덕산넵코어스 DS Navcours

IR

Shareholder Information

Disclosure Information: Check DS Navcours’ disclosure information.

Disclosures: Check DS Navcours’ Internal Information Management Regulations.

Internal Information Management Regulations

Chapter 1 General Provisions

Article 1 (Purpose): The purpose of these Regulations is to set forth matters related to the comprehensive management and adequate disclosure of the Company’s inside information to ensure prompt and accurate disclosure and prevent inside trading by executives and employees in accordance with the Financial Investment Services and Capital Markets Act (hereinafter referred to as the “Act”) and other relevant laws and regulations.

Article 2 (Definitions of Terms)

① “Inside information” refers to matters subject to disclosure requirements under Part 1 of the KOSDAQ Market Disclosure Regulations (hereinafter referred to as the “Disclosure Regulations”) of the Korea Exchange (hereinafter referred to as the “Exchange”), as well as other matters related to the Company’s management or financial status that may influence investors’ investment decisions.
② “Chief Disclosure Officer” refers to a person authorized to perform reporting duties on behalf of the Company pursuant to Article 2 (4) of the Disclosure Regulations.
③ “Executives” refers to directors (including those falling under any of the subparagraphs of Article 401-2 (1) of the Commercial Act) and auditors.
④ Any terms not defined in Paragraphs 1 through 3 shall be interpreted in accordance with their definitions under relevant laws and regulations.

Article 3 (Scope of Application): Matters concerning disclosure, inside trading, and management of inside information shall be governed by these regulations, except as otherwise prescribed by relevant laws and regulations or the Articles of Incorporation.

Chapter 2 Management of Inside Information

Article 4 (Management of Inside Information)

① Executives and employees shall strictly manage inside information of the Company learned in the course of performing their job duties and shall not disclose such information within or outside the Company, except when necessary for business purposes.
② The CEO shall take necessary measures for the management of inside information, such as establishing specific standards for the storage, transmission, and destruction of inside information and related documents.

Article 5 (Chief Disclosure Officer)

① The CEO shall appoint a Chief Disclosure Officer and report the appointment to the Exchange without delay. The same shall apply when the Chief Disclosure Officer is changed.
② The Chief Disclosure Officer shall oversee the establishment and operation of the inside information management system and perform the following tasks:
- 1. Execution of disclosures
- 2. Inspection and evaluation of the operation of the inside information management system
- 3. Review of inside information and decision on whether to disclose it
- 4. Measures necessary for the operation of the inside information management system, such as training of executives and employees
- 5. Direction and supervision of departments, executives, and employees responsible for the management or disclosure of inside information
- 6. Other tasks deemed necessary by the CEO for the operation of the inside information management system
③ The Chief Disclosure Officer has the following authority in performing his/her duties:
- 1. The authority to request the submission of various documents and records related to inside information and to review them
- 2. The authority to hear opinions from executives and employees of departments in charge of accounting or auditing, or other departments in charge of tasks related to the creation of inside information
④ The Chief Disclosure Officer may consult with executives in charge of related tasks when necessary in performing his/her duties and seek the assistance of experts at the Company’s expense.
⑤ The Chief Disclosure Officer shall regularly report the status of the inside information management system to the CEO (or the Board of Directors).

Article 6 (Disclosure Personnel)

① The CEO shall appoint disclosure personnel and report the appointment to the Exchange without delay. The same shall apply when any of the disclosure personnel is changed.
② The disclosure personnel shall, under the direction of the disclosure personnel, perform the following tasks related to inside information management:
- 1. Collection and review of inside information and reporting to the Chief Disclosure Officer
- 2. Tasks necessary for the execution of disclosures
- 3. Confirmation of matters necessary for the management of inside information, such as changes in disclosure-related laws and regulations, and reporting to the Chief Disclosure Officer
- 4. Other matters deemed necessary by the CEO or the Chief Disclosure Officer

Article 7 (Concentration of Inside Information)

① Executives and department heads shall promptly provide relevant information to the Chief Disclosure Officer in any of the following cases:
- 1. When inside information is generated or expected to be generated
- 2. When a reason to cancel or change previously disclosed inside information arises or is expected to occur
- 3. When such request is made by the Chief Disclosure Officer
② The Chief Disclosure Officer and the CEO must establish an efficient information transmission system within the Company to ensure the timely provision of inside information pursuant to Paragraph (1). If necessary, the Chief Disclosure Officer’s cooperation in the approval process may be sought for matters related to disclosure obligations.

Article 7-2 (Management of Information Related to the Largest Shareholder): In order to ensure the smooth handling of disclosure obligations and inquiry requests related to the largest shareholder, the Chief Disclosure Officer shall establish an information transmission system so that relevant facts can be sufficiently explained to the largest shareholder and that relevant information can be delivered in a timely manner.

Article 7-3 (Concentration of Inside Information of Subsidiaries)

① If inside information related to disclosure obligations is generated or expected to be generated in a subsidiary, the Company shall require the subsidiary to immediately notify the Company’s Chief Disclosure Officer or disclosure personnel of the details.
② To efficiently manage inside information related to disclosure obligations under Paragraph (1), the Company shall appoint a person to manage disclosure-related information at each subsidiary. Any such designation or change must be immediately notified to the Company’s Chief Disclosure Officer or disclosure personnel of the details.
③ The Company may request the submission of relevant materials from its subsidiaries to the extent necessary for disclosure tasks.

Article 8 (Provision of Inside Information to External Parties)

① If an executive or employee is required to provide inside information to an external party, such as the Company’s business counterparties, external auditors, agents, and those with whom the Company has entered into a legal or management consulting agreement, for business reasons, he/she shall report the matter to the Chief Disclosure Officer.
② In cases described in Paragraph (1), the Chief Disclosure Officer shall take necessary measures, such as concluding a confidentiality agreement regarding the relevant inside information.
③ If the disclosure of inside information under Paragraph (1) results in the obligation for fair disclosure, the information must be disclosed without delay (except in cases falling under the exceptions in Article 15 of the Disclosure Regulations).

Chapter 3 Disclosure of Inside Information

Article 9 (Types of Disclosure)

The Company’s disclosures are categorized as follows:

1. Reporting and disclosure of major business matters under Part 1, Chapter 2, Section 1 of the Disclosure Regulations
2. Inquired disclosure under Part 1, Chapter 2, Section 2 of the Disclosure Regulations
3. Fair disclosure under Part 1, Chapter 2, Section 3 of the Disclosure Regulations
4. Voluntary disclosure under Part 1, Chapter 3 of the Disclosure Regulations
5. Submission of securities registration statements, etc. under Part 3, Chapter 1 of the Act
6. Submission of business reports, etc. under Articles 159, 160, and 165 of the Act and Part 1, Chapter 2, Section 4 of the Disclosure Regulations
7. Submission of reports on major matters under Article 161 of the Act
8. Disclosures under other laws and regulations

Article 9-2 (Confirmation of Subject Matter of Disclosure): In determining whether disclosure obligations, including fair disclosure, are applicable pursuant to these Regulations, care shall be taken to include matters which may have a material impact on stock prices or investment decisions, as specified in Article 6 (1) 4 of the Disclosure Regulations.

Article 10 (Execution of Disclosure)

① If a matter requiring disclosure under Article 9 arises, the disclosure personnel shall document the necessary information, prepare the necessary documents, etc., and report the matter to the Chief Disclosure Officer.
② The disclosure personnel shall review whether the contents and documents specified in Paragraph (1) comply with relevant laws and regulations, report it to the CEO, and then make the disclosure.

Article 10-2 (Prompt Execution of Disclosure): If a matter requiring disclosure under Article 9 arises, the Chief Disclosure Officer shall make every effort to ensure that the relevant inside information is disclosed in a timely manner, even before the disclosure deadline set forth in the Disclosure Regulations.

Article 11 (Post-Disclosure Actions): If the Chief Disclosure Officer or the disclosure personnel discovers that any disclosure contains an error or omission, or if there is a need to cancel or modify the disclosed information, they shall, without delay, take corrective measures such as issuing a correction disclosure pursuant to Article 30 of the Disclosure Regulations.

Article 12 (Press Coverage, etc.)

① In principle, media inquiries about the company should be answered by the CEO or the Chief Disclosure Officer. If necessary, executives or employees from the relevant departments may respond to the inquiries.
② If a Company wishes to distribute a press release to media outlets, etc., it must consult with the Chief Disclosure Officer. The Chie Disclosure Officer must report to the CEO on any matters related to the distribution of the press release, if necessary.
③ If the content of a press release to be distributed pursuant to Paragraph 2 is subject to fair disclosure, the Chief Disclosure Officer must disclose the information prior to distribution.
④ If an executive or employee becomes aware of media reports that contain false information, he/she must report this to the Chief Disclosure Officer. The Chief Disclosure Officer must then report the matter to the CEO and take necessary action.

Article 12-2 (Verification of Press Release Content): The Chief Disclosure Officer, disclosure personnel, and departments where inside information is generated must routinely monitor media reports related to the company and take action to correct any discrepancies between the media content and the facts.

Article 13 (Investor Relations Meetings)

① Recognizing that investor relations (IR) activities are a management responsibility of KOSDAQ-listed companies, The CEO must strive to build trust with investors by voluntarily and continuously hosting IR meetings.
② IR meetings regarding the Company’s management, business plans, and outlook must be held in consultation with the Chief Disclosure Officer.
③ The Chief Disclosure Officer or disclosure personnel must publicly announce the date, location, and content of the IR meeting at least one day prior to the meeting and upload related materials on the Exchange’s disclosure submission system before the meeting.
④ All executives and employees of the Company must exercise caution to ensure that any information subject to fair disclosure that has not been previously disclosed is not revealed during the IR meeting.

Article 13-2 (Rumors)

① The Chief Disclosure Officer must consult with the relevant business departments to verify the factual accuracy of any rumors circulating in the market and determine whether the rumors contain inside information.
② If the rumors identified in Paragraph (1) fall under the disclosure obligations outlined in the Disclosure Regulations, the relevant information must be disclosed.

Article 13-3 (Request for Information)

① When shareholders or stakeholders request the disclosure of information related to the company, the Chief Disclosure Officer must review the legality of the request and decide whether to provide the relevant information.
② To decide whether to disclose the requested information, the Chief Disclosure Officer may consult with the legal department or external legal experts regarding whether the information could affect investor decisions or stock prices.
③ If the decision is made to provide the information under Paragraph (1), the provisions of Article 12 (3) shall apply mutatis mutandis.

Chapter 4 Regulations on Insider Trading, etc.

Article 14 (Return of Short-Swing Profits)

① Any executives or employees specified Article 172 (1) of the Act and Article 194 of the Enforcement Decree who purchase specified securities, etc. under Article 172(1) of the Act (hereinafter referred to as “specified securities, etc.”) and then sell them within six months, or who sell such specified securities, etc. and then purchase them within six months, must return to the company any profit gained therefrom (hereinafter referred to as “short-swing profit”).
② If a shareholder of the company (including any person who owns equity securities other than share certificates or securities depositary receipts; the same shall apply hereinafter in this Article) requests the Company to demand the return of short-swing profit pursuant to Paragraph (1) from the person who gained such short-swing profit, the Company must take the necessary measures within two months of receiving the request.
③ If the Securities and Futures Commission notifies the Company of the occurrence of short-swing profits under Paragraph (1), the Chief Disclosure Officer shall disclose the following matters on the Company’s website without delay:
- 1. The position of the person required to return short-swing profits
- 2. The amount of short-swing profits
- 3. The date the company was notified of the occurrence of short-swing profits by the Securities and Futures Commission
- 4. The plan for demanding the return of short-swing profits
- 5. The fact that a shareholder may request the Company to demand the return of short-swing profits from the person who obtained the short-swing profits, and if the Company does not make the demand within two months of receiving the request, the shareholder may make the demand on behalf of the Company
④ The disclosure period in Paragraph (3) shall be two years from the date the Company was notified of the short-swing profits by the Securities and Futures Commission or until the date the short-term trading profits are returned, whichever comes first.

Article 15 (Notification of Trading, etc. in Specified Securities, etc.): Executives and employees prescribed in Article 172 (1) of the Act and Article 194 of the Enforcement Decree of the Act shall notify the Chief Disclosure Officer when they engage in the trading or any other transactions involving specified securities.

Article 16 (Prohibition on the Use of Non-Public Material Information): Executives and employees shall not use, or allow others to use, non-public material information as defined in Article 174 (1) of the Act (including non-public material information of affiliates) for trading specified securities or any other transactions.

Chapter 5 Supplementary Provisions

Article 17 (Training)

① The Chief Disclosure Officer and disclosure personnel shall complete the training on disclosure duties pursuant to Article 36 and Article 44 (5) of the Disclosure Regulations, and the Chief Disclosure Officer shall inform relevant executives and employees of the training content.
② The CEO shall make sufficient efforts to prevent insider trading, etc., by providing training to executives and employees regarding matters set forth in Articles 14 through 16 and other legal provisions.

Article 18 (Amendment and Abolition of the Regulations): These Regulations shall be amended or abolished by the CEO.

Article 19 (Publication of the Regulations): These Regulations shall be published on the Company’s website. The same shall apply when the Regulations are amended.

Addendum: These Regulations shall take effect on December 1, 2025.