□ Basic purposes for establishing information walls

• Information walls are established and maintained to prevent conflicts of interest not only between the Company and investors but also among investors as well as to protect investors

□ Management of information flow controls

• An office in Compliance Department manages information flow controls within Samsung Securities, enforcing information flow regulations and evaluating the propriety of exceptions.
• Chief Compliance Officer oversees the information flow controls office.

□ Information subject to blocking

• Material nonpublic information, or MNPI, according to the Capital Markets ACT
• Such information that has not been made public as that of the financial investment trades or holdings of investors
• Such information that has not been made public as that of collective or discretionary investment assets or those in trust

□ Types of information exempted from information barriers

• Types of information exempted among information about investors’ trades or holdings of financial investment products
  • Total as well as item-by-item sums of investors’ holdings of electronically registered stocks
  • Total as well as item-by-item sums of stocks deposited by investors
  • Line-by-line sums of debt securities
  • Information that can be disclosed in accordance with the Article 32 of the Credit Information Use and Protection Act, or information requested to be transmitted in accordance with the Article 33, Section 2 of the above Act
  • Such information authorized by the information barrier protocol officer for disclosure as follows :
  1. 1. Information needed for conduct of foreign currency exchange or brokerage operations
  2. 2. Information exchanged between PB Solutions and Equity Financing teams for the purpose of conducting prime brokerage
  3. 3. Order-related information exchanged between PB Solutions and Sales Trading Teams for the purpose of executing related brokerage transactions.
  4. 4. Information exchanged between nonpublic and public sectors for the purpose of locking up stocks, establishing the right of pledge, and other IPO-related procedures.
  5. 5. Information exchanged between nonpublic and third-party sectors for the purpose of negotiating and sealing contracts in accordance with the level of customer demand for contract with third-party sectors assessed in the course of conducting IB.
  6. 6. Subscription information of customers under management exchanged between stockbrokerage and customer management units for the purpose of the latter’s management of customer assets.
• Information exempted among that about the composition or operation of assets in collective or discretionary investment schemes, or of trust assets
  • Information about real estate, specialty or other asset operations that has no potential risk of a conflict of interest
  • Such information approved by the information barrier protocol officer for disclosure as follows:
  1. 1. Information one month old or longer.
  2. 2. Information exchanged among departments dedicated to retirement fund management for the purpose of concluding, canceling, or operating retirement fund-related trust contracts.
  3. 3. Information exchanged between field and HQ offices for the purpose of concluding or canceling trust or investment discretionary contracts
  4. 4. Information exchanged between PB Solutions and Equity Financing teams for the purpose of conducting prime brokerage
  5. 5. Order-related information exchanged between PB Solutions and Equity Sales Trading Teams for the purpose of executing related brokerage transactions.
  6. 6. Information exchanged between fintech business and WM departments for the purpose of conducting work related to launching new financial products or services.

□ Types of information subject to complete or partial blockage

□ Products on watch and restricted lists

• On watch list
  1. 1. Domestic stocks issued by institutions that are registered in Samsung Securities’ internal systems as an institution with an expressed intent to entrust with the Company the trading of such products as those described in the No.1 to No.4 of the restricted list below.
  2. 2. Other domestic stocks that are considered necessary that they be on the watch list.
• On restricted list
  1. 1. Financial investment products of institutions with which nonpublic sectors have signed contracts for the purpose of mediating, arranging, or representing or advising clients in, M&A or spinoff
  2. 2. Financial investment products of institutions with which nonpublic sectors have signed contracts for the purpose of underwriting or arranging public/ private offerings or sales of shares (including convertible debentures)
  3. 3. Financial investment products of institutions with which nonpublic sectors have signed contracts for the purpose of mediating, arranging, or representing or advising clients in, equity acquisition/disposal
  4. 4. Financial investment products of institutions that have issued securities for which institutions or relevant institutions intend to make a tender offer that have appointed nonpublic sectors as a public tender agent in accordance with the Financial Investment Services and Capital Markets Act, Article 133, Section 2 (provided the tender offer is yet to expire)
  5. 5. Financial investment products the trading of which is restricted by law or contract.
  6. 6. Other financial investment products that the information flow control officer deems a potential source for a conflict of interest.
• Except for the No. 5, any of the restricted list can be exempted from restriction following such a judgment of the information flow control officer based on the scale and importance of related transactions.

□ Employee Education

• Guidelines and other related policies are posted through the Company intranet on types of information to be blocked from inter-departmental flows.
• Employees are regularly educated on penalties for using information classified as illegal or violating internal controls on information use or other related regulations.
• Employees are duly informed of all revisions made to internal controls on information use or other related regulations.

□ Types of activity deemed subject to conflicts of interest and countermeasures