Internal Information Management Regulations

Chapter 1 General Provisions

Article 1 (Purpose)

The purpose of these regulations is to prescribe the policies and procedures necessary for designing, operating, evaluating, and reporting the Company's internal accounting control system for the preparation and disclosure of reliable accounting information, pursuant to Article 8 of the Act on External Audit of Stock Companies, Etc. (hereinafter referred to as the "Act"), Article 9 of the Enforcement Decree of the same Act (hereinafter referred to as the "Decree"), and Article 6 of the Regulations on External Audit and Accounting (hereinafter referred to as the "External Audit Regulations").

Article 2 (Scope of Application)

Matters concerning the Company's internal accounting control system shall be governed by these regulations, except as otherwise provided by laws and regulations, the Articles of Incorporation, or the Board of Directors' regulations.

Article 3 (Definitions)

The definitions of terms used in these regulations are as follows.

  • 1. The term "Internal Accounting Control System" refers to a part of the internal control system designed and operated to provide reasonable assurance as to whether the Company's financial statements have been prepared and disclosed reliably. It refers to a process continuously executed by all members of the organization, including the organization that manages and operates it under these regulations.
  • 2. The term "Internal Accounting Manager" refers to a person designated by the CEO as the person responsible for the management and operation of the internal accounting control system pursuant to Article 8, Paragraph 3 of the Act.

Chapter 2 Management of Accounting Information

Article 4 (General Principles of Accounting Information Processing)

The identification, measurement, classification, recording, and reporting of accounting information shall follow the accounting standards prescribed in Article 5(1) of the Act.

Article 5 (Identification, Measurement, Classification, Recording, and Reporting of Accounting Information)

① Matters related to accounting processing methods and accounting records—such as identification, measurement, classification, recording, and reporting of accounting information—shall comply with the general principles in Article 4 and meet the following requirements.

  • 1. Assets and liabilities recorded in the statement of financial position must actually exist as of the reporting date. Equity represents the residual interest after deducting all liabilities from assets.
  • 2. Assets shown in the financial statements are owned by the company, and liabilities are obligations the company must settle.
  • 3. Transactions and events are deemed to have occurred within the accounting period.
  • 4. Items such as assets, liabilities, equity, revenues, and expenses in financial statements shall be presented in appropriate amounts without omission, in accordance with the general principles in Article 4.
  • 5. Components of financial statements shall be classified, described, and disclosed in accordance with the general principles in Article 4.

② All accounting information of the company shall be recorded in journals (including computerized systems) together with supporting documents.

③ Accounting information prepared under the internal control system shall be periodically reported to the internal control manager.

Article 6 (Error Control, Correction, and Internal Verification of Accounting Information)

The company’s auditors shall verify, through evaluations under Articles 15 and 16, whether accounting information has been prepared in accordance with Articles 4 and 5, in order to prevent errors in the accounting process.

Article 6-2 (Correction of Accounting Errors and Follow-up Procedures)

If published financial statements must be corrected due to omissions or errors in accounting information, the following procedures shall be followed.

  • 1. Report to the internal control manager and CEO regarding the details, causes, and impact of the correction on financial statements and the internal control system.
  • 2. Revise the systems and ledgers used to record and store accounting information related to the correction.
  • 3. Maintain a history of the corrections made.
Article 7 (Management and Retention of Accounting Records)

① Accounting books shall consist of subsidiary ledgers and general ledgers, and financial statements shall be prepared based on them.

② Accounting books and financial statements shall be prepared electronically using a computerized accounting system, with access and modification restricted to authorized personnel, and records shall be retained.

③ The company shall not prepare accounting information or financial statements that violate the internal control system, nor instruct others to do so.

④ To prevent loss, alteration, or damage of accounting information and records, accounting systems used for recording and storage shall operate under the company’s IT General Controls.

⑤ Accounting books prepared under the internal control system shall be stored at designated locations for the retention period specified in Article 33 of the Commercial Act.

Chapter 3 Duties and Responsibilities of Officers and Employees

Article 8 (Division of Duties and Responsibilities)

The Company shall appropriately divide the duties of officers and employees related to the preparation and disclosure of accounting information and define each person's authority and responsibility.

Article 8-2 (Duties of the CEO)

The CEO shall perform the following duties.

  • 1. Responsibility for the management and operation of the Internal Accounting Control System and support for various necessary matters.
  • 2. Review and designation of candidates for the Internal Accounting Manager.
  • 3. Reporting the results of inspection on the operation status of the Internal Accounting Control System to the General Meeting of Shareholders, the Board of Directors, and the Auditor (Audit Committee) every business year.
  • 4. Providing materials and information related to the Internal Accounting Control System upon request from the Auditor and External Auditor.
  • 5. Providing necessary materials, information, and expenses when the Auditor investigates violations of accounting standards by the Company, unless there are special circumstances.
Article 8-2 (Duties of the Internal Accounting Manager)

The CEO shall perform the following duties.

  • 1. Overall management of the operation of the Internal Accounting Control System and support for various necessary matters.
  • 2. Inspection of the design and operation of the Internal Accounting Control System.
  • 3. Overall handling of audit responses from the External Auditor regarding the Internal Accounting Control System.
  • 4. Various duties related to the Internal Accounting Control System according to the instructions of the CEO.
  • 5. Reporting the results of inspection on the operation status of the Internal Accounting Control System as delegated by the CEO.
Article 8-4 (Duties of the Auditor)

The Auditor shall perform the following duties.

  • 1. Independent evaluation of the operation status of the Company's Internal Accounting Control System.
  • 2. Review of audit plans and results of the External Auditor regarding the Internal Accounting Control System.
  • 3. Review of reports related to violations of Internal Accounting Control Regulations.
  • 4. Reporting the evaluation results of the operation status of the Internal Accounting Control System to the Board of Directors every business year.
  • 5. Investigation of violations of accounting standards notified by the External Auditor, etc., and requesting correction.
  • 6. Requesting the appointment of experts when investigating violations of accounting standards.
  • 7. Notifying the External Auditor and the Securities and Futures Commission of the results of investigations into violations of accounting standards.
Article 8-5 (Duties of the Dedicated Internal Accounting Department)

The Dedicated Internal Accounting Department shall perform the following duties:

  • 1. Establishment of internal accounting control regulations and guidelines, and periodic updates.
  • 2. Selection of the scope for inspection of the operation status of the Internal Accounting Control System and risk assessment.
  • 3. Establishment and reporting of inspection plans for the operation status of the Internal Accounting Control System.
  • 4. Inspection of the operation status of the Internal Accounting Control System.
  • 5. Evaluation of deficiencies related to the Internal Accounting Control System and follow-up management.
  • 6. Change management of the Internal Accounting Control System.
Article 9 (Chief Executive Officer)

The Chief Executive Officer shall perform the following duties.

① The CEO is responsible for the management and operation of the Internal Accounting Control System and shall support all related matters.

② The CEO shall designate the Internal Accounting Manager in accordance with Article 10-2.

③ The CEO shall inspect and report on the operation status of the Internal Accounting Control System in accordance with Article 15. However, if the CEO deems it necessary, the reporting to the Board of Directors and the Auditor may be delegated to the Internal Accounting Manager.

④ In the event that the CEO intends to delegate the report to the Internal Accounting Manager pursuant to the proviso of Paragraph 3, the reasons for such delegation shall be submitted in writing to the Board of Directors and the Auditor prior to the report.

⑤ The CEO shall comply without delay if there is a request from the Auditor pursuant to Article 11, Paragraph 4 or a request from the External Auditor. However, if there are special circumstances, the request may be refused, in which case the reasons for the refusal shall be submitted in writing to the Auditor or the External Auditor.

Article 10 (Internal Accounting Manager)

The Internal Accounting Manager shall perform the following duties.

① The Internal Accounting Manager shall oversee the management and operation of the Internal Accounting Control System and support all related matters.

② The Internal Accounting Manager shall inspect the effectiveness of the design and operation of the Internal Accounting Control System.

③ The Internal Accounting Manager shall report the operation status of the Internal Accounting Control System to the Board of Directors and the Auditor pursuant to the proviso of Article 9, Paragraph 3.

Article 10-2 (Qualification Requirements and Appointment/Dismissal Procedures for the Internal Accounting Manager)

① The Internal Accounting Manager must satisfy all of the following requirements:

1. A full-time director.

2. Expertise in internal control and the Internal Accounting Control System.

② Notwithstanding Paragraph 1, if there is no person who satisfies the requirement of Item 1 of Paragraph 1, Item 1 shall be applied by regarding the person as 'the person who executes the duties of the relevant director.'

③ In the event that the CEO determines that the performance of duties related to the Internal Accounting Control System is impossible or inappropriate due to reasons such as personnel appointments, the CEO shall re-designate the Internal Accounting Manager.

④ The appointment and dismissal procedures for the Internal Accounting Manager shall follow the Company's 'Personnel Regulations'.

Article 11 (Auditor)

① The Auditor shall independently evaluate and report on the operating status of the Internal Accounting Control System in accordance with Article 16.

② In the event that the Auditor is notified of a violation of accounting standards by the External Auditor, the Auditor shall appoint an external expert to investigate the violation and request the CEO to take corrective action based on the results.

③ The Auditor shall immediately submit the results of the investigation under Paragraph 2 and the Company's corrective action results to the Securities and Futures Commission and the External Auditor.

④ When performing duties under Paragraphs 1 through 3, the Auditor may request the CEO in writing to provide necessary materials, information, and expenses.

⑤ If the Auditor discovers any fraudulent act or a material fact that violates laws or the Articles of Incorporation in relation to a director's performance of duties, the Auditor shall notify the External Auditor.

Article 12 (Education Planning, Performance Evaluation, etc.)

① The Company shall establish education plans and conduct necessary training for the CEO, the Internal Accounting Manager, the Auditor, and employees who prepare and disclose accounting information (hereinafter referred to as "CEO, etc.") to facilitate an understanding of the Internal Accounting Control System.

② The Company shall evaluate the performance of the education conducted under Paragraph 1 and reflect the results in the plan for the next business year.

③ The evaluation results under Paragraph 2 may be operated in connection with the compensation policy prescribed in Article 13, Paragraph 1.

Article 13 (Linkage between Auditor's Evaluation Results and Compensation)

① The Company shall reflect the Auditor's evaluation results under Article 16 in the personnel evaluation and compensation of the CEO, etc., and in the operation plan of the Internal Accounting Control System for the next business year.

② Performance compensation for the CEO, etc., under Paragraph 1 shall follow the Company's 'Personnel Regulations'.

Chapter 4 Design and Operation of Internal Accounting Control System

Article 14 (Design and Operation of Internal Accounting Control System)

The company shall establish the standards and procedures necessary for designing and operating the internal accounting control system.

Article 14-2 (Components of Internal Control System, etc.)

In designing and operating internal controls, the company shall comply with the five components and seventeen principles defined in the conceptual framework, and apply key considerations and methods appropriate to the company’s circumstances to achieve each principle.

Article 14-3 (Risk Assessment and Scope Selection)

① The company shall conduct risk assessments periodically in the first half of each year and continuously update them through a change management system.

② The risk assessment shall include not only risks affecting financial reporting but also potential fraud risks that may occur within the company.

③ Based on the results of the risk assessment, the company shall establish the scope and plan for evaluating the operation of the internal accounting control system, obtain approval from the internal accounting manager and CEO, and report to the audit (audit committee).

Article 14-4 (Change Management System)

① The company shall establish a change management system to maintain effective internal controls despite changes in processes, systems, and organizational structure.

② The internal accounting manager and the internal accounting department shall periodically review changes and perform design evaluations of modified internal controls.

  • 1. Major process changes and accounting-related changes
  • 2. Impact of changes on the overall internal accounting control system
  • 3. Impact of changes on individual control activities

Based on the results of ongoing monitoring, the company shall revise and update internal accounting control documents and control activities.

③ Major changes and design evaluation results shall be reported to the audit and the CEO.

Article 14-5 (Documentation)

① The documentation scope and contents of the internal accounting control system are as follows.

  • 1. Operational evaluation plan: matters related to risk assessment and planning of internal control evaluations
  • 2. Process flowcharts: documents describing business processes and accounting documents
  • 3. Technical documents: documents describing control activities and related matters
  • 4. Deficiency evaluation report: results of evaluating deficiencies identified through CEO review
  • 5. Improvement plan report: plans and results for addressing deficiencies
  • 6. Operational evaluation report: results of the CEO’s evaluation of the internal accounting control system
  • 7. Evaluation report: independent evaluation results of the audit regarding operational effectiveness

Chapter 5 Evaluation and Reporting of Internal Accounting Control System

Article 15 (CEO’s Evaluation of Operational Status and Reporting)

① The company shall conduct periodic risk assessments in the first half of each year and continuously update them through a change management system thereafter.

② The CEO shall, for each fiscal year, evaluate the effectiveness of the internal accounting control system and report the results to the shareholders’ meeting, the board of directors, and the audit (or audit committee).

③ When reporting the evaluation results to the board and the audit pursuant to Article 2, the CEO shall prepare a document (hereinafter referred to as the “Report on the Operational Status of Internal Accounting Control System”) and present it in person.

④ The standards and procedures necessary to carry out this chapter shall be established.

Article 15-2 (Establishment of Operational Evaluation Plan)

① The internal accounting manager shall, in order to evaluate the operational status, first update the risk assessment and change management system, and then establish a plan considering the following.

  • 1. Status of control activities subject to evaluation
  • 2. Key schedule including evaluation period and reporting timeline
  • 3. Improvement plans for significant deficiencies and material weaknesses identified in the previous period

② The operational evaluation plan, including evaluation scope, methods, and timing, shall be reported in writing to the CEO and the audit.

Article 15-3 (Execution of Operational Evaluation)

① Operational evaluation shall, in principle, be conducted once per year, though it may vary depending on the plan.

② The evaluation shall be performed in accordance with the following procedures, unless otherwise specified in the plan.

  • 1. Status of control activities subject to evaluation
  • 2. Key schedule including evaluation period and reporting timeline
  • 3. Improvement plans for significant deficiencies and material weaknesses identified in the previous period

③ Deficiencies identified from the evaluation results shall be compiled, discussed with relevant personnel, and finalized.

④ If deficiencies are confirmed, improvement measures shall be reviewed with relevant personnel and finalized.

⑤ Confirmed improvement plans for deficiencies shall be reflected in the next operational evaluation plan.

Article 15-4 (Evaluation of Deficiencies)

① All deficiencies identified through operational evaluation shall be compiled and assessed for severity based on deficiency classification criteria.

② In addition to deficiencies identified through operational evaluation, the evaluation shall also include deficiencies identified from the following sources.

  • 1. Deficiencies identified through the audit’s independent evaluation
  • 2. Deficiencies identified by external parties such as external auditors
  • 3. Deficiencies identified during audits or reviews of financial statements by external auditors
  • 4. Deficiencies related to errors or violations of accounting treatment identified in financial reporting
Article 15-5 (Reporting on Operational Status)

① The internal accounting manager shall review the results of the operational evaluation and report to the CEO the causes of identified deficiencies and improvement plans.

② The CEO shall prepare an operational status report based on the evaluation results and report it to the board of directors, the audit, and the shareholders’ meeting.

Article 16 (Audit’s Evaluation and Reporting on Operational Status)

① The audit shall evaluate the “Report on the Operational Status of Internal Accounting Control System” prepared under Article 15-3 and document the results (hereinafter referred to as the “Internal Accounting Control System Evaluation Report”), and report it to the board of directors for each fiscal year. If there are any corrective opinions regarding the management and operation of the system, such opinions shall be included in the report.

② The audit shall present the Internal Accounting Control System Evaluation Report to the board of directors at least one week prior to the regular shareholders’ meeting.

③ The standards and procedures necessary to implement this Article shall be established.

Article 16-2 (Audit’s Evaluation of Operational Status)

① For an independent evaluation of the internal accounting control system, the audit shall review and document the following.

  • 1. Appropriateness of risk assessment and evaluation planning considering significant changes during the period
  • 2. Independence and competence of evaluators, and appropriateness of evaluation methods (method, scope, timing)
  • 3. Reporting of all significant deficiencies and material weaknesses
  • 4. Handling results and reflection of internal reports related to the internal accounting control system
  • 5. Appropriateness of evaluation and remediation plans for deficiencies included in the operational status report, and review of implementation status
  • 6. Appropriateness of plans and results reflecting performance impacts due to violations of internal accounting regulations and deficiencies

② In addition, the following shall be considered in performing the above.

  • 1. Communication with external auditors
  • 2. Major issues identified previously
Article 16-3 (Audit’s Reporting of Operational Evaluation Results)

① The audit shall report the results of the operational evaluation to the board of directors in person at least one week prior to the regular shareholders’ meeting.

② The report to the board shall include the following and the Internal Accounting Control System Evaluation Report.

  • 1. Audit’s conclusion on the CEO’s evaluation of operational status
  • 2. Details of evaluation of significant deficiencies and the appropriateness of remediation measures
  • 3. Results of external auditors’ evaluation of the internal accounting control system
Article 17 (Retention of Evaluation Reports)

The audit shall retain the Internal Accounting Control System Evaluation Report at the head office for five (5) years.

Article 18 (Disclosure of Evaluation Results)

① The company shall attach to its annual business report documents (hereinafter referred to as the “Report on the Operational Status of Internal Accounting Control System”) containing the following.

  • 1. Matters concerning the internal accounting control regulations pursuant to Article 8, Paragraph 1, and the organization and personnel responsible for managing and operating them
  • 2. Matters concerning the audit’s review and the audit report pursuant to Article 8, Paragraph 6
  • 3. Report on the operational status of the internal accounting control system
  • 4. Internal accounting control system evaluation report

① The format of the Report on the Operational Status of Internal Accounting Control System attached to the business report under Paragraph 1 shall follow the form prescribed in Appendix 3 of the Enforcement Decree of the Act on External Audit of Stock Companies.

Chapter 6 Measures in Case of Violation of Regulations

Article 19 (Measures for Violation of Regulations, etc.)

For disciplinary actions against officers and employees who violate the internal accounting control regulations, including the following cases, the company’s HR regulations shall apply.

  • 1. When accounting information is prepared in violation of regulations
  • 2. When accounting information is falsified, altered, damaged, or destroyed
  • 3. When the internal accounting control system is designed, operated, or reported in violation of regulations
  • 4. When instructing others to commit any of the above acts
Article 20 (Operation of Internal Reporting System)

① The company shall operate an internal reporting (whistleblowing) system to prevent violations of internal accounting control regulations.

② The internal reporting system shall protect the identity of the whistleblower, and no disadvantageous treatment shall be given to the whistleblower, directly or indirectly, in connection with the report.

③ If the CEO or others instruct violations of the internal accounting control regulations, employees may refuse such instructions, and no disadvantageous treatment shall be imposed in relation thereto.

Chapter 7 Supplementary Provisions

Article 21 (Enactment and Amendment of Regulations)

① 이 규정의 제정 및 개정은 감사의 승인 및 이사회의 결의를 거쳐야 한다.

② 제1항에 불구하고 법령, 다른 규정 등의 변경 및 조직체계의 변경 등에 의한 단순한 자구수정 및 용어변경 등 경미한 내용은 이사회 및 감사 사후 보고로 갈음할 수 있다.

③ 감사와 이사회는 제정 및 개정의 사유를 문서(전자문서 포함)로 작성·관리하여야 한다.

Addendum

Article 1 (Effective Date)

These regulations shall come into effect on January 1, 2025.