MPC Plus

ETHICS CODE

MPC Plus creating a sound and fair corporate culture

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HANKOOK CORPORATION strives to grow and develop with all stakeholders including shareholders by improving corporate value through progressive and efficient management activities and do its best to become a trusted company by faithfully fulfilling its duties and responsibilities as a listed company.

Our company respects all domestic and foreign laws and market order, establishes fair trade order, respects social values and customs and contributes to national and social development through various social contribution activities. Therefore, our company enacts the Code of Ethics to ensure a sound and fair corporate culture.

Attitudes towards shareholders and investors

1. Protection of Shareholders' Rights: · The company shall protect the rights of shareholders and respect the shareholders' legitimate demands and suggestions.; · The company will faithfully disclose management information to establish mutual trust with shareholders and investors and strive to maximize shareholder interests.

2. Equal treatment: · The company treats all shareholders including minority shareholders fairly and equitably.; · The company shall always decide the management opinion in consideration of the interests of all shareholders, so that the interests or rights of the minority shareholders are not unduly infringed.

3. Provide positive information: · The company records and manages accounting data in accordance with generally accepted accounting principles to provide transparent financial status and management performance.; · The company provides accurate management information in a timely manner in accordance with relevant laws and regulations, so that information users such as investors can make reasonable investment decisions.

Attitude towards customers

1. Customer respect: · The company always thinks and acts on behalf of the customer and strives to achieve customer satisfaction by providing the best products and services.; · The company provides accurate information about products and services to customers and does not advertise.

2. Customer Protection: · The company protects the interests, safety, and personal information of its customers and does not engage in unreasonable acts against customers.

Attitudes towards competitors and partner companies

1. Fair competition with competitors: · The company respects fair and free market economy order according to the principle of free competition and competes fairly with competitors.; · The company respects fair trade order and adheres to fair trade related laws and regulations.

2. Fair transactions with suppliers: · The company pursues joint development by establishing mutual trust and cooperation through fair transactions with partner companies.; · The company does not use any dominant position to impose or influence any form of unlawful conduct.

Responsibility to Employees

1. Fair treatment: · The company shall not give unfair discrimination to employees for reasons of favoritism, nepotism, cronyism, sex, religion, age, disability, marriage, etc.; · The company establishes evaluation criteria for employees' qualities, abilities and achievements, and fairly evaluates and compensates them.

2. Creating work environment: · The company strives for the health and safety of its employees.; · The company supports the self-realization with human resource development by fairly giving the opportunity to respect the autonomy and creativity of each employee and improve their ability.; · The company respects the independent personality and basic rights of its employees and creates an environment where suggestions can be made.

Responsibility for Society

1. Compliance with national and international laws and regulations: · As a member of the national and local communities, the company abides by all laws and regulations as well as international regulations.

2. Contribution to national economy and social development: · The company contributes to national economy and social development through improvement of productivity, creation of employment, sincere payment of taxes, and social contribution.

Basic Ethics of Employees

1. Establishment of sound corporate culture: · Employees share the management philosophy of the company and share the goals and values pursued by the company and faithfully carry out the mission assigned to them according to the company's business direction.; · Employees create an organizational culture based on smooth communication and mutual trust between leader and subordinate and employees.; · Employees shall perform their assigned duties in the most appropriate way and comply with all relevant laws and regulations of the company.

2. Prohibition of conflict of interest: · Employees shall endeavor to prevent any act or relationship that conflicts with the company's interests, and shall act in the best interests of the company when there is a conflict between the company and the individual or department.

3. Prohibition of use of internal information: · Employees shall not trade stocks using internal information acquired in the course of business.; · Employees shall not provide undisclosed material information to third parties without due process, which may affect the share price.

4. Protection of company property and important information: · Employees shall protect the company's material property, intellectual property, and trade secrets and shall not use them for private purposes.; · Employees do not engage in unfair business practices using private information obtained from the company or pursuing private interests using their positions.; · Employees do not disclose sensitive information to the outside that may affect the company's profits.

5. Sexual harassment prevention: · Employees shall not engage in any language or activity that would undermine sound co-workers, including physical, linguistic, visual language or behavior recognized as causing sexual humiliation.

6. No Political Involvement: · Employees do not engage in political activities during office hours and do not use company's organization, personnel, or property for political purposes.; · Individuals' political rights and political views are respected, but their political views and political involvement should not be misunderstood as a company’s position.

7. Prohibition for acceptance of money and entertainment: · Employees do not receive money, gifts, or entertainment from their stakeholders such as customers.; · Employees shall not give gifts or entertainment to stakeholders that are beyond the scope accepted by social norms to interested parties such as business partners in relation with the company's business.; · Employees do not accept money or excessive gifts and entertainment.

8. Compliance with the Code of Ethics: · All employees shall comply with the code of ethics and shall be responsible for any violation.; · Employees are required to report to the Ethics Office if they are forced to act against the Code or recognize any unfair conduct.; · Employees shall prevent recurrence by thorough investigation of cause and education in case of violation of Code of Ethics

Privacy Statement

‘MPC Plus' (hereinafter referred to as 'the Company') respects clients’ personal information and abides by the Act on Promotion of Information Network Usage and Information Protection. The Company will notify how and for what purpose the personal information provided by the customer is used and what measures are being taken to protect personal information. The company will notify you through the website announcement (or individual notice) when revising the privacy policy.

01. Purpose of Collection and Use of Personal Information
The Company uses the collected personal information for the purpose of ‘responding to inquiries'.

02. Personal information items to be collected and collection methods
1) Personal information items collected: Email
2) How to collect personal information: Collection through website homepage inquiry

03. Retention and use period of personal information
Personal information will be retained only until such working papers are no longer reasonably required for legal purposes.

04. Commitment of personal information
The Company will not disclose your personal information to any external organization unless we have your consent. In the event that such a need arises in the future, we will notify the user of the entrusted person and the contents of the entrusted business and will receive prior consent.

05. Procedures and methods of destroying personal information
Once the purpose of collecting and using personal information is achieved, the Company will immediately destroy the information. The procedure and method of destruction are as follows.
1) Destruction procedure: The personal information you provide to the company will be destroyed without delay after the purpose of collection and use is achieved.
2) Destruction method: Personal information stored in the form of an electronic file is deleted using a technical method to make it impossible to reproduce records.

06. Rights of clients and legal representatives and how to exercise them
1) You or your legal representative (if you are a child under the age of 14) may withdraw your consent to collect, use and provide personal information at any time.
2) You may require us to correct your personal information about the Company, and legal representatives to view, provide and correct any personal information of children under 14 years of age.
3) If you request correction of personal information error, the company will not use the personal information until the error correction is completed. If you have already provided the personal information to a third party, we will notify the third party without delay to correct the error.

07. Matters concerning the installation, operation and rejection of the automatic collection device of personal information
The company does not use automatic collection of personal information.

08. Matters concerning complaints about personal information manager and personal information
1) In order to protect your personal information and to handle complaints related to personal information, the company has designated the responsible department and personal information manager as follows.
* Personal Information Manager
The following administrative officer is responsible for the management duties under the authority of the CEO.
- Name: Bonggi Lee
- Contact: 02-3432-6530
- Email address: bklee01@besthc.co.kr

* Personal Information Department
- Department: IT Operation Team
- Contact person: Dong Min Lee
- Contact: 02-3432-6133
- E-mail address: dmlee@besthc.co.kr

2) If you give opinions or complaints about the personal information protection matters to the above department or the person in charge of personal information management, we will do our best to solve the problem promptly and sincerely.

3) Please contact the following organizations if you need to report or consult about other personal information infringement.
- Privacy Complaints Center (Tel: 118): privacy.kisa.or.kr
- Internet Crime Investigation Center, Supreme Prosecutor's Office (Tel: 02-3480-3573)
- Cyber Terror Response Center, National Police Agency (Tel: 02-392-0330)
* This policy will be effective November 1, 2017.

‘MPC Plus' (hereinafter referred to as 'the Company') places importance on the personal information of the members and respects the personal information protection regulations of the relevant laws and regulations, such as the Personal Information Protection Act. The Company will notify how and for what purpose the personal information provided by the customer is used and what measures are being taken to protect personal information. The company will notify you through the website announcement (or individual notice) when revising the personal information processing policy.

01. Items and Purpose of Personal Information to be Processed
The company processes personal information to the minimum extent necessary to respond to inquiries.

1) Processing Item: Email
2) Purpose of treatment:

02. Processing and retention period of personal information
Personal information will be retained only until such working papers are no longer reasonably required for legal purposes.

03. Providing third party of personal information
The Company shall use personal information only within the scope of the foregoing purpose of use and not disclose your personal information to any third party.

04. Matters concerning entrustment of personal information processing
The company does not entrust the information of the subject to an external company.

05. Regarding the rights, obligations and methods of information subjects
1) Personal information can be inquired or modified at any time, and withdrawal of consent such as collection can be requested. In order to inquire, correct or revoke the personal information of the information subject, contact the person in charge of personal information protection in writing, by phone or e-mail.
2) If you request correction of personal information error, the company will not use the personal information until the error correction is completed. If you have already provided the personal information to a third party, we will notify the third party without delay to correct the error. The Company shall process personal information that has been terminated or deleted at the request of an entity in accordance with the procedures specified in the "Processing and Retention Period of Personal Information" and is prohibited from being viewed or accessed for any other purpose.

06. Procedures and methods of destroying personal information
The company does not entrust the information of the subject to an external company.
1) Destruction procedure: The personal information you provide to the company will be destroyed without delay after the purpose of collection and use is achieved.
2) Destruction method: Personal information stored in the form of an electronic file is deleted using a technical method to make it impossible to reproduce records.

07. Matters concerning security measures for personal information
The company takes the following measures to ensure the safety of personal information.
1) Administrative measures: Establish and implement internal management plan, train regular staff, etc.
2) Technical measures: Management of access rights such as personal information processing systems, installation of access control systems, installation of security programs, etc.
3) Physical measures: Access control of computer room, data storage room, etc.

08. Civil Service on Personal Information
1) In order to protect the personal information of the information subject and handle the complaints related to the personal information, the company appoints the responsible department and the person in charge of personal information protection as follows.

* Personal Information Protection Officer
- Name: Bonggi Lee
- Contact: 02-3432-6530
- Email address: bklee01@besthc.co.kr

* Personal Information Department
- Department: IT Operation Team
- Contact person: Dong Min Lee
- Contact: 02-3432-6133
- E-mail address: dmlee@besthc.co.kr

2) One can notify the person and department in charge of personal information protection of all personal information related complaints arising from using the company's services. The company will respond quickly and fully to the complaint.
3) Please contact the following organizations if you need to report or consult about other personal information infringement
- Privacy Complaints Center (Tel: 118): privacy.kisa.or.kr

- Personal Information Dispute Resolution Committee (Tel: 118): privacy.kisa.or.kr

- Internet Crime Investigation Center, Supreme Prosecutor's Office (Tel: 02-3480-3573)

- Cyber Terror Response Center, National Police Agency (Tel: 02-392-0330)

09. Change of personal information processing policy
This privacy policy will be effective November 1, 2017.

Internal information management regulations

Chapter 1: General Provisions

Article 1 (Purpose) The purpose of this regulation is to establish matters concerning the comprehensive management and proper disclosure of company internal information in order to promptly and accurately disclose information according to laws and regulations and to prevent insider trading by employees.

Article 2 (Definition of Terms) 1. In this regulation, the term "internal information" means the disclosure requirements of Part 1 of the KOSDAQ Market Disclosure Regulations (hereinafter referred to as the "Disclosure Regulations"), It refers to matters that may affect investors' investment decisions.
2. "Officer in charge of disclosure" means a person who is able to perform the reporting business on behalf of the company pursuant to Article 2 ‘4’ of the Disclosure Regulations.
3. In this regulation, the term "officers" means the directors (including any person falling under any of the subparagraphs of paragraph 1 of Article 401 of the 「Commercial Act」) and auditors.
4. In addition to paragraphs ‘1’ to ‘3’, the definition of terms used in this regulation shall be defined by the terms used in relevant laws and regulations.

Article 3 (Scope of Application), Matters concerning disclosure, insider trading, and internal information management shall be governed by this Regulation except as provided in relevant laws, regulations or articles of incorporation.

Chapter 2 Management of Internal Information

Article 4 (Management of Internal Information)1. Employees shall strictly manage the internal information of the company that they have learned in their work, and shall not disclose the internal information to the inside or outside the company, except when necessary for business.
2. The representative director or disclosure officer shall take necessary measures for internal information management, such as setting specific standards for custody, transmission and destruction of internal information and related documents.

Article 5 (Disclosure Officer) 1. The representative director shall designate the person responsible for disclosure and report it to the Korea Exchange. It is also the same when the officer in charge of disclosure is changed.
2. The officer in charge of disclosure shall oversee the tasks related to the establishment and operation of the internal information management system and perform the following duties.
1) Execution of Disclosure
2) Checking and evaluating the operation of internal information management system
3) Review of internal information and determination of disclosure
4) Measures necessary for the operation of internal information management system, such as training for employees
5) Conducting and supervising internal information management or departments or officers in charge of disclosure
6) Other duties recognized by the CEO as necessary for the operation of the internal information management system
3. The officer in charge of disclosure shall have the following powers in performing his duties:
1) Permission to request and view the submission of documents and records related to internal information
2) Authority to listen to necessary opinions from the department in charge of accounting or auditing, and other employees in the department responsible for the creation of internal information.
4. The officer in charge of disclosure can consult with the officer in charge of carrying out the duties, if necessary, and obtain the help of experts at the expense of the company.
5. The disclosure officer shall periodically report the operational status of the internal information management system to the CEO.

Article 6 (Person in Charge of Disclosure) 1. The CEO or the person in charge of public disclosure shall declare a person in charge of disclosure and report it to the Korea Exchange. The same is true when the disclosure officer is changed.
2. The disclosure officer shall be under the direction of the officer in charge of internal information management and shall perform the following duties.
1) Collecting and reviewing internal information and reporting to the person in charge of disclosure
2) Duties necessary for execution of disclosure
3) Identification of matters necessary for the management of internal information, such as changes in laws and regulations related to disclosure, and reporting of disclosure officers
4) Other matters deemed necessary by the CEO or the officer in charge of disclosure

Article 7 (Concentration of Internal Information) The officers and the heads of the respective departments shall provide the disclosure officer with information on any of the following cases.
1. Internal information has occurred or is expected to occur
2. If there is a reason for cancellation or change of internal information,
3. If there is a request from the disclosure officer

Article 8 (Providing Internal Information Outside) 1. Employees shall inevitably disclose internal information to the Company's counterparts, external auditors, agents, companies, and legal consultants and management consultants If it should be provided, it should be reported to the disclosure officer.
2. In case of ‘Paragraph 1’, the disclosure officer shall take necessary measures, such as concluding a contract for maintaining confidentiality of related internal

Chapter 3 Disclosure of Internal Information

Article 9 (Kinds of Disclosure) The disclosure of the Company shall be divided as follows.
1. Notification and disclosure of major management items pursuant to ‘Part 1, Chapter 2, Section 1’ of the Disclosure Regulations
2. Disclosure in accordance with ‘Article 2, Section 2 of Part 1’.
3. Disclosure of fairness pursuant to ‘Part 2, Section 3 of Part 1’.
4. Disclosure Regulations In accordance with ‘Article 3 of Part 1’.
5. Submission of securities declaration, etc. pursuant to Chapter 1 of Chapter 3 of the 「Capital Market and Financial Investment Business Act」 (hereinafter referred to as the "Act")
6. Submission of business reports in accordance with ‘Article 159, 160 and 165 and Article 4 of the Regulations’.
7. Submission of the main matter report in accordance with ‘Article 161 of the Act’.
8. Disclosure in accordance with other laws and regulations

Article 10 (Execution of Disclosure) 1. The Disclosure Officer shall prepare the necessary information and report necessary documents to the Disclosure Officer in the event of the disclosure prescribed in ‘Article 9’.
2. The person in charge of disclosure shall examine whether the contents and documents in ‘Paragraph 1’ are not in violation of relevant laws and regulations, and report it to the CEO after disclosing it.

Article 11 (Post-Disclosure after Disclosure) The Disclosure Officer and Disclosure Officer shall take measures to rectify any errors or omissions without delay.

Article 12 (Press coverage, etc.) 1. If there is a request from a media company to report to the company, the representative director or the public officer shall respond accordingly. If necessary, employees of related departments may be allowed to cover the coverage.
2. If you want to distribute press releases to media companies, you should obtain the approval of the official in charge of disclosure. The disclosure officer shall, if necessary, report to the Representative Director the matters relating to the distribution of the press release.
3. Employees who know that the media reports are different from the facts should report them to the disclosure officer. The disclosure officer shall report the matter to the representative director and take necessary measures.

Article 13 (Business briefing session) The company briefing session on the management contents, business plan and prospect of the company shall be held with the approval of the disclosure officer.

Chapter 4 Regulation on Insider Trading, etc.

Article 14 (Return of Profits on Short Sale) 1. Officers and employees (limited to the person prescribed by Article 194 of the Enforcement Decree of the Act, who can know important non-publishing information in Article 174 (1) (Hereinafter referred to as the "Special Securities, etc.") Of the Securities Act (hereinafter referred to as "Securities") of Article 172 (1) of the Act, Short-term trading profits ") to the Company.
2. The shareholders of the Company (including those who own equity securities or securities deposit securities other than sovereigns, hereinafter the same shall apply in this Article) shall make a request for the return of short-term trading profits to the person who obtained the short- If requested, the disclosure officer shall take the necessary measures within two months from the date of receipt of the request.
3. In the event that the Securities and Futures Commission notifies the Company of the occurrence of short-term trading gains pursuant to ‘Paragraph 1’, the disclosure officer shall immediately disclose the following matters on the Company's website.
1) The status of the person who should return short-term trading gains
2) Amount of short-
3) Date of notification of the occurrence of short-term trading gains from the Securities and Futures Commission
4) Plan to return short-term profit
5) A shareholder of the Company may require the Company to request the return of short-term trading profits to the person who has earned the short-term trading profits. If the company does not make the claim within two months from the date of receipt of the request, it means that the shareholder can make a claim for the company
4. The disclosure period specified in Paragraph (3) shall be the period from the date of notification of the occurrence of short-term trading gains from the Securities and Futures Commission, or the date of first return of short-term trading profits,

Article 15 (Notification of the Sale and Purchase of Certain Securities, etc.) Officers and employees shall notify the disclosure officer of the sale or other transactions of certain securities.

Article 16 (Prohibition of Unauthorized Use of Important Information) Employees shall not use the undisclosed material information (including undisclosed material information of affiliated companies) set forth in ‘Article 174 1’ of the Act for the sale or other transactions of specified securities or otherwise make them available to others.

Chapter 5 Addendum

Article 17 (Education) The person responsible for public disclosure and the person in charge of public disclosure shall complete the education related to the disclosure duties pursuant to Article 36 and Article 44 (5) of the Public Disclosure Regulations, and the public officer shall ensure that the contents of education are disseminated to the related employees do.

Article 18 (Opening and Closing of the Regulations) The revision or abolishment of these regulations shall be made by the representative director.

Article 19 (Publication of Regulations) These regulations shall be published on the website of the Company. The same shall apply when the Regulations are revised.

Addendum

This regulation will be effective from September 1, 2009.