D.4.1
Does the company disclose trading in the company's shares by insiders?
Response
YES. The trading directors and officers of the Company and its subsidiaries are disclosed to the public under SEC Form 17-C and SEC Form 23-B.
Pursuant to the Company's Insider Trading Policy, the directors and officers are required to disclose their trading of shares within three (3) trading days (stricter than the five trading day requirement under the PSE and SEC rules).
They are likewise mandated to comply with the trading restrictions (black-out period) as provided in the Insider Trading Policy.