OUE Commercial REIT - Annual Report 2021

F. DEALINGS IN THE UNITS The Manager has adopted a formal policy on handling of confidential information and dealings in securities (the “Information Dealing Policy”) which applies the best practice recommendations issued by the SGX- ST. The Information Dealing Policy also sets out the implications of insider trading and guidance on dealings in the securities of OUE C-REIT as well as certain entities listed on the SGX-ST in which the Sponsor has an effective interest in (collectively, the “Restricted Securities”). It applies to and has been distributed to, inter alia , the Directors and employees of the Manager. Pursuant to Rule 1207(19)(c) of the Listing Manual, the Manager and its officers should not deal in OUE C-REIT’s securities during the period commencing two weeks before the announcement of OUE C-REIT’s financial statements for each of the first three quarters of its financial year and one month before the announcement of OUE C-REIT’s full year financial statements (if OUE C-REIT announces its quarterly financial statements), or one month before the announcement of OUE C-REIT’s half year and full year financial statements (if OUE C-REIT does not announce its quarterly financial statements). The Manager sends out memoranda and e-mails to the Directors and the employees of the Manager to remind them that the Directors and employees of the Manager and their connected persons are prohibited from dealing in the Units during the following periods: a. two weeks before the announcement of OUE C-REIT’s interim business updates for the first and third quarters of its financial year; b. one month before the announcement of OUE C-REIT’s half year and full year results and (where applicable) property valuations; or c. any time while in possession of price-sensitive or trade-sensitive information. The Directors and the employees of the Manager are prohibited from communicating price-sensitive or trade-sensitive information to any person. In addition, the Manager also discourages the Directors and employees of the Manager from dealing in the Units on short-term considerations. Pursuant to the Information Dealing Policy, Directors and employees of the Manager are required to give a pre-trading notification and declaration (that, amongst others, he or she is not in possession of any information that is not generally available but, if the information were generally available, a reasonable person would expect it to have a material effect on the price or value of the Restricted Securities (“inside information”)) to their head of department and/or the Legal department (as the case may be) before any dealing in the Restricted Securities. Details of the transaction that had been notified prior to being undertaken must also be provided in writing within two business days after the trade. A transaction which was notified but not undertaken must also be reported as such. All Directors and employees of the Manager must verify that confidential information is shared only to those persons who have a legitimate reason to have access to such information. The Information Dealing Policy sets out the procedures and safeguards which Directors and employees of the Manager should adopt to limit the risk of a leak of confidential information, including but not limited to signing of non-disclosure agreements, implementing Chinese walls, controlling access to documents containing confidential information, “clean-desk” policy, adoption of code names for transactions and maintenance of a list of persons who are privy to material inside information that has not been publicly announced. 139 A N N U A L R E P O R T 2 0 2 1