This CDP shall apply to Straits Group Board, its Management and employees of Straits Group, irrespective of their seniority or designation.

Even though the day-to-day business of the Company handled by the Management, the Straits Board , collectively and individually responsible for the establishment and adoption of a written set of policies and procedures for the Company with regards to the handling and disclosing of material information.

Guided by the ACE Market LR, material information is generally considered to be any information relating to the business, operations and financial performance of the Company that results in, or would reasonably be expected to result in a significant change in:

The members of the Disclosure Committee will be:

The Company’s primary spokesperson to the investment community and the public at large and for media-related inquiries would normally be either the Chairman or the Group Managing Director (“Authorized Spokesperson”) or any other person authorized by the Group Managing Director.

The Authorized Spokesperson may refer media-related inquiries to an external consultant or other person within the Company who are considered experts on the subject matter.

Employees who are not Authorized Spokesperson MUST NOT respond under any circumstances to any inquiries from, or initiate communication with the financial community , shareholders or media. All such communication must be referred to the Group Managing Director

Schedule A provides some of the examples of potentially Material Information.

In the event it is found that material information is leaked and after due enquiry it is found that confidentiality is not maintained, the Company will take appropriate action to make an immediate announcement of the material information to Bursa Securities.

If the Company wishes to make an announcement or release material information pursuant to its disclosure obligations under ACE LR , the CDC will consider such information and will approve the contents of any draft or documents disclosing such information. If needed, Straits Board need to be informed either via a circular or other means of communications.

Other than transactions entered into with related party, the company has determined the threshold for the disclosure of material information for the following transactions:-

Contracts entered into in the ordinary course of business (non-related party)

If requested by Bursa Malaysia or other securities regulatory authority to make a public statement, including a response to a market rumour, the CDC will consider and determine the content of the disclosure.

Authorised Spokespersons may meet with analysts, institutional investors, media and other market professionals on an individual or small group basis as needed and will initiate contacts or respond to their calls in a timely, consistent and accurate fashion in accordance with this Disclosure Policy. If during such meetings or responses to the calls, there is inadvertent selective disclosure of previously undisclosed material information, the Company will immediately disclose such information.

Analysts may from time to time request the Company to review draft analysts’ reports and only Authorised Spokespersons will comment on such reports. Comments will be limited to identifying publicly disclosed factual information that could affect the analyst’s model and to pointing out inaccuracies or omissions with reference to publicly available information. The Company will not attempt to influence an analyst’s conclusions. The Company will not externally distribute analyst’s research reports but, if requested, will advise which analysts follow the Company, accompanied by an appropriate disclaimer that the view expressed in any reports, including all forward-looking information, are the views of the analyst.

Generally, the Company should not entertain market rumours unless the said rumours are malicious and are specifically targeted to injure the reputation of the Company

The Company will undertake due enquiry when there is unusual trading activity or price movement of the Company’s securities. The due enquiry will be undertaken to determine the cause and thereafter issue a clarifying announcement.

All the Company’s publicly disclosed material information and presentations to analysts and conferences will be made available through the corporate website for a reasonable period of time.

Any employee who violates this Disclosure Policy may be cautioned or face disciplinary action up to and including termination of his or her employment with the Company. If it appears that the employee may have also violated certain securities laws, the Company may refer the matter to the appropriate regulatory authorities for further investigations.

The CDC shall have oversight responsibility for this Policy. The CDC will review and provide advice for this Policy to be updated from time to time as needed to ensure compliance with changing regulatory requirements and to ensure the Policy continues to be effective in providing accurate and timely disclosure in accordance with the Group’s disclosure obligations.

Approval of this Policy is the responsibility of the Board.

This revised Policy has been approved by the Board on 26 March 2018

The list provides the types of material information that may require immediate announcement to Bursa Malaysia. It gives a general description of matters which would be regarded as material information. This list is not exhaustive, and is for guidance purposes only.