Notice Concerning Replacement of

Interest Rate Benchmark

1. What is LIBOR?

The London Interbank Offered Rate (“LIBOR”) has been widely used in the calculation of interest and other payments under loans, derivatives and other financial products in the global financial market. LIBOR is determined based on submissions provided by a panel of banks, and these submissions are intended to reflect interest rate at which global banks could borrow money on unsecured terms from each other for various set periods for five different currencies consisting of U.S. dollar, British Sterling Pound, Euro, Yen and Swiss Franc.

The loan agreement you entered into with The Export-Import Bank of Korea (‘KEXIM”) utilizes LIBOR to determine floating interest rate applicable to your loan.

2. Why does LIBOR need to be replaced as an interest rate benchmark?

Regulators and policymakers have undertaken an in-depth review of the use of LIBOR as a benchmark for interest rates, particularly when it was discovered that LIBOR was manipulated by certain panel banks in 2012. In the process of their review, regulators have recognized that the lack of active interbank market and the scarcity of term unsecured deposit transactions raised serious questions as to whether LIBOR can continue to serve as a viable benchmark. The Financial Conduct Authority of UK (“FCA”), which oversees LIBOR setting activities, announced in July of 2017 that it will no longer require banks to submit the rates required to calculate LIBOR after 2022.

Following such findings, FCA, the Bank of England, Alternative Reference Rate Committee convened by the Federal Reserve Bank of the United States and other regulators of major economies have warned that starting from 2022, the determination of LIBOR may permanently cease. They have also continued to strongly urge the market participants to replace LIBOR with an alternative benchmark for determining interest rates and recommend that a risk-free rate (“RFR”) be used for such purpose. For more information on RFRs that are currently published by major administrators around the world, please refer to the Table below.

3. What replacement benchmarks are available?

Working groups have been formed in each of the U.S., the United Kingdom, the European Union, Japan, and Switzerland with a goal of identifying alternative rate that can replace LIBOR for its respective currency.

In the U.S., the Alternative Reference Rates Committee (“ARRC”), a group convened by the Federal Reserve Board and the Federal Reserve Bank of New York, for the purpose of identifying alternative benchmark rates, has identified the Secured Overnight Financing Rate (“SOFR”) as its preferred alternative rate for USD LIBOR. SOFR is a measure of the cost of borrowing cash overnight, collateralized by U.S. Treasury securities.

4. What measures will be taken by KEXIM to transition into replacement benchmark rate?

In the event that LIBOR is discontinued, it will no longer be possible for KEXIM to determine interest rate that will be applicable to a loan which matures after such event. Although the loan agreement which KEXIM has entered into with you contains a provision relating to a disruption in determination of LIBOR, KEXIM believes it is necessary to amend the loan agreement to provide additional certainty regarding the replacement benchmark that will be used in case LIBOR is discontinued or is no longer considered to be a representative rate by the relevant regulatory or supervisory body.

5. How will the loan agreement be amended?

KEXIM proposes to amend the loan agreement by inserting the following fallback provisions that relate to the replacement of LIBOR as a benchmark rate recommended by ARRC.

(a) Any of the following events will trigger the replacement of a benchmark (the “Benchmark”) with a replacement benchmark rate:

(1) a public statement or publication of information by or on behalf of the administrator of the then-current Benchmark (or the published component used in the calculation thereof) announcing that such administrator has ceased or will cease to provide all available tenors of such Benchmark (or such component thereof), permanently or indefinitely, provided that, at the time of such statement or publication, there is no successor administrator that will continue to provide any available tenor of such Benchmark (or such component thereof);

(2) a public statement or publication of information by the regulatory supervisor for the administrator of the then-current Benchmark (or the published component used in the calculation thereof), the Board of Governors of the Federal Reserve System, the Federal Reserve Bank of New York, an insolvency official with jurisdiction over the administrator for such Benchmark (or such component), a resolution authority with jurisdiction over the administrator for such Benchmark (or such component) or a court or an entity with similar insolvency or resolution authority over the administrator for such Benchmark (or such component), which states that the administrator of such Benchmark (or such component) has ceased or will cease to provide all available tenors of such Benchmark (or such component thereof) permanently or indefinitely, provided that, at the time of such statement or publication, there is no successor administrator that will continue to provide any available tenor of such Benchmark (or such component thereof); or

(3) a public statement or publication of information by the regulatory supervisor for the administrator of the then-current Benchmark (or the published component used in the calculation thereof) announcing that all available tenors of such Benchmark (or such component thereof) are no longer representative.

(b) The replacement benchmark will be designated and become applicable in the following order:

(1) the sum of: (A) Term SOFR and (B) the related Benchmark Replacement Adjustment;

(2) the sum of: (A) daily simple SOFR (calculated based on a lookback in accordance with the methodology recommended by the Relevant Governmental Body) or alternatively, daily compounded SOFR (calculated by compounding in arrears with a lookback in accordance with the methodology recommended by the Relevant Governmental Body), as selected by KEXIM in its sole discretion and (B) the related Benchmark Replacement Adjustment;

(3) the sum of: (A) the alternate benchmark rate that has been selected by KEXIM as the replacement for the then-current Benchmark for the applicable corresponding tenor giving due consideration to (i) any selection or recommendation of a replacement benchmark rate or the mechanism for determining such a rate by the Relevant Governmental Body or (ii) any evolving or then-prevailing market convention for determining a benchmark rate as a replacement for the then-current Benchmark for U.S. dollar-denominated syndicated or bilateral credit facilities at such time and (B) the related Benchmark Replacement Adjustment.

(c) “Benchmark Replacement Adjustment” means, for any interest period:

(1) If the Benchmark Replacement is the rate specified in paragraph (b)(1) or (b)(2) above, then the spread adjustment as of the reference time such Benchmark Replacement is first set for such interest period that has been selected or recommended by the Relevant Governmental Body; and

(2) If the Benchmark Replacement is the rate specified in paragraph (b)(3) above, then the spread or adjustment selected by KEXIM for the applicable corresponding tenor.

(d) “Relevant Governmental Body” means the Board of Governors of the Federal Reserve System or the Federal Reserve Bank of New York, or a committee officially endorsed by the Board of Governors of the Federal Reserve System or the Federal Reserve Bank of New York.

(e) “Term SOFR” means, for the applicable corresponding tenor as of the applicable reference time, the forward-looking term rate based on SOFR that has been selected or recommended by the Relevant Governmental Body.

6. What happens if no amendment agreement is entered into with KEXIM to provide for the replacement benchmark rate?

If LIBOR is discontinued or otherwise ceases to be a representative rate, and no amendment providing for a replacement benchmark as proposed above is entered into with you, then KEXIM will notify you of a market disruption event in accordance with the relevant provision of the loan agreement. If KEXIM fails to reach an agreement with you regarding the replacement benchmark rate within the period prescribed in the loan agreement, interest will accrue on the loan at the rate per annum equal to the aggregate of (i) the applicable margin and (ii) the cost to KEXIM of funding such loan as reasonably determined by KEXIM.

7. General risks related to use of a replacement benchmark rate, such as SOFR as a reference rate

An RFR, such as SOFR, is typically lower than LIBOR, and an adjustment spread may need to be added to make RFR comparable to LIBOR.  However, even with such adjustment, the amount of interest payable by you under the loan agreement may be higher or lower than the interest you would have paid with LIBOR as the benchmark rate.

You may need to make operational changes and incur additional administrative costs in connection with implementing the replacement of LIBOR with a replacement benchmark rate.

Replacement of LIBOR with a replacement benchmark may have unintended consequences, such as creating material economic mismatches. Such mismatches, for example, may occur in connection with a hedging or similar transaction. In addition, in the event that a hedging transaction is terminated due to replacement of LIBOR, you may need to make payment to the hedging provider in connection with such termination.

This notice is provided as general information only, based on information available to KEXIM as of the date of this notice. This notice is not intended to provide you with exhaustive overview of all information and risks related to benchmark reforms or benchmark replacement. This notice does not constitute and should not be relied upon for tax, legal, investment, regulatory or accounting advice. Any decision you make regarding the subject matters addressed in this notice must be made based solely on your independent investigation and analysis.

[Table] Risk-Free Rates Published by Major Administrators

Country	Reference Rate to be Replaced by RFR	RFR	Administ- rator	Introduced in
United States	USD LIBOR	SOFR (Secured Overnight Financing Rate)	Federal Reserve Bank of New York	April 2018
United Kingdom	GBP LIBOR	SONIA (Sterling Overnight Index Average)	Bank of England	April 2018
European Union	EUR LIBOR, EURIBOR, EONIA	ESTR (Euro Short-Term Rate)	European Central Bank	October 2019
Switzerland	CHF LIBOR	SARON (Swiss Average Rate Overnight)	SIX Swiss Exchange	August 2009
Japan	JYP LIBOR, TIBOR	TONAR (Tokyo Overnight Average Rate)	Bank of Japan	December 1992

(Source: Korea Capital Market Institute, Alternative Benchmark Rates Developed by Major Countries and the Implications for Korea)

I, the undersigned, hereby acknowledge that I have read and understand the contents of this notice.

Signature   : ___________________________

Print Name : ___________________________

Date       : ___________________________