Home > Privacy Statement
Article 1 (Purpose) This policy is to define the general management and proper disclosure of company’s inside information for quick/accurate announcement and prevention of executive/employee’s insider trading, in accordance with [Capital Market and Financial Investment Business Act] (“Law” hereafter) and various regulations.
Article 2 (Definition of Terms)
① “Inside information” in this policy refers to publication obligation matters in accordance with KOSDAQ Publication Regulations (“Publication regulations” hereafter) Vol. 1, and information regarding company’s management or state of property, which may affect investor’s judgment of investment. (Revised 2017.5.23)
② “Publication officer” in this policy refers to someone that can fulfill declaration tasks on behalf of the company.
Article 4 (Management of Inside Information)
① Executives/employees shall manage the company’s inside information, which are obtained on business, strictly and shall not leak inside information in or out of the company unless it is necessary for the business.
② C.E.O shall take necessary measures for inside information management, such as setting up a specific guideline on storage, delivery and disposal of inside information and relevant documents.
Article 5 (Chief Public Announcement Officer)
① C.E.O of the company must appoint a chief public announcement officer and report to the exchange without delay. Same applies when the public announcement officer is changed. (Revised 2017.5.23)
② Chief public announcement officer oversees tasks related to the establishment and operation of inside information management policy, and performs the following duties.
Public announcement execution
2. Inspection and evaluation of operation of inside information management policy
3. Review of inside information and decision of public announcement
4. Necessary measures for the operation of inside information management policy, including executives/employee education, etc.
5. Direction and supervision of department or executive/employee that is in charge of inside information or public announcement duty
6. Other duties that the C.E.O acknowledges as necessary for the operation of inside information management policy.
③ Chief public announcement officer has the following authority in performing the duties.
1. Right to demand and view documents and records related to inside information
2. Right to hear the necessary opinions from the executives/employees of the department that is related to accounting or auditing, and duties related to the generation of inside information
④ Chief public announcement officer may consult the executive that handles the relevant duty if necessary, and may seek expert help at company’s expense.
⑤ Chief public announcement officer shall report the operation status of inside information system to the C.E.O (or board of directors) regularly.
Article 6 (Public Announcement Officer)
① C.E.O of the company must appoint a public announcement officer and report to the exchange without delay. Same applies when the public announcement officer is changed. (Revised 2017.5.23)
② Public announcement officer receives orders from the chief public announcement officer regarding inside information management, and performs the following duties.
1. Collection and review of inside information, and reporting to chief public announcement officer
2. Duties necessary for the execution of public announcement
3. Confirmation of information necessary for the management of inside information, such as changes in public announcement-related laws, and reporting to chief public announcement officer
4. Other duties that the C.E.O or chief public announcement officer acknowledges as necessary
Article 7 (Concentration of Inside Information)
① C.E.O and managers of each department shall provide the information to the chief public announcement officer if any one of the following applies. (Revised 2017.5.23)
1. Inside information occurred or is expected to occur (Revised 2017.5.23)
2. If a reason to cancel or change the inside information that is already publicly announce occurred or is expected to occur (Revised 2017.5.23)
3. In cases where the chief public announcement officer’s request is present
② Chief public announcement officer and C.E.O must establish an efficient information delivery system within the company for a timely delivery of inside information in accordance with Clause 1, and may seek cooperation from chief public announcement officer in the approval process of duty related to public announcement if necessary. (Established 2017.5.23)
Article 7-2 (Management of Information Regarding the Largest Shareholder) In order to perform mandatory public announcement related to the largest shareholder and to perform duty related to inquiry notice requirements, Chief public announcement officer shall establish an information delivery system to explain the relevant fact fully to the largest shareholder and receive the relevant information in timely manner. [Article established 2017.5.23]
Article 7-3 (Concentration of Inside Information of Subsidiary Company)
① When an inside information related to the mandatory public announcement occurs in a subsidiary company or is expected to occur, company must advise the subsidiary company to notify the company’s chief public announcement officer or public announcement officer immediately.
② To manage inside information related to mandatory public announce in accordance with Clause 1 effectively, company must appoint an employee at the subsidiary company that handles information related to public announce, and must notify the chief public announcement officer of public announcement officer of the company immediately in case of appointment or change.
③ Company may request a submission of relevant data from the subsidiary company within the scope necessary in public announcement duty. (Annotation established 2017.5.23)
Article 8 (Provision of Inside Information Outside the Company)
① If an executive/employee needs to provide inside information inevitably to client/outside auditor/agent of company, or the party that is in an advice agreement (legal advice/business consultation) with the company, such information must be reported to the chief public announcement officer.
② In case of Clause 1, chief public announcement officer must take necessary actions, such as closing a confidentiality agreement regarding inside information.
③ In providing inside information according to Clause 1, if fair disclosure obligation occurs, it must be announced without delay (excluded when it applies to the application exception in Public Announcement Article 15). (Established 2017.5.23)
Article 9 (Types of public announcement) Company’s public announcements are classified as follows.
1. Report and public announcement of major management issues in accordance with Publication Regulations Vol. 1, Chapter 2, Clause 1
2. Inquiry disclosure in accordance with Publication Regulations Vol. 1, Chapter 2, Clause 2
3. Fair disclosure in accordance with Publication Regulations Vol. 1, Chapter 2, Clause 3
4. Voluntary Disclosure in accordance with Publication Regulations Vol. 1, Chapter 3
5. Submission of registration statement, etc. in accordance with Vol. 3 of the Law
6. Submission of business report, etc. in accordance with Article 159, 160, and 165 of the Law, and Publication Regulations Vol. 1, Chapter 2 Clause 4
7. Submission of Material Facts Report in accordance with Article 161 of the Law
8. Disclosure in accordance with other regulations
Article 10 (Execution of Public Announcement)
① If matters subject to public notification defined in Article 9 occurs, public announcement officer shall prepare necessary documents and report to chief public announcement officer.
② Chief public announcement officer shall review if the documents, etc. in Clause 1 violates any relevant regulations, report it to the C.E.O and make notice.
Article 10-2 (Prompt execution of notice) If the matter subject to public notification occurs in accordance with Article 9, Chief public announcement officer shall make every effort to disclose the relevant inside information even if it is before the dead of public announcement defined in Publication Regulations. [This article established 2017.5.23]
Article 11 (Post Management of Notification) If chief public announcement officer and public announcement officer intends to cancel or change the notice due to error or omission, they shall take measures to correct this without delay, such as correcting disclosure, in accordance with Article 30 of Publication Regulations. (Revised 2017.5.23)
Article 12 (Press coverage, etc.)
① If coverage request on the company is made from the press, etc., the C.E.O or the chief public announcement officer shall respond. If needed, the executive/employee of relevant department may be allowed to respond to the coverage.
② If company intends to distribute press release to the press, etc., it shall consult the chief public announcement officer. Chief public announcement officer must report the matter related to the distribution of press release to C.E.O if necessary.
③ If contents of press release to be released in accordance with Clause 2 corresponds to the subject of fair disclosure, Chief public announcement officer shall make the notice prior to the distribution of press release. (Established 2017.5.23)
Article 14 (Recovery of Short-swing Profits)
① If executives and employees defined by Article 172 Clause 1 of the Law and Article 194 of the Enforcement Ordinance of the Law profit by selling specific securities in Article 172 Clause 1 of the Law (“Specific securities” hereafter) within 6 months of purchase, or buying specific securities within 6 months of sales, such profit (“Short-swing profit” hereafter) must be returned to the company.
② If company’s shareholders (includes those in possession of equity securities or securities deposit receipt in addition to share. Same applies from here on) requested a claim return of short-swing profit from the person that earned short-swing profit in Clause 1, the company shall take necessary actions within 2 months from the demand.
③ When Securities & Futures Commission notified the company of occurrence of short-swing profit according to Clause 1, chief public announcement officer must announce the following on company’s internet homepage without delay.
1. Position of the person that needs to return short-swing profit
2. Amount of short-swing profit
3. Date when the notice of occurrence of short-swing profit was received from Securities & Futures Commission
4. Short-swing profit recovery claim plan
5. It means that the shareholders can have the company make the claim for short-swing profit from the person that gained such profit, and if the company does not make such claim within 2 months from the date of claim, such shareholder may make the claim on behalf of the company.
④ The announcement period in Clause 3 is 2 years from the date of notice from Securities & Futures Commission on the occurrence of short-swing profit, or the day short-swing profit was returned, whichever comes first.
Article 15 (Notice on Sales of Specific Share, Etc.) Executives and employees defined by Article 172 Clause 1 of the Law and Article 194 of the Enforcement Ordinance of the Law must notify the chief public announcement officer of any sales of specific securities or other transactions made.
Article 16 (Prohibition of Use of Undisclosed Important Information) Executives/employees shall not use undisclosed important information defined in Article 174 Clause 1 of the Law (including undisclosed important information of subsidiaries) for sales of specific securities or other transactions, or let others use such information.