Supalai Public Company Limited considers inside information and all business information to be important information in the operation and management of its business. Such information is confidential information of the Company that has not yet been disclosed to the public. If disclosed, it may affect the Company, its subsidiaries, associated companies, and the Company’s personnel, particularly by affecting changes in the price or value of shares traded on the Stock Exchange of Thailand. Therefore, the Company’s personnel are required to keep inside information confidential, unless disclosure is authorized or required by law. This requirement also applies to employees of the Company’s subsidiaries and associated companies, who shall comply with this Policy accordingly. The details are as follows:
The directors, executive and employees shall not use inside information of the Company or business trading partners of the Company, that they know from performing duties, to purchase or sell or offer to purchase or sell or persuade others to purchase or sell or offer to purchase or sell securities of the Company or those of the Company’s trading partners for personal gains or for the gains of others. They shall also strictly comply with related laws.
Directors, executives and employees of the Company shall keep confidentiality of inside information under their responsibility and shall not disclose such information to the public or other personnel of the Company who has no involvement.
The Company protects inside information that is not yet disclosed to the public by giving limited access to related and necessary parties only. Security system is also provided for such information. Personnel in charge shall insist that all parties involved must strictly comply with the rules.
A disclosure of information shall be made by authorized persons only. General personnel are not obliged to disclose the information. When asked to reveal information that they do not have authority to disclose, refer a question to the person in charge in order to provide accurate information and in the same direction.
Other than publicly available information, the Company considers all other information as inside information for directors, executives and employees to use under the duties and accountabilities as assigned.
Directors, executives and employees are due to take accountabilities on data protection and shall not exploit the inside information for personal gains even after resigning from the Company by arranging for an interview before resigning in order to return confidential information to the Company, and to remind resigning employee to continue to be responsible for the Company's confidential information after resigning. This shall be done by signing in a written acknowledgement.
The Company requires directors and executives to notify the Company Secretary of any trading in the Company’s securities at least one day in advance of such trading.
The Company's directors and executives are required to submit the list of their securities holding and report on changes of the list to the Securities and Exchange Commission Thailand within 3 working days from the date of purchase, selling, transferring or receiving the transfer of the securities. This is to comply with Section 59 of the Securities and Exchange Act. The directors and executives are also prohibited from buying and selling of the Company’s securities during the period of one month prior to disclosure of financial statements to the public.
The Company requires that the directors and executives report on the change of securities holding to the Securities and Exchange Commission Thailand and submit the copy of the report to the Company on the same day they submit the report to the Securities and Exchange Commission Thailand.
The Company requires that the directors and executives who know essential inside information that has influence on securities price must not buy or sell the Company’s securities for one month prior to the disclosure of financial statement to the public and they shall not disclose such essential information to other people. During 30 days before the disclosure of the financial statements, the Company Secretary shall notify in writing to the directors, executives and related departments who know about inside information not to disclose inside information to outsiders or unrelated persons.
The Company supports a campaign to use inside information via the Company’s communication channel, especially during major events such as an issuance of shares for capital increase or debentures etc.
Anyone who discloses information without consent of the Company and causes damage to the Company and customers shall be subject to penalty according to the law.
The Company has a systematic process for monitoring and reviewing compliance with the Policy on the Use of Inside Information at least once a year and reports the results of compliance with the Policy to the Board of Directors at least once a year. In the event that any violation is found, corrective actions and measures to prevent recurrence are clearly specified.