Investor Relations Policy and Internal Compliance Code on Dealing with Securities Transactions
- Sasseur Asset Management Pte. Ltd. (the "Manager"), as Manager of Sasseur REIT, is committed to achieving effective communication with the public and ensuring both individual and institutional unitholders as well as the investment community are provided with timely and equal access to balanced and understandable information about Sasseur REIT.
- General Principles
- The Manager is committed to making announcement and distributing all information to public in accordance with the listing rules stipulated by the Singapore Exchange Securities Trading Limited ("SGX-ST"), the Singapore Code of Corporate Governance 2018 issued by Monetary Authority of Singapore ("MAS"), and the best-known practices.
- All announcements on SGX-ST through SGXNET shall be made available on Sasseur REIT's own corporate website.
- The Manager strives to provide accurate, balanced and transparent information to its Unitholders and the investment community timely and in clear and plain language. The Manager will communicate only through its designated spokespersons.
- The Manager usually does not comment on rumours. If rumours are likely to have a strong impact on the Sasseur REIT's unit price, appropriate announcements will be made on SGX-ST to avoid unnecessary speculation in Sasseur REIT's units.
- The window period is 'closed' at least two weeks prior to the announcement of SASSR's quarterly results until after the announcement and one month prior to the announcement of its full-year results until after the announcement. The Manager and its Officers should not deal in SASSR's securities in the closed window period and clearly should refrain from doing so unless under extenuating or exceptional circumstances.
During this period, the Manager does not comment on industry outlook, Sasseur REIT's operational performance and financial results, unless such information has already been publicly disclosed.
Officers should also not deal in SASSR's securities on short-term considerations and should be mindful of the law on insider trading.
Officers should note that it is an offence to deal in the Company securities (as well as securities of other listed issuers) while in possession of unpublished material price sensitive information.
Officers, whom include (both of the Manager and any subsidiary or related corporation), will be notified of the closed window period by internal memo:-
- Directors (whether Executive or Non-Executive)
- Chief Executive Officer
- Chief Financial Officer
- Chief Operating Officer
- General Managers
- Company Secretary
- Financial Controller
- Finance Manager
- All levels of staff in the Accounts Department
- Heads of Department
- Assistant Managers
- Deputy Managers
- Direct/Immediate assistants to the Officers
- SASSR, its directors or CEO, its shareholders, or the unitholders of Sasseur REIT (the "Reporting Persons") are required to give notice using prescribed Notification Forms of the Monetary Authority of Singapore ("MAS"). Accordingly, Sasseur must use Form 7 to disseminate the Notification Forms received from the Reporting Persons to the securities market. For more information, please refer to the page 14 of the 'Regulatory Reporting and Submission Obligations to the Monetary Authority of Singapore', Section VI – Disclosure of Interests in REIT and interest in Shares of the REIT Manager.
The Notification Forms (i.e. Forms 1, 3, 5, 6 and C) in relation to the Part VII of the Securities and Futures Act and as may be amended from time to time by MAS can be found at: http://www.mas.gov.sg/Regulations-and-Financial-Stability/Regulations-Guidance-and-Licensing/Securities-Futures-and-Funds-Management/Disclosure-of-Interests/Disclosure-of-Interests-Forms-Version-2.aspx
- This Policy is subject to regular review by the board of directors of the Manager to ensure its effectiveness. Updates and amendments (as appropriate) will be made to reflect current best practices in communications with Unitholders and the investment community.
- Communication Channels
- The Manager seeks to engage unitholders and investment community through the channels as follows:
- Corporate website (http://www.sasseurreit.com/)
- Site visits;
- Annual reports;
- Press releases on major developments;
- Notices of, and explanatory notes for, annual general meetings ("AGMs") and extraordinary general meetings ("EGMs");
- Media and analyst briefings; and
- Other individual or group meetings, conferences local/overseas, conference calls, roadshows, and emails
- Corporate website
- The Manager maintains a corporate website to facilitate easy and all-day access to information about Sasseur REIT for the investment community and public.
- Information relating to Sasseur REIT's announcements, annual report, financial results, press releases, developments and other information are made available on the website.
- Investors communication
- The Manager meets with investors and analysts at appropriate times and participates in investor roadshows, and sector conferences throughout the year.
- Upon the release of Sasseur REIT's quarterly and full-year financial results, the Manager will hold media and analysts' briefings. Audio recordings of the briefings are archived on Sasseur REIT's corporate website within a reasonable time after the relevant briefing.
- Unitholders Meetings
- All unitholders are encouraged to attend the general meetings, and to participate in discussions relevant to the meetings. Unitholders who are unable to attend and vote at the AGM can appoint proxies to attend, speak, and vote on their behalf. The proxy forms are to be submitted 48 hours before the AGM.
- All Unitholders are sent a copy of the Manager's annual report in a CD format prior to the AGM. Hard copies of the annual report are available upon request from Unitholders.
- As and when an EGM of the Unitholders is to be held, each Unitholder will be sent a copy of a circular which contains details of the matters to be proposed for Unitholders' consideration and approval.
- Notices for the general meetings setting out all items of business to be transacted at the general meeting, are also announced via SGXNET.
- Members of the Board, the Manager's senior management and the external auditors of the Manager are in attendance at such general meetings.
- The Manager supports voting by poll at all Sasseur REIT's general meetings and the poll results are posted on SGX-ST on the same day of each Unitholders' meeting. The chairman of the general meeting, with the assistance of the Manager's staff and service providers engaged by the Manager, will brief Unitholders to familiarise them with the detailed procedures involved in conducting a poll.
- The Manager will prepare minutes of general meetings and make these minutes available to Unitholders upon their request.
- Company Contacts
- Unitholders can contact our Unitholder Registrar at the following address:
Mr Rick Ong
Boardroom Corporate & Advisory Services Pte. Ltd.
50 Raffles Place
#32-01 Singapore Land Tower
Tel: +65-6536 5355 | Direct: +6230 9730 | Fax: +65-6438 8710
- Unitholders, and the investment community can contact Ms Wong Siew Lu, Head of Investor Relations and Corporate Affairs, at +65 6360 0290, or by emailing to firstname.lastname@example.org