The Company shall abide with the provisions of law set forth in the Securities Regulation Code and shall implement policies and procedures to prevent the unauthorized disclosure or misuse of material, non-public information in securities trading to preserve the reputation and integrity of the Company.

The objectives are the following:

  1. To provide guidelines to promote compliance to the Securities Regulations Code provision relating to the prohibition of fraud, manipulation and insider trading (Appendix 1).
  2. To maintain the confidence and trust of stakeholders by preserving the reputation of integrity and ethical conduct of the Company as well as all the persons affiliated with it.
  3. To identify the duties of employees and responsible departments in ensuring compliance to the provisions of law and this Policy.

This Policy shall cover:

  1. This Policy shall apply to Company, its subsidiaries and affiliates.
  2. This policy shall apply to all transactions in the Company’s securities as defined in item 7 under the Definition of Terms.
  3. This policy shall cover everyone in the organization who receive, have access to or in possession of material, non-public information (as defined in item 5 under Definition of Terms) about the Company including all:
    1. 3.1. Members of the Board of Directors;
    2. 3.2. Officers;
    3. 3.3. Employees;
    4. 3.4. Advisors, Agents, Consultants, Contractors and other Stakeholders as defined in item 8 under the Definition of Terms);
    5. 3.5. Related Person as defined item 6 under the Definition of Terms.
  4. This policy also applies to material, non-public information relating to any other company with publicly-traded securities, including customers or suppliers obtained in the course of employment with, or the performance of services on behalf of the Company and for which there is a relationship of trust and confidence concerning the information.
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