Alucon Public Company Limited (the "Company") places importance on the use of inside information of the Company (the "Company") and is committed to treating all shareholders transparently and equally in accordance with the principles of good corporate governance. Therefore, a policy has been established to supervise the use of inside information by directors, executives, and employees in using inside information of the Company that has not yet been disclosed to the public for personal or other persons' benefits, both directly and indirectly, by enforcing the use of inside information by directors, executives, and employees involved or those who have access to inside information, and also covers spouses, cohabitants, and minor children of such persons.

Inside information means information or news that is material to the change of the price of securities that has not yet been disclosed to the public.  It is considered inside information used in the business operation and is considered the Company's confidential information, which affects the price of the Company's securities traded on the Stock Exchange. Directors, executives, and related employees must therefore keep inside information confidential and must not use this inside information to seek benefits for themselves and related persons in an improper manner.

Trading means buying, selling, transferring, or receiving transfers of securities, whether for themselves or others, and/or legal benefits in securities, including the exercise of rights to purchase shares or exercise rights under warrants to purchase shares or convertible debentures (if any) and inside information means information that has not yet been disclosed to the public or through the general stock exchange system, which is material to changes in the price or value of securities and decisions to buy and sell securities, and a person with access to inside information means a person with a position or duty who knows the inside information of the company, including spouses, cohabitants or minors, and children who have not yet reached the age of majority.

Persons responsible for preparing and submitting reports

1. In the case of being a director or executive of the company, they are responsible for preparing and submitting a report on their own securities holding, including spouses and minor children, according to the methods specified by the SEC (electronic) within 3 business days from the date of securities trading.
2. In the case of being a related person or a person who has access to inside information, they must prepare and submit the first securities holding report within 7 business days from the date of notification from the company secretary, using the securities holding report form and the securities holding change report form specified by the Securities and Exchange Commission.

Duties and responsibilities

1. Executives and employees are responsible for and supervise their subordinates to ensure that they are aware of the importance and understand the policy, including compliance with the policy.
2. Directors, executives, employees who have access to inside information, and related persons or persons who have access to inside information, including persons designated by the company, must comply with the policy, including communicating it to their spouses and minor children.
3. The company secretary informs the person responsible for reporting, persons who have access to inside information, and persons designated by the company of the blackout period in advance.
4. The board of directors Follow up on the implementation of the said measures by reporting changes in the securities holdings of directors and executives through the Company Secretary to present the report of such changes to the Board of Directors meeting.

The practices are as follows:

1. The Company provides training to directors, executives and employees who have access to inside information, including executives in accounting or finance who are at the manager level or equivalent (as defined by the Securities and Exchange Commission and the Stock Exchange of Thailand) on the prevention of the use of inside information and the prevention of conflicts of interest, so that they are aware of the practices and precautions in such matters. In addition, it has emphasized the reporting of the Company’s securities holdings in accordance with Section 59 and the penalties in Section 275 of the Securities Act, including the reporting of the acquisition or disposal of the Company’s securities in accordance with Section 246 and the penalties in Section 298 of the Securities Act, so that all relevant persons are aware and strictly comply with them.
2. It is stipulated that

(a) Directors and executives, including executives in accounting or finance who are at the manager level or equivalent, are required to prepare and disclose a report on their securities holdings issued by the Company, including spouses or cohabitants and minor children, and

(b) juristic persons in which persons under (a) hold shares in aggregate exceeding 30 percent of the total voting rights of such juristic person and such combined shareholding is the largest proportion in such juristic person. According to the announcement of the Securities and Exchange Commission and Section 59 of the Securities Act, within 7 business days from the date of the legal reporting duty and within 3 business days every time there is a change in the purchase, transfer or receipt of securities, by sending it to the Company Secretary to submit to the Securities and Exchange Commission every time and specifying that the Company Secretary summarizes the report of securities holding and changes in securities holding to the Board of Directors' meeting for acknowledgement regularly every 6 months.

3. Prohibits directors and executives, including executives in accounting or finance positions at the manager level or equivalent and related employees who are aware of inside information about the Company's financial statements, financial status or operating results, including other material inside information, from trading, offering to buy or sell, or persuading others to buy, offer to buy or sell, shares or other securities (if any) of the Company, either directly or indirectly, during the period before the release of financial statements or the release of the Company's financial status and operating results until the Company has disclosed the information to the public. The Company will notify the directors and executives to refrain from doing the above transactions in writing at least 30 days in advance before disclosing the information to the public and should wait at least 24 hours after disclosing the information to the public. Then the above transactions can be performed.
4. Prohibiting the Company's directors, executives, employees and employees, including persons who are assumed to know or possess inside information under the Securities Act, from using the Company's inside information that has or may affect the price of the Company's securities that has not yet been disclosed to the public, which they have learned of in their position or status, for trading, offering to buy, offering to sell or persuading others to buy, offer to buy or sell shares or other securities (if any) of the Company, whether directly or indirectly, and regardless of whether such action is for the benefit of themselves or others or revealing such facts to allow others to do so, with or without receiving any benefits in return.
5. Prohibiting the Company's directors, executives, employees and employees, including persons who are assumed to know or possess inside information under the Securities Act, from disclosing inside information or secrets of the Company, including secrets of the Company's business partners that they have learned from performing their duties, to an outsider, even if the disclosure of such information does not cause any damage to the Company or its business partners.
6. Prohibiting the Company's directors, executives, employees and employees, including persons who are assumed to know or possess inside information under the Securities Act, to keep the Company's secrets and/or inside information confidential and prohibiting the Company's directors, executives, employees and employees, including persons who are assumed to know or possess inside information under the Securities Act. Use the Company's secrets and/or inside information for the benefit of other companies
7. The Company's directors, executives, employees and employees, including persons who are assumed to know or possess inside information under the Securities Act, are required to comply with the guidelines for using inside information under the Securities Act and the Public Limited Companies Act, including other relevant regulations.

Penalties for violating the policy

1. Directors, executives
   1. Penalties under Section 275 of the Securities and Exchange Act
   2. Consider penalties such as dismissal or resignation from being a director, executive and have both criminal and civil liability under the Securities Act, as appropriate
2. Employees

Disciplinary punishments shall be determined in accordance with the Company's work regulations, which shall consider disciplinary punishments, including verbal warnings, written warnings, reprimands, up to dismissal or termination of employment, as appropriate, including possible criminal and civil liability under the Securities Act.