Chapter 1 General Provisions

Article 1【Purpose】
This regulation aims to provide ethical judgment and behavioral standards for employees of ICONIX Co., Ltd. (hereinafter referred to as 'the Company') to practice ethical management. Employees shall comply with the provisions based on the spirit of ethical management and create an honest corporate culture that the spirit of ethical management aims for.

Article 2【Scope of Application】

① This regulation applies to the entire company and domestic and overseas subsidiaries unless there are special provisions in laws, articles of incorporation, or other company regulations.

② This regulation applies to all stakeholders who have relationships with the Company, including employees, customers, business partners, shareholders, the nation, and society.

Chapter 2 Building a Sound Corporate Culture

Article 3【Company's Obligations to Employees】
The Company makes every effort to create a working environment that can simultaneously satisfy the company's development and the fulfillment of each member as follows.

① The Company respects employees as independent individuals and enables each employee to have pride and fulfillment in their work based on a sense of ownership.

② The Company applies fair standards in personnel management and operation of all systems, and does not discriminate based on educational background, region of origin, gender, age, appearance, etc.

③ The Company fairly evaluates employees based on their performance and abilities, and provides fair and reasonable compensation to individuals and organizations according to their contribution to company performance.

④ The Company discovers and recruits excellent talent through systematic human resource management and develops them into outstanding personnel.

⑤ The Company provides a working environment that maximizes work capabilities by reflecting individual competencies and intentions in work to the fullest extent.

⑥ The Company ensures that all employees have equal opportunities for job capability expansion and self-development.

⑦ The Company shares overall information about the business environment and company operations with employees.

⑧ The Company continuously improves the working environment so that employees can work in a pleasant and healthy state.

Article 4【Employees' Obligations to the Company】

① Employees faithfully perform their duties for the company's growth and development.

② Prohibition of Unfair Acts

1. Employees shall not engage in unfair acts such as using internal information for securities trading or infringing on company secrets.

2. Employees shall not commit misconduct during work performance using their position, etc.

③ Employees do not engage in inappropriate words or actions that may hinder the working environment, such as unauthorized drinking on company premises, or cause social controversy.

④ Employees do not receive money, entertainment, or favors from business partners and other stakeholders, or engage in unfair acts using their superior position.

⑤ When there is a conflict of interest with the company, employees prioritize and act in the company's interests.

⑥ Protection of Company's Tangible and Intangible Assets and Important Information

1. Employees must protect the company's physical assets, intellectual property rights, trade secrets, etc., and shall not use them for private purposes.

2. Employees do not leak important information that may affect the company's interests to external parties.

⑦ Employees do not embezzle or misappropriate company assets for private use.

⑧ Employees do not engage in acts that may cause conflicts of interest.

Article 5【Relationships Among Employees】

① Employees value mutual cooperation for common goals and do not engage in acts that promote departmental selfishness or unnecessary conflicts.

② Employees engage in company life as members of the community by observing the etiquette that should be maintained as workers among each other.

③ Employees faithfully perform their duties for mutual growth and development.

④ Supervisors cannot instruct or force work that violates laws and company regulations, and employees can refuse to perform work if they receive work that violates laws and company regulations from their supervisors.

⑤ Employees do not engage in inappropriate acts such as sexual harassment, inappropriate receipt of money, borrowing money and joint guarantees, or improper solicitation among each other.

Chapter 3 Customer Respect

Article 6【Customer Respect】
Customers are the foundation on which companies live and provide the reason for a company's existence. Therefore, we must create customer value from the customer's perspective to gain their trust, and always strive to respect customers and reflect their opinions.

Article 7【Customer Information Protection】
We safely store and manage customer information in accordance with relevant laws and regulations, and pay maximum attention to ensure that customers' privacy is not violated.

Article 8【Fulfillment of Promises with Customers】
When dealing with customers, we approach with a courteous and sincere attitude and strive to keep promises with customers.

Chapter 4 Enhancement of Shareholder Value

Article 9【Enhancement of Corporate Value】
The Company strives to increase corporate value through reasonable investment and transparent and sound management to ensure shareholder interests. In addition, the Company guarantees shareholder rights, respects shareholders' legitimate demands and reasonable proposals to the maximum extent, and makes continuous efforts to receive fair evaluation of corporate value from investors.

Article 10【Ensuring Transparency of Accounting Data】
For sound management, the Company manages to maintain the accuracy and reliability of accounting data.

Article 11【Enhancement of Shareholder Benefits】
The Company strives to increase actual shareholder benefits by developing profitable content through continuous research and efforts, thereby increasing company profits.

Article 12【Enhancement of External Credibility】
The Company enhances corporate value by establishing transparent and reasonable management to improve the company's external credibility.

Chapter 5 Respect for Business Partners

Article 13【Fair Transactions】
The Company pursues mutual development by building mutual trust and cooperative relationships through fair transactions with business partners.

Article 14【Prohibition of Unfair Acts】
The Company does not force or exercise influence in any form of unfair acts using its superior position.

Chapter 6 Social Contribution

Article 15【Compliance with Laws and Regulations】
The Company establishes and practices the correct values that a company should have, complies with various laws and regulations of the nation and local communities, and respects international law, international treaties, and international commercial customs.

Article 16【Social Activities】
As a member of the local community, the Company provides useful services to the local community and citizens, participates in various social and cultural activities to contribute to social development, and actively supports employees to fulfill their rights and duties as citizens.

Article 17【Avoidance of Unfair Competition】
As a holding company of a cultural convergence group that creates a prosperous life, the Company pursues good-faith competitive activities based on mutual respect with competitors and does not engage in unfair competition.

Chapter 7 Measures for Violations

Article 18【Measures for Ethics Violations】

① When it is unclear whether this regulation has been violated during work performance, employees should consult with the ethics management department and handle it after consultation.

② Employees who become aware that company policies or personal actions violate ethical management must immediately notify management and the ethics management department, and the Company conducts a fact-finding investigation without delay.

③ The ethics management department must provide immediate and accurate answers to inquiries related to ethical management and thoroughly investigate reports related to violations of ethical management.

④ The ethics management department must give the reported person an opportunity to explain after confirming the reported violation.

⑤ The Company must ensure confidentiality regarding the reporter and the report content, and the reporter does not receive any disadvantage as a result.

Article 19【Delegation Regulations】
The specific judgment criteria and behavioral guidelines for this ethics regulation are separately established and operated in the "Ethics Code of Conduct."

Addendum

Article 1【Effective Date】 This regulation takes effect from November 1, 2024.