Chapter 1 General Provision

Article 1 (Purpose and Scope of Application)

The Code of Ethics of ALTEOGEN Inc. (hereinafter "these Regulations") sets forth standards of conduct and value judgment that all executives and employees must observe in their business activities, with the aim of preventing unethical behavior and achieving the company's founding objectives.
These Regulations apply to the executives and employees (hereinafter "Employees") of ALTEOGEN Inc. and Altos Biologics Co., Ltd., which belong to the ALTEOGEN corporate group.

Chapter 2. Standards of Conduct

Article 2 (Basic Ethics of Employees)

• 1. Share the company's management philosophy and faithfully fulfill the mission assigned to each individual in accordance with the goals, values, and business policies pursued by the company.
• 2. Perform duties fairly and fulfill assigned responsibilities; when the interests of the company and those of an individual conflict, prioritize the interests of the company.
• 3. Do not trade in stocks using insider information obtained in the course of business, and do not provide undisclosed information that may affect the stock price to any third party except through lawful procedures.
• 4. Employees shall not use the company's tangible assets, intellectual property rights, trade secrets, etc. for personal purposes, and shall not disclose important information that may affect the company's interests to external parties.
• 5. Do not engage in any conduct that interferes with the work environment, including sexual advances, jokes, or physical contact that causes sexual discomfort.
• 6. Do not accept money, goods, gift certificates, entertainment, or bribes from business-related parties (individuals or companies involved in business transactions).

Article 3 (Ethics towards customers)

• 7. The company always thinks and acts from the customer's perspective, and strives to provide the best products and technologies that customers can be satisfied with and trust, in order to achieve customer satisfaction.
• 8. Customer-related information shall be kept strictly confidential except when necessary for business purposes.
• 9. The company complies with laws and regulations relating to consumer protection.

Article 4 (Ethics towards shareholders and investors)

• 10. Strive to enhance the rights and interests of shareholders and investors by achieving legitimate profits through efficient management.
• 11. Maintain a risk management framework and internal control system to secure the trust of shareholders and investors, manage them rationally, and handle accounting transparently in accordance with generally accepted accounting principles.
• 12. Employees shall thoroughly protect the company's assets and shall not engage in unfair acts such as unfair securities trading using inside information or infringement of trade secrets.

Article 5 (Ethics towards competitors and business partners)

• 13. The company respects the fair and free market economic order based on the principle of free competition and competes fairly with competitors.
• 14. Build mutual trust and cooperation with partner companies through fair transactions to pursue mutual development.
• 15. Refuse misconduct and do not coerce or exert influence in any form of unfair conduct by using a dominant position.

Article 6 (Ethics toward Employees)

• 16. The company does not discriminate against employees based on regional background, blood relations, academic background, gender, religion, age, disability, marital status, etc., and provides fair opportunities according to ability and qualifications.
• 17. Establish evaluation criteria for employees' qualifications, abilities, and achievements, and evaluate and compensate them fairly.
• 18. Create a comfortable and safe working environment and support employees to improve their quality of life, including health, education, and welfare.

Article 7 (Ethics toward Society and the Nation)

• 19. As a member of the nation and the global community, the company complies not only with various domestic laws and regulations but also with internationally recognized laws and regulations.
• 20. The company contributes to the national economy and social development through improvement of productivity, job creation, faithful payment of taxes, and social contribution activities.
• 21. The company does not engage in any conduct that impairs or creates the impression of impairing political neutrality.

Article 8 (Prohibition of Conflicts of Interest)

• 22. Employees shall endeavor to prevent any conduct or relationship that conflicts with the interests of the company in connection with the performance of their duties, and when interests conflict, they must prioritize the interests of the company.
• 23. Conflicts of interest that may exert influence in business or affect the judgment or conduct of members in the performance of business include the following:
  • 1) Entering into a contract or transaction with the company directly or through a third party
  • 2) Engaging in transactions with a competitor or partner company directly or through a third party
  • 3) Concurrently holding a position at a company with conflicting interests without the company's approval
  • 4) Entering into a transaction relationship with a partner company, such as a monetary loan, loan guarantee, or lease of real or personal property
  • 5) Acquiring stocks or bonds of a partner company
  • 6) Transactions between family members or relatives with the company or its partner companies
  • 7) Exerting undue influence by abusing one's business position, such as requesting personnel favors or demanding various conveniences from partner companies

Article 9 (Information Protection)

• 24. Employees shall obtain all information through legitimate means and record and report it accurately.
• 25. Do not manipulate or disregard information for the benefit of any specific individual or group.
• 26. Information such as personal data and stakeholder information shall not be disclosed to third parties without prior permission or approval from the company.

Article 10 (Prohibition of Corruption)

• 27. Employees shall not engage in misconduct such as solicitation, fraud, improper requests, or money laundering for their own or another's unjust profit.
• 28. Acceptance of bribes including cash, entertainment/hospitality is prohibited. Employees shall not accept transportation and accommodation costs incurred during business trips, nor receive any personal conveniences. However, if it is unavoidable to perform relevant sensitive duties, the matter must be reported and approved in the order of: Team Leader → Executive → CEO.
• 29. Employees shall not use budgets for business performance, such as business trip expenses and operating funds, for purposes other than those intended.
• 30. Employees shall not use company-owned assets, such as company vehicles and equipment, for personal purposes without justifiable reason.
• 31. Internal audits are conducted and reports are prepared on a regular basis or in cases of reported or suspected ethics violations or misconduct (Attachment 3).

Article 11 (Corruption Risk Assessment)

• 32. Corruption risk assessments shall be conducted in accordance with the Risk Assessment Form.
• 33. Risk factors with a risk level of 6 or higher shall have improvement measures prepared in accordance with the Risk Improvement Plan.
• 34. The internal audit officer shall verify whether improvement measures have been implemented, re-evaluate the risks after improvement, and confirm the risk level.

Article 12 (Reporting and Handling of Violations)

• 35. When a stakeholder becomes aware that an employee has violated these Regulations, they may report it in accordance with the Ethics Violation Reporting and Handling Procedures.
• 36. The responsible department shall proceed with such reports in accordance with the Ethics Violation Reporting and Handling Procedures.
• 37. In the event of a serious and urgent matter, a direct report shall be made to the CEO, and subsequently reported to the responsible department.

Article 13 (Confidentiality of Informants)

• 38. The responsible department shall maintain the confidentiality of the informant and the reported content, and shall ensure that the informant does not suffer any discrimination or disadvantage as a result of the report.
• 39. Notwithstanding the provisions of Paragraph 1, an informant who has suffered discrimination or disadvantage may request protective measures and remedy of disadvantages from the responsible department, and in such cases, the responsible department shall take appropriate action.
• 40. If an employee voluntarily reports their own misconduct prior to investigation in accordance with these Regulations, disciplinary measures against the informant may be reduced or exempted. However, in such cases, the Personnel Committee shall deliberate separately.

Chapter 3. Supplementary Provisions

Article 14 (Ethics Committee)

• 41. When inquiries and notifications related to ethics issues are received from employees, they shall be handled by the Ethics Committee, and important matters shall be processed in accordance with the resolution of the Ethics Committee.
• 42. The Ethics Committee reviews inquiries from employees, performs monitoring and encouragement functions for the establishment of corporate ethics, and penalizes violations of ethical issues in accordance with in-house regulations and relevant laws depending on the nature of the case, with warnings or otherwise.

Article 15 (Pledge of Compliance with Ethics Regulations)

Employees shall understand the purpose and content of these Ethics Regulations, prepare a pledge committing to their implementation, and submit it to the CEO (Attachment 1).

Article 16 (Enactment, Amendment, and Details of Regulations)

The enactment and amendment of these Regulations shall take effect upon approval by the CEO.

Addenda

(January 1, 2014) These Regulations shall take effect from January 4, 2014.

(September 15, 2021) These Regulations shall take effect from September 15, 2021.

(September 10, 2022) These Regulations shall take effect from September 10, 2022.

(March 4, 2025) These Regulations shall take effect from March 4, 2025.

(April 1, 2026) These Regulations shall take effect from April 1, 2026.