary Disclosure

The Company may prepare voluntary disclosure documents and file them with the KRX by the applicable due date.

Article 27 Judgment of Whether or Not the Matter Requires Voluntary Disclosure and Collection of Information

(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 requires voluntary disclosure or any reason for canceling or changing a 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 requires 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 Modifications

Provisions under Articles 13, 16 and 17 shall also apply to voluntary disclosure with necessary modifications, with “regular disclosure” under Article 13 substituted by “voluntary disclosure”, “review the information for whether it is subject to disclosure” under Article 16(1) substituted by “review the information for whether it requires disclosure” and “the matter is subject to timely disclosure” under Article 16(2) substituted by “When the matter is determined to be subject for disclosure.”

Article 29 Issuance Disclosure and Essential Information Reporting

The Company shall prepare issuance disclosure and essential information reporting documents and file them with 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 Article 161(1)6 to 8 of the Act occurs or is expected to occur, the head of the Disclosure Department shall check matters to be disclosed and disclosure schedule, etc., and establish a business plan for issuance disclosure and essential information reporting, obtain approval from the Disclosure Officer, and deliver it in documents to each business department.

Article 31 Application with Necessary Modifications

(1) Provisions under Article 9(3), Article 10(2) to (3), and Articles 11 to 13 shall also apply to issuance disclosure and essential information reporting under the preceding article with necessary modifications, with the “disclosure business plan” under Article 10(3) 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 substituted by “issuance disclosure and essential information reporting documents.”
(2) For essential information reporting under Article 161(1)1 to 5 and 9, provisions under Articles 15 to 18 shall apply with necessary modifications, with “timely disclosure” and “timely disclosure documents” substituted by “essential information reporting” and “essential information reporting documents.”

CHAPTER IV CONTROL OF DISCLOSURE RISK

Article 32 Control of Disclosure Risk

The Representative Director and the Disclosure Officer should 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.

- Financial information errors: Disclosure risk from disparity between actual financial condition and disclosed information caused by accounting errors or miscommunications between personnel. - 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 and typos, etc. - Unclearness, insufficiency and inaccuracy of disclosed information: Disclosure risk from use of jargon and abbreviations the general public cannot understand, insufficient explanation of relevant information, and disparity between actual occurrence and disclosed information, etc. - Failing to meet disclosure deadline as prescribed in relevant laws and regulations: Disclosure risk from failing to meet disclosure deadline due to delay in delivering information, delay in approval, and misunderstanding of disclosure deadline, etc. - 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. - Risk from disclosing predicted information: Disclosure risk from information predicted not based on rational grounds or assumptions or intentional false entries or omission of material information - Leakage of non-public information: Disclosure risk from leakage of non-public information through an unusual route, such as a director/officer or employee selectively providing such information to a certain person. - Risk from changes in the disclosure system: Disclosure risk from changes in laws and regulations relating to disclosure, changes in the exchange market on which the Company is listed, and changes in the personnel or activities of related supervisory authorities or market operation agencies. - Change in disclosure personnel: Disclosure risk from failure to transfer information or continue to fulfill disclosure obligations due to change in disclosure personnel. - Other disclosure risks that would negatively affect disclosure information.

Article 33 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 34 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 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 inspection as needed.

CHAPTER V. MONITORING

Article 35 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.

Article 36 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. However, such inspection and evaluation may also be conducted during the business year if the Representative Director recognizes it necessary to do so.

Article 37 Procedures

(1) The head of each business department and the head of the Disclosure Department shall submit a report on the operation status for each department 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, internal audit team and 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 38 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 with those involved in disclosure procedures, such as creating and forwarding information, reviewing related documents, and hearing opinions of external experts.
(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.

- Whether there has occurred any change that affected the function of the disclosure control system after the previous inspection and evaluation. - Whether the disclosure control system designed and operated by the Company contributes to producing continuous and accurate information and reducing disclosure risks. - Whether there is any illegal or defective part in the Company’s disclosure control system. - Whether there are sufficient procedures to check the accuracy of financial and non-financial information. - Whether prior review and ex-post inspection of the Company’s disclosed information are conducted sufficiently. - Whether those involved in the Company’s disclosure control process are all aware of their responsibilities. - Whether evaluation and control of previous disclosure risks and material disclosure risks are conducted properly. - Whether previous risks have been avoided through the existing disclosure control system.

Article 39 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 ex-post inspection for whether the action under the preceding paragraph is being implemented.

CHAPTER VI PROHIBITION ON UNFAIR TRADING BY DIRECTORS/OFFICERS AND EMPLOYEES

Article 40 General Principles

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

Article 41 Trading of Specific Securities, Etc. by Directors/Officers and Employees

(1) When a director/officer or 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 Disclosure Officer or the head of the Disclosure Department in advance.
(2) Upon receiving such notification under the preceding paragraph, the Disclosure Officer or the head of the Disclosure Department may prohibit such trading or other transactions if they could be considered as a transaction using essential non-public information. In this case, the director/officer or employee in question shall follow such prohibition.
(3) When a director/officer or 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 Disclosure Officer or the head of the Disclosure Department within 10 days after end of the quarter in which the transaction was made.

Article 42 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. Documents containing essential non-public information shall be kept in a secure place only authorized directors/officers and employees can access.

- Directors/officers and employees shall not discuss essential non-public information in any place where others can hear their conversation, such as elevators and corridors.
- 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.
- A director/officer or employee shall keep essential non-public information in their possession secure both inside and outside the Company.
- Electronic transmission of documents related to essential non-public information through fax, computer communications, etc., shall only be conducted with security guaranteed.
- 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.
- Extra copies of a document containing essential non-public information shall be destroyed thoroughly using a method such as shredding.

Article 43 Essential Non-public Information of Subsidiaries

Provisions under Articles 40 to 42 shall also apply to prohibition on use of essential non-public information of the Company’s subsidiaries by a director/officer or employee with any necessary modifications.

Article 44 Return of Short-swing Profits

(1) When any director/officer or 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.

- 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
- Employees involved in activities related to finance, accounting, planning and R&D

- The position of the person who is obliged to return the short-swing profits.
- The amount of the short-swing profits (referring to the sum of profits by director/officer, employee or major shareholder).
- The date on which the notice of short-swing profits was received from the SFC.
- The relevant corporation’s plan for filing a claim for return of short-swing profits.
- 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 VII OTHER DISCLOSURE CONTROLS

Article 45 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 and obtain approval of the Disclosure Officer and make fair disclosure in accordance with Articles 21 and 22.

Article 46 Hearing Opinions

If necessary, the Disclosure Officer may hear opinions from directors/officers and employees or external experts who have professional knowledge on the information to be released through a press release.

Article 47 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 instructed by the Disclosure Officer.

Article 48 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. If not possible, however, the Disclosure Officer may designate the person who will respond to such coverage, etc.

- Representative Director
- Disclosure Officer (including IR director/officer)
- Financial director/officer

Article 49 Market Rumors

(1) In principle, the Company should 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 50 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, and whether the information is subject to fair disclosure or would affect an investor’s 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 51 IR Presentations

(1) When an 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 an Q&A session, etc., the head of the Disclosure Department shall take necessary action to ensure that information is disclosed to the general public without delay.

Article 52 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 check the compliance of the information with relevant laws and regulations.
(2) Provisions under Article 45(2), Article 46 and Article 47 shall also apply to this article with necessary modifications, with “press release” and “information to be released through a press release” substituted by “information provided through website, email, etc.”

CHAPTER VIII SUPPLEMENTARY RULES

Article 53 Education

(1) The Disclosure Officer shall establish and execute education plan about the disclosure control system to ensure all the Company’s directors/officers and employees are fully aware of 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 and complete such education and take necessary action to ensure the content of the education is disseminated to relevant directors/officers and employees.

Article 54 Penalty

The Company may impose a penalty or punishment on any director/officer or employee who violates this Policy in accordance with the Company’s relevant policy.

Article 55 Establishment and Repeal of Policy

This Policy shall be established or repealed by the Representative Director.

Article 56 Effective Date

This Policy shall take effect on September 1, 2009.