MEMO SUNWAY CITY GROUP OF COMPANIES To : As Per Distribution List attached Date: 15 January 2008
From : Tan Kim Aun Company Secretary
Subject : SUNWAY CITY BERHAD DEALINGS IN SECURITIES FOR YEAR 2008
Please be advised that Chapter 14 of the Listing Requirements of Bursa Malaysia Securities Berhad (“Bursa Securities”) prohibits all Directors and Principal Officers from dealing in the securities of their own listed company (i.e. SunCity) and securities of other listed companies when by virtue of their position as such Director or Principal Officer, they are in possession of unpublished price-sensitive information in relation to such securities, during the closed periods.
“ Principal Officers” in this context shall include the Chief Executive Officer who is not a director, Chief Financial Officer or any other employee who has access or is privy to price- sensitive information in relation to the listed company.
The “closed periods” are:- a) during the period commencing from the time information is obtained, up to the date of announcement to Bursa Securities of a matter that involves price-sensitive information in relation to the securities concerned; and b) during the period commencing from 1 month prior to the targeted date of announcement to Bursa Securities of a listed company’s quarterly results, up to the date of announcement of the quarterly results.
As such, the closed periods for trading in the securities of SunCity for the year 2008 are as follows:-
Targeted Date Estimated Date of Release of Allowed for Quarterly Quarterly Commencement Results Results Closed Period of Trading
2nd Quarter 2008 19 Feb 2008 19 Jan 2008 to 19 Feb 2008 20 Feb 2008 (31/12/2007)
3rd Quarter 2008 27 May 2008 27 April 2008 to 27 May 2008 28 May 2008 (31/03/2008) 4th Quarter 2008 28 Aug 2008 29 July 2008 to 28 Aug 2008 29 Aug 2008 (30/06/2008) Page 3 Sunway City Berhad Dealings in Securities for year 2008
Targeted Date Estimated Date of Release of Allowed for Quarterly Quarterly Commencement Results Results Closed Period of Trading
1st Quarter 2009 25 Nov 2008 26 Oct 2008 to 25 Nov 2008 26 Nov 2008 (30/09/2008)
Please note that if there are any corporate exercises or any matters that involve price- sensitive information in relation to SunCity’s securities, the closed period will commence from the time information is obtained up to the date of announcement to Bursa Securities.
PROCEDURE FOR DEALINGS IN SECURITIES DURING CLOSED PERIODS
Paragraph 14.08 of the Listing Requirements of Bursa Securities however, stipulates that Directors and Principal Officers (“affected persons”) may deal in securities during a closed period subject to compliance with the following conditions:-
(a) prior to the proposed dealing, an immediate announcement must be made by the affected person to Bursa Securities, stating amongst other things:-
(i) the affected person’s current holdings of securities in the listed company whose securities are the subject of a proposed dealing; and (ii) the affected person’s intention to deal in the securities of the listed company during a closed period;
(b) the proposed dealing can only be effected after 1 full market day of the announcement being made;
(c) an immediate announcement must be made to Bursa Securities by the affected person, not later than 1 full market day following the dealing, stating amongst other things:-
(i) the date on which the dealing occurred; (ii) the consideration for the dealing; and (iii) the number of securities involved in the dealing, both in absolute terms and as a percentage of all issued securities of that class in the listed company;
(d) the affected person must give notice of the dealing in writing to the Company Secretary of the listed company within 1 full market day after the dealing has occurred. The notice shall contain all such information as was given in the announcement made;
(e) the listed company must maintain proper record of all notices received by it; and
(f) the Company Secretary must, at each board meeting, table a summary of dealings notified to the listed company since the last board meeting.
Notwithstanding the above, the affected persons must not deal in the securities of SunCity as long as they are in possession of price-sensitive information as they shall be liable for insider trading. Page 4 Sunway City Berhad Dealings in Securities for year 2008
PROCEDURE FOR DEALINGS IN SECURITIES OUTSIDE CLOSED PERIODS
Under Paragraph 14.09 of the Listing Requirements of Bursa Securities, when Directors and Principal Officers deal in the securities of their own listed company outside closed periods:-
(a) they must within 14 days after the dealing has occurred, give notice of the dealing in writing to the Company Secretary who will then make an immediate announcement to Bursa Securities of such dealing. The notice and announcement shall include the information set out under item (c) above;
(b) the listed company must maintain a proper record of all notices received by it; and
(c) the Company Secretary must, at each board meeting, table a summary of dealings notified to the listed company since the last board meeting.
EXEMPTIONS FROM RESTRICTIONS ON DEALINGS IN SECURITIES
Please note that pursuant to Paragraph 14.06 of the Listing Requirements of Bursa Securities, the following categories of dealings are exempted from the above restrictions:-
(a) Exercise of options or rights under an employee share or share option scheme;
(b) Exercise of warrants;
(c) Conversion of convertible securities;
(d) Acceptance of entitlements under an issue or offer of securities, where such issue or offer is made available to all holders of a listed company’s securities or to all holders of a relevant class of its securities, on the same terms;
(e) Undertaking to accept, or the acceptance of a take-over offer; and
(f) Undertaking to accept, or the acceptance of securities as part of a merger by way of a scheme of arrangement.
Please be further advised that pursuant to Paragraph 16.16 of the Listing Requirements of Bursa Securities, in the event of any breach of the above, Bursa Securities may, after consultation with the Securities Commission, take or impose such actions or penalties as it considers appropriate against the Directors and Principal Officers.
Please note accordingly.
Regards,
Page 5 Sunway City Berhad Dealings in Securities for year 2008
DISTRIBUTION LIST:
A) BOARD OF DIRECTORS
1. Tan Sri Dato’ Seri Dr Cheah Fook Ling 2. Tan Sri Dato’ Ir Talha bin Hj Mohd Hashim 3. Datuk Razman M Hashim 4. Mr Ngian Siew Siong 5. Mr Ngeow Voon Yean 6. Ms Low Siew Moi 7. Mr Teo Tong How 8. Mr Tan Siak Tee 9. Mr Lim Swe Guan
B) PRINCIPAL OFFICERS a) Directors of SunCity’s Subsidiaries:
1. Puan Sri Datin Seri (Dr) Susan Cheah Seok Cheng 2. Dato’ Haji Harun bin Salim 3. Mr Yuen Kam Wah 4. Ms Sarena Cheah Yean Tih 5. Mr Yeow Thean Chye 6. Mr Toh Wah San 7. Dr Chong Su-Lin 8. Dr Lee Foo Chiang 9. Dr Robert Patrick Jalleh 10. Dr Tan Teong Yong 11. Dr Wong Wing Keen 12. Dr Adam Pany Bin Abdullah 13. Dr Lee Chong Meng 14. Mr Lee Weng Keng 15. Mr Ong Pang Yen 16. Mr Ong Ghee Bin 17. Mr Ho Hon Sang 18. Mr Evan Cheah Yean Shin 19. Tuan Haji Alias Bin Abu Bakar 20. Hajah Noraida binti Mohd Yusof 21. Mr Wong Tong Men 22. Mr Jean Jacques Kiefer 23. Mr Wong Wan Wooi 24. Mr Woo Kok Weng 25. Mr Goh Hai Thun 26. Mr Loh Pak Lin 27. Tuan Haji Rahim bin Osman 28. En Mohd Nagib bin Ahmad 29. Mr Lim Chin Khuan 30. Mr Lim Lian Kheng 31. Mr Lim Chin Huat 32. Mr Kong Kok Leong 33. En Mohamad Suffian Bin Ismail 34. Ungku Azlina binti Ungku Aziz 35. Mr Cheah Kok Hoong 36. Mr Reuben Poh Yeong Han 37. Dato’ Beh Chun Chuan 38. Dato’ Mohamed Bin Hamzah Page 6 Sunway City Berhad Dealings in Securities for year 2008
39. Mr Yau Kok Seng 40. Mr Soo Boon Choon 41. Puan Noraihan Binti Abdul Rahman 42. Mr Yap Chin Leong 43. Dr Leong Yew Pung 44. Dato’ Ismail bin Shahbodin 45. Mr Yong Leng Kee 46. Mr Chan Hoi Choy 47. Mr Hanley Chew 48. Mr Koong Wai Seng 49. Ms Wai Sow Fun 50. Puan Siti Meriam @ Mariam Binti Mohd Desa 51. En Mohamed Nazri Bin Omar 52. Mr Alan Tang Yew Kuen 53. Mr Ho Kah Meng 54. En Abdul Ghani Bin Hashim b) Finance Department:
1. Ms Ch’ng Lin Ling 2. Mr Ben Ho 3. Ms Beh Soo Ming 4. Ms Chee Mei Keeng 5. Mr Adron Leow 6. Mr Lee Yu Ban 7. Mr Balbeer Singh 8. Mr Tan Chee Leng 9. Ms Hoo Yee Fong 10. Mr Leong Wy Joon c) Others:
1. Mr Chang Chee Hong 2. Mr Yee Meng Haw