THE POLICY ON PREVENTION OF INSIDER TRADING

As a part of good and corporate governance implementation, PT Dharma Satya Nusantara Tbk (“the Company”) established a policy on prevention of insider trading, in which a prohibition for the people inside the Company who know the unpublished material informations toinvolve in trading of shares and other securities owned by the Company and/or other companies who have business relationships with the Company.

This policy objectives aimed at avoiding the conflicts of interest as well as to regulate the Company’s shares or securities trading conducted by people who have special relationships with the Company regarding to take benefit for themselves and others.
The insider people of the Company are the individuals who have special relationships with the Company and have access to the material informations which have not been published to the public. The insiders of the Company who have access to such informations must also not abuse their position in disclosing non-public material information that can influence the investor’s decision.

The insiders of the Company in this policy are as follows:

  1. The Board of Commissioners
  2. The Board of Directors
  3. The Main Shareholders
  4. The Employees
  5. The individual who have the access to obtain the informations relating to his/her job position or profession or legal relationships with the Company.
  6. The certain parties who hold the Company’ confidential informations based on his/her working and business relationship with the Company.

Every insiders of the Company who have material informations as above are prohibited to take the following actions:

  1. To buy or sell shares or securities of both the Company and other parties who have business relationships with the Company.
  2. To influence other parties to buy or sell shares or securities.
  3. To provide insider informations to any potential suspected parties in using the information to buy or sell the shares or securities.

The sanctions to the violations of the above policy will be given accordance with applicable laws and regulations.