Nautilus Investment follows 'Principle on the Stewardship Responsibilities of Institutional Investors' enacted and
published by the Korea Stewardship Code Council of the Korea Corporate Governance Service.
We have introduced and are implementing the Stewardship Code as follows:

Principle 1

Institutional investors, as a steward of assets entrusted by their clients, beneficiaries, etc, to take care of and manage, should formulate and publicly disclose a clear policy to faithfully implement their responsibilities.

As a steward, we faithfully fulfill our fiduciary duty as prudent managers, prioritizing the interests of investors. We diligently carry out our responsibilities in accordance with relevant laws, fund agreements, articles of association, and internal regulations and procedures.

We pursue comprehensive risk management by formulating risk management regulations to minimize investment and operational risks, and to ensure stability.

In addition, when potential conflicts of interest arise during the management of investment assets, we will faithfully fulfill our stewardship responsibilities by informing the investors of the relevant details and engaging in prior consultation to ensure that the interests of investors are not infringed.

We will maximize long-term benefits for investors by regularly monitoring key management issues of the investee companies, exercising voting rights at shareholder meetings, providing counsel through communication with the management team to strive for the value enhancement and continuous growth of the company.

Principle 2

Institutional investors should formulate and publicly disclose an effective and clear policy as to how to resolve actual or potential problems arising from conflicts of interest in the course of their stewardship activities.

We have established internal control standards to prevent conflicts of interest between our company and investors, as well as between specific investors. We assess the possibility of conflicts of interest and manage them appropriately according to methods and procedures. Additionally, we have appointed a compliance supervisor to monitor and supervise compliance with internal control standards, aiming to minimize the potential for conflicts of interest.

As a trustee, if we determine that conflicts of interest may arise during the process of fulfilling our responsibilities, we will disclose relevant information to investors and ensure that the trustee's responsibilities are fulfilled faithfully through prior discussions, so as not to compromise the interests of investors.

Principle 3

Institutional investors should regularly monitor investee companies in order to enhance investee companies’ mid- to long-term value and thereby protect and raise their investment value.

We foster value enhancement and continuous growth of investee companies by regularly (monthly, bi-monthly, quarterly, depending on the status of the investee company) visiting them to discuss with the management team about key issues. Additionally, we conduct quarterly portfolio reviews to assess the situation of investee companies and ensure their progress.

Our investment team actively participates in major decision-making through real-time monitoring. If necessary, we may appoint our investment personnel as non-executive directors in investee companies, enabling closer collaboration and guidance. This fosters various financial support such as subsequent funding, IPO, as well as non-financial support such as industry connections, HR assistance, and exploring M&A opportunities. Through these efforts, we strive to enhance the company's value and achieve sustained growth, maximizing long-term benefits for our investors.

Principle 4

While institutional investors should aim to form a consensus with investee companies, when necessary, they should formulate internal guidelines on the timeline, procedures, and methods for stewardship activities.

We are actively endeavoring to form a consensus with investee companies with regard to key financial and non-financial management matters based on their pursuit of the mid- to long-term value enhancement of the investee company and their investment and stewardship policies, etc.

In the course of active shareholder activities, we comply with the Capital Markets Act's provisions on the prohibition of the use of undisclosed important information, and we will not benefit from transactions based on information superiority using internal information that has a significant impact on company value.

Principle 5

Institutional investors should formulate and publicly disclose a voting policy that includes guidelines, procedures, and detailed standards for exercising votes in a faithful manner, and publicly disclose voting records and the reasons for each vote so as to allow the verification of the appropriateness of their voting activities.

We exercise our voting rights based on sufficient information collection and analysis, in-depth review of the target company, conversation and participation results, and discussion with the target company in advance if necessary. In addition, the details of the exercise of voting rights and related issues are reported to funds and investors in accordance with the established procedures.

We are building up internal resources, organizational structures, and professional capacity to ensure that our voting rights are exercised in order to enhance the mid-to long-term value of investee companies and to advance the interests of clients and beneficiaries.

Principle 6

Institutional investors should regularly report their voting and stewardship activities to their clients or beneficiaries.

As a principle, we prepare semi-annual reports on the status of investee companies, progress in post-investment management, and voting activities, fulfilling our responsibilities as a steward for our investors.

In addition, we hold regular and extraordinary general meetings to report and seek approval from investors on the fund's operational status and significant matters that arise.

Principle 7

Institutional investors should have the capabilities and expertise required to implement stewardship responsibilities in an active and effective manner.

We are composed of professionals with extensive experience and expertise in various industries, including IT, manufacturing, and telecommunications, acquired through long-term investments. Furthermore, to enhance expertise specific to investment industries and ensure faithful fulfillment of stewardship responsibilities, we support job-related training programs and participation in relevant industry seminars for our staff.

We encourage and support our operational staff to maintain and enhance their expertise and capabilities in line with the rapidly changing investment landscape. To achieve this, we have established a performance-based reward system, motivating them to be fully committed to stewardship activities.