Internal Information Utilization and Securities Trading Policies

Phol Dhanya PCL (“the Company”) gives the importance to the utilization of the company’s internal information with the commitment in treating all shareholders with transparency, fairness and equality in accordance with good corporate governance. The Board of Directors have implemented the policy of internal information utilization for directors, executives and staff members as guidelines for utilizing the company’s the internal information that has not been announced or disclosed to the public yet and to not directly and indirectly seek for any personal benefits or for other’s benefits. Also, there is the policy of security trading for directors, executives and staff members in accordance with Securities and Exchange Act B.E, notifications of the Securities and Exchange Commission and the related rules and regulations

Policy and Guidelines

1. The company strictly follows or complies with regulations and laws that are related to securities trading by using the internal information that influences on security price as described in Securities and Exchange Act B.E Section 242. The directors, executives and staff members and individuals designated by the company, any person who can access to the internal information or any person who knows the internal information in advance or has the company’s internal information that has not been disclosed yet to the public must confidentially keep the internal information and cannot disclose the information or seek for any benefits from trading securities for oneself or for others either direct or indirect ways and regardless of having or receiving any benefits
2. The directors, executives and staff members and individuals designated by the company including any person who can access to the internal information and any person who are outsiders performing duties and knowing or having or doing any activities related to the company’s internal information must not trade any securities or futures contracts of any security which is related to the internal information undisclosed to the public unless the given actions do not take any advantage of others as specified by the Office of the Securities and Exchange Commission.
3. The directors, executives, staff members, any person who can access to the internal information and any person who is related to the internal information must follow the guideline and procedure that is to not do any securities trading before or after internal information disclosure (Blackout Period) to prevent the risk of using improperly internal information.
4. The directors, executives and staff members working in the company’s finance and accounting department are responsible for doing the report of change in one’s securities ownership including that of spouses and minor children according to the Securities and Exchange Act Section 59 and the notifications of the Securities and Exchange Commission and submit the report regarding to the trading of the company’s securities to the Board of Directors via the company secretary at least 1 day before the transaction date and reports the result to the Board of Directors within 3 days after the transaction date.
5. Directors, executives and staff members, those who are associated with the internal information and staff members who already resigned are prohibited from disclosing the internal information or the Company’s confidential information, as well as partners’ confidential information that one is aware of from performing duties to seek benefits for outsiders or other companies in which one is a shareholder, director, executive or staff member, even though such disclosure is not going to cause any adverse impact on the Company and the Company’s partners. The exception applies to when the information is required by law to be disclosed.
6. With regards to the safety of the information system, the Company controls and/or prevents access to the Company’s information from outsiders and allows rights of access to the information to different levels of staff members, based on authorized duties and responsibilities.