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Securities Transactions

Code of Best Practices of Securities Transactions by the Company and its Officers


As a company listed on the Singapore Exchange, the Company is required to ensure that the Company and its officers comply with this Code of Best Practices on Securities Transactions (“the Code”).

The Company and its officers are prohibited from dealing in the Company’s securities outside the window period and clearly should refrain from doing so unless under extenuating or exceptional circumstances.

Officers should not deal in the Company’s securities on short-term considerations and should be mindful of the law on insider trading.

Securities and Futures Act

Officers should note that it is an offence to deal in the Company securities (as well as securities of other listed companies) while in possession of unpublished material price-sensitive information.


Officers (both Company and its subsidiaries) include:

  • Directors (Executive and non-Executive)
  • Chief Executive Officer
  • Chief Financial Officer
  • Chief Operating Officer
  • Company Secretary
  • All General Managers
  • Heads of Department
  • All levels of staff in the Finance Department

Window Period

The Company and its Officer are prohibited from dealing in the Company’s securities when the window period is closed.

The window period is “closed” commencing two weeks before the announcement of the Company’s financial statements for the first, second and third quarters of its financial year and one month before the announcement of the Company’s financial statements for its full financial year and ending after the announcement of the relevant results.

Officers will be notified of the “closed” window period by the Chief Financial Officer through internal memo.

Director’s Disclosure

Directors are required to notify their dealings in securities:

  • To the Company, under the provisions of Section 165 of the Companies Act, Cap. 50; and
  • To the Exchange, under the provisions of Section 137 of the Securities & Futures Act, Cap. 289, if they are also substantial shareholders.

The notification must be made within two (2) business days.