Are venture capital firms and professional investors that invested before a KOSDAQ listing also subject to mandatory holding?

According to the Korea Exchange's guidance on KOSDAQ listing review, venture finance firms and professional investors whose investment period is less than 2 years as of the preliminary listing review application date (excluding shares, etc.

acquired through public offerings or sales) must hold their shares for 1 month to prevent short-term trading gains, applied to each within a limit of 10% of the company's capital as of the listing application date. Shares, etc. that they newly acquired through a third-party allotment and held until the review application date follow this standard instead of the 6-month mandatory holding applied to ordinary third-party allotment acquirers. For new shares received on conversion of convertible bonds or exercise of warrants, whether mandatory holding applies is judged based on when the bond was acquired, not when the new shares were acquired.