POSCO FUTURE M

The objectives of these policies is to set matters related to the comprehensive management and appropriate disclosure of the internal information for prompt and accurate disclosure and for prevention of insider trading by executives and employees in accordance with the Financial Investment Services and Capital Markets Act (“Act”) and other laws and regulations.

The Company processes private information for the following purposes. The processed private information will not be used for any purpose other than the following, and in any case where the purpose of use changes, we will take due measures, such as obtaining separate consent according to Article 18 of the Personal Information Protection Act.

• ① In this policy, “internal information” means information disclosed according to Part 1 of the Disclosure Regulation of the KOSDAQ market (“Disclosure Regulation”), and information that may affect the management or the property status of the Company, or the investment judgment of investors.
• ② “Disclosure Officer” in this policy refers to a person who can perform a reporting on behalf of the Company in accordance with Article 2.4 of the Disclosure Regulation.
• ③ “Executives” in this policy refers to directors (including a person falling under any subparagraph of Article 401-2.1 of the Commercial Act) and auditors.
• ④ In addition to paragraphs 1 through 3, the definition of terms used in this policy shall follow the definition of terms used in relevant laws and regulations.

Matters related to disclosure, insider trading, and internal information management are subject to this policy, except those stipulated in relevant laws or the articles of incorporation.

• ① Executives and employees shall strictly manage the internal information of the Company that they have come to know in the course of their work, and shall not disclose them inside or outside the company, except where necessary for work.
• ② The CEO shall take necessary measures for the management of internal information, such as setting specific standards for storage, delivery, and discarding of internal information and related documents.

• ① The CEO shall designate the Disclosure Officer and report it to the Korea Exchange (KRX). The CEO shall do the same when replacing the Disclosure Officer.
• ② The Disclosure Officer oversees the work related to the establishment and operation of the internal information management system and conducts the following tasks.
  • 1. Public disclosure
  • 2. Inspection and evaluation of the operating status of the internal information management system.
  • 3. Examination of internal information and decision on whether to disclose them.
  • 4. Taking actions for the operation of the internal information management system including education for executives and employees.
  • 5. Supervision of executives and employees or their departments responsible for the management of internal information and disclosure.
  • 6. Other tasks otherwise acknowledged by the CEO for operation of the internal information management system.
• ③ The Disclosure Officer has the following authority when performing his/her duties.
  • 1. The right to request and view various documents and records related to internal information.
  • 2. The right to listen to necessary opinions of executives and employees of the department responsible for accounting or auditing, or other departments in charge of tasks related to the generation of internal information.
• ④ The Disclosure Officer may, if needed, consult with the executives in charge of relevant tasks, and seek the assistance of experts at the company's expense.

• ① The CEO shall designate the Disclosure Manager and report it to the KRX. The CEO shall do the same when replacing the Disclosure Manager.
• ② The Disclosure Manager receives direction from the Disclosure Officer regarding the management of internal information and undertakes the following tasks.
  • 1. Collection and review of internal information and reporting to the Disclosure Officer.
  • 2. Tasks necessary for public disclosure.
  • 3. Confirmation of matters necessary for management of internal information, such as changes in disclosure-related laws, and reporting to the Disclosure Officer.
  • 4. Other matters the CEO or the Disclosure Officer has acknowledged as necessary.

Executives and the head of each department shall provide information to the Disclosure Officer in a timely manner for any of the following cases.

• 1. When internal information is generated.
• 2. Where there is a reason to cancel or revise internal information that has already been disclosed.
• 3. When otherwise requested by the Disclosure Officer.

• ① In the event that an executive or an employee needs to disclose internal information to the Company's counterparty, an external auditor, an agent, or a person who has signed an advisory contract with the company for legal or management advice, he/she shall report this to the Disclosure Officer.
• ② When a situation described in paragraph 1 occurs, the Disclosure Officer shall take necessary measures, such as concluding a non-disclosure agreement, etc.

The company disclosures are divided as follows.

• 1. Report and disclosure of important business information pursuant to Part 1, Chapter 2, Section 1 of the Disclosure Regulation
• 2. Inquired disclosure pursuant to Part 1, Chapter 2, Section 2 of the Disclosure Regulation
• 3. Fair disclosure pursuant to Part 1, Chapter 2, Section 3 of the Disclosure Regulation
• 4. Voluntary disclosure pursuant to Part 1, Chapter 3 of the Disclosure Regulation
• 5. Submission of a registration statement and other document as needed under Part 3 Chapter 1 of the act
• 6. Submission of a business report and other document as needed under Article 159, 160, 165 of the act and Part 1 Chapter 2 Section 4 of the Disclosure Regulation
• 7. Submission of a business report on major issues under Article 161 of the act
• 8. Other disclosures pursuant to other laws

• ① In case information to be released is generated pursuant to Article 9, the Disclosure Manager shall prepare disclosure document as needed and report to the Disclosure Officer.
• ② The Disclosure Officer shall review whether the information prepared under paragraph 1 does not violate relevant laws, report to the CEO and disclose the information.

When an error or omission of information is found in the disclosed information, the Disclosure Officer and the Disclosure Manager shall immediately take measures to revise the information.

• ① Upon request by the press to interview the Company, in principle, the CEO or the Disclosure Officer responses to such request. If necessary, an executive or an employee from the relevant department may be asked to respond to the interview.
• ② In case the Company wishes to distribute a press release, the matter shall be discussed with the Disclosure Officer. The Disclosure Officer shall, if necessary, report the matter related to the press release to the CEO.
• ③ Any executives or employees, who finds out that the report made by the press is different from the truth, shall report it to the Disclosure Officer. The Disclosure Officer shall report the matter to the CEO and take measures as needed.

Company briefings on the management details, business plans, and future prospects shall be held in consultation with the Disclosure Officer.

• ① If an executive or an employee prescribed in Article 172.1 of the act and Article 194 of the Enforcement Decree of the act sells specific securities and others (“specific securities”) as specified in Article 172.1 of the act within six months after purchasing them, or purchase them within six months after selling them and earns profit, he/she must return the profit (“short-swing profit”) made to the Company.
• ② In order for shareholders of the Company (including those who hold equity securities or depository securities other than stock certificates; the same applies to other articles) to request the Company to ask the person who made short-swing profit according to paragraph 1 to return the short-swing profit, the Company shall take the necessary measures within two months upon the Company receiving such a request.
• ③ In the event that the Financial Services Commission (FSC) notifies the company that short-swing profit has been made pursuant to paragraph 1, the Disclosure Officer shall immediately disclose the information in the following subparagraphs to the Company website.
  • 1. The position of the person who shall return the short-swing profit.
  • 2. The amount of short-swing profit generated.
  • 3. The date of notification of short-swing profit from the FSC.
  • 4. A plan for claiming the return of the short-swing profit.
  • 5. A shareholder of the Company may request the company to request the return of the short-swing profit from the person who has made such profit. In case the Company fails to claim the return within two months since the Company has received the request to make such a claim, the shareholder may subrogate the Company and make the claim.
• ④ The disclosure period under paragraph 3 shall be two years from the date of notification of short-swing profit from the FSC or until the date on which short-swing profit is returned, whichever comes first.

An executive and an employee prescribed in Article 172.1 of the act and Article 194 of the Enforcement Decree of the act shall notify the Disclosure Officer when he/she is involved in sales of specific securities or trading of other items.

Executives and employees shall not use, or allow others to use important information that is undisclosed (including such information of affiliates) prescribed in Article 174.1 of the act for the sale or trading of specific securities.

The Disclosure Officer and the Disclosure Manager shall complete training on disclosure duties pursuant to Articles 36 and 44.5 of the Disclosure Regulation, and the Disclosure Officer shall inform the relevant executives and employees of the content of the training.

This policy is to be announced on the Company webpage. The same shall be applied in the event the policy is revised.

This policy is effective as of December 5, 2016.