Insider Trading Policy

Policy on Insider Trading

This Policy provides the standards of Kejuruteraan Asastera Berhad (the "Company") on trading and causing the trading of the Company's shares or shares of other publicly-traded companies while in possession of confidential information. This policy is divided into two parts: the first part prohibits trading in certain circumstances and applies to all directors, officers, employees and consultants of the Company and the second part imposes special additional trading restrictions and applies to all (i) directors of the Company and its subsidiaries, (ii) executive officers of the Company and its subsidiaries and (iii) the employees listed on Appendix A (collectively, "Covered Persons").

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