Directors, officers and employees of GIL and its Manager (“Relevant Officers”) must ensure that all dealings in which they are or are deemed to be interested are conducted in accordance with the Policy and the provisions of the Securities and Futures Act, Chapter 289 of Singapore (the “SFA”) with respect to insider dealing and market misconduct.

Directors of GIL are required to seek the approval of the Board before trading in the Company’s shares and non-executive directors are encouraged to purchase shares in the Company and hold them till they leave the Board.There is no limit imposed on the number of shares purchased.

Relevant Officers who are aware of or privy to any negotiations or agreements related to intended acquisitions or disposals which are disclosable transactions under the rules of the listing manual (the “Listing Manual”) of the Singapore Exchange Securities Trading Limited (the “SGX-ST”) or any price-sensitive information must refrain from dealing in the Company’s securities as soon as they become aware of them or privy to them until proper disclosure of the information in accordance with the Listing Manual.

In addition, a Relevant Officer must not make any unauthorised disclosure of confidential information, whether to co-trustees or to any other person (even those to whom he owes a fiduciary duty) or make any use of such information for the advantage of himself or others.

The Relevant Officers are prohibited from dealings in the Company’s securities:-

  1. on considerations of a short-term nature;
  2. when in possession of unpublished price-sensitive information; and
  3. during the period commencing two weeks before the announcement of GIL’s financial results for each of the first three quarters of the financial year and one month before the announcement of GIL’s full year financial results and ending on the date of the announcement of the relevant results.

The restrictions on dealings by a Relevant Officer contained in this Policy will be regarded as equally applicable to any dealings by the Relevant Officer’s Connected Person and any other dealings in which for the purposes of the SFA or Companies Act, he is or is to be treated as interested.

Where a Relevant Officer is a Director, the Director must within two (2) business days notify the Company of such dealings and upon receipt of the notice, the Company will immediately make an announcement on the SGX-ST. Where a Relevant Officer is other than a Director, within two (2) business days of dealings in the Company’s Securities, the Relevant Officer (other than a Director) must notify the Company Secretary of such dealings.