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has not yet been made public and may such intention is under the conditions of
significantly affect price of the Company’s the relevant policy before signing for
securities, or securities of other companies acknowledgement.
in the process of joint transactions with the 4.4) Such form, which may be submitted by
Company, they must abstain from performing e-mail, is valid for seven days from the intended
the aforementioned actions until the end trading date.
Bangkok Commercial Asset Management Public Co., Ltd.
of the next business day immediately after 4.5) In case the top executive of the Corporate
such inside information has been entirely Governance and Risk Management Group
disclosed to the public, except for the actions wishes to do the trade, he/she must inform
performed under the exception specified the Chief Executive Officer according to the
by the laws and after consultation with the procedure described above.
Compliance Department.
3.2) Moreover, during the period of 30 days For each trading of BAM securities, the
before the disclosure of the Company’s securities holding period is at least three
quarterly and yearly financial information, months from the transaction date before
the persons designated by the Company selling is allowed. In case of selling, there
must abstain from trading the securities or must be a 3-month lapse before purchase of
entering into derivatives contracts that involve such securities again.
those securities, or from disclosing the inside
information to other persons until the end 5. Report on changes in holding of the Company’s
of the next business day after such financial securities and derivatives contracts
information has been entirely disclosed to the 5.1) Report under Section 59 of the Securities
public. and Exchange Act B.E. 2535 (Form 59)
The Company’s directors, executives
4. Advance notice before securities trading or and auditor are duty-bound to report changes
entering into derivatives contracts that involve in their holding of the Company’s securities
the Company’s securities: and derivatives contracts and holding by
4.1) The persons designated by the their spouses or people living together as
Company who wish to trade securities must husband and wife without marriage certificate,
inform the top executive of the Corporate underage children, as well as juristic persons
Governance and Risk Management Group at in which they, their spouses or people living
least three days before the intended trading together as husband and wife without
date. marriage certificate and underage children,
4.2) The persons designated by the Company hold shares in aggregate amount of more
must fill in the intention notification form for than 30% of the total voting shares of such
securities trading or entering into derivatives juristic person, and the said combined
contracts that involve BAM’s securities (Annex shareholding is the largest proportion in such
1) and send it to the top executive of the a juristic person. The report must be
Corporate Governance and Risk Management submitted through online data transfer system
Group. to the Office of the Securities and Exchange
4.3) Upon receiving such form, the top Commission (Office of the SEC) within three
executive of the Corporate Governance and business days from the date of the sale,
Risk Management Group will consider whether purchase, transfer or acceptance of transfer of

