Internal Information Utilization and Securities Trading Policies

Phol Dhanya PCL (“the Company”) places great emphasis on the utilization of internal information of the Company and subsidiaries (“subsidiaries”), with the determination in treating all shareholders with transparency and fairness, based on the principle of good governance. Hence, the Board of Directors have devised the policy governing the directors’, executives’ and staff members’ utilization of internal information that has not yet been disclosed to the public to seek personal benefits or for benefits of other individuals both directly and indirectly. With this, the Company has identified protocols in preventing the inappropriate use of internal information as follows:

Ways of Practices

1. It is regulated that the Company’s directors and executives are required to prepare reports on changes of one’s securities ownership, including that of spouses and children who have not attained legal age within 3 working days after the purchase, selling, transfer or receiving of securities, according to the Securities and Exchange Act Section 59 to the Securities and Exchange Commission and the Stock Exchange of Thailand, using means regulated by the SEC.
2. Directors, executives and staff members who are aware of the Company’s internal information must keep it strictly confidential and not disclose it to the public or seek benefits by trading such securities for oneself or for benefits of others both directly and indirectly, regardless of whether or not the benefits are obtained from doing so.
3. Directors, executives and staff members or those who are associated with the internal information are prohibited from buying or purchasing the Company’s securities during the 30-day blackout period prior to the disclosure of the quarterly and annual financial statements or internal information to the public, and during the 24-hour period after the financial statement or internal information is disclosed to the public and has been notified to the Stock Exchange of Thailand, and other periods as identified by the Company.
4. 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.
5. 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.
6. Directors, executives and staff members, notify the board (via company secretary) regarding the trading of the company's shares at least 1 day in advance of trading and report the result to the Board of Directors within 3 days after the transaction date.