WOORI INVESTMENT SECURITIES

Policy on Conflict of Interest and Information Barrier

Woori Investment Securities Co., Ltd., as a financial investment company, has established and operates its internal control policy to ensure that the interests of clients and shareholders are not violated in relation to "information barriers", according to Article 45 of the Capital Markets and Financial Investment Services Act (hereinafter referred to as the "Capital Markets Act") and Article 50 of its Enforcement Decree. The main descriptions are as follows:

Description of the Policy on Conflict of Interest and Information Barrier

1. Information Subject to Information Barriers

  1. 1) Undisclosed material information according to Article 174, Paragraph 1 of the Capital Markets Act.
  2. 2) Information on the trading or ownership status of financial investment products by investors, which has not yet been disclosed to the public.
  3. 3) Information on the composition and management of collective investment property, investment advisory property, and trust property that has not been publicly disclosed.
  4. 4) Undisclosed transaction or corporate information that requires special attention during communication.

2. Information Excluded from Information Barriers

  1. 1) Information on the trading or ownership status of financial investment products by investors, which has not yet been disclosed to the public.
  2. A. Information on the total amount of electronic registered stocks and the total amount by type of electronic registered stocks held by investors under Article 2 (4) of the "Electronic registered of stocks, bonds, etc."
  3. B. Information on the total amount of securities and the total amount by type of securities deposited by investors
  4. C. Information on the total amount of debt securities by type
  5. D. Personal credit information that has been consented to provision according to Article 32 of the Act on Use and Protection of Credit Information, or requested to be transmitted according to Article 33-2.
  6. E. Information approved by the compliance officer that is not subject to conflict of interest concerns.
  7. 2) Information on the composition and management of collective investment property, investment advisory property and trust property that has not been publicly disclosed.
  8. A. Information related to the operation of real estate (including real estate-related rights such as superficies, easements, leaseholds, lease rights, sales and purchase) and special assets(including securities issued by companies for the purpose of investing in real estate and special assets) without concerns of conflict of interest
  9. B. Information that has passed 1 month among information on the composition and operation of collective investment property, advisory investment property, and trust property: Provided that in the case of providing only information approved by a compliance officer among information on the composition and operation of collective investment property to the securities company, information that has passed 5 business days
  10. C. Information approved by the compliance officer that is not subject to conflict of interest concerns.

3. Departments Subject to Information Barriers

  1. Departments that handle undisclosed material information and various details related to advisory investment and trust property are subject to information barriers.
Departments Subject to Information Barriers
Departments Subject to Information Barrier Information Subject to Information Barrier
Investment Bank
  • Undisclosed important information according to Article 174 (1) of the Capital Markets Act
  • Information on the trading or ownership status of financial investment products by investors, which has not yet been disclosed to the public
  • Information on the composition and management of collective investment property, investment advisory property, and trust property that has not been publicly disclosed
  • Undisclosed transaction or corporate information that requires special attention during communication
Corporate Finance
Proprietary Trading
Investment Trading and Brokerage
Investment Advisory

4. Designation of Restricted Transaction

  1. 1) In cases where undisclosed material information or information equivalent to undisclosed material information or corporate information is obtained, financial investment products related to the entity in question will be designated as investment products subject to trading caution or trading restrictions
  2. 2) For financial investment products that fall under the trading caution or trading restricted list, trading by company and employees is prohibited.
Designation of Restricted Transaction
Classification List of Transaction
Trading Caution
  • When the company participates or is involved in payment guarantee business as creditors, debtors, etc.
  • A corporation that has designated the company as a tender offer handler under Article 133 (2) of the Capital Markets Act and a corporation that has issued securities that the corporation intends to make a tender offer. However, this is limited to cases where the tender offer period has not elapsed.
  • The company is requested by client and engages in brokerage/arrangement/ representation/advice for mergers and acquisitions, underwriting of stock (including stock-related corporate bonds) and arrangement for public offering/private placement/sales, or brokerage/arranging/representation/advice for sale and acquisition of shares.
  • The company contracts a confidentiality agreement with counterparty corporation where the information is undisclosed to the public and engages in brokerage/arrangement/representation/advice for mergers and acquisitions, underwriting of stock (including stock-related corporate bonds) and arrangement for public offering/private placement/sales, or brokerage/arranging/representation/advice for sale and acquisition of shares. (Refers to Article 201 (1) of the Enforcement Decree of the Capital Markets Act and where the period has not elapsed).
  • Cases where it is deemed necessary to pay attention to trading transactions, such as affiliate relationships or corporations holding more than 1% of the total number of issued stocks.
Trading Restriction
  • The company provides brokerage/arrangement/representation/advice services for mergers and acquisitions, underwriting of stock (including stock-related corporate bonds), and arrangement for public offering/private placement/sales, or brokerage/arranging/representation/advice for the sale and acquisition of shares. However, if there are reasonable grounds considering the scale and importance of the business, it may be exempted from restrictions.
  • When sales transactions are restricted by law or contract.
  • In other cases where it is deemed appropriate for the company to restrict trading transactions.

5. Transactions with Potential Conflicts of Interest and Countermeasures

Transactions with Potential Conflicts of Interest and Countermeasures
Classification List of Transaction Countermeasures
Investment Bank →
Investment Trading, Proprietary Trading
Using corporate information for oneself or a third party Stop the transaction
The company (including the parent company) engages in competitive or conflict-of-interest transactions with clients While acquiring securities, etc., the company recommends to other clients to participate in securities trading Stop subsequent transaction
When the PF-related department provides funding-related advice to a company, and the loan department makes a loan to the same company based on that advice
When the company becomes the agent of the client's counterparty When providing advice simultaneously to multiple clients with conflicts of interest related to finance or M&A Stop subsequent transaction
When providing advice on the issuance of securities, etc. to one client and recommending participation in trading in such securities, etc. to another client
If the company conducts a transaction with a client's competitor When providing financial, M&A and related advice simultaneously to multiple clients who are competing with each other in relation to a specific issue Stop subsequent transaction
The company's actions to obtain economic profits and avoid losses at the client's expense When underwriting or advising a client on the issuance of stocks, etc. while recommending such transaction to another client Stop subsequent transaction
When another affiliate collects the loan of the person who issued the securities acquired by the company, thereby transferring the risk to investors investing in the acquired securities Stop subsequent transaction
Pursuing the company’s private interests using client's undisclosed information Providing a client's undisclosed information without the client's consent to another department for the purpose of supporting company sales Stop the action
When the company receives benefits other than contracted commissions based on transactions with third parties When an employee of a company receives gifts or entertainment that may cause a conflict of interest with clients Stop the action

6. Consultation and Reporting on Conflicts of Interest Related to Undisclosed Information

  1. 1) Inquiry on conflicts of interest: Compliance Department
  2. 2) Head of information barrier control: Chief Compliance Officer