In formulating this policy, PMB Technology Berhad (“PMBT” or “the Company”) has taken into account the recommendations contained in the Malaysian Code on Corporate Governance (MCCG) 2017 and its disclosure obligations contained in the Main Market Listing Requirements (“MMLR”) of Bursa Malaysia Securities Berhad (“Bursa Securities”).PMBT is committed to provide accurate, clear and timely disclosure of material information pertaining to the Company’s performance and operations to shareholders, media, investing community and other stakeholdersPMBT will ensure material information concerning the Company is made as freely and widely as practicable and shareholders, media and the investing community have equal access to such information to avoid individual or selective disclosure, subject to compliance with the relevant rules and regulations. The Company encourages exchange of views with its principal stakeholders and will organise its communications to facilitate such dialogue. PMBT will take reasonable steps to ensure that all person invest in its securities enjoy equal access to such information.This Corporate Disclosure Policy applies to directors and employees of the Company and its subsidiaries (“PMBT Group” or the “Group”). It outlines the Company’s approach towards the determination and dissemination of material information especially price-sensitive information, the circumstances under which the confidentiality of the information will be maintained, and prohibitions on insider trading. It also sets out the internal guidelines to facilitate implementation and consistent disclosure practices across the PMBT Group.
2. Rationale and Objective
To develop an effective Investor Relations (“IR”) programme and strategy to communicate the corporate vision, strategies, developments, financial plans and prospects to investors, financial community and other stakeholders fairly and accurately and to obtain feedback from the stakeholders
This policy also aims to: -
3. Procedures and Practices on Corporate Disclosures
4. IR Structure and Responsibility
The Company has established the following IR structure and responsibility for the implementation of IR programme and strategy:-Primary Spokespersons:The Company’s Chief Executive Officer has 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, operation matters, and etc.Secondary Spokesperson:The Head of Corporate Affair may only communicate to audience constituents on information already in the public domain, unless they are authorised by the Primary Spokespersons to undertake broader communications.
5. Mode of DisclosureThe Company makes use of a broad range of communication channels to disseminate information regarding the Company. These would include:
6. IR Programme and StrategiesThe Company has the following programmes and strategies in place to bridge and enhance the relationship with investors or potential investors:-
7. Reports and Rumours
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 (provided always the employee must give prior notification to the Company if he/she is compelled by law to make disclosure). 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 advised 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.
The Company will only withhold material information from the public for legitimate business or regulatory purposes. These include:-
9. Insider TradingA person is an “insider” if that person
Insiders must not trade on the basis of material information which is not known to the investing public.
The relevant provisions of the Capital Markets and Services Act 2007 apply to all insiders.
10. Obtaining FeedbackThe Company has developed various channels for shareholders and major stakeholders to provide their comments and feedback in relation to the Company’s operational, performance, governance and strategic mattersThe Company will consider the relevant comments and feedback received in establishing its corporate strategy.
11. Continuing Training Programme
Continuous learning such as attending seminar and training courses will be recommended on an going basis to uplift the competencies and skills of the spokespersons and enable them to keep abreast with the micro and macro changes.
12. Periodic Review and DisclosureThe policy shall be reviewed periodically by the Board.13. Contact DetailsEmail: email@example.comThis policy is reviewed and approved by the Board on 24 February 2020.
(Pre-Determined Threshold for Announcement to Bursa Securities)
(Important: Notwithstanding the pre-determined threshold, the materiality test under Paragraph 9.03(2) of the MMLR remains applicable)