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INDORAMA VENTURES PUBLIC COMPANY LIMITED
The copy of the Minutes was also posted on the Company’s website.
Internal Information The Company has in place a written policy on the use of confidential and/or internal information so as to prevent any illegal use. The statement is prominently displayed at the head office and at the offices and the working places of all its subsidiaries, for the knowledge of all employees. The code of conduct prohibits employees from buying, selling, transferring or accepting the transfer of Company securities by using confidential and/or internal information in any manner that may take advantage of outsiders by using inside information. All directors, senior management, auditors and employees having access to financial statements of the Company are required to make a declaration of their movement in shareholding including their spouse and minor children, to the Company Secretary who in turn presents a summary report to the Board. Also the directors shall file with the company a report, in the form as approved by the Board, on their interest or a related person’s interest in the company or its subsidiaries.
Reporting of and Trading in IVL Securities The Company has in place a written policy on reporting of and trading in IVL Securities. As per this policy no director or “Management” shall directly or indirectly trade in IVL Securities during the period of 15 working days prior to and 2 working days subsequent to the date of filing with the SET of the quarterly and annual financial statements of the Company. Further if any director or management trades in IVL securities, they have to report to SEC in the prescribed form within 3 working days and inform the Company Secretarial Department. Moreover a quarterly declaration on their trading needs to be provided to the Company Secretary. This declaration is also taken from the Company auditors. Every Quarter a summary of the shareholding of Directors is reported to the Board.
Code of Conduct for Directors and Employees The Company has a Code of Conduct, available on its website, which explains among other things the Company’s firm stance against bribery and corruption.
Connected Transactions The Company has in place a detailed policy on connected transaction which is strictly followed. The policy states who is a connected party and what constitutes a connected transaction, the various types of connected transaction and their threshold criteria/values for approval and disclosure purpose and what procedures to follow when there is a new connected transaction. The guideline is circulated at the beginning of each year in order to remind all concerned about the compliance requirement on connected transaction. The Internal Audit Department is responsible to ensure that all connected transactions follow the