Anda Asset Management Co., Ltd.

Allegations: ON FEBRUARY 9, 2021, ANDA ASSET MANAGEMENT CO. LTD. ("ANDA") APPLIED FOR BOOK-BUILDING FOR XIILAB (189330 KS EQUITY) THROUGH THE UNDERWRITER, IBK SECURITIES CO., LTD. THE PORTFOLIO MANAGERS OF ANDA KOSDAQ VENTURE FUNDS ("THE FUNDS") DECIDED NOT TO COMMIT TO A LOCK-UP PERIOD, HOWEVER, DUE TO AN ADMINISTRATIVE ERROR ON THE BOOK BUILDING APPLICATION FORM THE FUNDS COMMITTED TO A 1MONTH LOCK-UP PERIOD FROM FEBRUARY 24, 2021 TO MARCH 23, 2021 AND THE FUNDS WERE ALLOCATED AN AGGREGATE OF 503 XIILAB SHARES. XIILAB SHARES WERE LISTED ON THE KOSDAQ MARKET ON FEBRUARY 24, 2021 AND ON THE SAME DAY THE FUNDS SOLD ALL THE ALLOCATED XIILAB SHARES, BREACHING THE LOCK-UP PERIOD AND IN VIOLATION OF SECTION 17.2 OF THE KOREA FINANCIAL INVESTMENT ASSOCIATION ("KOFIA")'S REGULATIONS ON SECURITIES UNDERWRITING BUSINESS. ON MARCH 18, 2021, THE UNDERWRITER NOTIFIED ANDA THE FUNDS BREACHED THE LOCK-UP PERIOD. AFTER CONSULTING WITH ANDA'S CHIEF COMPLIANCE OFFICER AND OUTSIDE COUNSEL, ON MARCH 19, 2021, ANDA RE-PURCHASED THE SAME NUMBER OF SHARES SOLD BY EACH FUND. THE REPURCHASE PRICE WAS LOWER THAN THE FEBRUARY 24 SALE PRICE. THE BREACH WAS REPORTED ON MARCH 26, 2021 TO KOFIA. KOFIA HELD A SELF-REGULATORY COMMITTEE MEETING ON JUNE 17, 2021 AND ON JUNE 18, 2021 IMPOSED ON ANDA A MONETARY FINE IN THE AMOUNT OF KRW 5 MILLION (USD 4,400), TAKING INTO ACCOUNT THE PROMPT AND IMMEDIATE REMEDY ACTIONS TAKEN BY ANDA ONCE ANDA REALIZED THE INADVERTENT MISTAKE. ANDA PAID KRW 5 MILLION (USD 4,400) ON JUN 23, 2021. THE AMOUNT OF THE FINE IS ONE OF THE LOWER AMOUNTS OF THE MONETARY PENALTIES KOFIA COULD APPLY UNDER ITS REGULATIONS. THE FUNDS AND, ULTIMATELY, ITS UNDERLYING INVESTORS, INCURRED NO FINANCIAL LOSS FROM THE ADMINISTRATIVE ERROR AND KOFIA DID NOT CLAW BACK THE GAINS THE FUNDS EARNED FROM THE ERROR. Status: Final Sanction Detail: ON JUNE 18, 2021 ANDA WAS IMPOSED OF A MONETARY FINE IN THE AMOUNT OF KRW 5 MILLION (USD 4,400). ANDA PAID KRW 5 MILLION (USD 4,400) ON JUNE 23, 2021. Summary: UNDER KOFIA REGULATION, SELF-REGULATORY COMMITTEE DECIDES THE AMOUNT OF FINE IMPOSED TO A FINANCIAL INVESTMENT FIRMS IN ACCORDANCE WITH FORMULA SET BY THE REGULATION. KOFIA RENDERED ITS FINAL DECISION ON JUNE 18, 2021.

Allegations: THE KOREAN FINANCIAL SUPERVISORY SERVICE ("FSS"), DURING THE COURSE OF A ROUTINE EXAM IN JUNE 2019, IDENTIFIED THREE SEPARATE TECHNICAL RULE VIOLATION MATTERS FOR ANDA ASSET MANAGEMENT CO., LTD. ("ANDA"). SUBSEQUENTLY, ANDA HAS BEEN ASSESSED PENALTIES BY THE FSS RELATING TO THESE TECHNICAL RULE VIOLATIONS AS OUTLINED IN MORE DETAIL BELOW. (1) ANDA WAS FINED FOR THE ESTABLISHMENT OF AN ENTITY, ANDA GLOBAL, IN MARCH 2015, AND THE EXERCISING OF VOTING RIGHTS FOR THIS ENTITY, WITHOUT OBTAINING PRIOR APPROVAL FROM THE FSC DUE TO AN INADVERTENT ADMINISTRATIVE OVERSIGHT. ANDA GLOBAL WAS AN ONSHORE COMPANY WHOLLY-OWNED BY ANDA AND WAS ESTABLISHED EXCLUSIVELY FOR THE PURPOSE OF HOLDING ANDA'S PROPRIETARY STAKE IN REAL ESTATE IN THE UNITED STATES. ANDA GLOBAL WAS LIQUIDATED IN JANUARY 2020. SINCE ANDA GLOBAL WAS ESTABLISHED IN VIOLATION OF THE ACT ON THE STRUCTURAL IMPROVEMENT OF THE FINANCIAL INDUSTRY ("ASIFI"), THE FSS IMPOSED AN ADMINISTRATIVE FINE ON ANDA IN THE AMOUNT OF KRW 16 MILLION (USD 13,000), TAKING INTO ACCOUNT THE PROMPT AND IMMEDIATE REMEDY ACTIONS TAKEN BY ANDA ONCE ANDA REALIZED THE INADVERTENT MISTAKE. (2) ANDA PROVIDED LOANS TO ITS OFFICERS AND EMPLOYEES TO PURCHASE SHARES IN ANDA, AS PART OF AN EMPLOYEE OWNERSHIP PROGRAM, HOWEVER THE LOANS WERE IN EXCESS OF THE LEGAL LIMIT OF KRW 100 MILLION (USD 82,000), VIOLATING THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT ("FSCMA"). THE FSS IMPOSED A MONETARY FINE IN THE AMOUNT OF KRW 56 MILLION (USD 47,000) AND ISSUED WARNINGS TO ANDA AND ANDA'S FORMER REPRESENTATIVE DIRECTOR. THE IMPOSED FINE IS THE MINIMUM MONETARY PENALTY THAT THE FSS COULD APPLY UNDER THE FSCMA GUIDELINES. (3) IN MAY 2019, ANDA DID NOT VALUE A CONVERTIBLE BOND HELD IN THREE PORTFOLIOS IT MANAGED IN A MANNER CONSISTENT WITH THE FSCMA. THE VALUATION ERROR OCCURRED AS A RESULT OF ANDA WAITING UNTIL THE COURT ACCEPTED THE CONVERTIBLE BOND ISSUER'S BANKRUPTCY FILING. UNDER THE FSCMA, ANDA SHOULD HAVE WROTE OFF THE DEBT AT THE TIME THE ISSUER FILED FOR BANKRUPTCY, ONE WEEK EARLIER. ANDA REIMBURSED ALL INVESTORS WHO SUFFERED A FINANCIAL LOSS AS A RESULT OF THE ERROR, WHILE ANY INVESTORS THAT BENEFITED FROM THE ERROR WERE PERMITTED TO KEEP THEIR GAINS. THE FSS ISSUED WARNINGS UPON ANDA'S OFFICERS AND EMPLOYEES WHO WERE IN CHARGE OF THE VALUATION. THERE WAS NO MONETARY FINE ASSOCIATED WITH THIS BREACH. Status: Final Sanction Detail: THE FSS IMPOSED A MONETARY FINE IN THE TOTAL AMOUNT OF KRW 72 MILLION (USD 60,000). ANDA PAID KRW 12.8 MILLION ON MARCH 11 AND KRW 56 MILLION ON MAY 29. THE REMAINING KRW 3.2 MILLION WAS WAIVED BY THE FSS AS A RESULT OF EARLY PAYMENT OF THE FINE BY ANDA. Summary: UNDER KOREAN REGULATIONS, THE FSS PROPOSED PENALTIES ARE FINALIZED AFTER A FINAL REVIEW IS CONDUCTED BY THE FSC. THE FSC RENDERED ITS FINAL DECISION ON APRIL 1, 2020. AFTER THE FSC RENDERED ITS DECISION, THE FSS ISSUED ANDA AND OFFICIAL NOTIFICATION OF THE RESULTS OF THEIR EXAMINATION ON APRIL 7,2020.