Corporate Disclosure Policy and Procedures

1. Introduction
In formulating this policy, Berhad (the “Company”) has taken into account the recommendations contained in the Malaysian Code on Corporate Governance (MCCG) 2012 and its disclosure obligations contained in the Main Market Listing Requirement of Bursa Malaysia Securities Berhad (“Bursa Securities”).


2. Rationale and Objective
To develop an effective Investor Relations (“IR”) programme and strategy to communicate the corporate vision, strategies, development, financial plans and prospects to the investors, financial community and other stakeholders fairly and accurately and to obtain feedback from the stakeholders.
This policy also aims to:-
• Develop and maintain a positive relationship with all the shareholders and stakeholders through active two-way communication; and
• Promote and demonstrate a high standard of integrity and transparency through timely, accurate and full disclosure.


3. IR Structure and Responsibility
The Company has established the following IR structure and responsibility for the implementation of the IR programme and strategy:-


• Independent Non-Executive Chairman
• Designated Person of Fund Manager
The Company’s Independent Non-Executive Chairman and the Designated Person of Fund Manager have been appointed to communicate with audience constituents and respond to questions in relation to the corporate vision, strategies, developments, future prospects, financial results and plans, operational matters, etc.


4. Mode of Disclosure
The Company makes use of a broad range of communication channels to disseminate information regarding the Company. These would include:-

4.1. Electronic facilities provided by Bursa Securities;
4.2. Press releases;
4.3. Letters to shareholders
4.4. Corporate website;
4.5. Emails;
4.6. Oral statements made in group meetings, individual meetings and telephone conversations with members of the investment community (which includes analysts, investors, investment dealers, brokers, investment advisers and investment managers) or with employees; Road shows or events, industry and investor conferences;
4.7. News conferences; and
4.8. Annual General Meetings / Extraordinary General Meetings


5. IR Programme and Strategies
The Company has the following programmes and strategies in place to bridge and enhance the relationship with investors or potential investors:-

5.1. Announcement of Material Information and Press Release
After the approval from the Board of Directors on releasing material information is obtained, an announcement is made to Bursa Securities and/or a company press release will be issued to all major newspapers.

5.2. Annual General Meeting or Extraordinary General Meeting and Press Conference
The Annual General Meeting / Extraordinary General Meeting / Press Conference is held to communicate with the shareholders on the Company’s performance, strategy, proposed corporate exercises, outlook and operational matters.

5.3. Annual and Quarterly Financial Reports
The annual report and quarterly financial reports are submitted to Bursa Securities and are also available on the corporate website of the Company.

5.4. Meetings or Interviews with Investors, Analysts and Media
The spokespersons will meet the shareholders, analysts or media to update them on the Company’s performance, strategy and development.

5.5. Corporate Website
The Company has established a corporate website to reach out to current and potential investors.

5.6. Weekly announcement of Net Asset Value/Indicative Optimum Portfolio Value
The Company releases weekly announcements of its net asset value/indicative optimum portfolio value to Bursa Securities pursuant to Paragraph 9.42 of the Main Market Listing Requirements of Bursa Securities.


6. Reports and Rumours
6.1. Analysts’ reports
It is the Company’s policy not to provide focused guidance to analysts in their efforts to develop their financial reports or earnings estimate of the Company. The Company will point out factual errors or assumptions which are inconsistent with previously announced information.

6.2. Rumours
It is the Company’s policy not to respond or comment on market rumours and speculation, unless they appear to contain material information or misinformation, or may be reasonably expected to affect the price of the Company’s securities or trading activity in those securities.


7. Obtaining Feedback
The Company has developed the following channels for shareholders and major stakeholders to provide their comments and feedback:-

The Company will consider the relevant comments and feedback received in establishing its corporate strategy.


8. Maintaining Confidentiality
Any employee privy to confidential corporate information is prohibited from communicating such information to anyone else, unless it is necessary to do so in the course of business or required by law. Efforts will be made to limit access to such confidential information to only those who “need to know” the information.

Outside parties privy to undisclosed material information concerning the Company will be told that they must not divulge such information to anyone else. Management shall ensure that such outside parties confirm their commitment to non-disclosure under a written confidentiality agreement.


9. Periodic Review
The policy shall be reviewed annually by the Board.

This policy is dated 10 April 2017.