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Conflict Management Policy

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Nguyễn Gia Hào

Academic year: 2023

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A control room formed to monitor (a potential) for a conflict of interest that may occur in CIMB Group environment including in CIMB Niaga. 6 court in accordance with the provisions of the statutes (Limited Liability Company Law). Immediate family spouses (husband/wife), children, adopted children, stepchildren, siblings and parents/in-laws of the Board of Directors and Board of Commissioners of CIMB Niaga.

The Board of Commissioners (including the Sharia Supervisory Board . 8), the independent party, the board and employees of the bank;. Blackout Period (1) The period beginning fifteen (15) calendar days prior to the publication of CIMB Niaga's quarterly financial statements and 30 calendar days prior to the publication of the annual financial results and ending two (2) business days from the date on which the disclosure occurs; or. by the Board at any time in connection with the Covered Transaction and/or Covered Actions of CIMB Niaga or CIMB Group. A securities transaction executed on behalf of CIMB Niaga and for the benefit of CIMB Niaga (not for the clients).

Objective

Regulations Reference

Policy Approval

Policy Maintenance

Policy Review

Employee Affirmation

Policy Breach

Sanctions and Others

The Bank reserves the right at any time to restrict any employee's trading in securities or to request the cancellation of any trade (sale/purchase) through the relevant personal account. Any limitation, cancellation or settlement of a personal trade is at the burden and risk of that individual. The Bank may at any time specify the special conditions or restrictions for trading in Securities through personal accounts.

For the immediate family of CIMB Niaga employees whose work requires them to conduct securities transactions that do not comply with this policy, such CIMB Niaga employee must contact immediately.

Transition Period

TYPES OF CONFLICT OF INTEREST

As long as it does not violate this Policy, an Employee is allowed to make a transaction through his/her personal account from time to time. Such a transaction is very likely to pose a risk of Conflict of Interest with the interests of clients. A conflict of interest between the interests of two (2) or more entities dealing with the same client;.

A conflict of interest between the interests of two (2) or more clients served by the same unit;. A conflict of interest between the interests of the Covered Division and/or the Employee of such division and the interests of one or more clients;. A conflict of interest between the interests of two (2) units or more in a division and/or two (2) or more divisions.

If the employee is in doubt as to whether there is a conflict of interest or a potential conflict of interest, the employee must immediately communicate the circumstances to the CIMB Niaga control room to obtain appropriate instructions before taking further action. Each employee is required to maintain the confidentiality of all information that he/she knew and obtained during his/her employment, specifically the confidential (non-public) information. An employee is not permitted to provide confidential (non-public) information sensitive to the price of the securities to any other person, whether to other employees or third parties, directly or indirectly in accordance with this policy and/or the Chinese Wall policy.

Restrictions on confidential (non-public) and price-sensitive securities information. 26 (i) Such employee needs information for. performs his duties in accordance with the business objectives of CIMB Niaga;. ii) obtaining this information does not violate the confidentiality/service agreement with the customer; and/or. iii) Such employee has followed the appropriate policy in accordance with the applicable policy of Great Wall of China.

INSIDER TRADING

  • Restriction of Trading
  • Restriction to Disclose
  • Meaning and Illustration of Chinese Wall
  • Control Room
  • Scope of CIMB Niaga Control Room

The share ownership will be registered in the special register administered by the Bank's Corporate Affairs. Meaning and illustration of Chinese Wall .. a) Chinese Wall is a policy designed to control and restrict the flow of confidential information in CIMB Group or CIMB Niaga, so that insider information sensitive to the price of securities or confidential (non-public) information is not disseminated (including accidentally) to other entities of CIMB Niaga or of the CIMB Group included to the public. It is the responsibility of the CCS to immediately notify the CIMB Niaga Control Room of any information (potential) of a new transaction that causes the information to become confidential (non-public), which is sensitive to the price of the Securities, and when such information becomes a public information.

The ongoing transactions that contain confidential information (non-public) and/or are sensitive to the price of Securities carried out by a unit/department/division. ii) Names of the employees in each unit/department/division involved in such transactions. iii) Names of the employees who will be included or have been included for the crossing of the Chinese Wall based on the transactions carried out. For operational reasons, the Inside information that is sensitive to the price of Securities provided in the intersection of the areas separated by the Chinese Wall. After the Employee has crossed the Great Wall of China and received the Insider information sensitive to the price of Securities, the Employee is categorized as a Permanent Insider, so all regulations related to the Permanent Insider will apply to such employee be.

All transactions (deals) of the unit included in the covered department shall be reported to the Corporate Affairs Department as the control room of CIMB Niaga. All transactions (deals) of an employee or a unit referred to as a covered department in CIMB Niaga must be reported to the CIMB Niaga control room before the transaction is carried out. In the event that there is no violation or no indication of violation of this provision, the CIMB Niaga Control Room will forward a report to the CIMB Group Control Room to conduct a review and ensure the presence/absence of any indication of transaction violation. that uses inside information and/or conflicts of interest.

Confirmation of the transaction by the CIMB Group Control Room will be communicated to the Employees or Covered Division through the CIMB Niaga Control Room. 40 e) Maintains the permanent list of Insiders and . issues notices to the Permanent Insider according to the relevant regulation. f) Reports every transaction carried out by the Board of Directors and the Board of Commissioners to the OJK of Capital Markets and the Indonesia Stock Exchange no later than two (2) working days after receiving the transaction report from the interested party. g) Performs the maintenance of this Policy in accordance with the internal regulation in force.

EMPLOYEE PERSONAL ACCOUNT DEALING

  • Personal Trading Account
  • Personal Trading Account Maintenance
  • Covered Transactions Approval
  • Trading of CIMB Niaga’s Securities during the Blackout Period
  • The Control Room Administration
  • Exceptions

A Permanent Insider must maintain his/her Personal CIMB Securities Account if he/she wishes to carry out all personal trading activities. Approval can be obtained by submitting the Employee Transaction Approval (ETA) form (Appendix 2 Form). If approved, CIMB Niaga control room will forward this form to CIMB group control room on the same day and CIMB group control room will give its response to the Employee who requested approval through CIMB Niaga control room within 1 x 24 hours. .

During the Blackout period, all employees or management of CIMB Niaga are prohibited from trading or dealing in CIMB Niaga's Securities. The Corporate Affairs will notify all employees of CIMB Niaga, including the CIMB Group Control Room, of this Blackout period. A statement from the Board of Commissioners (including the Sharia Supervisory Board), Independent Party, the Board of Directors, the Bank Management Committee (BMC), and all the top officers (the Head of) in the Covered Division will the.

If Corporate Affairs suspects an action inconsistent with this policy, Corporate Affairs will direct a suspension of the transaction to be reported to the Compliance Director. The Compliance Director and/or the President Director may cancel the plan to buy and/or sell CIMB Niaga's Securities or any other company submitted by the Permanent Insider without having to inform the reasons thereof. The President of the Commissioner could cancel the plan to buy and/or sell such securities as described above which is carried out by a member of the Board of Directors, the Board of Directors (including the Sharia Supervisory Board) and/or an independent party by informing the CIMB Niaga Control Room.

An employee engaged in proprietary trading for CIMB Niaga must comply with the Great Wall Policy. In particular, a separation should be made regarding physical, computer access and a certain separation of regulations related to securities and derivatives trading.

RESTRICTED LIST

Apa nama dan kode (jika ada) entitas/sekuritas yang terlibat dalam transaksi? Peran apa yang CIMB Niaga mainkan dalam transaksi tersebut (mis. lead advisor, underwriter, dll.)? Saya ingin melakukan transaksi berikut dan mengklarifikasi bahwa transaksi tersebut tidak memiliki benturan kepentingan dengan nasabah CIMB Niaga.

I wish to act on the following and declare that the transaction(s) do not in any way conflict with the interests of CIMB Niaga's customers. UNTUK DIISI OLEH CONTROL ROOM CIMB NIAGA | TO BE COMPLETED BY CIMB NIAGAS CONTROL ROOM. Mengat Keluarga saya memiliki rekening CIMB Niaga My family member has an account(s) with CIMB Niaga.

Harap eksliwa semua nama keluang keluarga pesuiai dengan data yang ditita pemalang mereka tidak memiliki rekening di CIMB Niaga. Please enter the names of all your family members/relatives in accordance with the required details even if they do not have a CIMB Niaga account. I have no family ties with any member of the Bank's Board of Commissioners, any member of the Board of Directors or the Bank's Controlling Shareholder.

Catat kepemilikan saham CIMB Niaga yang dimiliki baik langsung maupun tidak langsung oleh Anda dan/atau keluarga Anda, berapa pun jumlahnya. Sebutkan apakah Anda/keluarga Anda secara langsung atau tidak langsung memiliki saham CIMB Niaga, termasuk jumlah sahamnya. Daftar semua nama komisaris di perusahaan atau lembaga lain Daftar semua nama komisaris di perusahaan atau lembaga lain 2.

Pernyataan F.1 tidak berlaku untuk direksi bank Pernyataan F.1 tidak berlaku untuk manajemen bank.

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