Corporate Disclosure Policy

Objective

The objective of this Corporate Disclosure Policy is to provide guidelines and policies in disseminating material corporate information to the public by Protasco Berhad ('Protasco' or 'Company') in accordance with all applicable legal, regulatory requirements with an aim to ensuring that all public disclosures are factual, correct and on a timely and even basis.

Application

This Policy applies to all Protasco's directors, officers, employees, consultants and any other person or company that is engaged or may be engaged in a business or professional activity with Protasco (collectively, Protasco Personnel).

Copy of this policy is made available to all Protasco Personnel either directly or by posting of this policy on the Company's website.

References to 'Protasco' and 'Company' include Protasco Berhad and all of its subsidiaries.

Disclosure Committee

The Company has established a Disclosure Committee who will be responsible for overseeing the disclosure practices, use and setting benchmarks for the assessment of materiality and ensuring adherence to policy, legal and regulatory requirements before its release.

The Disclosure Committee comprised of the following individuals:

  1. Executive Vice Chairman/Group Managing Director
  2. Director, Corporate Affairs Department
  3. Chief Financial Controller
  4. Company Secretary

Members can be added to or removed from the list upon consensus of the existing Disclosure Committee.

Information is considered material if it is reasonably expected to have a material effect on the:

  1. Price, value or market activity of any of its listed securities; or
  2. Investor's decision in determining his choice of action.

Generally, disclosure of the Company's affairs to any person is deemed not material when such disclosure is not expected to affect the person's investment decision and will not give any advantage to the person making his investment decision.

Protasco Personnel must inform the Disclosure Committee of any potential material developments so that it can assess and evaluate if such events could give rise to a disclosure obligation.

Designated Spokespersons

Disclosure of corporate information and communication with investment analysts, potential investors, media or other parties will be made only by individuals who have been authorized for this purpose.

The following personnel are currently authorized as Protasco's primary corporate spokespersons. From time to time, they may authorize other persons to communicate with the media or the investor community.

  1. Chairman
  2. Executive Vice Chairman/Group Managing Director
  3. Director, Corporate Affairs Department
  4. Director, Corporate Finance Department

Anyone who is not authorized must not respond under any circumstances to inquiries on price sensitive information from the investment community, media or other parties. All such inquiries shall be referred to the Corporate Spokespersons.

It is not the intent of this policy to restrict employees from speaking to outside parties. However, when doing so, employees must ensure that any Company information provided is in compliance with this policy and should contact a member of the Disclosure Committee if in doubt about the appropriateness of supplying certain information.

Confidentiality of Information

All Protasco Personnel who are in possession of price sensitive information should not disclose undisclosed material information and shall not disclose confidential information to others prior to the broad public dissemination of that information.

Disclosure of material non-public information to a selected group of people is prohibited.

Protasco Personnel are expected to observe the following:

  1. Not to discuss business affairs in places where the discussion may be overheard.
  2. Confidential documents should not be read or displayed in public places or discarded where they can be retrieved.
  3. Documents and files containing confidential information should be kept in a safe place with restricted access.
  4. Transmission of documents by fax, email or other electronic means should be made only where it is reasonable to assume that transmission can be made and received under secure conditions.
  5. Documents containing confidential information should be promptly removed from conference room and work areas after meetings are concluded and extra copies of confidential documents should be destroyed.
  6. To immediately inform any member of the Disclosure Committee if they believe that there may have been an accidental or unintentional disclosure of material non-public information.

Unintentional Disclosure of Material Non-Public Information

If confidentiality of information is lost or cannot be maintained, the Disclosure Committee shall immediately take all appropriate steps to make immediate announcement of the relevant material information to Bursa Securities.

Consequences of Non-Compliance with Policy

Failure to adhere to this Policy may lead to disciplinary action and will constitute grounds for termination of office and of employment or if it appears that the Listing Requirements have not been complied with, the Company may refer the matter to Bursa Securities.

Amendment to this Policy

Amendment to this policy is at the discretion of Disclosure Committee, except for those that are material, which shall then be brought for the consideration of the Board of Directors.