Holdings Berhad’s Corporate Disclosure Policy
Objective of the Policy
Ensure that communications to the public are
timely, factual, accurate, complete, broadly
disseminated and where necessary, filed with
regulators in accordance with applicable laws.
Ensure accountability and transparency with
Enforce a commitment to comply with the
continuous disclosure obligations with an aim to
ensure that all communications to the investing
public about the business and affairs of Ta Win
Holdings Berhad are informative, timely,
factual, accurate, consistent and broadly
disseminated in accordance with all applicable
legal and regulatory requirements.
a confirmation of the existence of disclosure
policies, guidelines and procedures.
Ensure that all persons to whom this policy
applies understand their obligations to preserve
the confidentiality of material information.
Promote effective communication with
shareholders and encourage their participation
and feedback at general meetings.
Establish a disclosure committee to help achieve
policy applies to all directors, officers,
employees, consultants and contractors of Ta Win
Holding Berhad who have access confidential
corporate information as well as those persons
authorised to speak on behalf of the organisation.
This policy also covers all disclosure made in
documents filed with stock exchanges, securities
regulators, all financial and non-financial
disclosure, including management discussion and
analysis and written statements made in Ta Win
Holding Berhad’s annual and quarterly reports, press
releases, letters to shareholders, presentation by
senior management and information contained in Ta
Win Holding Berhad’s website and other electronic
communications. It includes oral statements made in
meeting and telephone conversations with analyst and
investors, interviews with the media as well as
presentations, speeches, press conferences,
conference calls and webcasts.
of the Policy
copies of this policy are made available to all
directors, employees and company secretary either
directly or by posting of this policy in the
organisation’s website. Any changes to this policy
will be amended and the copies and posting will be
Disclosure Committee is responsible for overseeing
the organisation’s disclosure controls, procedures
Ta Win Holding Berhad’s disclosure committee,
particularly Company Secretary and Finance Manager
will be responsible for overseeing the disclosure
practices, use and setting benchmarks for the
assessment of materiality, determining what
circumstances justify public disclosure and ensuring
adherence to the policy.
The Finance Manager will be the individual primarily
responsible for ensuring compliance with all legal
and regulatory disclosure requirements, including:
Overseeing corporate disclosure practices and
monitoring compliance with this policy.
Initiating with input and advice from other
member of senior management, Company Secretary,
external or internal auditor, disclosure of
material information in accordance with the
processes and procedures set out in this policy.
Dealing with any issues which may be raise from
time to time by the regulatory authorities.
Managing Director and those individuals delegated by
Managing Director from time to time
(‘Spokespersons’), are the individuals responsible
for communication with investment analysts,
potential investors and media, for initiating and
overseeing presentations, conference calls and other
communications with analysts, and other members of
the financial community and for overseeing the
electronic aspects of this policy. In carrying out
their responsibilities, the Spokespersons will seek
to ensure that no undisclosed material information
is made available to any select group. If, for any
reason, undisclosed material information is
disclosed to the analysts, investors, media or
others, the senior management should be notified
Ta Win Holding Berhad will establish a Disclosure
Committee which will be responsible for determining
whether information in material information, the
timely disclosure of material information in
accordance with securities laws and stock exchange
rules and regulations, monitoring compliance with
this policy and overseeing the disclosure controls
Members of the Disclosure Committee are:
Members can be added to or removed from the list
upon consensus of the existing Disclosure Committee,
provided that the Chairman of the Board is notified
as soon as practicable after any such decision is
advise will be consulted should such need arises for
an independent opinion.
The management of the organisation must inform the
disclosure committee of any potentially material
developments so that they can discuss and evaluate
any events that might give rise to a disclosure
Ta Win Holdings Berhad as a listed issuer must, in
accordance with the Exchange Requirements, disclose
to the public all material information necessary for
informed investing and take reasonable steps to
ensure that all who invest in its securities enjoy
equal access to such information.
Ta Win Holdings Berhad must adhere to the following
6 specific policies concerning disclosure, which are
Make immediate public disclosure of any material
Release of material information to obtain its
fullest possible public dissemination.
Make due enquiry and immediately publicly
provide for clarification, confirmation or
denial of rumours or reports.
Immediately seek the cause and response to
unusual market activity.
Refrain from any unwarranted promotional
Prohibition from insider trading.
disclosure requirements consist of the following:
Adherence to the corporate disclosure policy of
Preparation of announcements:
-ensure content is factual, clear, unambiguous,
accurate, succinct, sufficient , not false,
misleading or deceptive and is balanced and
Immediate disclosure requirements.
Periodic disclosure requirements:
-annual audited financial statements and annual
-status memorandum of understanding entered with
Circulars and other requirements.
Information is considered material, if it is
reasonably expected to have a material effect on:
The price, value or market activity of any of
the listed issuer’s securities; or
The decision of a holder of securities of the
listed issuer or an investor in determining his
choice of action.
directors, employees and consultants of Ta Win
Holdings Berhad should not disclose undisclosed
material information and shall not disclose
confidential information to anyone outside of the
organisation prior to the broad public dissemination
of that information. Selective disclosure to anyone
outside of organisation is illegal and is
They are expected to observe the following:
not discuss the business and affairs in places
where discussion may be overheard.
Confidential documents should not be read or
displayed in public places or discarded where
they can be retrieved.
Documents and files containing confidential
information should be kept in a safe place with
Transmission of documents by fax, email or other
electronic means should be made only where it is
reasonable to assume that transmission can be
made and received under secure conditions.
Documents containing confidential information
should be promptly removed from conference room
and work areas after meeting have concluded and
extra copies of confidential documents should be
Outside parties who received or are privy to
undisclosed confidential information in the course
of conducting business with Ta Win Holdings Berhad
Group must confirm their commitment to
non-disclosure in a written confidential agreement.
Unintentional Disclosure of Material Non-Public
If an employee believes that there may have been an
accidental or unintentional disclosure of material
non-public information, the employee must
immediately inform any member of the Disclosure
Committee of this incident. The Disclosure Committee
shall immediately take all appropriate steps
Notify the Exchange immediately and determine
whether a trading halt should be instituted
pending issuance of a public announcement.
Publicly disclose the material information.
Notify the person to whom the unintentional
selective disclosure was made that such
information had not been publicly disclosed and
must remain confidential and that they may not
trade in the securities of Ta Win Holdings
Berhad with knowledge of such information until
it is generally disclosed and available.
Non-Compliance with Policy
Failure to comply with this policy may result in
severe consequences, which could include but not
limited to internal disciplinary action or
termination of employment or consulting arrangements
without notice. If it appears that a Director,
officer or employee may have violated the Listing
Requirements on disclosures, the organisation may
refer the matter to the Exchange, which could to
penalties, fine and/or imprisonment.
Amendment to this policy is at the discretion of
Disclosure Committee, except for those that are
material, which shall be brought to the attention of
the Board of Directors.