Internal Information Management Policy

1. Scope

These Regulations govern matters concerning disclosure, insider trading and internal information management at INVENIA Co., Ltd. (the “Company”), except as otherwise provided by applicable laws, regulations or the Articles of Incorporation.

2. Purpose

These Regulations establish rules for the comprehensive management and appropriate disclosure of the Company's internal information to ensure prompt and accurate disclosure under the Financial Investment Services and Capital Markets Act (the “Act”) and other applicable laws and regulations, and to prevent insider trading by officers and employees.

3. Definitions

3.1 Internal information

“Internal information” means matters subject to mandatory disclosure under Part 1 of the KOSDAQ Market Disclosure Regulations (the “Disclosure Regulations”) of the Korea Exchange (the “Exchange”), and other matters concerning the Company's management or financial position that may affect investors' investment decisions.

3.2 Disclosure Officer

A person authorized to perform reporting duties on behalf of the Company under Article 2(4) of the Disclosure Regulations.

3.3 Officers

Directors (including persons falling under any subparagraph of Article 401-2(1) of the Commercial Act) and statutory auditors.

3.4 Terms used in these Regulations other than those defined in paragraphs 1 through 3 have the meanings given in the relevant laws and regulations.

4. Management of Internal Information

4.1 Management of internal information

(1) Officers and employees shall strictly manage the Company's internal information obtained in the course of their duties and, except where necessary for business purposes, shall not
      disclose it within or outside the Company.

(2) The CEO or Disclosure Officer shall establish detailed standards for storing, transmitting and destroying internal information and related documents, and take the necessary
      measures to manage internal information.

4.2 Disclosure Officer

(1) The CEO shall appoint a Disclosure Officer and report the appointment to the Exchange without delay. The same applies to any change in the Disclosure Officer.

(2) The Disclosure Officer shall oversee the establishment and operation of the internal information management system and perform the following duties.

1) Executing disclosures

2) Inspecting and evaluating the operation of the internal information management system

3) Reviewing internal information and deciding whether disclosure is required

4) Taking measures necessary to operate the internal information management system, including training officers and employees

5) Directing and supervising departments, officers and employees responsible for internal information management or disclosure

6) Performing other duties the CEO deems necessary for operating the internal information management system

(3) In performing these duties, the Disclosure Officer has the following authority.

1) Authority to request the submission of and inspect documents and records relating to internal information

2) Authority, in relation to accounting, auditing and other work involved in generating internal information,
    to hear necessary opinions from the officers and employees in charge

(4) When necessary in performing these duties, the Disclosure Officer may consult officers responsible for the relevant work and seek expert assistance at the Company's expense.

(5) The Disclosure Officer shall regularly report on the operation of the internal information management system to the CEO (or Board of Directors).

4.3 Disclosure Staff

(1) The CEO or Disclosure Officer shall appoint Disclosure Staff and report the appointment to the Exchange without delay. The same applies to any change in Disclosure Staff.

(2) Disclosure Staff shall perform the following duties under the direction of the Disclosure Officer in relation to internal information management.

1) Collecting and reviewing internal information and reporting it to the Disclosure Officer

2) Performing tasks necessary to execute disclosures

3) Checking matters necessary for internal information management, including changes in disclosure-related laws and regulations, and reporting them to the Disclosure Officer

4) Handling other matters the CEO or Disclosure Officer deems necessary

4.4 Centralization of internal information

(1) Officers and department heads shall provide relevant information to the Disclosure Officer in any of the following cases.

1) Internal information arises or is expected to arise

2) Grounds arise or are expected to arise for canceling or changing previously disclosed internal information

3) The Disclosure Officer otherwise requests information

(2) The Disclosure Officer and CEO shall establish an efficient internal information transmission system to ensure timely provision under paragraph 1 and, where necessary,
      may require the Disclosure Officer's involvement in approvals for work relating to mandatory disclosure matters.

4.5 Provision of internal information outside the Company

(1) If officers or employees must, for business reasons, provide internal information to counterparties, external auditors, agents or parties engaged by the Company for legal, management or other advisory services,
      they shall report the matter to the Disclosure Officer.

(2) In the case of paragraph 1, the Disclosure Officer shall take necessary measures, including entering into a confidentiality agreement covering the internal information.

(3) If providing information under paragraph 1 gives rise to a fair disclosure obligation, the information shall be disclosed without delay.
     (Except where an exemption under Article 15 of the Disclosure Regulations applies.)

4.6 Management of information relating to the largest shareholder

To facilitate disclosures concerning mandatory disclosure matters and inquiry disclosure requests relating to the largest shareholder, the Disclosure Officer shall fully explain the relevant facts to the largest shareholder and establish a system for receiving the information in a timely manner.

4.7 Centralization of subsidiaries' internal information

(1) If internal information relating to mandatory disclosure matters arises or is expected to arise at a subsidiary, the Company shall require the subsidiary to notify the Company's Disclosure Officer or
     Disclosure Staff immediately.

(2) To manage the information under paragraph 1 efficiently, the Company shall require subsidiaries to designate a person to manage disclosure-related information and
     to notify the Company's Disclosure Officer or Disclosure Staff immediately of any designation or change.

(3) The Company may require subsidiaries to submit relevant materials to the extent necessary for disclosure duties.

5. Disclosure of Internal Information

5.1 Types of disclosure

The Company's disclosures are classified as follows.

(1) Reporting and disclosure of material management matters under Part 1, Chapter 2, Section 1 of the Disclosure Regulations

(2) Inquiry 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 and related documents under Part 3, Chapter 1 of the Act

(6) Submission of annual business reports and related reports under Articles 159, 160 and 165 of the Act and Section 4 of the Disclosure Regulations

(7) Submission of material event reports under Article 161 of the Act

(8) Disclosures under other laws and regulations

5.2 Determining disclosure requirements

When determining whether a matter is subject to mandatory disclosure, including fair disclosure, under these Regulations, care shall be taken to include matters that have or may have a material effect on share prices or investment decisions under Article 6(1)4 of the Disclosure Regulations.

5.3 Executing disclosures

(1) When a disclosure matter specified in Article 9 arises, Disclosure Staff shall prepare the necessary content and supporting documents and report to the Disclosure Officer.

(2) The Disclosure Officer shall review the content and documents under paragraph 1 for compliance with applicable laws and regulations, report to the CEO and then make the disclosure.

5.4 Prompt disclosure

When a disclosure matter under Article 5.1 arises, the Disclosure Officer shall make every effort to disclose the relevant internal information in a timely manner, even before the applicable deadline under the Disclosure Regulations.

5.5 Follow-up after disclosure

If disclosed information contains errors or omissions or is to be canceled or changed, the Disclosure Officer and Disclosure Staff shall promptly take corrective measures, including a corrective disclosure under Article 30 of the Disclosure Regulations.

5.6 Media inquiries and related matters

(1) The CEO or Disclosure Officer shall respond to media requests for interviews concerning the Company. Where necessary, they may have officers or employees of the relevant department
      respond to the interview.

(2) The Company shall consult the Disclosure Officer before distributing a press release. Where necessary, the Disclosure Officer shall report matters relating to its distribution
     to the CEO.

(3) If the content of a press release under paragraph 2 is subject to fair disclosure, the Disclosure Officer shall disclose it before distribution.

(4) Officers or employees who learn that media reports are inaccurate shall report this to the Disclosure Officer, who shall report the matter to the CEO
      and take necessary measures.

5.7 Monitoring media reports

The Disclosure Officer, Disclosure Staff and departments that generate internal information shall routinely monitor media reports concerning the Company and take corrective measures if they contain inaccuracies.

5.8 Investor relations presentations

(1) The CEO shall recognize that investor relations activities are a management responsibility of KOSDAQ-listed companies and shall seek to build trust with investment stakeholders
      by voluntarily and consistently holding investor relations presentations.

(2) Presentations on the Company's management, business plans and outlook shall be held with the approval of the Disclosure Officer.

(3) The Disclosure Officer or Disclosure Staff shall disclose the date, venue and content of a presentation no later than the day before it is held and post relevant materials
     on the Exchange's disclosure submission system before the presentation begins.

(4) All officers and employees shall ensure that information subject to fair disclosure that has not already been disclosed is not revealed during investor relations presentations.

5.9 Rumors

(1) If rumors circulate in the market, the Disclosure Officer shall consult the relevant business departments and otherwise verify their accuracy and whether they constitute internal information
      as necessary.

(2) If verification under paragraph 1 shows that a rumor concerns a mandatory disclosure matter under the Disclosure Regulations, the relevant information shall be disclosed.

5.10 Requests for information

(1) If shareholders or other stakeholders request information about the Company, the Disclosure Officer shall review the legality of the request and determine
      whether to provide the information.

(2) To decide whether to provide information, the Disclosure Officer may seek opinions on whether the requested information could affect investment decisions or share prices
      from the legal department or external legal experts.

(3) Article 5.6(3) applies mutatis mutandis when providing information pursuant to a decision under paragraph 1.

6. Regulation of Insider Trading and Related Activities

6.1 Recovery of short-swing profits

(1) Officers and employees (limited to those specified in Article 194 of the Enforcement Decree of the Act who may learn material nonpublic information under Article 174(1) through their duties; the same applies in Article 15) shall
      return to the Company any profit (the “short-swing profit”) obtained by selling specified securities under Article 172(1) of the Act (the “specified securities”) within six months of purchase, or
      by purchasing them within six months of sale.

(2) If a shareholder of the Company (including holders of equity securities other than share certificates or depositary receipts; the same applies in this Article) requests that the Company seek recovery of short-swing profits
      from a person who earned them under paragraph 1, the Company shall take necessary measures within two months of receiving the request.

(3) If the Securities and Futures Commission notifies the Company of short-swing profits under paragraph 1, the Disclosure Officer shall disclose the following matters without delay
      on the Company's website.

1) Position of the person required to return short-swing profits

2) Amount of short-swing profits

3) Date of notification from the Securities and Futures Commission

4) Plan to seek recovery of short-swing profits

5) A statement that shareholders may request that the Company seek recovery from the person who earned the profits and, if the Company fails to make the claim
     within two months of receiving the request, the shareholder may pursue the claim on the Company's behalf.

(4) Disclosure under paragraph 3 shall continue until the earlier of two years from the date of notification by the Securities and Futures Commission
      or the date the short-swing profits are returned.

6.2 Notification of transactions in specified securities

Officers and employees shall notify the Disclosure Officer when they buy, sell or otherwise transact in specified securities.

6.3 Prohibition on using material nonpublic information

Officers and employees shall not use, or allow others to use, material nonpublic information under Article 174(1) of the Act (including such information about affiliated companies) to buy, sell or otherwise transact in specified securities.

7. Supplementary Provisions

7.1 Training

(1) The Disclosure Officer and Disclosure Staff shall complete disclosure training under Articles 36 and 44(5) of the Disclosure Regulations, and the Disclosure Officer shall communicate the training content
      to the relevant officers and employees.

(2) The CEO shall make sufficient efforts, including training officers and employees, to prevent insider trading and other activities regulated by Article 6 and other applicable laws.

7.2 Amendment or repeal

The CEO shall amend or repeal these Regulations.

7.3 Publication

These Regulations shall be published on the Company's website. The same applies to amendments.

8. Addenda

These Regulations take effect on March 1, 2016.

These amended Regulations take effect on June 1, 2017.