Insider trading is illegal. The purpose of this Policy is:
|a.||to remind the directors, officers and employees of SMRT Holdings Berhad (“Company”) and its subsidiaries (collectively, “Insiders”) with regard to their personal duty and obligation to comply with the relevant insider trading laws and restrictions; and|
|b.||to reflect the seriousness with which the Company views any breach of such provisions on the part of the Insiders.|
Insider trading can take many forms. Among others, the use or disclosure of information that is not generally available, which on becoming generally available would or would tend to have a material effect on the price or value of securities of the Company (“Material Non-Public Information”) by any Insider – whether for personal benefit or the benefit of others – is expressly prohibited. Further details of these prohibitions can be found in Section 188 of the Capital Markets and Services Act 2007 (“CMSA”).
It is important to note that any person who possesses Material Non-Public Information and knows (or ought reasonably to know) that the information is not generally available is regarded as an “insider” for purposes of Section 188 of the CMSA. Penalties for any breach of Section 188 of the CMSA includes imprisonment for a term not exceeding ten years and a fine of not less than RM1 million, as well as civil liabilities pursuant to Section 201 of the CMSA.
Subject to and without derogating from the provisions of Section 188 of the CMSA and other provisions relating to insider trading, the Company wishes to highlight the following:
|3.3||Confidentiality of Material Non-Public Information
|3.4||Other Listed Securities
|All directors, principal officers and other relevant employees (referred to as “affected persons”) are prohibited from dealing in the Company’s listed securities during the Closed Period and as long as he or she is in possession of price-sensitive information relating to the Company’s shares or securities. For purposes of Chapter 14 of the AMLR, a “principal officer” means, among others, the chief executive who is not a director, the chief financial officer or any other employee of the Company or its major subsidiary who has access or is privy to price-sensitive information in relation to the Company.|
Each director, officer and other employee of the Company has the personal responsibility to ensure their respective compliance with laws and restrictions. In this regard, each Insider also has a duty to keep himself or herself duly updated and informed of all relevant prevailing insider trading laws and restrictions on a continuing basis.
In addition to constituting breaches of securities laws, the Company views such breaches of insider trading laws and restrictions seriously. As such, the Company reserves full rights to take further disciplinary and other action (as may be appropriate) against the relevant Insider (such action may include immediate termination of employment).
If you have any questions with regard to this Policy, please direct them to the Managing Director or the Chairperson of the Audit and Risk Management Committee or the Chairman of the Company. For further information with regard to the relevant laws and restrictions in relation to insider trading, and how they apply to (or affect) you personally, please consult your own lawyers or other appropriate professional advisers.