Defendant shall be punished by a fine of KRW 10 million.

If the defendant does not pay the above fine, KRW 100,000.

Punishment of the crime

The Defendant is a person working as a vice-chairperson of the D Group, and on November 6, 2012, the Defendant entered into a contract to take over (5,024,321 shares of (41.41%) and management rights of (14 billion won) from (i)G, the largest shareholder of (ii) KOSDAQ-listed corporations, as a package company in collaboration with E, a high school established, and (iii) a package company.

1. No person who intends to acquire or dispose of stocks, etc. of a listed corporation that violates the prohibition against the use of undisclosed information shall use or allow another person to use undisclosed information regarding the initiation or discontinuance of such acquisition or acquisition in bulk for the trading or any other transaction of specific securities, etc. related to such stocks;

The Defendant, around October 26, 2012, specified the terms and conditions of the contract, such as the amount of (i) F’s acquisition of shares and management rights through a negotiation with H’s representative director, the largest shareholder of (ii) HaF, and (iii) on October 28, 2012, immediately after requesting the law firm I to review the contract’s acquisition of shares and management rights, the Defendant was requested by the joint assignee of the said contract from the above E to make an investment of KRW 2.8 billion, and accepted the request around that time.

In addition, the Defendant, who is a material nonpublic information, anticipated that the acquisition of shares following the change of the largest shareholder of the F, would make a rapid increase in the share price of the F if disclosed to many and unspecified persons. Before the disclosure of the foregoing fact, the Defendant intended to obtain profits from market price by purchasing the shares of the F using a borrowed account.

Thus, around October 31, 2012, prior to the disclosure of the above fact on November 7, 2012 to many unspecified persons, the Defendant used the borrowed account in the name of J, K, and L, as shown in Appendix I, to purchase KRW 46,00 stocks of (State) F 46,90,00 listed in the Korea Exchange located in Yeongdeungpo-gu Seoul Metropolitan City, Young-dong 33, by using the treatment securities account under the name of the Defendant’s mother, the Defendant’s mother, from November 6, 2012 to November 6, 2012.