Insider Trading Prevention Policy and Guidelines

1. Policy Objectives

• • To establish guidelines for preventing insider trading.
  • To build investor confidence and ensure compliance with Thai laws.
  • To develop operational frameworks aligned with good corporate governance practices.

2. Scope of Application

• • Applies to directors, executives, employees, as well as their spouses and minor children.
  • Includes legal entities in which the aforementioned individuals hold more than 30% of shares.

3. Definition of Insider Information

Non-public information that may affect stock prices, such as:

• • Financial performance
  • Mergers and acquisitions
  • Dividend announcements
  • Major contracts or new product launches

4. Trading Blackout Period

• • Trading is prohibited for 1 month prior to financial statement disclosure and 1 business day after the disclosure.
  • Applies to directors, executives, and related persons.

5. Policy Principles

The Insider Trading Policy is established to safeguard against the misuse of non-public information for personal gain in securities transactions, thereby maintaining investor confidence and ensuring compliance with Thailand’s securities regulations. This policy extends to directors, executives, employees, affiliated individuals including spouses and minor children, and any legal entities in which these persons possess more than 30% ownership. Insider information encompasses all non-public data that could affect securities prices, such as financial results, mergers and acquisitions, and dividend declarations. The policy mandates a specific blackout period surrounding financial disclosures during which trading activities are strictly prohibited. Additionally, directors and executives are required to report their holdings and any changes in securities. Violations may result in legal consequences, including imprisonment or fines commensurate with the gains obtained. These measures uphold principles of sound corporate governance and adhere to applicable regulatory standards and protocols.

6. Compliance

6.1. Guidelines for Preventing Insider Trading

1. The directors, executives and employees are forbidden from exploitation of inside information that has a significant impact on the Company’s securities trading and the change in share price that has not yet been declared to the public for their personal or other’s interest.

2.Directors, executives, employees, and external parties with insider information must:

2.1) Protect insider information to prevent leaks.

2.2) Avoid sharing insider information with anyone not involved in company duties to prevent misuse.

3. Ensuring the directors and executive officers of the Company including their spouse and minor children report the holding of securities and report the changes in the Company's securities holdings to SEC pursuant to Section 59 and penalty provisions under section 275 of the Securities and Exchange Act B.E.2535 (include the amendment) and send copies of this report to the Company the same day that the reports are submitted to SEC.the Securities transactions of directors and executives, Report on changes in securities trading and prevention of use of inside information.

4.The directors, executives as well as those in the executive positions of accounting or finance unit from the level of manager and above and employees in the unit where inside information is available must refrain from the Company’s stock trading for one month prior to the date of announcement of operation results and financial statement or important information that have impact on the change in the Company’s stock price until such information is declared to the public.

5. The directors, executives as well as those in the executive positions of accounting or finance unit from the level of manager and above shall report ownership of all securities issued by the Company, pertaining to themselves, spouses and/or minor children to the Company Secretary within 30 days after formally assuming the position. Besides, the directors and high-ranking executives shall report to the Board of Directors or the delegated person all of their securities trading at least 1 day in advance in order to notify SEC within three business day after transaction date as specified by the Securities and Exchange Act. More guidelines in the changes in securities and derivatives holding report.   

ดูแนวทางปฏิบัติได้จากการรายงานการเปลี่ยนแปลงการถือหลักทรัพย์และสัญญาซื้อขายล่วงหน้า 

6. The Company secretary is to inform all the closed periods in the yearly meeting plan of the Board meeting announced in advance for directors, executives as well as those in the executive positions of accounting or finance unit from the level of manager and above and relevant employees to refrain from the Company’s stock trading for one month prior to the date of announcement of operation results and financial statement Directors, executives, employees who violate the inside information policy will be subject to disciplinary action and/or the law up to the intent of the act and the seriousness of the offense.

6.2. Securities transactions of directors and executives, Report on changes in securities

1. 1. 1. 1. Directors and executives shall follow SECTION 59.5 identifying A director, manager, person who holds management position as specified in the notification of the SEC Office and an auditor of the securities issuing company under Section 32 or Section 33 shall have the duty to prepare and disclose reports to the SEC Office on each person holding securities and derivatives and the changes to such holding as well as the holding and changes to the holding of their spouse, cohabiting couple and minor children in accordance with the rules and procedures as specified in the notification of the SEC Office.
         2. Directors and executives shall follow the Notification of Capital Market Supervisory Board Sor. Jor 38/2551 in reporting securities holdings pursuant to section59 of the Securities and Exchange Act B.E.2535 as an initial supervisory of their securities transactions as identified as a piece of inside information.
         3. The Directors, executives and management in accordance with the definition of SEC, shall report the Board of Directors or responsible person on their Change of Management’s Securities Holding (Form 59 )at least one (1) day prior to the trading day. The Board prescribes a company secretary shall submit a copy of report to the SEC Office within three business days and within 30 days for a new director from the date on which the company has received such report.