HYOSUNG CHEMICAL

1. Purpose

The purpose of these Regulations is to establish matters necessary for disclosure-related tasks and procedures and the management of publicly disclosed information so as to ensure that all the Company's information is disclosed in an accurate, complete, and fair manner, and on time in accordance with applicable laws and regulations, and to prevent employees from engaging in unfair trading.

2. Scope of Application

Unless otherwise specified by laws, related regulations, or the Articles of Incorporation, these Regulations shall govern the performance of disclosure-related duties and the management of information disclosure.

3. Definition of Terms

• 3.1 The term "publicly disclosed information" refers to disclosed matters and information related thereto as defined in the Financial Investment Services and Capital Markets Act (hereinafter referred to as the "Act"), the Enforcement Decree of the same Act (hereinafter referred to as the "Decree"), the Financial Services Commission (hereinafter referred to as the "FSC")'s regulations on issuance and disclosure of securities (hereinafter referred to as the "Issuance and Disclosure Regulations"), and other applicable laws and regulations, such as the Korea Exchange (hereinafter referred to as the "Exchange")'s stock market disclosure regulations (hereinafter referred to as the “Disclosure Regulations”).
• 3.2 The term "publicly disclosed documents" refers to reports and briefing documents (including electronic documents) submitted for the disclosure of publicly disclosed information as well as documents attached thereto.
• 3.3 The term "disclosure control system" refers to a variety of business activities for managing publicly disclosed information in accordance with specific control procedures in related internal organizations.
• 3.4 The term “disclosure control organization” refers to the CEO, disclosure officer, disclosure department, and business departments associated with the creation of disclosure information that perform disclosure-related tasks, such as the creation, collection, review, preparation, and approval of disclosure documents in accordance with these Regulations.
• 3.5 The term “disclosure officer” refers to a person designated by the CEO to oversee the Company's disclosure-related affairs and registered with the Exchange in accordance with Article 88(1) of the Disclosure Regulations.
• 3.6 The term “disclosure department” refers to the department responsible for the Company's disclosure-related affairs in accordance with its business and organizational regulations.
• 3.7 The term "business department" refers to a department tasked with producing the Company's publicly disclosed information.
• 3.8 The term “regular disclosure” refers to the submission of business reports, semi-annual reports, and quarterly reports to the FSC or the Exchange regarding the Company's business and financial status and management performance in accordance with Articles 159, 160, and 165 of the Act; Articles 168 and 170 of the Decree; Articles 4-3 of the Issuance and Disclosure Regulations, and Article 21 of the Disclosure Regulations.
• 3.9 The term "ad hoc disclosure" refers to the reporting or disclosure of significant facts or decisions that influence investment decisions regarding the Company's management activities to the Exchange in accordance with Articles 7 through 8(2) of the Disclosure Regulations.
• 3.10 The term "fair disclosure" refers to disclosing information to the Exchange so that general investors are aware of the information at the same time (or before selectively providing it to a specific person) if the Company selectively provides information that is not subject to the disclosure obligation under applicable laws and regulations or information for which the Company is exempt from the disclosure obligation in accordance with Articles 15 and 16 of the Disclosure Regulations and the Fair Disclosure Operation Standards of the Exchange.
• 3.11 The term "inquiry disclosure" refers to the confirmation of the veracity of rumors and reports pertaining to the Company or the presence or absence of material information upon request from the Exchange in accordance with Article 12 of the Disclosure Regulations.
• 3.12 The term "self-disclosure" refers to disclosure to the Exchange in accordance with Article 28 of the Disclosure Regulations and Article 8 of the Detailed Enforcement Regulations of the Disclosure Regulations if the Company determines that the information may have a significant impact on the Company's management and property, and investors' investment decisions, or that it is necessary to disclose information that is not subject to the disclosure obligation, other than the matters subject to ad hoc disclosure in paragraph 3.9.
• 3.13 The term "issuance and disclosure and reporting of major issues" refers to the submission of related reports to the FSC regarding organizational changes in the Company, such as securities offerings, sales, merger, and split, or the acquisition and disposition of treasury stocks under applicable laws and regulations in accordance with Articles 119, 121 through 123, 130, and 161 of the Act; Articles 120 through 122, 137, and 171 of the Decree; and Articles 2-4, 2-6, 2-14, 2-17, 4-5, 5-8 through 5-10, and 5-15 of the Issuance and Disclosure Regulations.
• 3.14 The term "subsidiary" refers to a subordinate company in a controlling and subsidiary relationship, as defined by Article 1(2)2 of the Act on External Audit of Stock Companies.
• 3.15 Regarding the terms used in these Regulations, the terms used shall follow those used in applicable laws and regulations, unless otherwise specified in these Regulations.

4. CEO

The CEO shall be responsible for all tasks related to the disclosure control system.

5. Disclosure Officer

• 5.1 The disclosure officer shall be appointed by the CEO.
• 5.2 The disclosure officer shall be responsible for directing the design and implementation of the disclosure control system.
• 5.3 The disclosure officer can, if deemed necessary to fulfill his or her responsibilities, consult with relevant departments and consider the opinions of external experts.

6. Disclosure Department

• 6.1 The disclosure officer shall organize a disclosure department consisting of experts in disclosure-related affairs. Two members of the department shall be designated as disclosure managers in accordance with Article 88(2) of the Disclosure Regulations.
• 6.2 The disclosure department shall execute the following responsibilities as directed by the disclosure officer in relation to disclosure-related affairs.

• 6.2.1 Collection and review of a variety of information subject to disclosure
• 6.2.2 Preparation of documents subject to disclosure and implementation of disclosure
• 6.2.3 Review of necessary measures to comply with laws and regulations, such as regular checks on the enactment and amendment of disclosure-related laws and regulations, and reporting to the disclosure officer
• 6.2.4 Other matters deemed necessary by the disclosure officer

7. Business Department

• 7.1 In the event that disclosure takes place or is expected to take place, as well as in the event that a reason for cancellation or change of previously disclosed information has occurred or is expected to occur, each business department shall provide the disclosure department with pertinent information in a timely manner.
• 7.2 In the case of delivering the publicly disclosed information outlined in the preceding paragraph, all pertinent content, evidence, and references shall be provided to the disclosure department.

Section 1 Regular Disclosure

8. Regular Disclosure

• 8.1 The Company shall prepare regular disclosure documents and submit them to the FSC and the Exchange within the deadline.
• 8.2 Each business department shall complete the tasks assigned for the disclosure of regular disclosure matters and submit them to the disclosure department by the deadline established by the disclosure department.
• 8.3 The disclosure department shall compile the information received from each business department, prepare regular disclosure documents in accordance with the format and method specified in the applicable laws and regulations, and submit them to the disclosure officer.
• 8.4 The disclosure department shall obtain the approval of the disclosure officer and the CEO before implementing regular disclosure within the statutory deadline for submission.
• 8.5 In the case where errors or omissions are discovered as a result of inspecting the publicly disclosed contents, the disclosure department shall take immediate action, such as correcting the publicly disclosed contents.

Section 2 Ad Hoc Disclosure

9. Ad Hoc Disclosure

The Company shall prepare ad hoc disclosure documents and submit them to the Exchange within the deadline.

10. Business Department

• 10.1 In the event that ad hoc disclosure takes place or is expected to take place, as well as in the event that a reason for cancellation or change of information previously disclosed via ad hoc disclosure has occurred or is expected to occur, each business department shall provide the disclosure department with pertinent information in a timely manner.
• 10.2 When requested by the disclosure department to supplement the information in paragraph 10.1 or submit additional data, each business department shall respond immediately. However, if business departments determine that the matter requires extensive security or must be kept confidential, they may consult with the disclosure department.

11. Disclosure Department

• 11.1 When the disclosure department receives information about ad hoc disclosures from a business department, it shall immediately review whether the information is subject to disclosure and evaluate the information's accuracy and completeness. The disclosure department may, if necessary, request the relevant business department to supplement information or submit additional data.
• 11.2 If the information is subject to ad hoc disclosure as a result of the review described in the preceding paragraph, the disclosure department shall prepare the review contents and ad hoc disclosure documents for the relevant information, report the results to the disclosure officer, and disclose the relevant information according to the method of disclosure outlined in the applicable laws and regulations, with the approval of the disclosure officer. However, disclosure may take place without approval if obtaining approval from the disclosure officer is not possible, such as when the disclosure officer is absent; in such cases, the disclosure must be reported to the disclosure officer after it has been made.
• 11.3 The disclosure department shall review whether ad hoc disclosures fall under Article 11-2 of the Monopoly Regulation and Fair Trade Act and disclose the relevant matters after reviewing whether they fall under disclosure of large-scale internal transactions.

12. Disclosure Officer

The disclosure officer shall examine whether the reviewed contents and disclosure documents described in paragraph 11.2 have been prepared in accordance with applicable laws and regulations before approving the disclosure.

13. Inspection of Publicly Disclosed Contents

• 13.1 Business departments involved in ad hoc disclosures and the disclosure department shall immediately inspect the disclosure's appropriateness.
• 13.2 In the case where errors or omissions are discovered as a result of the inspection in the preceding paragraph, the disclosure department shall take action, such as correcting the publicly disclosed contents.

Section 3 Fair Disclosure

14. Fair Disclosure

The Company shall prepare fair disclosure documents and submit them to the Exchange within the deadline.

15. Prohibition of Indirect Disclosure of Information Subject to Fair Disclosure

The fair disclosure information provider (referring to the person specified in Article 15(2) of the Disclosure Regulations) shall not provide indirect fair disclosure information to the subject of fair disclosure information (referring to the person specified in Article 15(3) of the Disclosure Regulations) through various ratios and scales of increase or decrease prior to disclosure.

16. Precautions

• 16.1 In the case of fair disclosure, the disclosure manager and his or her contact information shall be indicated so that investors can easily inquire about the contents of the fair disclosure.
• 16.2 A summary of the fair disclosure and the website address shall be disclosed upon the Exchange's request, and both the summary and the original text shall be posted on the Company's website.

17. Mutatis Mutandis

Articles 10 through 13 shall apply mutatis mutandis regarding fair disclosure. In this case, "ad hoc disclosure" shall be regarded as "fair disclosure."

Section 4 Inquiry Disclosure

18. Inquiry Disclosure

The Company shall prepare inquiry disclosure documents and submit them to the Exchange within the deadline.

19. Disclosure Department

• 19.1 Where the disclosure department receives a request for inquiry disclosure from the Exchange, it shall immediately verify the facts and the presence or absence of material information, prepare disclosure documents, and respond to the inquiry disclosure with the approval of the disclosure officer.
• 19.2 The disclosure department may request a data submission or statement of opinion from each business department in order to confirm the existence or veracity of material information in the preceding paragraph; in this case, the respective business department shall respond accordingly. However, if the business department determines that the matter requires extensive security or must be kept confidential, it may consult with the disclosure department.
• 19.3 If the disclosure department discloses that it is in the process of making a decision in response to a request for inquiry disclosure (hereinafter referred to as "unconfirmed disclosure"), it shall obtain the approval of the disclosure officer after identifying the confirmed details or progress of the relevant matters for disclosure and execute re-disclosure within one month from the date of the unconfirmed disclosure. If it is determined that re-disclosure within one month is virtually impossible, the re-disclosure deadline shall be specified and the disclosure shall be made accordingly.

20. Mutatis Mutandis

Articles 12 and 13 shall apply mutatis mutandis regarding inquiry disclosure. In this case, "ad hoc disclosure" in Articles 12 and 13 shall be considered to be "inquiry disclosure," and "reviewed contents and disclosure documents" in Article 12(2) shall be considered to be "confirmed contents and disclosure documents" in Article 12(1).

Section 5 Self-disclosure

21. Self-disclosure

The Company may prepare and submit self-disclosure documents to the Exchange.

22. Determination of Self-disclosure Matters and Collection of Information

• 22.1 Where there is or is expected to be a cancellation or change of matters deemed necessary for self-disclosure or matters that have already been disclosed through self-disclosure, the disclosure department may request a business department to provide the necessary information or data.
• 22.2 If matters deemed necessary for self-disclosure or reasons for cancellation or change of details already disclosed through self-disclosure have occurred or are expected to occur, or if the disclosure department has requested the provision of necessary information or submission of data in accordance with the provisions of the preceding paragraph, the relevant business department shall immediately deliver relevant documented information or data to the disclosure department in accordance with the method specified in paragraph 7.2.
• 22.3 When requested by the disclosure department to supplement or submit additional data to the information or data described in the preceding paragraph, the relevant business department shall respond immediately. However, if the business department determines that the matter requires extensive security or must be kept confidential, it may consult with the disclosure department.

23. Mutatis Mutandis

Articles 11, 12 and 13 shall apply mutatis mutandis regarding self-disclosure. In this case, "ad hoc disclosure" in Articles 11, 12, and 13 shall be considered "self-disclosure," and "review whether the information is subject to disclosure" in paragraph 11.1 shall be considered "review of the necessity of disclosure." In paragraph 2 of the same Article, "if subject to disclosure" shall be considered "if disclosure is deemed necessary," and "if it is not subject to disclosure" shall be considered "if disclosure is deemed unnecessary.”

Section 6 Issuance and Disclosure and Reporting of Major Issues

24. Issuance and Disclosure and Reporting of Major Issues

The Company shall prepare and submit issuance and disclosure and major issue report documents to the FSC by the deadline.

25. Establishment of a Work Promotion Plan

In cases where issuance and disclosure and reporting of major issues reported under Article 161(1) subparagraphs 6 through 8 of the Act have occurred or are expected to occur, the disclosure department shall verify necessary disclosure matters and disclosure schedules, and establish issuance and disclosure and major issue reporting plans.

26. Mutatis Mutandis

Articles 10 through 13 shall apply mutatis mutandis to Article 161(1) subparagraphs 1 through 5 and 9 regarding the reporting of major issues. In this case, "ad hoc disclosure" and "ad hoc disclosure documents" shall be considered "reporting of major issues" and "major issue reporting documents," respectively.

27. Collection and Maintenance of Information

• 27.1 In order to ensure the accuracy, completeness, fairness, and timeliness of publicly disclosed information, each disclosure control organization shall collect, maintain, and manage the necessary information and supporting data from within and outside the Company.
• 27.2 The disclosure officer may provide the necessary work instructions so that employees can collect, maintain, manage, and utilize the information described in the preceding paragraph for related tasks.

28. Communication

In the course of carrying out disclosure-related affairs, the disclosure officer shall strive to establish an efficient information exchange and communication system between the disclosure control organizations and employees.

29. Disclosure Risk Management

The disclosure officer shall be responsible for ensuring that the disclosure risks outlined in the following subparagraphs, which may have a negative impact on the accuracy, completeness, fairness, and timeliness of publicly disclosed information, are continuously monitored and managed.

• 29.1 Errors in financial information: Disclosure risk due to discrepancies between actual financial status and disclosures caused by accounting errors or misunderstandings between managers
• 29.2 Inadequate descriptions in forms, and description errors: Disclosure risk due to omission or error in required forms related to disclosure caused by a lack of comprehension of description points, or typos
• 29.3 Uncertainty, insufficiency, and inaccuracy of disclosure contents: Disclosure risk due to the use of technical terms and abbreviations, inadequate explanation of related content, or discrepancies between actual occurrences and disclosure contents
• 29.4 Failure to comply with disclosure deadlines imposed by applicable laws and regulations: Disclosure risk in the event that disclosure deadlines are not met due to delays in information delivery or approval, or misinterpretation of disclosure deadlines
• 29.5 Omission, concealment, and reduction of disclosures: Disclosure risk due to omissions in disclosures due to misunderstanding of disclosure obligations or concealment or reduction of negative company information
• 29.6 Risk of disclosure of predictive information: Disclosure risk resulting from predictive information that is not based on reasonable grounds or hypotheses, intentional false statements, or omission of essential information
• 29.7 Disclosure of confidential information: Risk of disclosure when non-public information is leaked through an abnormal channel, such as when an employee selectively provides information to a specific person
• 29.8 Risk of modifications to the disclosure system: Disclosure risk that may arise as a result of changes in disclosure-related laws, government policies, the exchange market to which the Company belongs, and the managers or practices of relevant supervisory and market operating agencies
• 29.9 Change of disclosure managers: Disclosure risk that may arise as a result of the discontinuation of information succession as a result of a change of disclosure managers, and loss of continuity in fulfillment of disclosure obligations
• 29.10 Other disclosure risks that could have a negative impact on publicly disclosed information

30. Business Department

If a disclosure risk occurs or is likely to occur during the performance of disclosure-related tasks, each business department shall immediately notify the disclosure department and take the necessary measures to prevent the risk from occurring.

31. Disclosure Department

• 31.1 The disclosure department shall oversee the inspection and management of disclosure risks across the Company.
• 31.2 The disclosure department shall ensure that disclosure risk factors are continuously inspected and managed.
• 31.3 The disclosure department shall classify major disclosure risks that have a significant impact on the Company separately and ensure that they are managed appropriately.

Section 1 Routine Monitoring

32. Routine Monitoring

• 32.1 Business departments and the disclosure department shall conduct routine monitoring to determine if disclosure-related tasks are being performed in accordance with the disclosure control system, and take immediate corrective action if vulnerabilities are discovered.
• 32.2 During routine monitoring, various tasks such as document approval, requests for reference materials, interviews with employees regarding publicly disclosed information, and consultation with the accounting or audit department may take place.

Section 2 Inspection of Operations

33. Subjects and Timing

• 32.1 The disclosure officer shall evaluate the status of the disclosure control system's operations.
• 32.2 The operations shall be inspected after the end of each fiscal year and prior to the submission of annual business reports.

34. Procedure

• 34.1 The disclosure department shall be responsible for identifying the operation of each business department, inspecting the operation of the Company's disclosure control system, and reporting the results to the disclosure officer. In this case, the disclosure officer may seek advice from an auditor (Audit Committee), the internal audit team, and external experts.
• 34.2 Using the results provided by the disclosure department, the disclosure officer shall examine the operation of the Company's disclosure control system. 35. Methods and Considerations

35. Methods and Considerations

For the purpose of determining the operation of the disclosure control system, the disclosure officer may employ multiple parallel methods, such as interviews with individuals involved in the disclosure procedure, such as the generation and delivery of information; review of relevant documents; and consultation with external experts.

36. Use of Operation Inspection Outcomes

The disclosure officer shall take the necessary steps to address control vulnerabilities uncovered during an audit of the disclosure control system's operations.

37. General Principles

Employees of the Company shall be prohibited from using undisclosed information pertaining to the Company's businesses as stipulated in Article 174(1) of the Act (hereinafter referred to as "confidential information") for trading, engaging in other transactions involving specific securities, etc. as stipulated in Article 172(1) of the Act (hereinafter referred to as "specific securities"), of granting a third party to use the confidential information.

38. Rights Related to Confidential Information

• 38.1 Employees shall be prohibited from divulging the Company's confidential information. However, if confidential information must be shared with the counterparty to a transaction, a legal representative, or an external auditor in the course of work, the disclosure department shall be consulted in advance and only the minimum amount of information required may be shared.
• 38.2 Where an employee unintentionally discloses confidential information, he or she shall immediately notify the disclosure department of this fact.
• 38.3 The disclosure department shall report the incident to the disclosure officer and take appropriate measures, such as fair disclosure, after receiving the notification described in the preceding paragraph.

39. Confidential Information of Affiliates

Articles 37 through 38 shall apply mutatis mutandis regarding the prohibition of the use of confidential information of affiliates of the Company by employees.

40. Return of Short-term Gains

• 40.1 Employees falling under each of the following subparagraphs shall return profits to the Company in accordance with Article 172 of the Act if they sell specific securities within six months of acquiring them or repurchase securities within six months of selling them. 40.1.1 Employees engaged in the establishment, modification, promotion, or disclosure of matters subject to reporting of major issues under Article 3(13), as well as those engaged in other related duties
• 40.1.2 Employees engaged in finance, accounting, planning, and research and development
• 40.2 Where the disclosure department receives a request from shareholders (including owners of equity securities or depositary receipts other than stock certificates; hereinafter the same applies in this Article) for the return of profits from employees who have engaged in short-term trading, this shall be reported to the disclosure officer.
• 40.3 Within two months of receiving the request outlined in the preceding paragraph, the disclosure officer shall initiate the necessary procedures to receive the return of profits, including the filing of judicial claims against the employee.
• 40.4 The disclosure officer shall ensure that the following matters are disclosed on the Company's website without delay for two years from the date the Securities and Futures Commission (hereinafter referred to as the "SFC") notifies the Company of short-term gains. However, this shall not apply when short-term gains are returned.

• 40.4.1 Position of individuals who must return gains from short-term trading
• 40.4.2 Gains from short-term trading (referring to the sum of the gains of each employee or key shareholder)
• 40.4.3 The date on which the SFC was informed of short-term gains
• 40.4.4 The pertinent corporation's plan for claiming the return of short-term profits
• 40.4.5 Shareholders of the pertinent corporation (including owners of equity securities or depositary receipts other than stock certificates; hereinafter the same applies in this subparagraph) may request the corporation to demand the return of short-term profits from the individual who earned them. This means that the shareholder may file the claim on behalf of the corporation if the corporation fails to do so within two months of receiving the request.

Section 1 Contact with the Media, such as Press Release Distribution

41. Press Release Distribution

• 41.1 In principle, the public relations department shall be responsible for the distribution of press releases.
• 41.2 If a business department intends to distribute a press release to mass media such as the press, the public relations department shall be notified in advance. In the case of a press release pertaining to disclosure, the public relations department shall distribute it after consulting with the disclosure department.
• 41.3 Where information transmitted through a press release is subject to the fair disclosure requirements of Article 14, the disclosure department shall prepare fair disclosure documents, obtain approval from the disclosure officer, and disclose the information in accordance with Articles 16 and 17.

42. Soliciting Opinions

The disclosure department may, if necessary, solicit the opinions of employees with professional insight, as well as external experts, regarding press releases.

43. Inspection of Press Release Contents

The business department that created the press release and the public relations department shall conduct an inspection of the reported contents after the press release has been distributed, and if false information is reported, the disclosure department shall be notified to take appropriate action.

44. Press Coverage

• 44.1 In principle, the public relations department shall be responsible for the Company's media coverage and related duties.
• 44.2 If deemed necessary, the public relations department shall respond to a media interview request after consulting with the disclosure department.
• 44.3 If false information is reported in the media such as by the press, the public relations department shall notify the disclosure department and take appropriate action.

Section 2 Market Rumors, etc.

45. Market Rumors

• 45.1 The disclosure department shall determine if the content of market rumors corresponds to confidential information by inquiring of business departments, and if they do, it shall take the appropriate steps, such as disclosure.
• 45.2 Where it is determined that a matter may have a negative impact on the Company's interests, the disclosure department shall establish and implement appropriate countermeasures, even if the contents of market rumors do not correspond to confidential information.

46. Requests for Information

• 46.1 Where shareholders and stakeholders request disclosure of company-related information, the disclosure officer shall evaluate the legitimacy of the request and decide whether to provide the requested information.
• 46.2 In the case of disclosing information in accordance with the decision made in the preceding paragraph, the disclosure officer may consult with the legal department or external legal experts to determine if the disclosed information can influence investment decisions and stock prices. Information subject to fair disclosure or that influences investment decisions and stock prices shall be disclosed to the public at the same time (or before) it is provided to the individual requesting it.

47. Company Briefings

In the event of a company briefing, the relevant business department shall notify the disclosure department in advance of the date, location, topic, and other necessary details of the company briefing, and the disclosure department shall make a public announcement prior to holding the briefing.

48. Provision of Information through the Website and Other Means

When each business department intends to provide company-related information via the website and other means, it shall first consult with the disclosure department.

49. Training

• 49.1 The disclosure officer shall develop and implement training programs to ensure that all employees of the Company have a thorough understanding of the disclosure control system and can perform all related tasks effectively. In particular, the disclosure department shall ensure the completion of professional education or training.
• 49.2 The disclosure department shall identify the schedule and other information for mandatory training conducted by the Exchange or the Korea Listed Companies Association, ensure that the training is completed, and take the necessary steps to ensure that the contents of the training are disseminated to relevant employees.

50. Subsidiaries' Notification of Publicly Disclosed Information to the Company

• 50.1 Where information has been or is expected to publicly disclosed, the Company shall require its subsidiaries to immediately notify the disclosure department of the Company of the contents.
• 50.2 The Company shall have its subsidiaries appoint a disclosure manager, and the Company shall be notified immediately of any designation or change of a disclosure manager.
• 50.3 The Company may request its subsidiaries to submit relevant information within the scope required for disclosure. If it is unable to obtain necessary data or if it is necessary to verify the contents of the data submitted by a subsidiary, the Company may investigate the business and property status of the subsidiary.

51. Penal Provisions

The Company may take action against employees who have caused significant losses to the Company by violating these Regulations, in accordance with the relevant regulations.