Investment Governance Code Policy

The company has a written investment governance policy that focuses on creating and transferring a good investment culture both inside and outside the organization. The aforementioned policy has been approved by the Board of Directors with the following characteristics:

• The Company has established an organizational structure that clearly divides the line of command according to the scope of duties and responsibilities. and has an independent governance and risk management structure There is an appropriate system to prevent conflicts of interest that may occur. The roles and responsibilities of the Board of Directors are specified. senior management as well as a committee appointed by the Board of Directors to be responsible for setting investment management policies. and monitoring and evaluating fund management
• The Company has a process to perform duties responsibly, make effective investment decisions and monitor as well as participate in the monitoring of the operations of the companies investing in the business with good corporate governance. We are responsible for society and the environment (ESG), including the prevention of corruption. with reference to legal and industry requirements.
• The company has controls to prevent the use of information that is material to price changes that has not yet been disclosed to the public.
• The Company implements strict risk management and supervision measures in accordance with the anti-money laundering law. and financing terrorism To prevent individuals or groups of persons determined by the AMLO from using the company as a source of money laundering. or as a resting place for money from committing a predicate offence.

The company has a policy to prevent actions that may cause conflicts of interest. The company has communicated and trained employees to understand and comply with the policy effectively. By making arrangements for employees to acknowledge the policy, code of conduct and practices. From the first day of operation and when there is a change in the policy various criteria and guidelines The company has a process to supervise and review various policies. keep current in line with changes in laws and practices of regulators on a regular basis.

The company has a policy to prevent and manage conflicts of interest as follows.

• Set rules to prevent receiving benefits from service providers. Or any other person (Soft Commission)
• Set a policy on the frequency of securities trading. in order to avoid trading more than necessary (Churning)
• Specify measures to control investments for employees' assets (Staff Dealing Rule)
• Specify measures and guidelines for borrowing employees by considering approval, taking into account the prevention of actions that may cause conflicts of interest and specifying that Written approval must be obtained by senior management in the line.
• Installing measures to prevent the use of inside information of the fund (Insider trading), such as the establishment of the Chinese Wall and regulations. Implementation of operations to limit the scope of use of inside information to the extent that is necessary for the operation (Need to Know Basis) and designate a person who can access inside information (Access Person). for monitoring Proper communication and utilization of inside information and prevention of conflicts of interest as required by law.
• Set policies and practices for transactions with related parties. by taking any action between the Company and persons related to the Company must be at an appropriate level (At arm's length basis)

The company has established a process to regularly monitor the operations of the invested companies. in order to know the performance of the invested company and be able to know the problem from the beginning and keep up with the event

The company defines the investment decision process. and follow up on the operations of the invested companies by analyzing important factors such as nature of business, business structure Performance monitoring developments that are both internal and external factors that may affect the value, etc. In addition, the company also considers the sustainability of the invested company. by covering the factors Good Corporate Governance social responsibility environment, including considering the quality of reports and information disclosures. of the company invested

Tracking the invested company will include

• Follow up on news and information disclosure. related to the invested company
• The company's investment management department has a meeting with the management or investor relations of the company that invests.
• Exercise of voting rights in shareholders' meetings

If it is found that the invested company does not comply with good corporate governance principles or there are issues related to social responsibility, environment, or there are signs of problems that may significantly affect the investment value. The Company will consider exercising the right to vote in the shareholders' meeting of such company as appropriate.

The company has a guideline that specifies the necessary events and directions for taking action with the additional invested company. After the company has followed up and implemented the 3rd principle, it is not enough. So that the company can participate in solving the problem and recovering the investment value in the company that invests in it from the beginning.

in further action The Investment Management Division will consider intensifying the measures taken as necessary, for example:

• Issued a letter to the Board of Directors of the investing company to report issues, remarks, concerns
• Meet the Chairman or other directors including independent directors
• Show the company's position through attending the shareholders' meeting or requesting to add an agenda to the meeting

In the event that the Company is aware of information that may affect the price and is not publicly available. The company will have measures to maintain the confidentiality of such information to prevent illegal actions and take advantage of other investors.

The company exercises its voting rights in the invested company with prudence by considering complete information. The Company has policies and guidelines for voting rights in meetings with investee companies. The guidelines are as follows:

• Guidelines for considering information in each agenda. to make a decision in exercising the right to vote in favor or against or abstain.
• It is disclosed that the company has a conflict of interest with the investing company
• The company has disclosed guidelines for exercising voting rights. and report on the exercise of voting rights in the invested company for customers and unitholders to know

Results of voting rights and details of voting rights through various channels. As required by law, such as via the company's website, etc.

In dealing with investment firms that have issues of concern and that firms have not been able to successfully resolve issues after increasing their monitoring levels. The company has a policy of cooperating with other investors. and stakeholders (Collective Engagement) by disclosing the policy To make the investing company realize the importance of the issues of concern of the company. It indicates the type of situation to work with. Other investors and readiness to work with other investors both formal and informal groups in cooperation with other investors or stakeholders to proceed with the investment company If it is a cooperation to the point of agreeing to cooperate in business management or taking any other action The Company will exercise caution and comply with relevant laws.

The company has a system to store information in accordance with the investment governance policy appropriately. for the best benefit of customers and regularly reviewing the policy to be consistent with the investment governance guidelines of the SEC Office that are newly issued or when there is a change The company will disclose the investment governance policy and policy compliance to customers and unitholders through various channels such as the annual report or the company's website, etc.