1. Purpose

The purpose of this guideline is to prescribe matters relating to the operation of the Insider whistleblower program, the protection of whistleblowers and confidentiality in order to prevent accidents in advance, and to minimize losses in the event of an accident by promoting the Insider whistleblower program.

2. Definition of Terms

1. The definition of the terms used in this guideline shall be as follows
   1. a. “Insider” means an officer or employee, including any contractual or temporary employee, of the Financial Holding Company or any subsidiary, second-tier subsidiary, or third-tier subsidiary of a holding company (a “Subsidiary”) within the meaning of Article 2 Paragraph 1 Subparagraphs 2, 3, and 3-2 of the Financial Holding Companies Act.
   2. b. “Operations Department” means the department in charge of matters relating to the operation of the Insider whistleblower program, including the acceptance of Insiders’ reports, investigation, training, and the enactment and amendment of rules.
   3. c. “Investigation Department” means the Operations Department that conducts investigations of Insider whistleblower reports, or any other department that conducts such investigations at the request of the Operations Department.
   4. d. “Person Bound by Confidentiality Obligations” means a person who accepts and conducts investigations regarding Insider whistleblower reports, or an Insider who directly or indirectly comes to know the identity of a whistleblower or the details of a whistleblower’s report.

3. Establishment of an Operations Department

1. 1. a. The Operations Department in charge of the Financial Holding Company’s Insider whistleblower program shall be its compliance department.
   2. b. In principle, the Operations Department of a Subsidiary shall be established and operated by each Subsidiary, but if deemed necessary for the efficient operation of the Insider whistleblower program, the head of the Financial Holding Company’s Operations Department may take full charge of the Subsidiary’s Insider whistleblower program.

4. Management of the Whistleblower Program

1. 1. a. The personnel in charge of the Insider whistleblower program shall be appointed in the Operations Department for the purpose of efficiently managing the Insider whistleblower program.
   2. b. The personnel in charge of the Insider whistleblower program shall take necessary measures to actively promote the program.

5. Insiders’ Duty to Whistleblow

1. 1. a. An Insider, after becoming aware of the occurrence of any act by officers and employees subject to whistleblowing, as provided in Article 6(a) (including where the act subject to whistleblowing is compelled or suggested to be conducted by an officer or employee or a person other than an officer or employee), shall promptly report it to the Operations Department of the Financial Holding Company or Subsidiary.
   2. b. A person who fails to report to the Operations Department of the Financial Holding Company or Subsidiary, after becoming aware of any act subject to whistleblowing in violation of Paragraph a above, may be subject to disciplinary action in accordance with the internal rules.

6. Acts Subject to Whistleblowing

1. 1. a. Any of the following acts occurring at the Financial Holding Company or a Subsidiary (the “Financial Holding Company, Etc.”) shall be subject to whistleblowing by Insiders
      1. (1) Suspected acts of crime, including embezzlement, breach of duty, blackmail, theft, acceptance of bribes, arranging private financing, unjust acts related to savings, and escape of property out of country;
      2. (2) Suspected violations of the Act on Real Name Financial Transactions and Confidentiality or the Act on Reporting and Using Specified Financial Transaction Information;
      3. (3) An act of neglecting the prevention of financial accidents and not doing so
      4. (4) Financial accidents that are expected to violate company regulations or fails to follow standard procedures
      5. (5) Unlawful or unreasonable instructions given by supervisors in relation to job duties
      6. (6) Sexual harassment using sexual language or behaviors;
      7. (7) Acts that intentionally or negligently cause losses to the Financial Holding Company or its Subsidiary;
      8. (8) Any other acts that are believed to be an illegal or unreasonable handling of job duties or a sign of accident.
   2. b. With respect to any act subject to whistleblowing by Insiders that occurs at a Subsidiary, the Subsidiary’s Operations Department may accept and process the relevant whistleblower reports.

7. Reporting Principles

1. 1. a. An Insider whistleblower report shall specifically state the details based on the “Five Ws and How” (who, what, when, where, why, and how).
   2. b. In principle, whistleblower reports shall be made anonymously, but if the whistleblower desires, for example, to provide additional information, whistleblower reports may be made in the whistleblower’s name. However, even if a whistleblower report is made in the whistleblower’s name, anonymity shall be fully protected outside of the Operations Department.
   3. c. If a false report is filed for the purpose of slandering or defaming another employee, the report shall be excluded from the application of this guideline, and the relevant whistleblower shall be considered to be in violation of the internal control rules.

8. Reporting Methods

1. The methods for whistleblowing by Insiders pursuant to this guideline are as follows:
   1. a. Sending a report by postal mail to the Operations Department of the Financial Holding Company, Etc. (the personnel in charge of the Insider whistleblower program);
   2. b. Sending a report via the computer system of the Operations Department of the Financial Holding Company, Etc. (the personnel in charge of the Insider whistleblower program), or via the exclusive telephone line for accepting Insiders’ reports, e-mail, or the website of DGB Financial Group (through its anonymous reporting channel), etc.

9. Deletion of Reports, etc.

1. 1. a. The head of the Operations Department of the Financial Holding Company, Etc. may delete or modify a whistleblower report if the whistleblower requests such a deletion or modification, or if it is determined that the purpose of the report was obviously to slander or defame another employee without any grounds.
   2. b. Where a report is deleted or modified, the details and grounds thereof shall be separately recorded and maintained and shall be regularly reported to the representative director of the Financial Holding Company or Subsidiary.

10. Reporting the Receipt of Whistleblower Reports

1. 1. a. Upon receipt of an Insider whistleblower report, the head of the Financial Holding Company’s Operations Department shall immediately report it to the representative director of the Financial Holding Company and make it available to the audit committee for inspection.
   2. b. Notwithstanding ‘a’ above, in any of the following cases, the related procedures maybe terminated after deliberation by the Compliance working council. However, in this case, the head of the operating department shall separately record and store the details and reasons therefor and report them to the representative director of the Financial Holding Company on a regular basis.
      1. (1) In cases where it is inappropriate to initiate an investigation due to unclear target or lack of evidence, contrary to ‘7-a’
      2. (2) In case of false accusation for the purpose slander, malign, etc. That falls under ‘7-c’
   3. c. Upon receipt of an Insider whistleblower report, the head of the Subsidiary’s Operations Department shall immediately report it to the representative director of the Subsidiary and the head of the Financial Holding Company’s Operations Department.

11. Investigation

1. 1. a. After reporting the receipt of an Insider whistleblower report to the representative director of the Financial Holding Company, Etc., the head of the Operations Department of the Financial Holding Company Etc. shall immediately investigate to determine whether the report is true.
   2. b. If the head of the Operations Department of the Financial Holding Company, Etc. deems it necessary for an effective investigation, he or she may request that the internal audit committee and the related departments of the Financial Holding Company, Etc. investigate the whistleblower report.
   3. c. If the head of the Investigation Department of the Financial Holding Company, Etc. deems it necessary for the performance of his or her duties, he or she may request that the person subject to investigation and the relevant department submit relevant documents and to appear and make statements.
   4. d. The head of the Investigation Department of the Financial Holding Company, Etc. shall conduct all investigations fairly and independently and shall make the best efforts to improve the internal controls and other relevant programs in the course of conducting these investigations.

12. Investigation Period

1. 1. a. The investigation regarding Insiders’ reports shall be completed within 20 business days from the date of initial receipt of the report.
   2. b. Where the investigation period is to be extended due to unavoidable reasons, it may be extended with the approval of the representative director of the Financial Holding Company or Subsidiary; provided, however, that, the extension of the investigation period shall be limited to the minimum extent.

13. Handling the Results of the Investigation

1. 1. a. After completing the investigation, the head of the Operations Department of the Financial Holding Company, Etc. shall report the results of the investigation to the representative director of the Financial Holding Company; provided, however, that, in the case of a Subsidiary, reporting shall be done through the head of the Financial Holding Company’s Operations Department.
   2. b. If necessary, the head of the Operations Department of the Financial Holding Company, Etc. may request that the head of the relevant department of the Financial Holding Company or the head of the relevant department of the Subsidiary (the “Head of the Relevant Department”) take disciplinary action in accordance with the relevant internal rules.
   3. c. The head of the Operations Department of the Financial Holding Company, Etc. may request that the Head of the Relevant Department rectify or improve any unreasonable procedure, etc. relating to whistleblower reports. After receiving such request, the Head of the Relevant Department shall comply with the request unless there are extraordinary circumstances.

14. Exclusion those involved

1. 2. a. If the representative director of the Financial Holding Company or an employee of the operation department (including the head of the operating department) is related to the report, he or she shall be excluded from the duties under ‘10’ to ‘13’
   3. b. If a whistleblower report relates to the representative director of the Financial Holding Company, the audit committee shall supervise the execution of the process relating to reporting the receipt of the report, investigation, extension of the investigation period, and reporting the results of the investigation under Articles 10 through 13.

15. Notification to Whistleblowers

1. The head of the Operations Department of the Financial Holding Company, Etc. shall, at the request of the whistleblower, notify the whistleblower of the results of the report. Even if it is an anonymous report, it shall be notified in an appropriate manner upon request of the repoter.

16. Confidentiality, Etc.

1. 1. a. The Person Bound by Confidentiality Obligations shall not provide or divulge (including acting in a way that implies) to any third party the details of an Insider’s report, the identify of a whistleblower, or any other matters that directly or indirectly come to his or her knowledge in connection with an Insider whistleblower report.
   2. b. When investigating a report, the head of the Operations Department of the Financial Holding Company, Etc. shall require that the person in charge of the matter and the investigator submit a confidentiality agreement (see the attached form), and the person in charge of the matter and the investigator shall perform their duties fairly and independently in accordance with the terms of such agreement.
   3. c. Any officer or employee in violation of the confidentiality obligations under Paragraphs a and b above may be subject to disciplinary action in accordance with the relevant internal rules.

17. Protection of Whistleblowers

1. 1. a. The Financial Holding Company, Etc. shall not place whistleblowers at a personal disadvantage, for example, in terms of working conditions, on the grounds of the Insider whistleblower report.
   2. b. The head of the Operations Department of the Financial Holding Company, Etc., after determining that the whistleblower has been placed at a disadvantage on the grounds of the whistleblower report, shall request that the Head of the Relevant Department take the relevant corrective action. After receiving such request, the Head of the Relevant Department shall comply with the request unless there are extraordinary circumstances.
   3. c. If the whistleblower requests that his or her workplace be relocated, etc., due to concerns that he or she may be disadvantaged on the grounds of the whistleblower report, the head of the Operations Department of the Financial Holding Company, Etc. shall request that the Head of the Relevant Department take the relevant measures. After receiving such request, the Head of the Relevant Department shall comply with the request unless there are extraordinary circumstances.
   4. d. If it is determined that an officer or employee who has cooperated in an investigation by making statements or otherwise has received or is likely to receive any personal disadvantage on the grounds of such statements, etc., the officer or employee shall be provided the same level of protection as that provided to whistleblowers.
   5. e. Any officer or employee in violation of the duty to protect whistleblowers under Paragraphs a through d above shall be disciplined in accordance with the relevant internal rules.

18. Preferential Benefits and Compensation for Whistleblowers

1. 1. a. The Financial Holding Company may provide whistleblowers with commendations, awards, etc. if it determines that the whistleblower’s report is effective in preventing possible losses to the Financial Holding Company, Etc.
      1. (1) In cases of that the whistleblower’s report prevented or reduced any financial losses of the Financial Holding Company that had already occurred
      2. (2) In cases where finanacial accidents are prevented due to reporting of violation of compliance policy processes although they did not actually occur.
      3. (3) In cases where finanacial accidents are prevented by reporting non-compliance with company regulations and important procedures
   2. b. Commendations, etc. : Decisions regarding commendations, etc. for whistleblowers shall be made in accordance with the HR guidelines and other relevant rules.
   3. c. Awards
      1. (1) The whistleblower compensation committee (the “Committee”) shall be established to determine the payment of awards to whistleblowers, and when awards are to be paid, the whistleblower compensation committee shall be convened to determine the amount of awards, which amount shall not exceed one billion Korean won.
      2. (2) Detail of award
         1. (a) In case a-(1)

            1. (Money unit : Korean won)
               prevented or reduced amount	award criteria
               Less than 500 million won	1%
               more than 500 million won less than one billion won	5 million won + more than 500 million won × 2%
               more than one billion won less than 10 billion won	20 million won + more than one billion won × 2%
               more than 10 billion won	2%

         2. (b) The committee can decide on the details, etc the payment of awards to whistleblowers, when awards are to be paid, prevented or reduced amount
      3. (3) Whistleblower compensation committee
         1. (a) The chairperson of the Committee shall be the compliance officer, and the head of the compliance assistance department, the head of the HR department and the head of the inspection department shall be the members. However, the chairperson may appoint an additional member if he or she determines that a person is not qualified to be a member or if otherwise necessary.
         2. (b) The Committee shall determine the amount of rewards after reviewing the degree of contribution to the prevention of losses, the degree of improvement of practices, the timeliness, the degree of contribution to the improvement of the internal controls culture, the appropriateness of the motives for reporting, etc.
   4. c. Timing and Method of Compensation
      1. (1) When providing commendations, rewards, etc., the method and timing of compensation may be adjusted, for example, through a deferred payment, to prevent the disclosure of the identity of the whistleblower, and the details regarding compensation may not be disclosed to protect the whistleblower.
      2. (2) An anonymous whistleblower may request compensation along with real-name evidence for the contents of the report within up to three years from the date of reporting.
      3. (3) If an Insider submits a whistleblower report to the Financial Holding Company’s Operations Department as an officer or employee of a Subsidiary, the Subsidiary may provide the whistleblower with commendations, rewards, etc. in accordance with the relevant rules of the Subsidiary.

19. Investigation into violation of reporting obligations

1. 1. a. In the event of a financial accident more than 3 hundread million won, The Financial Holding Company, Etc. may investigate whether the relevant executives and employees have violated their obligation to report, if necessary, request disciplinary action in accordance with the relevant internal rules
   2. b. If the executives and employees to be investigated actively cooperate, the reduction may be made.

20. Training

1. The head of the Operations Department of the Financial Holding Company, Etc. shall provide training for Insiders regarding the Insider whistleblower program at least twice a year.

21. Records

1. The head of the Operations Department of the Financial Holding Company, Etc. shall maintain and manage records relating to the operation of the Insider whistleblower program for five years.